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PRIVACY POLICY

PRIVACY POLICY

Pursuant to art. 13 of the Regulation (EU) 2016/679 of the European Parliament and of the Council

Red Keep S.r.l. would like to inform you that, pursuant to art. 13 of the Regulation (EU) 2016/679 of the European Parliament and of the Council concerning the protection of individuals with regard to the processing of personal data (hereinafter referred to as “European Regulation”), needs to proceed with the processing of your personal data collected automatically or provided by you while browsing or using the website https://international.cliomakeupshop.com/ (hereinafter referred to as “Website”).

This Privacy Policy, therefore, refers exclusively to the Website and does not cover other websites, pages or online services reachable through hypertext links that may be published within it.

  1. DATA CONTROLLER

The Data Controller is Red Keep S.r.l., in the person of its legal representative, domiciled at the registered office of Via Timavo n. 34, Milan, Italy (hereinafter referred to as “ClioMakeUp Shop” or “Data Controller”).

  1. TYPE OF DATA PROCESSED

To allow you to use the Website and its services, including the ability to make purchases, register and get in touch with ClioMakeUp Shop for specific requests, as well as send us your curriculum vitae (hereinafter referred to as “Services”), the data controller needs to know and process some of your personal data.

Browsing data

The computer systems and software procedures used to operate the Website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet network communication protocols.

This category of data includes the IP addresses or domain names of the computers used by users connecting to the website, the URI (Uniform Resource Identifier) ​​addresses 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 numeric code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and the user's IT environment.

These data, necessary for the use of the Website, are processed for the sole purpose of obtaining statistical information on the use of the Services (most visited pages, number of visitors by time or day, geographical areas of origin, etc.) and to check the correct functioning of the Services offered.

The navigation data do not persist for more than seven days and is deleted immediately after their aggregation, subject to the possible need for the investigation of crimes by the judicial authority.

Voluntarily provided data

In order to create your account on the Website, ClioMakeUp Shop needs to process your first and last name, your date of birth and your contact details (such as phone number and email address). To allow you to purchase our products, your name and surname, your residential address and your contact details (such as telephone number and email address) will be requested.

The optional, explicit and voluntary sending of e-mails, as well as the filling and submission of the forms on the Website and/or your curriculum vitae, involve the acquisition of the sender's e-mail address, as well as of the further personal data included in the requests you forwarded, in the forms or in your CV, if attached.

In particular, users wishing to propose their candidacy and curriculum vitae via the Website are invited to pay close attention to its content and should not include any personal data belonging to particular categories, or personal data suitable for revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as data related to health or to sexual life or to sexual orientation.

If necessary, specific privacy policies will be published on the pages of the Website pages prepared for the provision of certain services.

Cookie Policy

The Website uses the following types of cookies.

Technical cookies

Technical and session cookies are used, i.e. small text files containing a certain amount of information exchanged between your terminal or your browser and the Website, which allow its correct functioning and use. No persistent cookies of any kind are used.

Analytical cookies

Analytical cookies are used and made available by a third party, namely Google Analytics and Shopify. This is done for mere internal statistical analysis of access, to improve the site and simplify its use, as well as to monitor its correct functioning. However, the Data Controller has adopted the most appropriate tools to minimize the identifying power of this type of cookie. Google Analytics publishes its cookie policy here. Shopify publishes its cookie policy here. The user can selectively disable the action of Google Analytics by installing the opt-out component provided by Google on his browser. To disable the Google Analytics action, please refer to the following link. To disable the Shopify action, please refer to the following link.

Profiling cookies

We use profiling cookies installed exclusively by third parties. These cookies are not essential, but they help us personalize and improve your experience on the Website. For example, they help us to know and remember your preferences and show relevant and personalized advertisements. They also allow us to limit the number of times each ad is shown, measure the effectiveness of the advertising campaign, remember the visit and share the data collected with third parties, such as advertisers.

The cancellation of these cookies, therefore, even if it does not prejudice the generic use of the Website, could however lead to a limitation of some features.

