WHY THIS NOTICE

This privacy policy (the “Privacy Policy”) is intended to assist you in understanding what information we gather when you visit this Website, whether you are a registered user or not, and to describe how we use that information. If applicable, this Privacy Policy describes also how we process the information you may provide us or we collect about you.

These documents provide you with important information about the following:

  1. PROCESSING OF PERSONAL DATA
  2. PERSONAL DATA WE COLLECT
  3. HOW WE USE PERSONAL DATA
  4. HOW WE SHARE PERSONAL DATA
  5. CHILDREN’S PRIVACY
  6. STORAGE, ACCESSIBILITY AND TRANSFER OF PERSONAL DATA
  7. SECURITY AND CONFIDENTIALITY OF PERSONAL DATA
  8. RIGHTS IN RELATION TO PERSONAL DATA– MANAGING YOUR CHOICES
  9. CALIFORNIA PRIVACY RIGHTS
  10. DATA RETENTION
  11. OUR POLICY ON COOKIES AND SIMILAR PROCESSES
  12. LINKS, ADVERTISERS, SPONSORS & ADS
  13. DATA CONTROLLER –DATA PROTECTION OFFICER-  AND HOW TO CONTACT US 
  14. UPDATING THIS POLICY – NOTICES

 

ACCEPTANCE

 By visiting the  Website, using its services or, otherwise by interacting with us, our Points of Sales, Boutique and/or Websites, you acknowledge that you have read and understand this Privacy Policy and you agree that we may collect, use, store, transmit and disclose the personal data we collect through the Websites, Boutiques and/or Points of Sale in accordance with this Privacy Policy. Unless you already registered with us, we may ask you to opt-in (e.g., ticking a checkbox) if we deem it appropriate to safeguard your rights or if so required by the applicable laws. If you do not agree to the terms of this Privacy Policy, please do not visit this Website, create an account and do not otherwise use or submit personal data to this Website, or do not opt-in when this option is offered to you pursuant to the applicable laws.

  1. Data Controller Scrambled_Ego s.r.l., with registered office at Via XXIX settembre 10, 60121 Ancona (VAT number: 02698090426)
  2. Purpose The conclusion, management and execution of online store’s sales
  3. Legal basis Fulfilment of contractual obligations or the steps necessary prior to entering into a contract or by law, in order to manage the online sales
  4. Data transfer The data may be transferred if there are adequate safeguards in place protecting the rights of the data subject
  5. Rights of the data subject
  • Access to the personal data;
  • Obtain rectification or erasure of the data or restriction of processing;
  • Obtain data portability;
  • Object to processing of the data;
  • Lodge a complaint with the competent supervisory authority.

 

1. PROCESSING OF PERSONAL DATA

  When we use “Personal Data” in this Privacy Policy we refer to any information enabling us to identify you (or a third party whose personal data you provide us) directly or indirectly including any information incidental to the purchase of goods or services; or that you chose to communicate to us or share with us, or third parties, while using the Websites or at Points of Sales . We will process the personal data in accordance with the General Data Protection Regulation (EU) 2016/679 “Reg.(EU) 2016/679” and with the legislation of the country where data should be collected, if applicable. We reserve the right to carry out additional processing as required by law or as part of a criminal or other investigation or proceedings.

 

2. PERSONAL DATA WE COLLECT

 2.1 Source of Data

We collect personal data from you only when you voluntarily provide us with this information, such as:

Branded Websites distributing our products: when placing an order through the Website(s) , as a “guest”; establishing an account or modifying your account; by setting up a wish list; entering a contest, sweepstakes or promotion; searching on the Website; contacting us with a comment or question; signing up to receive email newsletters and updates regarding our latest products and services, boutique openings, events or promotions; or requesting to receive an order confirmation, shipping confirmation or other alerts;

Events: when participating to our events, surveys and market researches, challenges, and other promotions, also online, e.g., minisites that we run on third party social networks such as Facebook;

Our customer services: when asking for assistance, special services or aftersale care;

E-mail, text and other electronic messages.: when communicating between you and us.

If you provide us with personal information of third parties (e.g., your family members, other customer or prospects of us), you should make sure that said third parties are informed and authorized the use of their data as described in this Privacy Policy.

