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Prada S.p.A., with its registered office in Milan (Italy), the operating holding company of the PRADA Group (defined below) and site manager of www.bbfreebies.com, together with its subsidiary, PRADA USA Corp., with its registered office in New York (USA), (collectively, "PRADA") is committed to protecting the Personal Data (defined below) that you share with us, and explaining how we collect, process, and share that information online. We collect your Personal Data on the Website (defined below) to enhance the services we offer you, maintain and improve the Website, protect the security of you and our Website, comply with legal obligations, and inform you about other services and products that may be available through us, our affiliated companies, and our marketing partners.
Scope and information that this Privacy Statement covers
This Privacy Statement applies to Personal Data collected on our websites, mobile applications, cloud-based services, or controlled widgets embedded in communication platforms, each with a link to this Privacy Statement (collectively, the "Website"). It covers how we collect, use, share, and otherwise process personal information as of the date that this Privacy Statement is posted. This Privacy Statement also applies to the Personal Information collected in stores operated by PRADA USA as well as Prada S.p.A and its subsidiaries and/or affiliates (collectively the "PRADA Group"). It does not apply to any other information collected by PRADA through any other means. By "Personal Data," we mean information that identifies or can identify you personally.
The Website contains links to third-party websites, including websites of our business partners. We do not own, operate or control the websites of those third-parties. Accordingly, this Privacy Statement does not apply to any websites maintained or operated by third-parties for the collection, use, storage, disclosure, or other processing of your Personal Information. When you click on those links, you will go to a third-party website where you will be subject to that website’s privacy statement and we encourage you to read that policy statement.
1. Type and source of data
During their normal operation, the computer systems and software procedures used to operate our Website collect certain personal data (log files). The transmission of such data is inherent to the use of internet communication protocols. This information is not collected in order to be associated with specific data subjects. However, due to its nature, this information can allow users to be identified by means of its processing and integration with data held by third parties. Such information includes the IP addresses or domain names of the computers you use to visit our Website, URIs (Uniform Resource Identifiers) 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 reply, the numerical status code of the server reply (successful, error, etc.) and other parameters concerning the user's operating system and computer environment. This data is used with the sole purpose of obtaining anonymous statistical information on the use of our Website and to guarantee its correct operation.
Controlling Our Tracking Tools
Your browser may give you the ability to control cookies. How you do so, however, depends on your browser and the type of cookie. Certain browsers or browser plugins can be set to reject all browser cookies. If you configure your computer to block all cookies, you may disrupt certain web page features, and limit the functionality we can provide when you visit or use our Website. (e.g., we will not be able to provide you with searches that you have asked us to save). You can change your cookie settings at any time. Some browsers have a "Do Not Track" feature that lets you tell websites that you do not want to have your online activities tracked. These browser features are still not uniform, so we are not currently set up to respond to those signals.
Controlling Online Interest-Based Ads. We sometimes work with online advertising vendors to provide you with relevant and useful ads. This may include ads served on or through our Website. This may also include ads served on other companies’ websites. These ads may be based on information collected by us or third parties. For example, your postal code may be used to target an ad for people in your area. These ads may also be based on your activities on our Website or on third-party websites.
For more information about our ad service provider and its cookies, including information about how to opt out of these technologies, you may visit http://optout.aboutads.info In addition, users may prevent Google’s collection of data generated by your use of the Website (including your IP address) by downloading and installing a Browser Plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.
Personal Data voluntarily provided by the data subject
PRADA collects and processes the Personal Data that you directly and voluntarily provide through our Website when: (i) you place online orders; (ii) register to our Website; (iii) and/or your use of other functionalities available on the Website (for example: to subscribe to our newsletter, to participate in promotions or surveys, to submit comments, reviews, or other user-generated content, to send a request to our Client Service, to book an appointment in the store, to connect or interact with us through social networks, etc.). PRADA may also collect and processes the Personal Data that you provide by filling in our customer card ("Customer Card") at our stores. If you decide to register the Website through the Social login function, please be informed that PRADA will have access to the Personal Data of your social account (for example, your email address and your public profile) in accordance with the privacy settings of the applicable social media platform. For more information, please refer to the related privacy statements on the applicable social media platform; PRADA does not oversee or control such social media services or user profiles on these platforms and does not establish privacy settings or rules regarding how Personal Data is used on such platforms.
