PRIVACY POLICY
INFORMATION ON THE PROCESSING OF PERSONAL DATA
PURSUANT TO ARTICLES 13 AND 14 OF REGULATION (EU) 2016/679
Data subjects: users and customers of the ‘AEFFE S.P.A.’ website www.philosophyofficial.com
WHY THIS INFORMATION
Pursuant to Regulation (EU) 2016/679 (hereinafter the ‘Regulation’, or ‘GDPR’), this page describes how the personal data of users and customers of the website of ‘AEFFE S.P.A.’ accessible by electronic means at the following address: www.philosophyofficial.com are processed.
This information does not concern other sites, pages or online services that can be reached via hypertext links that may be published on this site, but which refer to resources outside the domain www.philosophyofficial.com
DATA CONTROLLERS
Following consultation of the site or the purchase of products on the site, data relating to identified or identifiable natural persons may be processed.
AEFFE S.P.A. with registered office in Via delle Querce 51 - 47842 San Giovanni in Marignano (RN) VAT no.: 01928480407, Email: privacy@aeffe.com, Tel: 0541 965211.
Aeffe S.P.A. is the owner of the processing of your personal data relating to navigation on the site,registration on the online portal, orders placed and to respond to customer care requests received and in general to guarantee the functions available on the website; as well as, subject to your free consent, for the optional purposes of marketing and profiling.
Drop Srl with registered office in Montegranaro (FM), via Sandro Pertini n.1, cap. 63812, tax code, registration number with the Marche Companies' Register and VAT number 01383870431. E-mail privacy@drop.it.
Drop Srl is the owner of the processing of your personal data for the sole purposes necessary to comply with regulatory obligations in tax and accounting matters arising from purchases made at the online shop on the site
- Legal basis: legal obligation and contractual obligation.
DATA PROTECTION OFFICER
The Data Protection Officer (‘DPO’) for Aeffe S.p.A. is the company Studio Paci & C. Srl (Contact person Dr. Gloriamaria Paci) who can be contacted at the following address:
dpo.aeffe@studiopaciecsrl.it, telephone: 0541 -1795431 and PEC: studiopaciecsrl@pec.it.
The Data Protection Officer (‘DPO’) of Drop Srl can be contacted at the following e-mail address: dpo@drop.it.
TYPES OF DATA PROCESSED, PURPOSE OF PROCESSING AND LEGAL BASIS
Given that personal data means any information relating to an identified or identifiable natural person, directly or indirectly (art. 4 no. 1 GDPR), that the data subject means the natural person (user and/or client of the Site) to whom the data refer and that processing means any operation or set of operations carried out with or without the aid of automated processes and applied to personal data or sets of personal data (art. 4 no. 2 GDPR), the personal data that Aeffe S.p.A. processes as a result of navigation on the Site are as follows.
1) Navigation data
Legal basis: ‘data processing necessary for the navigation of the website’ - contractual obligation - art. 6 par. 1 letter b) GDPR
The computer systems and software procedures used to operate this site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.
This category of data includes the IP addresses or domain names of the computers and terminals used by users, the URI/URL (Uniform Resource Identifier/Locator) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user's operating system and computer environment.
This data, which is necessary to navigate the Site and to use the information it contains, is also processed by Aeffe Sp.A. in order to:
- obtain aggregate and anonymous statistical information on the use of the Site (most visited pages, number of visitors per time slot or per day, geographical areas of origin of visitors, etc.);
- check the correct usability of the contents offered by the Site;
- prevent or combat any possible computer offences, fraudulent use of the functionalities available on the Site, also for the purpose of reconstructing security incidents and their traceability
Duration of storage:
browsing data in compliance with the principles of lawfulness, purpose limitation, data minimisation, in accordance with Article 5 of the GDPR, will be kept for a period of time not exceeding the achievement of the technical purposes described above for which they are collected and processed, except for any need to ascertain crimes by the judicial authorities.
2) Data communicated by the user
Legal basis: ‘data processing necessary to answer users’ questions’ - contractual obligation - art. 6 par. 1 letter b) GDPR
The optional, explicit and voluntary sending of messages to the contact addresses of Aeffe S.p.A., private messages sent by users to institutional profiles/pages and on social media, as well as the completion and submission of forms on the owner's site, entail the acquisition of the sender's contact data, necessary to respond, as well as all the personal data included in the same communications.
