Privacy Policy

 

Welcome to the AUSTIN BODD website, at the url www.austinbodd.com (AustinBodd).

Please carefully read this Privacy Policy, which applies whenever you access this Website. Please also read the General Terms and Conditions of Use, since they contain important information on the Website.

We remind you that this Privacy Policy is regulated by English law, and in particular by the Data Protection Act 2018 and by the European Regulation 2016/679. Together the Code and the Regulation guarantee that the personal data be processed in accordance with fundamental rights and liberties, as well as in respect of the dignity of the interested party, particularly as concerns confidentiality, personal identity and the right to protection of personal data.

1. Personal Data Controller

AUSTIN BODD, with registered office at 20-22 Wenlock Road, London. N1 7GU, United Kingdom is the data controller for the data processing related to the Website, including therein navigation data, marketing data and profiling data, as well as all the data related to sales made through the Online Boutique and to the corresponding pre- and post-sales support activities.

The appointed data processor is Austin Bodd, with registered offices in 20-22 Wenlock Road, London. N1 7GU United Kingdom.

To contact the Data Protection Officer and to exercise your rights (also for having a complete list of processors), you may write to contact@austinbodd.com, or send a request to the attention of the Data protection Officer at the address of the registered office noted above.

2. Personal Data Protection Officer

AUSTIN BODD has appointed a personal data protection officer, who can be contacted at the following e-mail address contact@austinbodd.com for any information regarding the processing of your personal data and to exercise the rights set out below.

You can also submit any queries regarding privacy by selecting the appropriate section in the Customer Service contact form.

3. Type and purpose of processing performed on the Website – Legal basis for Processing

Through the Website, different types of personal data are collected and processed, for different purposes and with different methods. More precisely:

(a) Personal data related to browsing, which is processed both for the purpose of allowing the Website to function properly, and for marketing purposes. To this end, please read the “Cookie Policy” in the Legal Area of the Website;

(b) Personal data provided voluntarily by the user (such as e-mail address, personal information, password provided by filling in the "My Account" registration form) or otherwise lawfully acquired during the user's visit to the website, to respond to the user's requests and to offer the requested services, assistance and information regarding products and the AUSTIN BODD world. Please note that registration and access through a social profile involves the disclosure of certain data (including first name, last name, email and any other data relating to the user and present on the same social profile) by the chosen social network and therefore requires explicit permission to be given before logging in, which will allow you to carry out activities with the user account. In some cases, social networks require some feedback and information about the use of the log-in. For more information please refer to the relevant privacy documentation on the social network;

(c) Personal data provided by the user as part of the processes of online registration on the Website, of sending purchase orders for products on the Online Boutique for the conclusion of e-commerce transactions and of interacting with users for activities that are operational and essential to the sale, as well as for any necessary pre- and after-sales assistance;

(d) With the express consent of the user, AUSTIN BODD may process the user's personal data for marketing purposes, i.e. to send the user information and updates on products, sales, promotional campaigns, events and other initiatives promoted by AUSTIN BODD (using traditional tools and by means of telematic tools such as newsletters, e-mails, text messages, MMS and smart messages);

(e) With the express consent of the user, AUSTIN BODD may also process the user's personal data for the purpose of studying shopping habits and choices in order to make products and initiatives more responsive to the tastes and needs of its customers.

With the exception of browsing data, which is covered by the Cookie Policy, the processing of personal data is based on:

  1. consent that the user may provide for the purposes referred to in point b) - with exclusive reference to the Social Network Login - and in points d) and e);
  2. the legitimate interest of both AUSTIN BODD in providing the Website's services and of the user in browsing the Website and/or the legitimate interest of AUSTIN BODD in responding to any customer requests.

With reference to point 2 (c) above, the legal basis of the processing referred to therein lies in the fulfilment of the contract and the obligation to fulfill pre and post contractual obligations.

