Introduction

This is the privacy and cookies policy for www.marceloburlon.eu being the e-commerce website of County S.r.l. (we, us and our) for the sale and purchase of our products (Site). For the purposes of European data protection legislation (Data Protection Law), we are the data controller in relation to the personal data processed in accordance with this policy.

We are committed to protecting your privacy on-line when visiting the Site or communicating electronically with us. We appreciate that you do not want the personal information you provide to us distributed indiscriminately and here we explain how and why we collect and process personal data, what we do with it and what controls you have. We will also treat all your personal information as confidential, l keep it on secure servers, and comply with all applicable Data Protection Law and consumer legislation.

By using the Site, you acknowledge that you have read the terms of this privacy and cookies policy.

Whose personal data do we process?

We may process personal data relating to you if:

- You are a user of our Site.
- You are our customer.
- You use our products.
- You are someone to whom we want to advertise or market our products.

Information we may collect from you

Through your use of the Site, we may collect and process the following information about you:

information (such as but not limited to your name, email address, billing address, delivery address, telephone number, product selections, payment type and card expiry number or log in and password details) that you provide by completing forms on the Site, including if you register as a user of the Site, purchase any goods from the Site, upload or submit any material via the Site, request any information, or enter into any competition or promotion we may sponsor;
Information relating to transactions with us involving details of goods that we have supplied to you.
Information provided to us when you communicate with us, for example by email or phone. This includes communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Site or its content.
information from surveys that we may, from time to time, run on the Site for research purposes, if you choose to respond to, or participate in, them.
Internet pages you have visited immediately before coming to the Site or pages you visit immediately after leaving the Site.

You are under no obligation to provide any such information. However, if you should choose to withhold requested information (e.g. your address or payment details), we may not be able to provide you with certain services.

Cookies

What are Cookies

Most websites you visit will use cookies to improve your user experience by enabling that website to remember you, either for the duration of your visit (using a 'session cookie') or for future visits (using a 'persistent cookie').

A cookie is a simple text file that is issued to your computer when you visit a website and which stores and sometimes tracks information about your use of a website. Each cookie is unique to your browser. It will contain some anonymous information such as a unique identifier, the website name and some digits and numbers. It allows a website to remember things like your preferences or what's in your shopping basket.

Although they do identify a user's computer, cookies do not personally identify users, and passwords and credit card information are not stored in cookies.

Cookies are not programs and therefore cannot contain viruses or other malicious software.

How We Use Cookies

You can find a summary of the various types of cookies we use below. Our cookies are used for 5 types of purpose:

We use the following categories of cookies on our Site.

◾CATEGORY 1: STRICTLY NECESSARY COOKIES

These cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided. These cookies are passed under HTTPS in an encrypted format. This provides the most security when identifying you as a user.
We will also use cookies in order to protect the brand and our customers from fraudulent activities during the checkout operations. In this context, we may engage third parties, that will help us to conduct this activity. All the data collected throughout these cookies will be encrypted and stored for a period of 4 (four) years and will be processed only in the case that a customer checks out any of our products.

◾CATEGORY 2: PERFORMANCE COOKIES

These cookies collect anonymous information on how people use our Site. For example, we use Google Analytics cookies to help us understand how customers arrive at our Site, browse or use our Site and highlight areas where we can improve areas such as navigation, user experience, shopping experience and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.

Google Analytics is a system used by many websites to record information about who visits a website. Google sets five different cookies with expiry dates ranging from 1 day to 2 years. These cookies are used mainly to differentiate between first time visitors to a website and repeat visitors. They do not contain any personally identifiable information. You can find out more about how Google uses cookies at http://www.google.com/intl/en/analytics/privacyoverview.html

◾CATEGORY 3: FUNCTIONALITY COOKIES

These cookies allow us to:

remember choices you make such as the country you visit our Site from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
remember that you have visited us before; this means we can identify the number of unique visitors we receive. This allows us to make sure we have enough capacity for the number of users that we get.

◾CATEGORY 4: TARGETING COOKIES OR ADVERTISING COOKIES

These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, we use third party companies such as Criteo to provide you with more personalised adverts when visiting other websites.

