PRIVACY POLICY

PRIVACY POLICY
Art. 13 of EU Regulation 2016/679 General Data Protection Regulation

With this policy DAN JOHN ITALIA S.p.A., in their capacity as autonomous data controllers, intend to inform users who are visitors to the website www.danjohn.com of the policy adopted with regard to the protection of personal data, underlining their commitment and attention with reference to the protection of the privacy of visitors to the Site. Please read carefully our Privacy Policy that applies both in the case of simple navigation within the Site and registration to the same and related services.

Navigation within the Site is free and does not require any registration, with the exception of certain areas in which the User may freely and expressly provide a set of data concerning him/her in order to access specifically identified services. Where the visitor intends to provide his/her personal data to access such additional services, he/she will be expressly informed in accordance with EU Regulation 2016/679 - General Data Protection Regulation and Legislative Decree No. 196 of 30 June 2003 - Code on the protection of personal data, with an indication (by way of example) of the purposes and methods of use of the data by DAN JOHN ITALIA S.p.A., as well as the right to request at any time the deletion of the data or their updating.

We remind Users that personal data are defined as"any information relating to an identified or identifiable natural person." processing means"any operation or set of operations, whether or not by automated means, applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, comparison or interconnection, restriction, erasure or destruction�"

By browsing the Site you acknowledge that you have read and understand this Privacy Policy.

Information on the processing of personal data

Pursuant to Article 13 of the Regulations, DAN JOHN ITALIA S.p.A. provide the following information:

1. Identity and contact details of the data controllers

The data controllers of the personal data collected through the Site, each within the limits of the processing actually carried out, are the following:

2. Type of personal data processed

No registration is required to access the Site. However, there are sections that require registration or the use of a username and password (e.g., to register for the Site), or services for the use of which you must provide your information (e.g., to contact us, subscribe to the newsletter, etc.).

Moreover, in order to allow a normal and efficient navigation and fruition of the Site, DAN JOHN ITALY SPA will collect some personal data of Users related to the connection and navigation within the Site. With reference to data related to navigation within the Site collected through the use of "cookies" see also point 10 below regarding Profiling Tools.

Where necessary, the Companies will obtain the specific consent of the User to the relevant use of the data.

Here is an example of the type of information that is collected through the Site:

Identifying data: first name, last name, address, etc;

√ Contact data: residential address, e-mail address, telephone number;

√ Connection data: IP address, device number/ID, data about your Internet connection and service provider, the equipment you use to access websites, your browsing history, and other technical and usage details;

√ Interest and preference data: data about your purchases (e.g., number, value, and types of purchases), products placed in your shopping cart, etc;

√ Transactional data: credit card number, tax code, VAT, etc;

3. Optional provision of personal data

Some of the personal data requested on the Site, such as first and last name, telephone number and e-mail address, may be marked as "mandatory" [e.g., indicated with an (*)] as they are necessary to access the Site services you wish to use (e.g., if you place an order). Failure to provide the data marked as "mandatory" will result in the Companies being unable to provide the requested service (for example, if the User does not provide his/her e-mail address, Dan John Italia S.p.a. will not be able to proceed with sending the newsletter). Failure to provide data marked as "optional" will have no consequences.

Users are required to indicate on the Site only the personal data that concern them. If personal data of third parties are indicated, Users must expressly declare and acknowledge that they have obtained the consent of third parties for the processing of the corresponding personal data by the Companies, or other data controllers.

4. Purpose and legal basis of processing

Users' data are collected and processed for purposes strictly related to the use, management and updating of the Site, the services offered within it and its presentation to Users. The specific purposes of data use are detailed in this paragraph.

(a) Site registration

Users' personal data will be processed by DAN JOHN ITALY SPA to enable registration on the Site, proceed to the creation of a personal account and ensure access to areas and any benefits reserved for members (e.g. make purchases faster, check purchase history, etc.).

Users' e-mail address may also be used to send any communications related to how to use the Site's features (e.g., confirmation of registration, invitation to renew credentials, etc.).

The processing of data for this purpose does not require the consent of the Users, as it is necessary for the performance of a contract between the Users and DANJOHN ITALIA SPA (art. 6, paragraph 1, letter b) of the Regulations).

(b) E-commerce
Where you make a purchase on the Site, your personal data will be processed by DANJOHN ITALIA SPA to

  • completing the sales process and executing the contract in place between the parties (e.g. managing and processing payment, completing the delivery and/or return process, etc.);
  • To fulfill legal obligations (e.g., in tax matters, accounting for billing, bookkeeping and accounting records) inherent in the contract with concluded with the User;
  • Handle any services closely related to the sale (e.g., requesting information about products, using customer service, sending order confirmation, etc.);
  • Protect the rights arising from the contract with concluded with the User, including through agents, in or out of court.