Please note that, based on the principle of legitimate interest, AUSTIN BODD may contact you in order to offer you services and products similar to those you have previously purchased. Please also note that, under current legislation, this type of contact (known as "soft spam") does not require consent. You may, however, request the discontinuation of the processing at any time and AUSTIN BODD will do so without delay.

4. Source of personal data

AUSTIN BODD collects personal data directly from the user (by registration or during the purchase steps) with the exception of the data collected with the navigation as per section 2 (a) above and data collected with the social log-in as per section 2 (b) above).

5. Analysis of user's buying habits and selections

As indicated in Section 2 (e) above, with the user's express consent, AUSTIN BODD may also process the latter's personal data for the purposes of analysing user's buying habits and selections, in order to make the AUSTIN BODD products, services and initiatives more responsive to its customers' tastes and needs.

AUSTIN BODD will process, by automatic means the value purchased within a framework of time, the frequency of the purchases (even if the purchases are made during the sale period) and the kind of product purchased (accessories, clothes, haute couture, pret-a-porter). AUSTIN BODD will not proceed with an intrusive study of the users’ behavior and the study is only intended to propose to clients and users products, services and initiatives more responsive to their tastes and needs.

Moreover, please note that as per Section 2 (a), with the user's express consent, AUSTIN BODD can process personal data through an automatic means to study cookies in order to verify the navigation through the Website and too purpose products and services in line with the navigation.

6. Personal data processing methods carried out by AUSTIN BODD

The personal data collected through the Website of AUSTIN BODD is primarily processed using computer and electronic means, adopting security measures in order to reduce to a minimum the risks of destruction or loss, including accidental loss, of the data itself, unauthorized access or processing without consent, or processing that is not in conformity with the purposes of collection indicated in this Privacy Policy.

However, these measures, due to the nature of the online transmission method, cannot limit or absolutely exclude the risk of access without consent, or of dissemination of data. To that end, we recommend that you periodically verify that your computer is equipped with the appropriate software devices to protect from the transmission of incoming and outgoing data on the network (such as up-to-date antivirus systems) and that the Internet service provider has adopted suitable measures to ensure the security of data transmission on the network (such as, for example, firewalls and antispam filters).

Each purchase on www.austinbodd.com is made with the utmost security thanks to the use of the most advanced technological systems and coding (SSL).

7. Mandatory or voluntary nature of providing data

With the exception of the navigation data (the provision and collection of which are regulated by Section 7 "Cookies" of this page/Cookie Policy), the provision to AUSTIN BODD of personal data, both for requests and queries, and for the purposes of marketing and analyzing consumer habits and preferences, is voluntary and optional. Failure to provide such data does not limit the use of the Website, although it may make it impossible for AUSTIN BODD to respond to requests for information and queries, or to purpose customized products and services, or to send informational material, updates, newsletters and invites to AUSTIN BODD events.

The provision of the data, especially personal details, email address, postal address, telephone number and bank details in case of credit card payments, is compulsory for executing, through the Website, the product purchase agreement.

Some of said data, moreover, may be necessary for providing to the user other services made available on the Website in connection with the sales (post sales and pre sales services such as made to measure services, pickup in boutique service, delivery, exchange, etc.) or for discharging the obligations deriving from the law or regulatory provisions (tax obligations and antimony laundering). Any failure by the data subject to provide us with the data may therefore constitute, as the case may be, a lawful and justified reason for not performing the agreement of the products purchased on the Website and not providing the related services.

The mandatory or voluntary nature of the data to be provided will be, if necessary, and as the case may be indicated by means of a special character (*) placed next to the relevant information or to the data the provision of which is necessary for the purpose of providing the services and for purchasing the products on the Website. Any failure to furnish the data the provision of which is voluntary, does not entail obligations or disadvantages of whatever type.

