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PERSONAL DATA PROCESSING POLICY

Dear User,
This policy is provided pursuant to articles 13 and 14 of European Regulation 2016/679 concerning the protection of Personal Data. This page is provided to help you in understanding the manner in which your personal data is collected and processed while you are using the website https://www.julian-fashion.com and the reasons for which the data is collected.
The information provided below pertains to the website https://www.julian-fashion.com (hereinafter “website”) and does not apply to third-party websites and/or applications referred to by links on the website.
Any personal data that you wish to provide Julian Fashion, directly or otherwise, through the website, including in the context of services provided by Julian Fashion (hereinafter “Services”) will be processed with respect to the fundamental principles of data protection, which include the principles of transparency, minimization, lawfulness and fairness.
This policy is divided into the paragraphs listed in the index below to make navigating it easier, with each paragraph dedicated to a specific topic.

INDEX

1. Data Controller
2. Processed Information
3. Purpose of Processing and Legal Basis
4. Recipients
5. Retention Times and Criteria
6. Rights of the Interested Party
7. Updates and Changes

1. Data Controller
The Data controller of the personal data processed through the website for the purposes described below, is Julian Fashion S.r.l., Viale Matteotti n. 31- 45015 Milano Marittima (RA), VAT: 01304480393, email address: privacy@julian-fashion.com (hereinafter “Julian Fashion” or “Data Controller”).

2. Processed Information
In the context of the Services offered on the website, the Data Controller will process information concerning you and that could be automatically collected during your browsing of the website or information provided directly by you (for example when compiling the form on the Contact page, subscribing to the newsletter or requesting to use Services offered through the website).

In particular, the personal data processed through the website are:
   a) Name, Contact Details and other Personal Data
In some sections of the website, for example on the Contact page, you will be requested to provide Personal Data such as your First Name, Last Name, Telephone number, Email address, as well as any additional information you wish to provide us using the dedicated space for your request. Also, when purchasing a product, you can use the “notes” or “ticket notes” fields to provide some information that could contain your or third-party data.

In the sections that provide free-entry fields, we invite you to not send us Personal Data that could reveal your racial or ethnic origins, political opinions, religious or philosophical beliefs, union membership, genetic or biometric data, health data or sexual orientation. We wish to underline that should you provide such information, that would imply your explicit consent in doing so. Should you provide us with other people’s Personal Data, you accept the responsibility of an independent data controller and in turn assume all obligations foreseen by the current legislation, including verifying the suitability of the legal basis of the processing. In such cases, you confer to Julian Fashion every indemnity and guarantee regarding any possible disputes or claims of third parties referring to Personal Data that you have provided or communicated to Julian Fashion.

   b) Personal Data for the Creation of an Account (Registration)
Registering to create a personal account is one of the Services available on the website. If you decide to create a personal account on the website, you will be asked to provide the following Personal Data: First Name, Last name, Email Address, Country of Birth and Date of Birth.It is also possible to register on the website using one of your personal accounts registered on third parties and social media websites such as Google and Facebook. In such cases, your Personal Data such as your Name, Last name, and Email Address, is sent automatically from the third parties to Julian Fashion. To find out which data will be shared by the aforementioned third parties, you can refer to their respective privacy policies.

   c) Personal Data Relevant to the Purchasing of Products on the Website
You can access Julian Fashion’s e-commerce platform and purchase through it using either your registered account or in guest mode at check out. When you purchase items through the website, therefore benefiting from its Services, the Personal Data you provide during the purchasing process, or the Personal Data provided during registration in case you are a registered user, will be collected and processed to manage the activities pertaining to and necessary to finalising the sale. While using the Services, you could also be requested to provide information related to your chosen payment method, such as credit card or bank transfer for example.
Additional Personal Data might be collected during the management of any relationship with Julian Fashion following the sale, such as the information you decide to provide us by contacting customer care and/or using the contact details available on the website.

   d) Job Applications
On accessing the section on the website dedicated to receiving spontaneous job applications for working at Julian Fashion, you will be asked to provide some Personal Data and other professional and work-related details concerning you. The Data provided for these reasons, including sending your Curriculum Vitae/Resumé, will be processed by Julian Fashion as described in the specific policy available in the job application sections , to which reference should be made in full.