Specific information is published on the pages of the site set up for the provision of certain services, where necessary the user's consent is collected, informing the user of the purpose and the option of providing it.
Duration of storage:
The data communicated by the user are stored for the time necessary to handle individual requests, any subsequent storage for statistical purposes provides for the anonymisation of such data (except for any need to ascertain criminal offences by judicial authorities).
3) Registration and purchase data
Legal basis: User registration and purchase - contractual obligation - art. 6 par. 1 letter b) GDPR
Invoicing and fiscal and accounting fulfilments - legal obligation - art. 6 par. 1 letter c) GDPR
Registration on the portal is preparatory to correct identification in anticipation of and against a purchase. Registration will allow you to create your user profile without having to re-enter your data for subsequent purchases. Your user profile will store your residential address, shipping address (if different from your residence), tax code if required by law, and your purchase history. You can request the deletion of your user profile at any time. It is possible to make an online purchase even without registering on the portal, your data will be processed exclusively for your correct identification, to allow
the purchase and shipment in application of the general conditions of sale, and to allow invoicing in accordance with the law.
Information on the processing of Level I data can be found in the specific information available in the registration and purchase forms.
4) Data acquired through cookies and other tracking systems
Use is made of:
a) technical cookies necessary for user navigation, they facilitate the correct navigation of the site and the usability of its contents by the user. Legal basis: ‘contractual as they are functional and necessary’.
b) analytical cookies used to process aggregate statistical analyses of the use of and interaction with the site by the user. Subject to the user's consent. Legal basis: ‘consent’.
c) Profiling cookies are used to collect information on the preferences expressed by the user during browsing and to prepare reports to be used for targeted advertising and marketing campaigns. Legal basis: ‘consent’.
For analytical and profiling cookies, consent to the processing of personal data, pursuant to Art. 6(1)(a) GDPR, is expressed by the data subject by clicking on the accept all cookies button or by managing the preferences available by clicking on the customise button, in accordance with the
provisions of the ‘Cookie and other tracking tools guidelines’ annexed to the GPDP (Garante per la Protezione dei Dati Personali) Measure no. 231 of 10.06.2021.
Information on the processing of data, the purpose, duration and complete management of cookies, including their consent and revocation, can be found in the document ‘Cookie Policy’ also in the footer.
5) Direct marketing
Legal basis: consent of the data subject - Art. 6 para. 1 letter a) GDPR
By entering the personal data (identification and contact details) requested in the forms providing for the granting of consent for direct marketing activities (including newsletter subscription), the User declares that he/she having read this information notice, and gives consent, on an optional basis, to the processing of personal data for marketing activities.
In addition to the data communicated by the User, Aeffe S.p.A. also acquires the date and time the form was sent, the page it came from and the IP address of the device used to register consent.
The data communicated and, in any case, acquired by Aeffe S.p.A. are used to receive periodic e-mail communications containing information about new products on sale at the e-commerce site, events and promotions (marketing purposes) from Aeffe S.p.A..
In relation to the sending of promotional material to your e-mail inbox, interactions with the communications transmitted (e.g. rate of opening of e-mails, any clicks on links and/or banners and/or buttons) may also be processed.
6) Profiling
Legal basis: consent of the data subject - Art. 6 para. 1 letter a) GDPR
By entering the personal data (identification and contact details) requested in the forms providing for the granting of consent for profiling, the User declares that he/she has read this information notice, that he/she is over 16 years of age and gives his/her consent, which is in any case optional, to the processing of personal data for profiling activities.
In addition to the data communicated by the User, Aeffe S.p.A. also acquires the date and time the form was sent, the page it came from and the IP address of the device used to register consent.
As a result of the specific consent given to the profiling activity, Aeffe S.p.A. acquires a series of data and information suitable for revealing consumption habits and lifestyles based on the preferences shown by the User when interacting with the pages of the Site, the products purchased and the contents of the communications received by Aeffe S.p.A..
These data, associated with each other, contribute to defining, through their inclusion in clusters, i.e. groups of distinct Users based on the preferences shown, the User's profile and are functional to receiving communications that are personalised on the basis of the profile.