The items of Personal Data collected include personal information (title, name and surname, country, day and month of birth), contact and billing details (postal address, billing address, payment card information, email, telephone), details of purchases and/or other information regarding you that you may decide to provide during the interactions with our Client Service or with sales staff.
Furthermore, when you voluntarily send an e-mail through our Website and/or to the addresses indicated in our Website, we collect your e-mail address so that we can reply to any request, as well as any additional Personal Data contained in your message.
We may combine passively collected data (i.e. device being used (for our mobile site), browsing data, location via IP address, and cookies) with data that you actively submit so as to, for example, provide better service to Website visitors, customize the Website based on your preferences, compile and analyze statistics and trends, administer and improve the Website for your use, and to personalize offers (for example, combined information may allow us to recommend products to you based on what you have liked in the past). We also use the Personal Data you voluntarily submit to prevent fraud and allow for safer web experiences.
Personal Data of minors
You must be at least 16 years old (depending on the state of residence) in order to provide us with Personal Data, and at least 18 years old to purchase products from our Website.
If we have actual knowledge that a minor has provided, through the Website or otherwise, their Personal Data, we will de-activate the minor’s account and disable the minor’s Personal Data in our systems.
2. Purposes and legal bases of the processing
Your Personal Data may be processed and used for the following purposes:
(a) to respond to all your requests and to manage your relationship with the PRADA Group;
(b) to fulfil your online orders and perform all management activities connected with it (including administrative management of the contract, delivery of goods, payment processing, management of any claims and litigation, and fraud prevention), and to comply with any applicable legal or regulatory obligations;
(c) to send by email the newsletters and other marketing communication regarding the PRADA Group’s products, services, initiatives and events as a result of your subscription to the service.
Furthermore, if you register to the PRADA Group customer database (as a result of your registration to the Website or your signing the Customer Card at a PRADA Group store), your Personal Data will be managed by PRADA S.p.A. and shared with all PRADA Group stores globally, and may be processed, together with the details of your purchases online and/or in stores, for the following purposes:
(d) to confirm your identity as a registered PRADA Group customer and, consequently, to provide a customized global customer service and post-sales service and allow you to access exclusive services and benefits reserved for registered members (e.g.: preservation of your purchase order history, faster online checkout, simplified procedures for product repair and warranty, commercial discounts, pre-sale and other promotional events, etc.);
(e) to perform individual or group studies, statistical and/or market research on your preferences for PRADA and the other brands, products and services of the PRADA Group, so that a personalized service can be offered and cultural and recreational activities may be promoted based on customers’ interests;
(f) for marketing: to contact you and/or send you (by post, telephone, e-mail and any other form of electronic communication or digital means including social network platforms and other instant messaging applications) information and promotions, including commercial information, newsletters, direct marketing material, advertising, catalogues and invitations to events concerning PRADA and other brands, products and services of the PRADA Group.
The Personal Data processing referred to in subsections (a), (c) and (d) is necessary to provide the service requested by the data subject. The processing referred to subsection (b) is necessary to execute the contract with the data subject or the related pre-contractual measures and to fulfill the connected legal obligations of an administrative and fiscal nature. Further, the data procession referred to in subsections (e) and (f) is based on the prior consent of the data subject.
3. Nature of the provision of personal data
Providing your Personal Data to us is optional.
However, if you wish to purchase products offered on our Website, register to the PRADA Group customer database, receive information on PRADA Group’s products and/or use any other services offered on the Website, you need to fill in all mandatory fields of the relevant forms, otherwise PRADA cannot proceed with the contractual services requested.
The provision of your Personal Data for the purposes indicated in Sections 2 (e) and (f) is optional and the use of such Personal Data is subject to your express prior consent. If you withhold your consent, we may not be able to proceed with the indicated purposes, including the ability to offer you personalized services, inform you of any initiatives that may interest you and/or send you any other commercial information on products, initiatives and events of the PRADA Group.