   e) Browsing Data and Cookies
The system and software procedures in place to operate the Website collect, during their normal operation, some Personal Data which is collected and transmitted implicitly during the use of Internet communication protocols. This includes IP addresses or the domain names of the computers and terminals used by the users, URI/URL addresses (Uniform Resource Identifier/Locator) of the requested resources, the time of the request, the method used to submit the request to the server, the dimensions of the file received in response, the numerical code indicating the status of the response on the server (successful, error, etc.) and other parameters relative to the user’s operating system and IT environment.
Processing this Data also aims to obtain statistical information regarding the use of the Website and to ensure it functions correctly.The information pertaining to the use of cookies on the Website is available in the Cookie Policy, which we invite you to read carefully.  

3. Purpose of Processing and Legal Basis

The Data Controller processes your Personal Data for the following purposes:

   a) Providing Services and Sale of Products: your Data will be processed to carry out all the activities related to the purchase of products and to provide you with assistance before, during and after a sale. Your Data will be processed to: assist you, verify your identity, allow you to view your purchase history, finalize your purchase order and to send you the products purchased on the Website in addition to providing you with any other Services you might request.The optional, explicit and voluntary sending of messages to the contact addresses listed on the Website, such as through the Contact page or by contacting Julian Fashion, involves the acquisition of the Data necessary to respond to your requests, as well as any Personal Data that might be included in your communications.
The legal basis for processing this information is the execution of a sales contract in which you are a party or the execution of precontractual measures taken at your request. This is necessary to receive your order, process it correctly (including invoicing activities) and to deliver your products to you. 

   b) Soft Spam: Your data will be used, only in case you have previously bought items or services from the Website, to send you marketing, promotion and advertising emails related to similar products or services to those you have purchased. You can choose to not receive these communications at any time by following the instructions outlined in the “Rights of the Interested Party” section or by simply clicking the Unsubscribe link found at the bottom of all our emails. You could also choose to leave a review of the purchased items and services on third party website, Trustpilot . That option is completely up to you.

   c) Marketing: Only in case you have expressed your consent, either through ticking the appropriate checkbox or by subscribing to our newsletter, your Personal Data will be processed to inform you about Julian Fashion’s products and services, in addition to promotional, commercial, market research, or marketing activities. You might also be contacted to complete forms such as questionnaires or surveys as part of Julian Fashion’s client satisfaction measurement activities. If you have a personal account, we could send you email communications containing offers or promotions on products in your shopping cart that you haven’t purchased. Such activities could be carried out either automatically without the operator’s intervention via email, or through traditional communication methods such as via post or telephone. Should you subscribe to the newsletter by filling the dedicated form on the Website, you will receive promotional and commercial emails related to Julian Fashion’s services and activities.Processing your Data for these purposes is based on your free and explicit consent: you are not obliged to provide said consent and if provided, you are always free to revoke it at any moment with the only consequence being not receiving further marketing communications from Julian Fashion. You can revoke your previously provided consent by following the instructions outlined in the “Rights of the Interested Party” section or by simply clicking on the Unsubscribe link found at the bottom of all our emails.

   d) Profiling: Through certain types of cookies on the Website, the Controller could carry out profiling activities, provided you have given your consent to use profiling cookies or similar technologies. This includes, for example, analysing Website usage and the efficiency of the advertisements and promotions including those present on third party platforms. For further details regarding cookies and similar technologies, we invite to refer to the Cookie Policy and the list of cookies, including third party cookies, accessible via the cookie banner or the link in the Website’s footer. You can revoke consent related to cookies via the “Cookie Policy” link in the Website’s footer and by following the instructions outlined therein.

   e) Legal Obligations: Your data may be processed to allow Julian Fashion to fulfil its obligations under national, EU or international laws, regulations, or mandatory provisions issued by the competent authorities. The legal basis for this type of processing is the fulfilment of legal obligations by the Controller. The provision of Personal Data for these purposes is necessary to allow Julian Fashion to fulfil the regulatory obligations to which it is subject. 

   f) Security: Your Data might be processed to prevent and/or identify any anomalies, fraudulent activities and/or abuses related to the usage of the Website or Services. The legal basis for this type of processing is the legitimate interest of the Data Controller in preventing or identifying activities or abuses that might also have criminal relevance. 