For more information on processing for profiling purposes, we invite you to read the provisions of paragraph 7 concerning automated decision-making processes.

Third-party cookies

This site uses analytical cookies created and made available by Google Analytics and Shopify, as mentioned above.

Other third parties may also install cookies on your device. We do not control the use of third-party cookies and, therefore, we are not responsible for their use. Third parties have their own privacy policies and data collection methods. These policies can be consulted at the following links: DoubleClick(Google), Facebook, Instagram, Twitter, YouTube, Google+, PayPal.

Lastly, for what it concerns the reproduction of multimedia files, such as videos, the website uses external managers, which may consequently install cookies. YouTube cookie policy can be viewed here.

Options about the use of cookies by the website through the browser settings

The delivery of all cookies can however be deactivated by changing the settings of your browser. It is worth noting, however, that this could render useless the website in the event that the cookies necessary for the provision of our Services were blocked. However, each browser has different settings for disabling cookies. Below are links to instructions for the most common browsers: Apple Safari, Google Chrome, Microsoft Internet Explorer, Mozilla Firefox.

  1. PURPOSE OF THE PROCESSING AND LEGAL BASIS

The personal data that the Data Controller receives is exclusively provided by you when browsing the Website and during the use of the Services. This data will be processed exclusively to:

  1. allow you to use the contents and Services of the Website, including the ability to make purchases, as well as, if you wish and have forwarded an email to customer service, to allow us to receive and reply to your possible communications or to receive your unsolicited application.

    The legal basis on which this treatment is based is (i) your consent to the processing expressed through the sending of the application, (ii) the execution of a contract of which you are a part and (ii) the fulfilment by the company with legal obligations.
  2. allow us to keep you up to date on ClioMakeUp Shop activities and initiatives, by sending newsletters, advertising material and/or communications and information of a commercial and direct marketing nature about our Services, related offers, discounts and any other promotional and loyalty initiative that we have adopted, both through traditional and totally automated contact systems, as, for example, through the use of your e-mail address, or also via SMS.

    The legal basis on which this treatment is based is represented by your express consent to treatment.
  3. allow you to receive offers, discounts and any other benefit and promotional initiative modelled on your specific purchase needs and propensities, also participating in loyalty programs, which provide for the purpose of their operation the registration, identification and profiling of data relating to Your purchase volumes, your habits and consumption choices.

    The legal basis on which this treatment is based is your express consent to processing.

Your personal data may be processed either through IT tools or paper supports.

  1. DATA RETENTION PERIOD

The data controller intends to store your personal data for a period of time not exceeding that necessary for the achievement of the purposes for which they were collected and processed.

Therefore, the personal navigation data and those acquired through the use of the Website will not be stored for more than seven days.

Personal data contained within your curriculum vitae, on the other hand, will be kept for no more than 12 months from the time of their receipt.

Regarding the processing of your personal data for the purposes of direct marketing and/or profiling, in compliance with regulatory requirements and provided you have explicitly authorized it, ClioMakeUp Shop has established to provide for the automatic deletion of your personal data, or to their transformation into anonymous form in a permanent and non-reversible way, within 24 months from the registration of the data collected for marketing purposes, and within 12 months from the registration of that data for profiling purposes.

With regard to any other personal data, since it is not possible to accurately predetermine their storage period, the Data Controller undertakes from now on to base this specific processing on the principles of adequacy, relevance and minimization of data, as required by the European Regulation, checking annually the need for their conservation. Therefore, once reached the purposes for which it was collected and processed, your personal data will be removed from our systems and registers and/or we will take appropriate measures to make it anonymous, so as to prevent you from being identified.

This, without prejudice to the case in which we will need to maintain such data to comply with regulatory obligations, or to ascertain, exercise or defend our right in court.

