YOOX ASIA controls the use of www.karl.com users' personal data together with KARL LAGERFELD B.V. (Besloten vennootschap), whose registered address is in Looiersgracht 43, 1016 VR Amsterdam Amsterdam, Tax Code NL 850960678B01 (jointly referred to as "YOOX ASIA and B.V. (Besloten vennootschap)").
Since personal data of users and customers of the www.karl.com may be processed in Italy, any such processing of personal data will be conducted in compliance with applicable laws of Hong Kong as well as the Italian Data Protection Code (Legislative Decree no. 196 dated June 30, 2003). Pursuant to the Italian Data Protection Code, YOOX ASIA is the controller of personal data of users and customers of www.karl.com. As controller of personal data, YOOX ASIA independently determines the purposes and means by which your personal data are processed, including all security measures. As required by the Italian Data Protection Code, YOOX ASIA has appointed YOOX NET-A-PORTER GROUP S.p.A. as its data protection representative in Italy. As our data protection representative in Italy, YOOX NET-A-PORTER GROUP, together with B.V. (Besloten vennootschap), independently ensures that personal data are processed in Italy in a correct and lawful manner and in accordance with good practice.
1. Our Policy
Everyone has the right to protection of his/her personal data. YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. respect its users' right to be informed regarding the collection of and other operations involving their personal data. In using data that may directly or indirectly identify you personally, we will apply a principle of strict necessity. For this reason, we have designed www.karl.com in such a way that the use of your personal data will be kept to a minimum and will not exceed the purposes for which your personal data was collected and/or processed; we do not process your personal data when we can provide you with services through the use of anonymous data (such as marketing research made for improving our services) or by other means which allow YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. to identify you, apart from when it is strictly necessary or upon request by competent public authorities or the police (for example, in case of traffic data or your IP address).
YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. determine the purposes and means for processing your personal data, including security measures, as YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. control www.karl.com users' personal data.
2. Who Processes Your Personal Data
YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. control the use of www.karl.com users' personal data; YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. autonomously determine the purposes and means of processing personal data and the instruments used, including those for security measures. Due to organisational and operational purposes only, we have appointed certain entities that will also process personal data belonging to www.karl.com's users for purposes strictly connected to the performance of services on www.karl.com, including the sale of products.
The above mentioned processors have been chosen by YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. because of their experience in processing personal data and they provide sufficient guarantees regarding compliance with data processing laws (including the technical security measures governing the processing to be carried out). In processing the personal data of www.karl.com's users, the processors shall act only on instructions from YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V.. We regularly check that our processors comply with our instructions and that they continue to provide sufficient guarantees regarding their full compliance with the provisions on personal data processing.
Some of the processors of your personal data are:
- United Parcel Service, for for purposes related to shipping, delivering and returning products purchased on www.karl.com;
- BT Italia S.p.A., for purposes related to the housing of YOOX NET-A-PORTER GROUP servers;
- Prestige International UK ltd, for for purposes connected to providing call centre and Customer Care services to www.karl.com's users.
Please contact our Customer Care or send us an e-mail at email@example.com if you would like to receive a full list of our data processors.
3. How We Use Personal Data and for What Purposes
Your personal data is collected and processed by YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. for purposes which are strictly connected to the use of the web site, its services and to the purchase of products on the web site. However, your personal data may also be used for other processing operations within the limits of such purposes.
In particular, your personal data shall be processed for the following purposes:
- when you register with our website we collect your personal data (for example, your personal details, password, e-mail address, gender) through the registration form (My Account) in order to provide you with services in www.karl.com’s reserved access areas and to send you our Newsletter, when specifically requested;
- when you require assistance from our Customer Care, we collect your personal data (for example, your name and surnames, e-mail address and password) for purposes strictly necessary to providing you with Customer Care services related to www.karl.com services and to the purchase of products on www.karl.com;
- when you execute purchasing procedures for products sold on www.karl.com, we collect your personal data (such as personal details, e-mail address, address, Credit Card numbers, bank code, tax code and telephone number) on your order form only for the purpose of selling the products ordered by you;
- when you require technical assistance, we collect your personal data in order to provide you with information on net-surfing, browser compatibility and viewing or loading www.karl.com web pages ;
- when creating a Wish List, we process your personal data in order to customise our services for the purchase of products on www.karl.com.