 

 2.2 Types of Data

We may collect and use different types of personal data depending on the specific purpose we have, as described below:

personal details, such as name, surname, gender, age/date of birth, country of origin, and other personal details as allowed by applicable laws;

contact details, such as address, email address, phone number, mobile number, fax number (if any), and other contact details as allowed by applicable laws;

payment details, such as payment instrument (credit card, debit card) if applicable, passport number when required for tax or anti money laundering reasons;

sales related information, such as date, products or services provided, place of purchase, product codes, amount, total of sales, VAT number, complaints, returns, refunds and other sales related information as allowed by applicable laws;

 

3. HOW WE USE PERSONAL DATA

 Personal data may be used for the following purposes, depending on the specific circumstances in which you interact with us.

 

 3.1  For online sales

Your personal data provided by you or collected when you make any purchase, regardless as a guest or registered user, i.e. basic personal details, contact details, data regarding your purchases, fiscal data, payment details, sales related information, and any other data strictly necessary for the delivery of products, will be used:

to manage, administer and process your purchase of our products, sale and post-sale services, e.g. administrative activities, accounting, returns, warranties, tax free refunds if applicable, fraud prevention, communicating with you, including by e-mail, for any problem relating to the handling of the order or to subsequent requests relating to the order;

to comply with obligations imposed by laws, regulations or EU legislation (including anti-money laundering laws) and to establish or defend a legal claim.

Providing your personal data for the purposes above is necessary; denial thereof would make it impossible to complete your purchase.

Unless otherwise required to comply with local applicable laws, data may be processed for these purposes without seeking your consent because this is necessary to comply with the contractual and legal obligations.

 

3.2 For specific purposes for which it was volunteered

Your personal data provided by you or collected when you ask for a specific service (e.g., registering your account on our Websites, handling complains, asking for information) i.e. personal details, contact details, data strictly necessary for follow-up your request, will be used

to provide the services you requested (e.g., operating the processes of registering your account, managing authentication on the Website, operating your accounts, assisting you, and handling any complaints, handling wish lists, follow up to any question or contact request you may submit to us, also through our customer care service);

to manage newsletter subscription if you are not also registered with us.

Providing your personal data for the purposes above is necessary; denial thereof would make it impossible to complete your request.

Unless otherwise required to comply with local applicable laws, data may be processed for these purposes without seeking your consent because this is necessary to follow up your request.

 

4. HOW WE SHARE PERSONAL DATA

 

We share your personal data collected with other companies that provide services on our behalf (as further described below), whether upon our direction or the direction of a third party .We will only provide those companies and organizations the personal data required to deliver the services and will prohibit them from using that personal data for any other purpose.

 

 4.1 Sharing with data processors

When you purchase our products or use our online sale services your personal data may be shared by the e-commerce vendor of this Website with selected third parties who provide services to the vendor, including those that fulfill orders, ship products, process credit and debit card payments, and anti-fraud controls.

Your personal data may be shared with third parties to monitor and analyze Website activity, host Website content, provide technical and organizational services functional to the purposes above, maintain our customer database, assist in marketing and administer emails, market analysis, surveys, contests, sweepstakes or promotions.  Such third parties may have access to, store and process your personal data to provide those services on our behalf, which may occur in Italy, your country or abroad.  Our service providers are not authorized to use personal data for any purpose other than to provide the contracted services.

 

4.2  Sharing with other third parties

Your personal data may need to be shared with companies providing payments management, and anti-fraud controls acting independently as data controllers, for providing you with the online sales services.

We may also disclose your personal data to third parties (i) when required by a law of the EU or of a Member State (ii) in response to legal proceedings; (iii) in response to a request from a law enforcement agency under legitimate basis; or (iv) to protect our rights, privacy, safety or property, or the public.

Moreover, to the extent permitted by law, we may also communicate personal data to third parties in the event of a complaint about your use of the Website and, where we deem it necessary to investigate, prevent or take measures regarding illegal activities, suspected fraud, or where we believe, at our sole discretion, that your use of the Website is incompatible with the terms of the Website.

The full list of data processors appointed and of the third parties to which data are communicated can be obtained  at the contact point below (point 11).

 

5. CHILDREN’S PRIVACY

 This Website is a general audience site; however our services are intended for people aged 18 years or older. We do not knowingly request or collect, use and disclose personal data provided by a person under the age of 18 both online and at the Boutiques/Points of Sales. In the event we learn we have collected personally data from a child, we will delete that information.

If you are under this age, please do not register or proceed with the online purchase and ask an adult (i.e. your parents or your legal guardian) to proceed with the required procedures.

 

6. STORAGE, ACCESSIBILITY AND TRANSFER OF PERSONAL DATA

 The personal data collected through the Websites is processed mainly using electronic or web means, including web analytics services hosted by servers of our selected providers. 