  1. CATEGORIES OF RECIPIENTS OF DATA

The processed data will not be disclosed to third parties. They may, however, become aware of your personal data in relation to the processing purposes previously set forth:

  • subjects that can access the data in force of law provision foreseen by the law of the European Union or from that of the Member State to which the Holder of the treatment is subjected;
  • subjects who carry out, within the European Union's borders, in total autonomy, as distinct Data Controllers, or in their capacity as Data Processors appointed for this purpose by ClioMakeUp Shop, auxiliary purposes for the activities and Services referred to in paragraph 3., i.e. the companies that offer IT infrastructures and IT assistance and consultancy services as well as the design and implementation of software and Internet websites and e-commerce portals, companies that offer housing and hosting services, companies that provide useful services to make payments with credit cards and provide services to customers, postal services and home delivery and delivery agencies, companies that offer advertising and marketing services, agents and business partners, banking and insurance institutions, law and notary offices, recovery companies credits, companies specializing in prevention, detection, mitigation and assessment of potentially illegal acts, violations of the General Conditions of Use of this portal, of fraud and/or security breaches, companies or consultants charged with providing specific services to the Data Controller, within the limits of the purposes for which they were collected.

Furthermore, our employees may also become aware of your personal data, provided that it is previously designated as a subject acting under the authority of the Data Controller in accordance with the art. 29 of the European Regulations or as System Administrator.

As our business is in continuous development, we may decide to sell or buy stores, branches or production units. In general, in such transactions the personal data of the customers fall within the corporate assets that is transferred, but remain subject to the commitments assumed through this Privacy Policy. Furthermore, in the event that the ownership of ClioMakeUp Shop or substantially all of its assets are transferred to third parties, the personal data of the customers will naturally fall under the transferred assets.

Any communication of your personal data will take place in full compliance with the legal provisions of the European Regulation and the technical and organizational measures prepared by the Data Controller to guarantee an adequate level of security.

  1. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

The Data Controller does not intend to transfer your personal data to third countries. In fact, the entire processing of personal data takes place within the borders of the European Union.

  1. POSSIBLE AUTOMATED DECISION-MAKING PROCESSES

If you explicitly authorize the processing of your personal data for profiling purposes, the Data Controller will use automated decision-making processes aimed at profiling your browsing habits, your preferences and your interactions with the Website. The objective is to offer you the possibility of using the Website according to your interests and preferences, as well as sending you business communications modelled on your specific purchase needs and propensities. Therefore, as a result of the profiling activities, you will be able to take advantage of viewing content on ClioMakeUp Shop and receiving discounts, offers and benefits exclusively based on your interests,

As required by current legislation, your prior consent is required for the installation of these profiling cookies. For this reason, when you access the Website, a banner is displayed informing you that (i) profiling cookies are used on the Website and that (ii) by closing the banner, scrolling the homepage or clicking any element outside the banner, you consent to the use of these cookies. Moreover, should you express your consent to the installation of cookies in this way, we will keep track of your consent through a specific technical cookie. This is in order to avoid the banner displaying during your subsequent visits to the Website. We inform you that should you delete this technical cookie from your device or your browser, your consent would be lost and, therefore, during your next visit to the Website, the cookie banner will be displayed again.

Naturally, you are free to block the installation of profiling cookies at any time, without compromising in any way the possibility of visiting the Website and using its Services. Moreover, if you decide to disable behavioural advertising, this does not mean that you will no longer receive advertising through the Website, but only that it will display advertisements that do not reflect your interests or preferences.

Likewise, your prior consent is also required for sending offers, discounts and any other benefits and promotional initiatives modelled on your specific purchase needs and propensities. For this reason, when registering on the Website, the appropriate consent can be ticked. Also in this case you can change your choice at any time through the dedicated control panel in your personal area, reachable through this link.

In any case, as required by art. 22, paragraph 3, of the European Regulation, the Data Controller implements all the most appropriate measures to protect your rights and freedoms even in the case of profiling, in addition to any further and legitimate rights as better explained in the Paragraph 9 (“Rights of the data subject”) of this Privacy Policy.

  1. NATURE OF THE COMMUNICATION

The provision of your personal data for the purposes referred to in paragraph 3.A is mandatory, as your refusal to provide the requested personal data would make it impossible for ClioMakeUp Shop to allow you to use the contents and Services of the Website, as well as to process personal data contained in your curriculum vitae.

