1. CONTROLLER, DATA PROTECTION OFFICER, PROCESSOR
The Controller, Data Protection Officer and Processor is the Company LES HOMMES S.r.l., in the person of its legal representative, with registered office in Via Privata Vasto no. 4, 20121 Milan – Italy, Tax Code, VAT number and registration number at the Companies Register of Milan 07630780968, Economic & Administrative Index no. MI - 1972439.
The LES HOMMES Data Protection Officer can be contacted at the following email address: email@example.com.
Information relating to the processors is available from the Controller’s registered office and may be requested by you by the methods and at the addresses indicated above.
2. TYPES OF DATA PROCESSED
The IT systems and software procedures that enable this website to function acquire, during their normal exercise, some personal data whose transmission is implicit in the use of internet communication protocols. This is information that is not collected to be associated with identified data subjects but that, by its very nature, may, through processing and association with data held by third parties, allow for you to be identified.
This category of data includes IP addresses or domain names of the computers used by you when connecting to the website, addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to your operating system and the IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on use of the website and to check its correct functioning and they are erased immediately after processing. The data may be used to ascertain liability in the case of hypothetical computer crimes in detriment to the website; except in this case, the data on web contacts do not persist for more than seven days.
Data provided voluntarily by you
The personal, tax and contact details, including the email address and any other personal data provided to the Controller are processed.
i. during registration to the LES HOMMES websites in the specific section, as well as when completing any data collection forms present on those Websites;
ii. during the request for supply/activation of a LES HOMMES service, such as the Newsletter service;
iii. during the transmission of your communications to LES HOMMES via the specific section of the Websites;
iv. in addition information acquired on your consumer habits and on your consumer preferences manifested whilst browsing on the Website is processed, also via cookies, as well as during the purchase process of LES HOMMES products.
Your personal data will be processed by LES HOMMES in compliance with the Regulation and national legislation, including any measures issued by the Control Authority (Data Protection Supervisor), where applicable.
Protecting the safety and confidentiality of minors is very important to us. By registering on the LES HOMMES websites in the specific section, as well as when completing any data collection forms present on those Websites or when requesting the provision of/registration to the Newsletter service, you confirm that you are over 16 or in any case not aged below what is indicated by the regulations of your country of residence providing other age limits.
3. PROCESSING PURPOSES
The personal data requested via the LES HOMMES websites are collected and processed for the following purposes:
a. to implement and fulfil the requested services, including registration to the Website and/or the finalisation of product purchase orders, as well as to manage the relationship to be established with LES HOMMES or that already in place between you and LES HOMMES;
b. for administrative purposes connected with the fulfilment of the respective contractual obligations, to fulfil legal obligations such as, for example, those of accounting or tax nature, or to implement requests of the Judicial Authority;
c. in the case of consent, for sending promotional messages following activation of the newsletter service, and commercial offers (by post, email, telephone with operator, fax, SMS, MMS, social media, social chat) relating to the LES HOMMES products and services, for sending advertising material on the LES HOMMES products and services, as well as catalogues and brochures or invitations to events, and in general commercial communications about LES HOMMES and its initiatives, as well as to complete market research and to identify the customer satisfaction level;
d. if you consent, LES HOMMES, based upon the purchase data and preferences made by you, will proceed with analyses and profiling, by entering your data into our CRM system, in order to perform an analysis of your purchasing habits and your consumer choices for sending (by post, email, telephone with operator, fax, SMS, MMS, social media, social chat) promotional communications expressly dedicated to you based upon the aforementioned habits and consumer preferences shown by you when purchasing LES HOMMES products.
The profiling activity consists of an analysis of your habits and consumer choices and of creating a profile for you using the personal data provided to LES HOMMES in combination with the information and preferences manifested during your purchases of LES HOMMES products in order to send to you personalised commercial communications.
The profiling activity will not produce legal effects for you and will not affect your person, except for the formulation and reporting of personalised promotional offers.
LES HOMMES informs you that you may, at any time, object to the marketing purposes, including profiling, by sending an email to firstname.lastname@example.org and unsubscribe from the newsletter service by clicking on the unsubscribe link found at the bottom of the promotional emails that you will receive when registering to the aforementioned service.
4. NATURE OF PROVISION
The provision of data with respect to the purposes indicated in letter a) and b) is mandatory and any refusal to provide it will prevent LES HOMMES from implementing the contractual commitments assumed and executing its legal obligations. With regard, on the other hand, to the purposes indicated in letters c) and d), the provision of the personal data is optional and their use is conditional upon your issuance of explicit consent. Any refusal to issue consent will not produce any effect other than not being able to keep you duly informed regarding LES HOMMES initiatives that may interest you and not being able to analyse your habits and purchasing preferences.