Personal data will be accessed, on a need-to-know and under multi-level access control tools, only by our authorized staff of  e-commerce vendor.

If we need to transfer the personal data abroad for achieving the purposes of this Privacy Policy, including where the data protection legislation differs from the one applicable in your country, we take steps to ensure that these communications happen in compliance with the European data protection standards, or other local standards in the country where we collect the data, so that your data remain secure and confidential.

  

7. SECURITY AND CONFIDENTIALITY OF PERSONAL DATA

 

We have implemented appropriate measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration and disclosure. Although we have implemented security measures for this Website, you should be aware that 100% security is not possible.  Therefore, your providing of your personal data is done at your own risk and, to the greatest extent permitted under applicable law, we shall have no liability as a result of the disclosure of your personal information due to errors, omissions or unauthorized acts of third parties during or after the transmission thereof to us. We recommend you (i) to periodically update your software for protecting data transmission over networks (for example, antivirus software) and check that your provider of electronic communication services has adopted suitable means for the security of data transmission over networks (for example,firewalls and ant spamming filters); (ii) keep confidential, and not to disclose to any else, your username and password to access to your account; and (iii) to change your password from time to time.

In the unlikely event we believe that the security of your personal information in our possession or control was or may have been compromised, we will notify you of that development as required by applicable law using any of the methods prescribed thereunder (by providing us with your email address, you hereby consent to receiving any such notification in electronic form through such email address).

 

8. RIGHTS IN RELATION TO PERSONAL DATA– MANAGING YOUR CHOICES

 

8.1 Your rights

At any time and free of charge, you may access your data, receive your electronic personal data in a structured, commonly used machine-readable format and transmit it to another data controller (data portability), have your data corrected, updated, changed or removed (subject to exemptions which may apply).  You may update any information you have given to us by contacting us at the addresses given below. Requests to delete your data are subject to any applicable legal and document retention obligations imposed on us.

If you think there is a problem with the way we are handling personal data, you have a right to file a complaint to your national and/or any other data protection authority in the EU or the EEA.

To exercise those rights you may send your request sending an email at scrambled@scrambled-ego.com or regular mail at the address appearing below (point 13). When contacting us, please be sure to provide us with your name, email address, mailing address and/or telephone number(s) in order to be sure we handle your request correctly.

 

8.2   Accuracy – Keep Personal Data Updated

 To allow us to serve you better we encourage you to regularly review and update your personal data.  If you are a registered user you may access and edit your personal data through your user account settings on the Website; otherwise you may contact us (see point 13) to assist you in updating your personal data.

 

9. DATA RETENTION

Personal data will be retained for the duration of the business relationship and for as long as  necessary for the purposes described in this Privacy Policy (e.g., if you subscribe to a newsletter, for the duration of your subscription; if you have a user account, until you close the account). Beyond this period, your personal data will only be retained to comply with our legal and regulatory obligations (e.g, for 10 years for accounting purposes; for the duration of the mandatory retention requirements for tax purposes, etc.), or to allow us to maintain evidence of our respective rights and duties.

 

10. OUR POLICY ON COOKIES AND SIMILAR PROCESSES

 Please consult the Cookie and Advertising Management section of the Website https://www.scrambled-ego.com/cookie for more information about cookies generally and how to turn cookies on and off.

 

11. DATA CONTROLLER – HOW TO CONTACT US

 For the purpose of this Privacy Policy and the data processing described therein please note that “We” “our”, “us” “Company” is Scrambled_ego s.r.l. with registered place of business in Via XXIX Settembre n.10 – 60121 Ancona, Italy. 

 

12. UPDATING THIS POLICY – NOTICES

We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time by posting such revised Privacy Policy on this page of the Website and updating the “Last Modified” date below.  It is your responsibility to review this Privacy Policy from time to time to take notice of any changes we made.  In some cases, we may provide additional notification of material changes to this Privacy Policy by adding a statement on the homepage of this Website or, for registered users, by sending a notification email or by adding a statement on their account page.  By accepting such revised Privacy Policy through a “click accept” in such notification email or account page statement (made available when required to comply with the applicable laws), or by completing a purchase on the Website or in any stores after this Privacy Policy has been revised, or, otherwise, by using or submitting information to the Website following the posting of the revised Privacy Policy, you agree to such revised Privacy Policy. As a consequence of the changes no processing of your data will be carried out without your explicit consent if so required by the applicable law.