Your personal data shall not be disclosed to third parties for purposes which are not permitted by law or without your explicit consent.
Your personal data may only be disclosed to third parties when it is necessary for processing an order. For example, your personal data is disclosed to GlobalCollect for the performance of electronic distance payment services using Credit/Debit Card when you purchase a product on www.karl.com. Moreover, your data may be disclosed to the police or to judicial authorities, according to law and upon a formal request by such entities, for example in the event YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. need to prevent fraud on www.karl.com (anti-fraud services).
Data processors will also have access to your personal data as stated in section 2 for the specific purposes stated therein. In all the above circumstances, your consent for data processing is not required. Your personal data will not be transferred abroad to non-EU countries that do not ensure an adequate level of protection of individuals. Should this be necessary in order to supply services or to execute a contract for the purchase of products, your personal data shall be transferred to such non-EU countries only after the execution of specific contracts between YOOX NET-A-PORTER GROUP, KARL LAGERFELD International B.V., and such entities in accordance with applicable law and regulations.
We wish to inform you that YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. shall process its users' personal data for purposes that are strictly connected to the supply of services on www.karl.com, execution of contracts related to the sale and purchase of products on www.karl.com and, after receiving your consent, to send you information on new commercial initiatives which are strictly connected to the web site's activities and services.
YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. shall process your personal data for direct marketing purposes, including by e-mail, only after receiving your consent. YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. may have access to third parties' personal data which was directly disclosed by their users, for example when a user bought a product to be sent to a friend, when the user paying for the product is different from the recipient of the product, or when a user wishes to recommend to a friend a service of www.karl.com or the sale of a particular product.
4. What Happens if You Do Not Disclose Your Personal Data to YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V.
Granting your personal data to YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. (in particular, your personal details, your e-mail address, your address, your Credit/Debit Card numbers and bank code and your telephone number) is necessary for processing your order for the purchase of products on www.karl.com, supplying other services provided on the web site upon your request, or when your personal information is needed to fulfil obligations required by law or regulations.
The refusal to provide YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. with some of your personal data necessary for performing the above purposes may consequently prevent YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. from processing your order for the purchase of products sold on www.karl.com or from supplying other services provided on www.karl.com, such as Customer Care services, sending the Newsletter, using the Wish List or fulfilling obligations required by law and other regulations. Therefore, failing to provide data may constitute, in some cases, a legitimate and justified reason for not processing your order for the purchase of products sold on www.karl.com or not providing www.karl.com’s services.
Disclosure of further personal data to YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. other than that required for fulfilling legal or contractual obligations or for providing the services requested, is, on the contrary, optional and does not have any effect on the use of the web site and of its services or on the purchase of products on www.karl.com (for example, if we ask you the name of your favourite designer).
In some circumstances and if required, from time to time we will duly inform you if the personal data you are disclosing to YOOX NET-A-PORTER GROUP and iKARL LAGERFELD International B.V. s compulsory or optional. We will point out to you whether the disclosure of your data is compulsory or optional by marking with an appropriate symbol (*) the information that is compulsory or data needed for providing the required services on www.karl.com and for the purchase of products on www.karl.com. Failing to provide optional personal data will not imply any obligation or disadvantage to our users.
5. To Whom Your Personal Data Will Be Disclosed
Personal data will be disclosed to third party companies that provide, on behalf of YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V., specific services as data processors or to other recipients of personal data collected by YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. that autonomously process your personal data only for the performance of a contract for purchasing products on www.karl.com (for example, GlobalCollect) and only when such purpose does not exceed the purposes for which your personal data was collected and subsequently processed and, in any case, according to applicable laws and regulations.