The processing of data for this purpose does not require the consent of the Users, as it is necessary for the execution of the sale and purchase contract concluded with the User and the execution of pre-contractual measures adopted at the request of the User himself, as well as to properly fulfill the legal obligations to which DANJOHN ITALIA SPA is subject (art. 6, paragraph 1, lett. b) and c) of the Regulations) and - in case of disputes - for the pursuit of the legitimate interest of the Company in the protection of its rights (art. 6, paragraph 1, lett. f) of the Regulations).

(c) ContactUs
Data provided by filling out the
"Contact Us" form or by using the contact services (via e-mail, fax, telephone or paper mail) will be processed by DANJOHN ITALIA SPA to respond appropriately to User reports and/or requests for information.

The processing of data for this purpose does not require the consent of the Users, as it is necessary for the execution of the contract of sale and purchase concluded with the User or the execution of pre-contractual measures taken at the request of the User (Article 6, paragraph 1, letter b) of the Regulations).

Furthermore, subject to the collection of appropriate and specific consent, Users' data will be processed by Rinah for:

(d) Marketing
Allow subscription to update service on promotions, SALES and initiatives - through the use of automated and non-automated means, such as newsletters, e-mail, telephone contact, text messages, instant messages, posts, communications and posts on social networks, etc. -, related to the brand "Dan John".

In case of subscription to the"Newsletter", the User will receive only commercial communications on the e-mail address indicated during registration.

Where the User has consented to preference analysis, communications may be tailored based on the interests and additional available information about the individual User (e.g., indicating only active promotions in the region to which the individual belongs).

The processing of data for this purpose requires the consent of the Users (art. 6, paragraph 1, letter b) of the Regulation).

(e) Preference analysis
Analyse your data (including, where available, your browsing data) to learn about your purchasing preferences and tastes and enable Rinah to improve its commercial offerings accordingly and personalise its communications.

The processing of data for this purpose requires the consent of the Users (art. 6, paragraph 1, letter b) of the Regulation).

(f) Geolocation ("Store Locator" feature)
DANJOHN ITALIA SPA will detect your location through the use of special geolocation cookies in order to show the User accessing the"Store Locator" feature branded "Dan John" stores close to your location.

The processing of data for this purpose requires the consent of Users (art. 6, paragraph 1, letter b) of the Regulations). The User gives consent to such geolocation when he/she activates the appropriate store search functionality and/or (ii) when he/she authorizes from a mobile device the Site to detect his/her location.

It is understood that failure to provide consent for purposes (d), ( e ) and (f) shall in no way affect the possibility of registering on the Site, making a purchase or contacting the Companies for any type of complaint or information.

We remind Users that any consents provided may be revoked at any time by. (i) By accessing their personal area on the Site and changing the relevant settings, (ii) (as to Newsletters) by clicking on the appropriate link in all communications; (iii) by contacting Rinah's customer service department, (iv) by sending appropriate notice to info@danjohn.com. In case of revocation of consent regarding Rinah's update service, the User will no longer receive any type of communication, by any mode. It is always possible to revoke consent limited to the receipt of communications by electronic means (e.g., e-mail, text message, telephone call, instant messages), continuing to receive commercial communications only by paper mail or telephone contact with operator.


5.Method of treatment

The processing of Users' personal data is carried out by means of storage on electronic media, in compliance with the regulations in force and, in any case, in such a way as to guarantee the security and confidentiality of the data and prevent unauthorized disclosure or use, alteration or destruction. All information collected is transmitted in secure connection so as to prevent its interception by outsiders.

If the User consents to processing for analytical purposes, DAN JOHN ITALIA S.p.a. will use the data collected (e.g., age and source data) to examine the interests and preferences of the data subject in order to improve its offerings and personalizeits own communications. All data and preference analysis activities will not take place using exclusively automated methods, but will always involve the intervention and evaluation of duly authorized natural persons.

6.Recipients of personal data

The data of the Users will come to the knowledge (limited to their respective sphere of competence) of the personnel expressly authorized by the Companies, pursuant to Article 29 of the Regulations.

Within the scope of the purposes indicated in the outline below, Users' personal data may become known to the following third parties:

Purpose

Target audience

(a)

(i) Public authorities, public and administrative bodies, state and community control bodies; (ii) Banks and credit institutions; (iii) Legal, tax and accounting consultants; (iv)the company in charge of managing the company's information systems; (v) companies entrusted with the management of functional services for the payment of purchases; (vi) companies in charge of shipping and delivery of products; (vii) companies that provide services instrumental to the management of the contractual relationship (e.g., e-commerce platform providers); (viii) the companies Dan John Italia S.p.a., which provide accounting, administrative, tax and management control related services.

(b)

(c)

(i) The company in charge of managing the company's information systems; (ii) the companies that provide services instrumental to the management of the contractual relationship (e.g., suppliers of the e-commerce platform); (iii) the companies Dan John ItaliaS.p.a., which provides accounting, administrative, tax and management control-related services.