◾CATEGORY 5: SOCIAL MEDIA COOKIES

These cookies allow you to share what you’ve been doing on the Site on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work.

Controlling or deleting cookies

Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set.

If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.

Information on deleting or controlling cookies is available at www.AboutCookies.org, which includes additional useful information on cookies and how to block cookies using different types of browser or mobile device.

Please note that by deleting or restricting cookies or by disabling future cookies you may not be able to access certain areas or features of our Site or take full advantage of the Site.

To opt out of being tracked by Google Analytics across all websites visit Google Analytics Opt-out Browser Add-on.

If you'd like to opt out of other third party cookies relating to behavioural advertising, please go to www.youronlinechoices.eu. Opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

Uses made of your information

We will use the information you provide only for the following purposes:

Information you give to us

We will use this information:

to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
to provide you, with information about goods or services we feel may interest you, if you have ticked the relevant box situated on the form on which we collect your data (the order form or registration form to create an account with the Site) indicating your consent to receiving marketing material from us;
verify and carry out financial transactions in relation to payments you make online;
to notify you about changes to our service provided by the Site;
to ensure in our legitimate interests that content from our Site is presented in the most effective manner for you and for your computer.

Information we collect about you

We will use this information:

to administer our Site and your account with us under our terms and for internal operations, including identifying visitors to the Site, troubleshooting, and, in our legitimate interests, auditing the downloading of data, data analysis (demographic and sales data), testing, research, statistical and survey purposes;
to improve our Site to ensure that content is presented in the most effective manner for you and for your computer;
to identify visitors to the Site;
to allow you to participate in interactive features of our Site, when you choose to do so;
as part of our legitimate efforts to keep our Site safe and secure;
for our legitimate interest of measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them in our legitimate interests and subject to your stated preferences where relevant.
send you information we think you may find useful or which you have requested from us, including information about our products and services, provided you have indicated that you do not object to being contacted for these purposes;

allow, with your consent, carefully selected third parties to send you information directly which you may find useful regarding their products and services.

You can tell us not to contact you with information regarding our products and services either at the point such information is collected on the Site (by checking (as directed) the relevant box) or, where you do not wish us to continue to use your information in this way, by following the unsubscribe instructions on any communications sent to you. You can also exercise the right at any time by contacting us using the Contacting us details at the end of this privacy policy.

Legal grounds for our processing of your personal data

The basis on which we process your personal data is as follows:

- Where it is necessary to obtain your prior consent to the processing concerned in order for us to be allowed to do it, we will obtain and rely on your consent in relation to the processing concerned.
- Otherwise, we will process your personal data only where the processing is necessary:
- for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract;
- for compliance with a legal obligation to which we are a subject; or
- for the purposes of the legitimate interests pursued by us or another person, provided that this will only be in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data.

Information sharing

We may disclose aggregate statistics about visitors to the Site, customers and sales in order to describe our services to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information.

We may disclose your personal information to any of our affiliates or Group Companies – The Ambush Italy S.r.l. is incorporated in the Farfetch Group. Our group of companies, which means our subsidiaries, our ultimate holding company, and that company’s subsidiaries as defined in section 1159 of the UK Companies Act 2006 includes, but is not limited to Farfetch UK Limited, New Guards Group Holding S.p.A, Browns (South Molton Street) Limited, Farfetch Portugal – Unipessoal, Lda., Farfetch (Shanghai) E-Commerce Co. Ltd., Farfetch.com US LLC, Stadium Enterprises LLC, Farfetch RU LLC, Farfetch. Com Brasil Serviços Ltda., Farfetch India Private Limited. –, or to our agents or contractors who assist us in providing the services we offer through the Site, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks, from time to time.

We have subcontracted the operation of certain aspects of the Site to Farfetch Black & White Limited, a trading division of Farfetch UK Limited (company number 06400760, VAT number GB 204 0769 35) (Farfetch). Services provided or procured by Farfetch include, but are not limited to, payment processing, customer service, hosting and delivery logistics. Our agents and contractors will only use your information to the extent necessary to perform their functions, and always subject to appropriate security and contractual safeguards.