Personal data will not be disclosed to third parties or disseminated or transferred without informing our users of such disclosure/dissemination/transfer, without their consent and, in any case, in accordance with the law.
6. How We Collect Your Data on www.karl.com
When you are using www.karl.com, some personal data might be collected automatically (through "cookies"), for example, when we automatically collect users' IP addresses and other information regarding the users' data traffic or the users' preferences in the choice of services provided on this web site and of the products purchased through the provided services. This information and data are collected directly and automatically by the web site as part of its operational functions. This information and data are then processed in a collective and anonymous way for commercial purposes in order to optimize the services provided on www.karl.com for the needs and preferences of the web site's users.
In other circumstances, YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. directly collect personal data and information from its users when they register online with www.karl.com or when they send purchase orders of products sold on the web site in order to finalise e-commerce transactions. YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. will process such data only for the purposes and within the limits of what is stated in the section regarding data collection and may be disclosed to third parties only for the purposes related to providing the services requested by the user.
7. Security Measures
It is advisable that your computer be provided with software devices that protect network data transmission/receipt (such as updated antivirus systems) and that your Internet service provider take appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering).
9. Opt-in/Opt out
YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. process your personal data only after receiving your consent, freely expressed, in order to send you advertising material and direct marketing or other commercial communications, including by e-mail, which do not fall within customer requested services provided by www.karl.com. Each time your consent is required, we will inform you in advance and we will give you the option to either provide or refuse your consent for the use of your personal data, including your e-mail address, for the above purposes, by ticking the appropriate boxes.
We wish to inform you that YOOX NET-A-PORTER GROUP and www.karl.com may process your personal data also without your consent in certain circumstances provided by law, such as when such processing is necessary for performing a legal obligation to which YOOX NET-A-PORTER GROUP and www.karl.com are subject or when such processing is necessary for performing obligations undertaken in contracts with the users (such as, for example, if you purchased products on www.karl.com or if you asked to use specific services through our web site).
In any case, we wish to inform you that YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. guarantee that its users may exercise, at any time and without having to state their reasoning, their right not to receive future communications connected to particular services upon request.
10. Your Right to Access Personal Data and Further Rights
You are entitled to obtain, at any time, confirmation from YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. as to whether or not data relating to you is being processed, whether the data is not yet registered, and the communication in intelligible form of the data undergoing processing.
Moreover, you are entitled to receive from YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. information on the source of your personal data; the purposes and way of processing your personal data; the logic involved in any electronic data processing; details of the data controller and of the data processors; the names of the entities and categories of entities to whom your personal data may be disclosed or who may access your personal data, for example, as a data controller or a party so appointed.
- the updating, adjustment or, when you have an interest in such, the integration of your personal data;
- the deletion, the transformation into an anonymous form or blocking of your personal data (unlawfully processed), including data which does not need to be stored for the purposes for which it was collected and subsequently processed;
- the confirmation that the operations under letters a) and b) have been reported (together with the contents of the same) to whom the data was disclosed or disseminated, except when it becomes impossible or if the means used are clearly disproportionate to the right’s protection.
- for legitimate reasons, to the processing of your personal data, even if it is related to the purposes for which it was collected;
- to the processing of your personal data for advertising or direct marketing purposes or in order to carry out marketing research or commercial communications.
11. Links to Other Web Sites
If you wish to receive further information on how YOOX NET-A-PORTER GROUP and KARL LAGERFELD International B.V. process your personal data, please send an e-mail to firstname.lastname@example.org. Should you require any further information on your rights and on personal data protection law you can contact the personal data protection authority at the following address: www.garanteprivacy.it.
13. Governing Law
The Personal Data (Privacy) Ordinance (Cap 486) protects the privacy of individuals in relation to personal data.