(d)

(i) The company in charge of managing the company's information systems; (ii) the company Dan John Italia S.p.a., which provides services related to the management of the Site; (iii) the companies that provide services instrumental to marketing activities (e.g. providers of platforms for sending commercial communications) and analysis (e.g. providers of dedicated software).

Email addresses may also be momentarily communicated - in encrypted and protected form - to social networks (e.g., Facebook, Instagram, etc.) to allow Users subscribed to the social networks to viewnews or advertising related to the "Dan John".

(e)

(f)

(i) The company in charge of managing the company's information systems; (ii) the companies that provide services instrumental to the operation of the "Store Locator" functionality (e.g., providers of geolocation cookies, such as Web Geo Services).

Where necessary, the Companies have appointed recipients of Users' personal data as data processors, pursuant to Article 28 of the Regulations. A list of all data processors may be requested by communication to be sent to the contact details of indicated in this Privacy Policy.

Users' personal data will never be disseminated.

7. Non-EU transfers:

To enable proper and efficient operation of the Site, Users' personal data may be subject to transfer to countries outside the European Union, including the U.S.

The transfer of data will take place in full compliance with the guarantees, measures and rights provided by the privacy regulations. By simple request, the User may receive more information about the transfer of his dai and the guarantees provided for their protection.

8. Retention period

Users' data will be stored for the time strictly necessary to pursue the purposes indicated in point 4 of the Privacy Policy and in compliance with any consents provided. At the end of the storage period, the data will be destroyed or made anonymous.

Specifically, data will be stored according to the criteria set out in the following table.

Purpose

Conservation

(a)

The data will be retained for the duration of registration to the Site. After a period of 5 years of total inactivity of the account, the data will be deleted.

(b)

Data will be retained for the time necessary for the management and completion of the sales process, and thereafter in fulfillment of legal obligations related to the contractual relationship. In any case, Users' personal data will not be retained for a period longer than 10 years after the termination of the contractual relationship (subject to any further retention in case of litigation related to the contract between the parties).

(c)

Data will be kept for as long as necessary to properly handle the User's report and/or request. In any case, Users' personal data will not be kept for a period longer than 5 years after the request for information.

(d)

The data will be processed for the entire duration of the subscription to the update and/or newsletter service, in full compliance with the consents provided by the User, without prejudice to the possibility of withdrawing consent at any time.

In particular, the data relating to the Users' purchase details will be processed for marketing or analysis purposes for a maximum period of 48 and 36 months respectively from their registration.

(e)

(f)

DAN JOHN ITALY SPA does not transmit to Web Geo Services the User's personal and contact data, nor does it save the User's location data, when used to show the User the points sold near him/her.


9.Links to other sites

This Privacy Policy is provided only for the site www.danjohn.com and not for other websites that may be consulted by the User through links. The Companies cannot be held responsible for personal data provided by Users to external parties or to any websites linked to this Site.

10. Profiling and/or personalisation tools

Rinah does not carry out any promotional and/or advertising communication activities without the prior express consent of the User.

The Site uses "cookies," both technical (i.e., to facilitate navigation and use of the Site) and profiling (i.e., to analyze Users and their behaviors and preferences, and get them personalized advertisements).

For a detailed explanation of the cookies used by the Site and how to disable them, we invite Users to read our Cookie Policy.

11. Rights of the persons concerned

By contacting the customer service of Dan John Italia S.p.a. or by sending a communication to info@danjohn.com the User may at any time exercise - with respect to DAN JOHN ITALIA S.p.A. - the rights set forth in articles. 15 to 22 of the Regulations, including among which to know what data we are processing, in what manner and for what purposes we use it, to modify the data you have provided us or to delete it, to ask us to limit the use of the data, to request to receive or transmit the data, without prejudice to the possibility of always revoking and/or modifying any processing consents you may have provided.

In addition, the User can always object to the processing of his or her data carried out for marketing or preference analysis purposes.

In case of exercising any of the rights provided for in the Regulations, the Holder reserves the right to verify the identity of the User by requesting to send a photocopy of an identity document attesting to the legitimacy of the request. Once the identity has been confirmed, the photocopy received will be immediately destroyed.

12. Complaint to the Regulatory Authority

If a User believes that the processing concerning him or her violates the provisions of the Regulations, he or she may always lodge a complaint with the Data Protection Authority(www.garanteprivacy.it), or with the Data Protection Authority of the country in which he or she habitually resides, works, or where the alleged violation occurred.

13. Revision clause

The Companies reserve the right to revise, modify or simply update, in whole or in part, at their sole discretion, in any manner and/or at any time, without prior notice, this Privacy Policy, including in consideration of changes in data protection laws or regulations. Changes and updates to the Privacy Policy will be notified to Users as soon as they are adopted and will be binding as soon as they are posted on the Site. We therefore kindly ask Users to regularly access the "Privacy" section of the Site to check the publication of the most recent and updated Privacy Policy.