With regard to the sending of promotional material to your e-mail inbox, interactions with the communications transmitted (e.g. rate of opening of e-mails, clicks on links and/or banners and/or buttons) may also be processed.
7) Further data acquired by the Data Controller
The subscription to the newsletter, the possible request to receive personalized commercial communications and also the interaction with the pages of the Site that the User can reach also through social networks, as a result of the marketing campaigns promoted by Aeffe S.p.A. that determine the redirection to a specific page (so-called ‘landing page’), allows Aeffe S.p.A. to acquire other data than those communicated by the Users, such as, for example, the date and time of the request and the date and time of the request. so called ‘landing page’), allows Aeffe S.p.A. to acquire other data than those communicated by the Users, such as, for example, the date and time of opening of e-mails containing newsletters and commercial communications, the contents of interest and therefore the preferences shown by the recipients.
This data is functional for establishing a relationship with customers and also for sending news and/or information selected on the basis of demonstrated preferences.
For the purposes set out above, the legal basis legitimising the processing is represented by the consent to the processing, pursuant to Art. 6, par. 1 lett. a) GDPR, expressed by the data subject by clicking on the relevant boxes within the form intended for newsletter subscription and the request to receive personalised communications.
Further details on the processing of the data communicated by Users, the legal bases and processing methods are available in the complete information notices of the data acquisition forms of the marketing campaigns.
8) Social Media Policy: Information about the processing of personal data carried out through the Social Media platforms used
For information on the processing of personal data carried out by the operators of the Social Media platforms, please refer to the information provided by them through their respective privacy policies. Aeffe S.p.A. processes personal data provided by users through the pages of the dedicated Social Media platforms, as part of its corporate promotion and advertising purposes, in order to manage interactions with users (comments, public posts, messages, shares, etc.) in compliance with current legislation on the protection of personal data and with this privacy policy; where necessary, the user's consent is collected, informing the user from time to time on the purposes and the optionality of providing it.
Personal or “sensitive” data included in public comments or posts within social media channels may be removed.
9) Customer Care
Legal basis: contractual obligation - art. 6 para 1 letter b) GDPR.
Handling and responding to any reports, post-sales inquiries (including order status and tracking), purchase assistance, returns, refunds, order cancellations and complaints submitted by the Customer, in compliance with the general terms and conditions of sale.
OPTIONAL PROVISION OF DATA AND REVOCABILITY OF CONSENT
With the exception of automatically acquired navigation data, the provision of personal data is always voluntary and optional, although the refusal of communication may prevent the sending of messages, requests for information or assistance, as well as the submission of any complaints, reports and requests for assistance in general.
Consent to data processing, where required, is also optional but necessary in the event that the data subject wishes to subscribe to the newsletter and/or receive personalized commercial communications.
Full information on data processing is available in the information notices attached to the aforementioned forms, to which reference is made.
The right to revoke consent to the processing given, both for marketing and profiling activities, is recognized at any time to the data subject and can be exercised by accessing their personal area, after registration, or by using the unsubscribe functionality present at the bottom of the commercial communications received and/or profiling or by sending a communication to privacy@aeffe.com.
PERSONAL DATA OTHER THAN THOSE IDENTIFIED IN THE CONTACT FORMS
Since the contact forms on the pages of the Site contain free text fields or allow in some cases the sending of files the User is invited to verify the personal data he/she intends to share, avoiding communicating the so-called special data, i.e., data likely to reveal the person's political opinions, religious or philosophical beliefs, state of health, sexual life or sexual orientation. With regard to such data, if Aeffe S.p.A. considers that the communication was made in error or does not consider it
necessary to process the request received, it will not take it into account and/or will provide for its immediate deletion.
PERSONAL DATA REFERRING TO OTHER PERSONS (OTHER THAN THE DATA SUBJECT)
For the same reasons explained above, contact forms and files sent as attachments may in fact contain personal data referring to other persons concerned (for example, in the case where the shipment of the order is requested to a person other than the buyer). In the event that the User decides to communicate such data, he/she assumes full responsibility for it, even by proxy of the data subject.
