1. WHAT TYPE OF PERSONAL INFORMATION DO WE COLLECT?
AVERCINI may collect the following categories of personal information for the purposes described in this Policy:
- Identification and contact information, such as your name, address, phone number, or email address. This may be collected when you sign up for an online account, participate in an event, make a purchase, or request a VAT refund.
- Payment information, such as credit card details, bank account numbers, PayPal account details, or other payment details required to receive products or services you have ordered from us.
- Demographic information, such as your gender and birthday.
- Your voice when you call AVERCINI Client Services (calls may be recorded).
- Preferences and interests that you choose to disclose during your interactions with our client advisors (these may include your preferences about our collections or other luxury brands, your size, your lifestyle, or basic information about your family).
- Information that you submit or post in a public space, such as product reviews on our social media pages or websites.
- Information about your purchases online, including the products you purchased and their prices.
- Information about the browser you are using and your browsing behavior if you use our websites.
- Information about your use of connected products, such as which features you use most often, battery level information, and geolocation information if necessary to provide the service you requested.
- Information posted on third-party websites or social media platforms about AVERCINI products and services, if necessary for the purposes described in this Policy.
Your personal information may be collected directly from you (e.g., when you create an account or interact with our client advisors in through our AVERCINI Client Services), passively (e.g., through tracking tools like browser cookies), or from third parties (e.g., through social media platforms). If you choose not to submit personal information when required to enter into a contract or as required by law, you will not be able to receive the product or service you ordered or register on our websites or other media.
2. HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the information described above for the following purposes:
- To improve our understanding of your interests and concerns and to improve our understanding of your use of our products. We may use your information to make our website and products/services better and to tailor our marketing activities to your needs and interests. We believe that it is in our legitimate interest to better serve you and respond to your needs.
- To provide you with our connected services, process your order, respond to your requests or questions, and manage your complaints. For example, we use your information to process your order and deliver your products. We may also use your information to send you requested information or communicate with you about your account or our relationship. We may contact you about changes to the site or service updates, or to ask for feedback or to provide information about this policy or website terms. In these cases, your information is processed to perform the contract we have with you.
- For security purposes. We may use your information to protect our company, our customers, our associates, and our websites against fraud, theft, or any wrongdoing that may affect our business. We have a legitimate interest in ensuring the security of our business online and offline.
- For anti-counterfeiting purposes and to combat illegal resale channels for our products in violation of our general terms and conditions of sale and our selective distribution network (by monitoring quantities or frequency of products purchased). We have a legitimate interest in protecting against online counterfeiting and preserving our distribution network.
- For marketing purposes, subject to your consent when required. We may use your information to contact you about new products and special offers that we think you will find valuable.
- For analytics purposes. We may use your information to analyze the reputation of our company or products and to measure the effectiveness of our online or offline campaigns or events. We have a legitimate interest in preserving the reputation of our company and optimizing our marketing campaigns.
- Other purposes. We use information to maintain transaction and other business records for legal, administrative, and audit purposes. We also use information to meet legal, insurance, and processing requirements.
3. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
We do not disclose or share your personal information, except in the following cases:
- With our affiliated companies within the AVERCINI Group Ltd. Only authorized personnel with a need to know have access to this information for purposes of internal audit, billing, and administrative tasks, and to provide you with the same level of service worldwide.
- With service providers and agents who perform services on our behalf. For example, we may share information with vendors who send emails for us or with service providers that help us operate our websites.
- With banks or other online payment services companies.
- Subject to your consent, with our business partners. For example, we may share information with third parties who jointly sponsor an event or promotion with us.
- In the case of business restructuring or reorganization, including dissolution or liquidation. This includes if we merge or transfer all or part of our business or assets.
- When required by law or necessary to comply with applicable law. For example, we may share information to respond to a court order.
4. TRANSFERRING YOUR PERSONAL INFORMATION
We may transfer the personal information we collect about you to other countries for storage, processing, and other purposes described in this Policy. These countries may have data protection laws that are different from the laws in your home country. However, we will take steps to ensure that your personal information is treated securely and in accordance with this Policy. When we transfer your personal information to other countries, we will use appropriate safeguards to protect it, such as using data transfer agreements based on the standard contract clauses approved by the European Commission or other valid transfer mechanisms. You may request a list of the countries where your personal information will be transferred and a copy of the safeguards in place to protect it by contacting us using the information provided in the "Contact Us" section of this Policy.
5. RETENTION PERIOD
We will retain your personal information for as long as is reasonably necessary for the purposes for which it was collected or processed. This includes retaining your personal information for the duration of your commercial relationship with us and for 10 years thereafter, unless we are required to keep it for a longer period due to legal or regulatory requirements. We may also retain your personal information for the purposes of potential litigation or disputes, and if a judicial action is initiated, we may retain it until the end of the action and any potential periods of appeal. After this time, we will anonymize or delete your personal information. For prospect data (i.e. those who have not made a purchase with us but are interested in our products), we will retain the data for three years from the last contact. We may also retain personal data collected through telephone conversations with our customer service for the applicable legal retention period.