8. Categories of recipient of personal data

AUSTIN BODD communicates the personal data of the Website's users only as permitted by the law and as indicated below. Further to what indicated in point 2 b. (namely the Social log-in) personal data shall be processed and disclosed to

  • (i) employees and consultants of AUSTIN BODD processing data in their capacity of persons in charge of the processing for internal organization of the activities;
  • (ii) other companies of the same Group acting as data processors in order to carry out contractual activities and services and to carry out specific marketing activities (such as inviting the user to local events); and
  • (iii) companies acting in their capacity of data processors and providing AUSTIN BODD with specific technical and organizational services in relation to the Website (logistics services, IT services and marketing services).

Personal data may also be disclosed to

  • (i) third parties for the sole purpose of performing the agreement of the products purchased on the Website (the financial institutions in charge of providing remote card payment services through credit/debit cards).
  • (ii) police officers and judicial authorities, in compliance with the law and upon their request, or in case there are good reasons to believe that such disclosure is reasonably necessary to (1) investigate, prevent or take initiatives in relation to suspected unlawful activities, or assist national supervisory authorities; (2) prepare a defence against third party claims or charges, protect the security of its own website and of the company; (3) exercise or protect the rights, property or security of AUSTIN BODD, the AUSTIN BODD Group companies, its affiliates, customers, employees and third parties.

Your data will not be disseminated, and will be transferred abroad only and if adequate levels of protection and sufficient safeguards, as provided for by the law, are guaranteed. AUSTIN BODD mainly process personal data using Shopify platform (see Shopify data policy for more details). In order to allow the processing by the subsidiaries for contractual and marketing activities, the data will be transferred to the relevant country (also non-EU countries). For this reason, AUSTIN BODD entered into with all its non-EU subsidiaries the Standard Model Clauses in order to protect the transferred personal data. Persona data may be transferred to non IT services providers in order to grant the subsidiaries to have access to the transferred personal data and AUSTIN BODD also entered with them a data processing agreement and Standard Model Clauses in order to protect the transferred personal data (previously verifying the security measures applied by said processors to the data).

9. Storage Period

Personal data linked to the purchase will be stored for at least 10 years to comply with tax and civil law. Moreover, the data linked to the purchase may be stored for a longer period of time in order to comply with the contractual unlimited warranty granted to the client.

Personal data provided for marketing and profiling activities are kept as long as necessary for the particular processing also with reference to the specific sector of activity (luxury products) and considering the interest demonstrated by the clients to be updated on the products, events and runaways of AUSTIN BODD.

10. User rights recognized by the privacy law

A user always has the right to obtain from AUSTIN BODD confirmation of whether or not personal data concerning him/her exists, even if it is not yet recorded, and to have it communicated to him/her in an intelligible form. A user also has the right to obtain information about the source of personal data; the purposes and methods of processing it, the logic applied in the event of processing that is performed with the aid of electronic instruments; the identification details of the controller and data processors; and indication of the persons or categories of persons whose personal data may be communicated, or who could end up being known by, for example, data processors or agents as data supervisors or data processors. A user also has the right to request an update, correction or, when s/he has an interest in doing so, an inclusion of personal data, deletion, conversion to an anonymous form or the blocking of personal data, that has been processed in violation of the law, including data which it is not necessary to keep in relation to the purposes for which it was collected or subsequently processed; a statement that the above operations were disclosed, including in terms of their content, to those parties to whom the data was communicated, except in the case in which such performance proves impossible or entails the use of methods that are clearly disproportionate to the right protected. The user can also ask for the portability of his/her data.

A user nevertheless has the right to object, in part or in full, for legitimate reasons, the processing of personal data concerning him/her, even if it is pertinent to the scope of the collection, the processing of personal data concerning him/her for the purposes of sending advertising or direct marketing materials, or to conduct market research or commercial communications and he has the right to ask restriction of processing concerning itself. The right to object may also be exercised specifically with regard to one or more methods of sending marketing communications. The user also has the right to lodge a complaint with a supervisory authority as well as the right to withdraw the consent previously given.

The above rights may be exercised by contacting the Data Protection Officer by writing to contact@austinbodd.com or by selecting the appropriate category in the online contact form.