We may share your information with other companies and organisations for identity verification and fraud protection purposes to the extent permitted by applicable laws.

In the event that we undergo re-organisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.

You should be aware that we may be under a duty to disclose or share your personal information and/or user information in order to comply with any legal obligation. We may also disclose your personal information if we believe that such action is necessary to prevent fraud or cyber crime or to protect the Site or the rights, property or personal safety of any person.

Child safety

Protecting the safety of children when they use the Internet is very important to us. We recommend that children receive permission from their parent or guardian before gaining access to the Site or sending personal information to us or anyone else online.

External links

The Site may, from time to time, contain links to external sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and processes and that we do not accept any responsibility or liability for these policies and processes. Please check these policies before you submit any personal data to these websites.

Payment processing

Payment details you provide will be encrypted using secure sockets layer (SSL) technology before they are submitted to us over the internet. Payments made on the Site are made through our payment gateway provider from time to time, [including PayPal and Adyen]. You will be providing credit or debit card information directly to such payment provider which operates a secure server to process payment details, encrypting your credit/debit card information and authorising payment. Information which you supply to such payment providers is not within our control and will be subject to their own privacy policy and terms and conditions. For more information please contact us.

Security

We place great importance on the security of all personally identifiable information associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal information. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.

You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via the Site whilst it is in transit over the internet and any such submission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal information if you use a shared computer or a computer in a public place.

Data Retention

We process personal data only for so long as it is necessary for the purpose(s) for which it was originally collected, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject or for another legitimate and lawful purpose.

In particular, the data relating to purchases will be kept for 10 years in accordance with the accounting and fiscal obligations provided for by law (art. 2220 Italian Civil Code); (ii) data collected for marketing purposes will be kept until your consent is revoked or until the newsletter service is active.

Furthermore, the data collected may be stored to allow the company to defend itself in court. In such cases, only the data necessary to ensure full rights of defence will be stored. With regard to data collected through cookies please refer to the cookie policy.

Storage of your information

Your personal information may be transferred to, and stored at a destination outside of the European Economic Area including the US. The US and other non-EEA countries do not have similar data protection laws to the EEA, and you should be aware in particular that the law and practice in the United States in respect of law enforcement authority access to data is significantly different from Europe. Where we transfer your information we will take all reasonable steps to ensure that your data is subject to appropriate safeguards, such as relying on EU approved standard contractual clauses relevant to transfers of personal information and that it is treated securely and in accordance with this privacy policy.

Information submitted by you may be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above (see Information sharing), which may be situated outside the European Economic Area (EEA) and may be processed by staff operating outside the EEA who work for these third parties or for us or one of our suppliers. This includes staff engaged in, among other things, the processing of payment details and the provision of support services. The countries concerned may not have similar data protection laws to the EEA. Where we transfer your information we will take all reasonable steps to ensure that your data is subject to appropriate safeguards, such as relying on EU approved standard contractual clauses relevant to transfers of personal information and that it is treated securely and in accordance with this privacy policy.

Your rights

You have the following rights in relation to personal data relating to you that we process:

- You may request access to the personal data concerned (please see the section on how to access to your personal data, below).
- You may request that any incorrect personal data about you that we are processing be rectified.
- In certain circumstances (normally where the personal data has been provided by you and it is no longer necessary for us to continue to process it), you may be entitled to request that we erase the personal data concerned.
- Where we are processing personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent at any time, after which we shall stop the processing concerned. If you do withdraw your consent here, please note that this may affect our ability to provide you with our goods or services.
- If you have a complaint about any processing of your personal data being conducted by us, you can contact us or lodge a formal compliant with the Supervisory Authority

Contacting us

Please submit any questions, concerns or comments you have about this privacy policy or any requests concerning your personal data by email to privacy@newguardsgroup.com between the hours of 9am to 6pm, Monday to Friday or write to us at:

Via Filippo Turati, 12 20121 Milano (MI)

The Supervisory Authority

The Italian Data Protection Authority is the supervisory authority of County S.r.l. and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

Changes to this policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy and cookies policy.

Date of this policy

This policy was last updated on 4/9/2020.