4. Recipients
Your Personal Data could be shared with the following parties:
   a) Personnel authorized for processing by the Data Controller, duly designated and who are committed to or have a legal obligation to confidentiality, such as Julian Fashion employees.

   b) Third parties designated as Data Processors, tasked with processing the Data on behalf of the Data Controller. This includes parties with whom it is necessary to interact for the provision of services such as hosting providers, email platform providers, third parties tasked with carrying out maintenance activities of network equipment and electronic communication networks. 

   c) Third parties with whom it is necessary to interact for the fulfilment of the Services available on the Website and who also act as independent data controllers, such as couriers and freight forwarders who deliver your purchased items.

   d) Subjects, bodies, or authorities to whom it is mandatory to communicate your Data in order to comply with legal obligations or for security reasons.

Your Personal Data is not intended for publication or dissemination.

Some of your Personal Data might be shared with recipients in countries outside the European Union (EU) or the European Economic Area (EEA). In such cases, the Controller ensures that the processing of your Personal Data is performed according to the applicable legislation. That in turn means that the transfers are done following adequate measures, such as adequacy decisions, models of Standard Contractual Clauses approved by the European Commission or other guarantees considered adequate.


5. Retention Times and Criteria
Personal Data processed for the “Provision of Services and the sale of products” will be retained for the time strictly necessary for the correct fulfilment of your requests and of the pre-contractual or contractual relationship in progress with you, barring necessary or legal obligations that impose a longer retention time.Personal Data processed for “Soft Spam” or “Marketing” will be retained until you revoke your previously given consent or until you object to the processing.Personal Data processed for “Legal Obligations” will be retained for the period foreseen by the specific legal obligations and the applicable legislation.Personal Data processed for “Security” reasons will be retained for the time strictly necessary for those purposes, also considering the time necessary for court protection and/or the communication of such Data to the competent authorities.

6. Rights of the Interested Party
As an interested party, you have the right to obtain access to your Personal Data from Julian Fashion, in the cases provided for, and to modify and delete it.You also have the right to limit the processing of your Data and to object to its processing (Articles 15 and following of the Regulation).
You can also revoke your consent at any time to the processing of your Personal Data for “Marketing” purposes and you can object to their processing for “Soft Spam” purposes. The consent expressed for receiving promotional communications for Marketing purposes does not only cover communications sent via automated systems without the operator’s intervention (email, for example), but also extends to traditional communication methods such as via post or telephone. You could therefore revoke your consent to processing your information in a more granular and selective way; deciding for example to receive these communications solely via post and not through automated systems like email. You can also interrupt the receipt of promotional communications sent via email for purposes of Marketing and Soft Spam by using the unsubscribe link found at the bottom of all our emails.You can object to the use of profiling cookies when using the Website, by following the instructions in the Cookie Policy.If you have registered on the Website, you can change the Personal Data you provided Julian Fashion at any time by accessing the reserved area of your account.For any enquiries regarding the Personal Data you provided Julian Fashion or to request their modification or deletion,  you can fill this request form and send it, preferably to the email address privacy@julian-fashion.com, or to any of the Data Controller contacts indicated in the first paragraph of this Policy.Interested parties who deem the processing of their Personal Data carried out on this website to be in violation of provisions of the Regulation, have the right to lodge a complaint with the Italian Data Protection Authority, as foreseen by Article 77 of the Regulation, or take the appropriate legal steps (Article 79 of the Regulation).

7. Updates and Changes
The Data Controller reserves the right to periodically change, supplement or change this policy in compliance with the applicable legislation or the measures adopted by Guarantor for the Protection of Personal Data (Italian Data Protection Authority).