The provision of your personal data for the purposes referred to in paragraph 3.B is optional but failure to provide it, while not in any way impeding the use of the Website, may not allow us to make you fully enjoy the advantages we offer to our community through advertising, commercial and direct marketing information, as well as informing you about additional services, events and promotions that we aim to offer you.

The provision of your personal data for the purposes referred to in paragraph 3.C is optional, but failure to provide it, while not in any way impeding the use of the Website, may not allow us to send you personalized communications based on your volumes of purchase, as well as your browsing habits and choices.

  1. RIGHTS OF THE DATA SUBJECT

In relation to the processing of your personal data, in accordance with the European Regulation, you as data subject have the right to:

  • withdraw your consent to the processing at any time. It should be noted, however, that the withdrawal of consent does not affect the lawfulness of the treatment based on consent before the revocation, as provided for by art. 7, paragraph 3, of the European Regulation;
  • ask the Data Controller to access your personal data, as required by art. 15 of the European Regulation;
  • obtain from the Data Controller the rectification and integration of your personal data deemed inaccurate, even providing a simple supplementary declaration, as required by art. 16 of the European Regulation;
  • obtain the cancellation of your personal data from the Data Controller in the event of even only one of the reasons provided by art. 17 of the European Regulation;
  • obtain from the Data Controller the limitation of the processing of your personal data if one of the hypotheses envisaged by art. 18 of the European Regulation;
  • receive from the Data Controller the personal data concerning you in a structured format, commonly used and readable by an automatic device, as well as having the right to transmit such data to another data controller without hindrance, as required by art. 20 of the European Regulation;
  • oppose at any time, for reasons connected to your particular situation, to the processing of your personal data carried out pursuant to art. 6, paragraph 1, letters e) or f), including profiling on the basis of these provisions, as required by art. 21 of the European Regulation;
  • not be subjected to decisions based solely on automated processing, including profiling, which produce legal effects that concern you or that significantly affect your person, if they have not previously and explicitly consented to, as provided for by art. 22 of the European Regulation. By way of a non-exhaustive example, this category includes any form of automated processing of personal data aimed at analysing or predicting aspects concerning consumption and purchase choices, economic situation, interests, reliability, behaviour;
  • lodge a complaint with a supervisory authority (art. 77) or take appropriate judicial proceedings (art. 79), if you believe that the processing violates the European Regulation. The complaint can be brought in the Member State where you habitually reside or work, or in the place where the alleged violation occurred.

To exercise each of your rights, you can contact the Data Controller by sending a communication to the registered office of Via Timavo n. 34, Milan (MI), Italy, or by sending an email to privacy@redkeep.it.

  1. CHILD'S CONSENT IN RELATION TO INFORMATION SOCIETY SERVICES

It is explicitly forbidden to children under sixteen (16) to use the Services provided through the Website, without prejudice to other limitation of age provided for specific Services (for example, the purchase of products) under the General Conditions of Sales. In view of the available technologies and the Services provided, ClioMakeUp Shop has established master data verification systems to verify that the consent to the processing of personal data of the minor is lent or authorized by the subject exercising parental authority. By creating a personal account on our website, as well as by making purchases, you confirm that you have reached the age indicated above.

  1. CONSENT TO USE YOUR PERSONAL DATA

Having read and understood the aforementioned privacy policy, I expressly and freely consent to the processing of my personal data for the purpose of using the Website and its Services, including those aimed at allowing the receipt and evaluation of my curriculum vitae, provided for in paragraph 3.A.

Red Keep S.r.l. a socio unico – Cap. Soc. Euro 10.000,00 i.v.

Cod. Fisc. Registro Imprese e P. IVA 09551070965, R.E.A. Milano 2098389

Sede legale: Via Timavo, 34, Milano, 20124, PEC: redkeepsrl@legalmail.it

Società soggetta all’attività di direzione e coordinamento di 177C S.r.l.