PERIOD OF DATA RETENTION
In compliance with the principle of limitation of storage under Article 5 GDPR, data are kept for the time strictly necessary to achieve the purposes described above.
In particular:
- In the case of portal registration, your data will be retained until your eventual cancellation of membership or following a period of inactivity of 5 years.
- The data related to the optional purposes (4. Direct Marketing - 5. Profiling) are kept until revocation of consent to be requested either by accessing your personal area, by the automatic modalities present in the e-mails, or by sending the request to the contact data of the Data Controller. At the end of 2 years from the acquisition of consent, you will be sent a communication to the issued contact channels to allow the revocation of consent or continuation of the same.
- for activities carried out in performance of a contract or pre-contractual measures taken at the request of the data subject, pursuant to Art. 6(1)(b) GDPR, the data are retained for the duration of the contract; for example, for portal registration, your data will be retained until your eventual cancellation of your membership or following a period of inactivity of 5 years. If you have made a purchase, the same may be retained for a period of time in compliance with the obligations prescribed by applicable laws, for example on the basis of tax legislation for at least 10 years;
It is without prejudice, however, to the right of the Data Controllers to retain the data for a longer period than that indicated above in order to ascertain and/or defend its rights in court (e.g. in case of complaints). In such cases, the retention times are those related to the aforementioned defensive needs and the terms may coincide with the decadential and prescriptive terms provided by law.
RECIPIENTS OF THE DATA
Recipients of the data collected as a result of the consultation of some of the services listed above are certain entities designated by the Data Controllers in accordance with Article 28 of the Regulations, as data processors, and other additional service providers in the sphere of web-agencies, digital communication, support
systems, social networks in the area of data collection through marketing campaigns and any other digital service providers for which you can request a full list by writing to privacy@aeffe.com and privacy@drop.it. Some data and information may be transmitted or acquired by parties identified as independent data controllers, including Third Party Companies such as payment method operators chosen by the data subject (e.g., PayPal, Scalapay, Klarna), data related to cookies that are usually anonymized before sending, for statistical purposes.
The personal data collected are also processed by the staff of the Data Controllers acting on the basis of specific instructions provided by the Data Controllers regarding the purposes and methods of such processing.
SECURITY OF PROCESSING
The personal data transmitted and stored for the time necessary for the stated purposes are protected by specific technical organizational security measures with reference to art. 32 of the Regulations, capable of guaranteeing on a permanent basis the confidentiality, integrity, availability, as well as the ability to promptly restore the availability and access of personal data in the event of a physical or technical incident, including against the risks of destruction, loss, modification, unauthorized disclosure or from access, accidental or unlawful, to personal data transmitted, stored or otherwise processed. The communication of data via the web is protected by SSL encryption of the communication channel, the completion of contact forms on the Site, is protected by Google's “ReCaptcha” system that allows to distinguish between so-called “human” and automated access in order to prevent “robotized” systems can simulate data entries that cannot be traced back to a person with the intention of compromising the functionality of the Site.
your personal data of which Drop Srl is the Data Controller are processed by Drop Srl within the European Union and are not transferred to other non-EU countries.
RIGHTS OF DATA SUBJECTS
The exercise of rights is guaranteed by both data controllers, respectively to the purposes of their own competence, by writing to the contact details above. Data subjects have the right to obtain, in the cases provided for, access to their personal data, rectification, deletion of the same, limitation of the processing concerning them, portability, or to object to the processing and to revoke consent (where used as a legal basis) with reference to Articles 15 to 22 of the Regulations). The request is made through the contact details of the Data Controllers.
For the exercise of rights, it is also possible to use the template prepared and available on the website of the Data Protection Authority at this link: https://www.garanteprivacy.it/home/docweb/-/docweb display/docweb/4535524
RIGHT TO COMPLAIN
Data subjects who believe that the processing of their personal data through this website is in violation of the provisions of the Regulation have the right to file a complaint with the Supervisory Authority, as provided for in Article 77 of the Regulation, or to take legal action before the competent courts (Article 79 of the Regulation). The complaint form is available on the website of the Data Protection Authority at the following link:
https://www.garanteprivacy.it/home/docweb/-/docweb display/docweb/4535524
Last Update: 17/03/2025