COOKIE POLICY

INDEX
1. Definitions, types, and application of the legislation
2. Types of Cookies Used on the Website
3. How to Manage or Delete Cookies

1. Definitions, types, and application of the legislation

Cookies are small text files that are sent or stored on the user’s computer or mobile device by the website they visit, which are then sent back to those same sites on the next visit. Cookies are how a website remembers the user’s actions and preferences (such as login details, chosen language, font size, other display setting, etc.) so that they do not have to be chosen again when the user returns to the website or browses from one page to another.Cookies are used for computer authentication, session monitoring and storage of information related to user activities when accessing a site. They can also contain a unique identification code which keeps track of user navigation within the site for statistical or advertising purposes. Some operations could not be performed without the use of cookies, which in certain cases are technically necessary for the functioning of the website.For further information regarding cookies and their general functions, the user could consult dedicated websites such as www.allaboutcookies.orgCookies can be either set directly by the website or web server that the user is visiting or created and stored by the website whose address has been typed and displayed in the URL window (referred to as "first party" cookies).While browsing a website, the user can receive cookies on their device from websites or servers other than the one they are visiting (referred to as “third party” cookies). Third party cookies are stored when visiting a website and a third-party with respect to the operator of the visited site releases a cookie they own through it.There are also various types of cookies which, depending on their characteristics and functions, can remain on the user's computer for different periods of time. These include session cookies, which are automatically deleted when the browser is closed and persistent cookies, which remain on your device until a set deadline.Based on the current applicable legislation in Italy, user consent is not always required for the use of cookies. Technical cookies, which are cookies who have the sole purpose of transmitting a communication over a communication network, or to the extent strictly necessary to provide a service that has been explicitly requested by the user, do not require consent. Among the technical cookies, which do not require consent for their usage, are:• First-party analytical cookies used to collect information, in aggregate form, regarding the number of users and how they visit the website.• Third-party analytical cookies, when tools are used that reduce their identifying capacity and the third party doesn’t cross the collected information with others in their possession.• Browsing or Session cookies, used to authenticate and access a service.• Functional cookies, which aim to improve the service provided to the user by configuring the website to match some of their previously indicated preferences (for example: the language, the products selected for purchase). Inversely, profiling cookies, which create user profiles and are used to send advertising messages in line with the user’s overall online activity, require the user’s prior consent. Users’ consent is also requested for third-party analytical cookies when tools that reduce their identifying capacity aren’t used and the third-party crosses the collected information with information already in their possession.  

2. Types of Cookies Used on the Website

The Website uses the following types of cookies:
a) Technical browsing or session cookies, strictly necessary for the functioning of the Website or to allow the user to take advantage of the requested content or Services.
b) Functional cookies, used to activate specific functions on the Website and to configure it according to the user’s preferences (language, for example) with the aim of improving their browsing experience.
c) Analytical cookies, which help in understanding how the Website is used by its visitors and to track the website’s entering and exiting traffic. Google Analytics is used with the adoption of measures that reduce the identifying power of these cookies by masking a portion of the IP. Please note that it is possible to install an add-on to deactivate Google Analytics on the browser in use (https://tools.google.com/dlpage/gaoptout).
d) Profiling cookies used to observe the user’s preferences expressed by their usage of the website and to send them advertising messages that are in line with these preferences.
Please note that disabling browsing, session and/or functional cookies, could lead to the Website being unreachable or to certain Services or functions of the Website not being available or not functioning correctly. The user might also be restricted to modifying or manually inserting certain information or preferences every time they visit the Website.
The user can view the cookies used by the Website by accessing the list of cookies, third party cookies included, through the Cookie Policy.

3. How to Manage or Delete Cookies

Most internet browsers are initially setup to automatically accept cookies. The user can modify these settings to block cookies or to be notified every time cookies are sent to the browsing device. The user can also delete collected cookies from their device at the end of each browsing session. There are numerous ways to manage cookies. Please refer to the instructions for your browser of choice. If the user uses different devices to view and browse the internet (for example, computer, smartphone, tablet etc.). It is the user’s responsibility to ensure that each browser on each device is set up to reflect their preferences regarding cookies.For further information on managing cookies, please head to http://www.allaboutcookies.org/manage-cookies/
It is possible to access the specific instructions for cookie management for the main web browsers, using the links below.
Microsoft Windows Explorer
http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
Google Chrome
https://support.google.com/chrome/answer/95647?hl=en&p=cpn_cookies
Mozilla Firefox
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Apple Safari
http://www.apple.com/legal/privacy/it/cookies/

If the user does not use any of the browsers listed above, they could select “Cookies” in the relevant section of the guide  to find out where the cookie folder is located.
You can also manage your choices regarding third-party cookies using online platforms such as AdChoice.