6. YOUR RIGHTS
You have the right to request access to the personal information we maintain about you. If you make this request, we are required by law to provide you with information about the purposes of the processing, the categories of data being processed, the categories of recipients, the data retention period, and any other relevant details. You can also request a copy of any personal information we have on file for you in a format that allows you to exercise your right to data portability, provided that the processing is based on your consent or on the performance of a contract between you and us.
You can also give us general or specific instructions on how your personal data should be processed and used after your death. You have the right to request that we correct, amend, or delete any information that is incomplete, out of date, or inaccurate. You can request the deletion of your personal information if (1) it is no longer necessary for the purposes of the processing, (2) you have withdrawn your consent for processing based solely on that consent, (3) you object to the processing, (4) the processing is unlawful, or (5) the personal information must be erased to comply with a legal obligation applicable to us. If you make this request, we will take reasonable steps to inform other entities in our group of your request.
You can also request the restriction of processing if (1) the accuracy of your personal information is contested and you want us to verify it, (2) you want to restrict your personal information rather than delete it, even though the processing is unlawful, (3) you need your personal information for the defense of legal claims, but you want to restrict its processing, or (4) you have objected to the processing and we are verifying whether we have legitimate grounds for the processing that may override your rights.
You have the right to file a complaint with the competent supervisory authority. If you have any questions or concerns, you can contact us at email@example.com. If you have given your consent for processing (such as when you agree to receive communication materials), you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on your consent before it was withdrawn. If your information is being processed to pursue our legitimate interests, you have the right to object to such processing if our legitimate interests may be overridden by your interests and fundamental rights. To exercise any of these rights, please contact us at firstname.lastname@example.org and we will respond.
7. PROTECTING YOUR PERSONAL INFORMATION
We take appropriate measures to protect the personal data that we collect and process, including implementing technical and organizational security measures to prevent unauthorized access or misuse. However, no data transmission or storage is completely secure, so we cannot guarantee the absolute security of your personal information. We recommend that you take care when using the internet, particularly when accessing our websites or social media.
We do not intentionally collect personally identifiable information from children under the age of 16 without the permission of a parent or guardian. If we discover that a child under the age of 16 has provided us with personal information, we will delete it in accordance with applicable law. Our website is not intended for children and we do not knowingly market to or target children. In order to engage in transactions on our online store or use our websites or apps, you must be at least 18 years old and have the legal capacity to enter into a binding contract. By engaging in transactions with us or using our websites or apps, you affirm that you are at least 18 years old and have the legal capacity to enter into and be bound by such transactions.
9. THIRD PARTY SITES
Our website may contain links to third party sites or services that we do not control. These sites and services are governed by their own privacy policies, which may differ from ours. We strongly recommend that you review the privacy policies of any third party sites or services that you visit to understand how they are using your personal information. This Policy does not apply to those third party sites or services.
If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information above.
Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.
If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information above.
If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at email@example.com
Cookies are small pieces of data that are stored on your computer or mobile device when you visit a website. These cookies help websites remember your actions or preferences over a period of time so that you don't have to keep re-entering them whenever you come back to the site or browse from one page to another. Cookies are used for a variety of purposes, such as to keep you logged in to a website, to remember the items in your shopping cart, and to customize the content and ads that are shown to you.
Some cookies track your browsing and shopping habits when you use our websites on the same device. This information includes the pages you visit, the products you purchase, and your overall movement within the website. All data collected by cookies is anonymous and does not include personal details such as your name, address, phone number, or payment information. However, it may contain a unique customer reference number specific to you. For more in-depth information about how cookies work, you can visit www.allaboutcookies.org.
HOW ARE COOKIES MANAGED?
The cookies stored on your device when you visit our websites are created by:
- AVERCINI or by entities working on our behalf, and are necessary to allow you to make purchases on our websites.
- Third parties that partner with us in marketing programs.
- Third parties that display web banner ads for us.
WHAT ARE COOKIES USED FOR?
Cookies are used by our marketing partners to show you relevant offers and ads as you browse other websites, based on your browsing activity on our site. They also allow us to work with our web analytics partner, Google Analytics, to understand how you use our website and identify any preferences or preferred pages or features. We may combine the data collected through cookies with personal data we already have about you to gain a better understanding of you. This helps us to continually improve the relevance of our promotional communications, your shopping experience, and our products and services. The main purposes for which cookies are used are:
- Functionality, including online transactions, site navigation, and preferences.
- Marketing and advertising, such as web banner ads and targeted updates through digital channels and social media.
- Tracking browsing and shopping behavior to improve the shopping experience and monitor performance.
- Fulfilling contractual obligations to make payments to third parties when a product is purchased by someone who has visited our website from their site.
