Last updated: 31 january 2020

This “Privacy Policy” describes the privacy practices of TUTTOFASHION, Inc., and our subsidiaries and affiliates (collectively, “Tuttofashion”, “we”, “us”, or “our”) in connection with the www.tuttofashion.com website, the Tuttofashion mobile application, any other website or mobile application that we own or control and which posts or links to this Privacy Policy (the “Sites”) as well as our related services (together with the Sites, the “Service”), and the rights and choices available to individuals with respect to their information.

 

PERSONAL INFORMATION COLLECTION

We will collect various types of personal data about you for the purposes described in this Policy, including:

  • Contact data, personal or business contact information such as your first and last name, email and mailing addresses, phone number, professional title and company name.

  • Registration data, such as information that you provide to register for an account or sign up for an event, including the day and month of your birth and the event you registered for.

  • Data about others for whom you purchase an item or gift, such as name, delivery address and phone number. Please do not purchase a gift for someone or share their contact information with us unless you have their permission to do so.

  • Profile data, such as your username and password that you may set to establish an online account with us and your interests and preferences.

  • Communications, such as information you provide when you contact us with questions, feedback, survey responses, or otherwise correspond with us,

  • Marketing data, such as the email address or contact details that we use to send marketing communications and your preferences for receiving communications about our activities, events, sweepstakes and contests.

  • Purchase data, including your order history and information needed to process and fulfill your order, including order details, billing address, and delivery address.

You are under no obligation to provide any such information. Providing your personal data to us (in particular, your personal details, your email, your address, your credit/debit card numbers and bank code and your telephone number) is necessary for processing your order for the purchase of products on the Website, supplying other services provided on the Website upon your request, or when your personal data is needed to fulfil obligations required by law or regulations. The refusal to provide us with any personal data necessary for performing the above purposes may consequently prevent us from processing your order for the purchase of products sold on the Website or fulfilling obligations required by law and other regulations. Therefore, failure to provide personal data may constitute, in some cases, a legitimate and justified reason for not processing your order for the purchase of products sold on the Website or not providing the Website’s services.

 

USE MADE OF YOUR PERSONAL INFORMATION

We may use your personal information to:

  • Verify and carry out financial transactions in relation to payments you make

  • Administer your account on the Service;

  • communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages;

  • Improve and customise our Website, and our products, services and our business in general, such as by tracking your product preferences, shopping history and interactions with the Website

  • facilitate your login to the Sites via third party platforms, such as Google and Facebook, Instagram;

  • enable security features of the Sites, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in.

Direct Marketing: We may use your personal information to send you Tuttofashion-related marketing communications as permitted by law.

To comply with laws and regulations: We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

With your consent: In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

We may also share your personal data with third parties in connection with potential or actual sale or restructuring of our company or any of our assets, or those of any associated company, in which case personal data held by us about our users may be one of the transferred assets.

 

YOUR RIGHTS

You have the following rights with respect to your personal data:

• Right to withdraw consent - where applicable, you have the right to withdraw your consent at any time. For example, if you wish to opt-out of receiving electronic marketing communications, you can contact us directly with and we will stop sending you communications.

• Right of access, rectification and erasure - you have the right to request access to and obtain a copy of any of your personal data that we may hold, to request correction of any inaccurate data relating to you and to request the deletion of your personal data under certain circumstances by contacting us directly info@tuttofashion.com.

• Right of data portability - Under certain conditions, you have the right to receive all such personal data which you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.

• Right to restriction of processing - you have the right to restrict our processing of your personal data where:

o you contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy;

o the processing is unlawful but you do not want us to erase the data;

o we no longer need your personal data for the purposes of the processing, but you require such data for the establishment, exercise or defence of legal claims; or

o you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether we have overriding compelling legitimate grounds to continue processing.

Where personal data is subject to restriction in this way, we will only process it with your consent or for the establishment, exercise or defence of legal claims.

• Right to object to processing for marketing purposes - where we process personal data for direct marketing purposes, then you have the right to object to that processing at any time.

For further information regarding your rights, to exercise any of your rights, or if you have any complaints or questions regarding the processing of your personal data please contact info@tuttofashion.com.

Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We will endeavour to respond to your request as soon as possible and in any case within the applicable timeframes.

 

SECURITY PRACTICES

The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.


Changes to this Policy

We may occasionally change this Policy, for example, to comply with new requirements imposed by the applicable laws or technical requirements. We will post the updated Policy on the Website. We may also notify you in case of material changes and seek your consent to those changes, where required by applicable law. You are thus encouraged to periodically review this page.

 

HOW TO CONTACT US

If you have any question or want to send us suggestions, please contact us at: email info@tuttofashion.com.

 

NOTICE TO CALIFORNIA RESIDENTS

Section effective as of: January 1, 2020

We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their Personal Information, and of the rights and choices we offer to California residents with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”).

 

PERSONAL INFORMATION THAT WE COLLECT, USE AND SHARE

We do not sell personal information. As we explain in this Privacy Policy, we use cookies and other tracking tools to analyze website traffic and facilitate advertising. We also work with third party advertising and social media companies like Google and Facebook that collect your device data and online activity data from individuals who visit our website to help deliver interest-based ads to you,

You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.

We have provided additional information about how you can opt-out of the use of your information for interest-based advertising in the “Your Rights” section of our Cookie Policy.

NOTICE TO EUROPEAN USERS: The information provided in this “Notice to European Users” section applies only to individuals in the European Union, the European Economic Area or the United Kingdom (collectively, “Europe”).

PERSONAL INFORMATION: Except as otherwise specified, references to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation. 

CONTROLLER: The controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation is Tuttofashion.