5. PROCESSING METHOD
The personal data will be processed by LES HOMMES and by its officers using IT (and manual) systems according to principles of correctness, lawfulness and transparency provided by the applicable regulations on personal data protection and protecting the confidentiality of the data subject and your rights by adopting suitable technical and organisational measures to guarantee a level of security adequate to the risk. Specific measures are observed to prevent the loss of data, unlawful or incorrect uses and unauthorised accesses.
6. DATA STORAGE
With reference to the purposes indicated in points a) and b) of paragraph 3 (Processing Purposes), the personal data will be processed throughout the period of duration of the relationship and necessary to achieve the aforementioned purposes. The personal data functional to fulfilling any legal obligations will be stored even subsequently, in compliance with those obligations and in respect of the storage times provided by the rules applicable from time to time.
For the data provided for the purposes indicated in points c) (marketing) and d) (profiling) of paragraph 3 (Processing Purposes), in view of the fact that the personal data that LES HOMMES intends to store relates to purchases of ‘high end’ products and that the average annual frequency of purchase, for each customer, is protracted over time, the personal data provided by you will be stored for a maximum period of 7 years, as that timeframe is deemed to be congruous and proportionate both to the purposes to be pursued and to the type of personal data being processed. At the expiry of that period, the data will be erased or made anonymous; however, you may always provide consent again to the processing of your data by LES HOMMES for the same purposes.
7. LEGAL BASIS OF PROCESSING
The legal basis of processing is constituted by your consent, by the fulfilment of a contractual obligation and by legal provisions.
8. SCOPE OF PROCESSING. COMMUNICATION OF DATA. DISSEMINATION AND TRANSFER OF DATA
Your personal data is processed by internal personnel of LES HOMMES. The data collected to execute the indicated purposes will also be processed by third parties appointed as external Processors for that purpose, or, as appropriate, communicated to the same as autonomous controllers and, more precisely:
i. companies forming part of our corporate group for the purposes specified above;
ii. persons, companies, associations or professional firms that provide support and consultancy activity to LES HOMMES, for the purposes indicated in letters c) and d), as well as in relation to accounting, administrative, legal, tax and financial matters;
iii. companies, entities, associations that perform services connected and instrumental to the execution of the purposes indicated in letter a) and b) (couriers for delivering catalogues and/or purchased products, our stores, customer care service, analysis and market research service, maintenance of IT systems);
iv. public administrations for the conduct of their institutional functions within the limits established by law and by regulations.
The complete and updated list of the entities that process the personal data in the capacity of processors and autonomous controllers is available upon request from LES HOMMES S.r.l. with registered office in Via Privata Vasto no. 4, 20121 Milan. In addition, the personal data may be made accessible, communicated and transferred to Public Bodies, Judicial Authority, Forces of Order, in order to pursue requests for assessment or if expressly required by a legal obligation. The personal data relating to you will not in any case be disseminated outside the European Union.
9. REDIRECTION TO EXTERNAL WEBSITES
The LES HOMMES websites may use social plug-ins. Social plug-ins are special tools that allow for the functions of Social Networks to be incorporated directly into the Website (e.g. the Facebook “like”). All social plug-ins present on the LES HOMMES websites are marked by the respective logo of ownership of the social network platforms.
When you visit a page of our website and interact with the plug-in (e.g. by clicking the “Like” button) or you decide to leave a comment, the corresponding information is sent from the browser directly to the social network platform (Facebook, Instagram, etc.) and memorised by it.
10. RIGHTS OF THE DATA SUBJECTS
The data subjects may exercise, in relation to the processing described above, the rights provided by the European Regulation (Art. 15-21), therein including:
• to receive confirmation of the existence of your personal data and to access their content (rights of access);
• to update, modify and/or correct your personal data (right of rectification);
• to request the erasure or restriction of processing of data processed in violation of the law, including those whose storage is not necessary in relation to the purposes for which the data were collected or otherwise processed (right to be forgotten and right to restriction);
• to object to the processing (right to object);
• to withdraw consent, where provided, without prejudice to the lawfulness of the processing based upon consent provided prior to the withdrawal;
• to lodge a complaint with the Supervisory Authority in the case of a violation of the rules on personal data protection;
• to receive a copy of the personal data provided to LES HOMMES in a structured, commonly-used and machine readable format, and to ask for the data to be sent to another controller (right to data portability).
Requests should be sent to LES HOMMES by sending an email to email@example.com or by post to the following address:
LES HOMMES S.r.l., Via Privata Vasto no. 4, 20121 Milan, Italy
11. CHANGES TO THE POLICY
Any entry into force of new industry regulations, along with the constant examination and update of services to you, may involve the need to alter the processing method of your personal data. Our policy may undergo changes over time and we therefore invite you to consult this page periodically. To that end, the policy document shows the date of update.
Latest update, February 2020