You may withdraw or modify your consent to the processing of your Personal Data by us at any time, by writing to the Data Controller at the contact addresses indicated in paragraph 7, or by using the "unsubscribe" link included in all of our commercial electronic communications, and/or by using any other appropriate procedures which may be made available to you by PRADA.
4. Processing Methods
Your Personal Data will be processed by suitable electronic or automated means and computerized tools, or manually and on hard copy, exclusively for the purposes for which they have been collected and guaranteeing the security and confidentiality of any processed information through the adoption of appropriate measures to prevent the alteration, cancellation, destruction, unauthorized access or not allowed processing or not in accordance with the purpose of collection. Your Personal Data will be processed by the PRADA Group’s internal staff who are duly authorized to do so in accordance with their respective job duties. Your Personal Data may also be processed by third parties to the extent necessary and/or instrumental for the above purposes. These third parties will act on behalf of PRADA as data processors (e.g. service providers, carriers, IT technicians or any other suppliers appointed by PRADA to carry out and/or manage any promotional campaigns for PRADA’s products and services, etc.).
5. Transfer and disclosure of data
Whenever necessary and/or instrumental to the abovementioned purposes, your Personal Data may be processed on behalf of PRADA by other entities acting as data processor, including:
As PRADA is part of an international network, your Personal Data may be transferred abroad in accordance with applicable legislation, including to countries outside the United States and the European Union, where PRADA pursues its interests, by adopting all appropriate security measures and safeguards to ensure an appropriate level of data protection and security.
Your Personal Data will not be used for third-party advertising purposes or for the promotion of products, services or initiatives by entities other than the PRADA Group, nor shall they be disclosed to unknown persons under any circumstances.
Communication of data to the other PRADA Group companies
Please also note that if you register on the PRADA Group customers database for the purposes referred to in Sections 2(d)-(f), your Personal Data will be automatically visible to, and shared with, all PRADA Group stores globally to provide you with the same level of service around the world. PRADA will take all appropriate security and confidentiality measures as required by applicable legislation to ensure an adequate standard of data protection.
6. Retention period
Your Personal Data will be processed and stored for: (a) as long as required to carry out the purposes for which the Personal Data were collected; (b) in accordance with the storage periods required by applicable laws; or (c) until you revoke your consent to the processing/storage of your Personal Data, if applicable. After the conclusion of such period(s), and where there is no legal or business purpose for retaining your Personal Data, it will be automatically and permanently erased, or made anonymous.
In particular, regarding the data processing of registered members into PRADA Group customer database:
7. Data controllers and contacts
For the purposes referred to in Sections 2(a)-(c), the Data Controller is:
PRADA USA Corp.
610 West 52nd Street, New York, New York 10019
e-mail address: email@example.com
For the purposes referred to in Sections 2 (d)-(f), the Data Controller is:
Via Antonio Fogazzaro 28, Milan (Italy)
e-mail address: firstname.lastname@example.org
If you have any requests regarding your Personal Data, have any inquiries regarding this Privacy Statement, or you would like to exercise your rights or receive any information about your rights, please contact (free of charge) the Data Controller or its Data Protection Officer ("DPO") by writing to the addresses/email addresses listed above.
8. Your Rights
Please note that you may exercise the rights under the applicable privacy laws including the right to request information as to whether your Personal Data is being processed and as to the characteristics of the processing, the right to rectification and erasure of your Personal Data, and/or the right to have such Personal Data transmitted to another controller.
You also have the right to withdraw your consent for the collection and processing of your Personal Data by PRADA at any time, without charge. The withdrawal of your consent will not affect the lawfulness of processing based on your consent before its withdrawal.
9. Effective Date, Amendments
This Privacy Statement is effective March 18th, 2019. We may amend it from time to time, and if we make material changes, we will prominently post a revised version on the Website. Where required to do so by law, we may seek your prior consent to any material changes we make to this Privacy Statement.
Last updated: March 18th 2019