LEGAL BASES FOR PROCESSING: The legal bases of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it.  However, the legal bases we typically rely on are set out in the table below. If you have questions about the legal basis of how we process your personal information, contact us at  info@tuttofashion.com. 

Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

SENSITIVE PERSONAL INFORMATION: Unless we specifically request it, we ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us.

 

YOUR RIGHTS

European data protection laws give you certain rights regarding your personal information.  You may ask us to take the following actions in relation to your personal information that we hold:

  • Access.  Provide you with information about our processing of your personal information and give you access to your personal information.

  • Correct.  Update or correct inaccuracies in your personal information.

  • Delete.  Delete your personal information.

  • Transfer.  Transfer a machine-readable copy of your personal information to you or a third party of your choice.

  • Restrict.  Restrict the processing of your personal information.

  • Object.  Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights. 

You may submit these requests by email to info@tuttofashion.com.  We may request specific information from you to help us confirm your identity and process your request.  Applicable law may require or permit us to decline your request.  If we decline your request, we will tell you why, subject to legal restrictions.  If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction.

 

COOKIE POLICY

1. What is a cookie?

 Cookies are text files containing small amounts of information that a user’s device (computer, tablet or mobile) downloads when it visits a website. They allow the site to “remember” your computer, but not specifically who is using it, and improve your user experience. By associating the identification numbers in the cookies with other customer information when, for example, you log-in to the site, then we know that the cookie information relates to you 

 

2.    What is the scope of Cookies?

Cookies are used generally for different purposes, such as letting the user navigate between pages efficiently, implementing the user's preferences and generally improving their browsing experience, by customizing the website according to their navigation and user profile. They can also help ensure that the adverts that the user sees online are more relevant to them and their interests. 

 

3.    What cookies do we use?

Our website uses several type of cookies for different purposes as better explained below.

In particular we use: 

A)   Session cookies, which only last for the duration of a browsing session. They are usually used to facilitate the access to the services on our website, to authenticate you when you are a registered member, and to remember what a user has put in their shopping basket, and

B)   Persistent cookies, which last for more than one visit. They are used to remember a user’s preferences and actions within the website. In this case, when a user returns to our website, or visits sites that use the same cookies, the site reads the cookies and identifies the user’s browser.

Among these cookies it is possible to refer to:

C)   First party cookies, which are supplied by the website you are visiting, tuttofashion.com and can be read only by such site. For example the cookies that maintain product in the shopping bag of a user while the user is still surfing the site. First party cookies can be either session or permanent cookies.

D)   Third party cookies, which are meant to collect data on an anonymous way, for example analytics information, including browsing statistics. Other third party cookies are meant to track our visitors’ response to our online promotional activities. This technology uses information about your visits to our website and third parties' sites on which we advertise, to deliver relevant advertisements. We also use this to learn which banner adverts bring users to our website.

Also third party cookies can be either session or permanent cookies.

The type of cookie used on our website can fall under one of the categories below.

A - Technical Cookies

Based on the Guidelines  & Data Protection Authority (Garante) on simplification of procedure to release the data protection notice and to collect the consent for cookies (dated 8 May 2014) technical cookies include navigation or session cookies, cookies analytics and functionality cookies.

We do not need to seek your consent to use these cookies.

A.1: Navigation or Session Cookies

These cookies are strictly necessary session cookies essential to enable you to move around the website and use its essential features, such as accessing secure areas of the website. These cookies include session authentication cookies. Without these cookies, necessary services such as shopping baskets or e-billing cannot be provided.

We are able to identify you as being logged in to Tuttofashion.com and to ensure that you are able to access the appropriate features on our site.

 We also use a cookie to track that you have been informed of our use of profiling cookies and consented (if so) to it.

A.2: Analytics

These cookies are also known as performance cookies and collect information about how you use our website, so that we can improve the quality of our site and services.  Some examples include which pages you visit most often, whether you get error messages from web pages. Performance cookies allow us to implement these choices and optimise the way our site works. All the information that these cookies collect is aggregated and therefore they do not collect personal identification information. 

These types of cookies may be first party or third party.

These cookies include analytics that allow us to obtain statistics about website access and browsing, monitor which website our users arrive from, help us improve the site by measuring usage information and any errors which occur during our users browsing experience, as well as the effectiveness of advertising campaigns, using aggregated information.

These cookies can also be used to remember changes you made to text size, fonts and other parts of web page that you can customize. They may also be used to provide services you have asked for or to prevent you from receiving services you have already refused. 

These types of cookies may be first party or third party. Presently we only use first party cookies, and can be session or permanent.

When you choose functionalities and services, you agree to our use of the related functionality cookie.

 

B - Profiling Cookies

These cookies, that include advertising and targeting cookies,  are used by Tuttofashion, our advertising providers and/or third parties to offer you a customised browsing experience by delivering you advertisements that are relevant to you and your interests on third party websites. Cookies are used to identify your preferences and analyse your online interactions and transactions with us. This information is exclusively for the benefit of Tuttofashion and will not be shared with any third party, except with Tuttofashion service providers for the purpose of processing it on our behalf.

Under certain circumstances, especially if you are logged-in on your account, we may combine data collected through the cookies with your personal data for the purposes set out above, unless you have explicitly refused to be the subject of such  processing and you have opted out from these type of cookies.  We invite you to read our privacy policy for full details of how we can process your personal data under such circumstances.

 

INFORMATION SHARING

We do not share information collected through the use of cookies and pixel tags with any third party, our advertising agencies/providers and our IT service providers, exclusively for the purposes set out above.

 

CHANGES

Information about the cookies we use may be updated from time to time, so please check back on a regular basis for any changes.

 

QUESTIONS

If you have any questions about this Cookie Policy, please contact us by email at info@tuttofashion.com.