AVERCINI partners with other companies to serve ads or present online offers on our behalf. Many of these marketing partners use both session and persistent cookies. These cookies help deliver ads that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement and to measure the effectiveness of an advertising campaign. All data collected by third-party cookies is anonymous and does not include your name, address, phone number, email address, or payment details.
WHAT TYPE OF COOKIES DO WE USE?
There are two types of cookies that may be used during your visit to our site:
- Session cookies: These cookies are deleted after each visit to our site. For example, when you are browsing our site, it will remember you for the duration of your visit, but the cookie will be removed from your computer as soon as you close your internet browser. Session cookies allow you to add items to your shopping cart and move through the checkout process. If you disable these cookies through your web browser, you will not be able to place an order on this site.
- Persistent cookies: These cookies remember you for a set period of time, allowing your wishlist and/or previously viewed products to be displayed the next time you visit our site, and remembering whether you were logged into your account.
TURNING OFF AND DELETING COOKIES
Most web browsers allow you to turn off or disallow cookies. The process for doing this varies depending on the browser you are using. You can usually find instructions for disallowing cookies in the browser's "Help" menu. Please note that, like most other transactional websites, disabling third-party cookies will not prevent you from making purchases on our websites, but refusing the cookies we use through your web browser will prevent you from making transactional purchases on our website. Additionally, the functionality of many other websites and services may be affected. You can delete cookies using your web browser, but unless they are disallowed, they will be reapplied the next time you visit a website.
To disable cookies, you need to change your website browser settings to reject cookies. The process for doing this varies depending on the browser you use. Here are instructions for disabling cookies in the most popular desktop browsers (these may vary depending on your operating system and browser version):
- Choose “Settings” and click on “Advanced”
- Under "Privacy and Security" click “Content Settings”
- Click “Cookies”
- Choose the menu “Tools” then “Internet Options”
- Click on the “Privacy” tab
- Select “Advanced”
- Choose the appropriate settings
- Choose Preferences > Privacy
- Click on “Block all cookies”
- Click on the menu icon then select “Options”
- Click on the icon “Privacy & Security”
- Find the menu “cookie” and select the relevant options
- Choose the menu icon and select “Settings”
- Click on “Privacy & Security”
- Choose the appropriate settings
Cookies Necessary for the Functioning of the Store
|_ab||Used in connection with access to admin.||2y|
|_secure_session_id||Used in connection with navigation through a storefront.||24h|
|_shopify_country||Used in connection with checkout.||session|
|_shopify_m||Used for managing customer privacy settings.||1y|
|_shopify_tm||Used for managing customer privacy settings.||30min|
|_shopify_tw||Used for managing customer privacy settings.||2w|
|_storefront_u||Used to facilitate updating customer account information.||1min|
|c||Used in connection with checkout.||1y|
|cart||Used in connection with shopping cart.||2w|
|cart_currency||Used in connection with shopping cart.||2w|
|cart_sig||Used in connection with checkout.||2w|
|cart_ts||Used in connection with checkout.||2w|
|cart_ver||Used in connection with shopping cart.||2w|
|checkout||Used in connection with checkout.||4w|
|checkout_token||Used in connection with checkout.||1y|
|dynamic_checkout_shown_on_cart||Used in connection with checkout.||30min|
|hide_shopify_pay_for_checkout||Used in connection with checkout.||session|
|keep_alive||Used in connection with buyer localization.||2w|
|master_device_id||Used in connection with merchant login.||2y|
|previous_step||Used in connection with checkout.||1y|
|remember_me||Used in connection with checkout.||1y|
|secure_customer_sig||Used in connection with customer login.||20y|
|shopify_pay||Used in connection with checkout.||1y|
|shopify_pay_redirect||Used in connection with checkout.||30 minutes, 3w or 1y depending on value|
|storefront_digest||Used in connection with customer login.||2y|
|tracked_start_checkout||Used in connection with checkout.||1y|
|checkout_one_experiment||Used in connection with checkout.||session|
|checkout_session_lookup||Used in connection with checkout.||3w|
|checkout_session_token_<<token>>||Used in connection with checkout.||3w|
|identity-state||Used in connection with customer authentication.||24h|
|identity-state-<<token>>||Used in connection with customer authentication.||24h|
|identity_customer_account_number||Used in connection with customer authentication.||12w|
Reporting and Analytics
|_landing_page||Track landing pages.||2w|
|_orig_referrer||Track landing pages.||2w|
|_shopify_sa_p||Shopify analytics relating to marketing & referrals.||30min|
|_shopify_sa_t||Shopify analytics relating to marketing & referrals.||30min|
|_shopify_ga||Shopify and Google Analytics.||session|
Our policy may be updated from time to time to reflect changes in the way we process your personal information. We will inform you of any significant changes as required by law and will post an updated version of the policy on the website.
Last updated: 5.1.2023