Data protection information

This Global Privacy Policy (the "Policy") describes how Bikinilista, a company registered in Milan, Italy, and/or its affiliates ("bkn"), each in their capacity as data controllers, process personal information about their customers and potential customers in order to provide you with the best possible service.

Bikinilista and/or your respective local bkn company (hereinafter "we", "our" or "us") collects, stores, processes, uses and discloses personal information about you as described in this Policy, in connection with your use of bkn's websites and apps, your use of our "Connected Products" (if any) or social media pages in your country or region.

For the purposes described in this Policy, bkn may collect the following categories of personal information:

(a) identification data and contact information (such as name, address, telephone number or e-mail address) if you provide it, for example, when creating an online account or to attend an event or make a purchase, or identity data necessary for a VAT refund request.

b) payment information: for example, credit card details, bank account numbers, PayPal account details or other payment details that you are required to provide in order to receive products or services ordered from us.

c) Demographic information such as your gender and birthday.

d) Your voice when you call bkn customer service, as the call may be recorded.

e) preferences and interests that you share with us in the course of your privileged contacts or encounters with our customer advisors (this may include your preferences in relation to our collections or other luxury brands, your clothing size, your lifestyle or basic information about your family environment).

f) Information relating to potential adverse effects of our cosmetic products, which may be health data.

g) Information that you post or submit publicly, in our social networks or on our websites, for example for product reviews.

h) Information about your online and in-store purchases. This may include the products you have purchased and their prices.

i) When you use our websites, we may collect information about the browser you use and your browsing behavior.

j) If you use our mobile app, we may collect your GPS location where necessary, subject to your consent. We may also track how often you use the app and where you have downloaded it. We may collect information about the browser you use and your browsing behavior.

k) When you use our Connected Products, we may collect information about your use of these products (for example, which features of our products you use most or battery level information) as well as geographic data to the extent necessary to provide you with the requested service.

l) To the extent necessary for the purposes defined here, we may also collect information posted on third-party websites or social networks about bkn products and services.

Your personal information is either provided directly by you (e.g. when you create an account on one of our websites / via one of our apps, make a purchase or otherwise contact our bkn customer service) or passively by you (e.g. through the use of tracking tools such as browser cookies) or collected from third parties (e.g. via social networks).

If you choose not to provide us with personal information when requested to do so for the performance of a contract or when required by law, you will not be able to receive the products or services you have ordered or register on our websites, for our apps or in other media.

We use the information described above for the purposes set out at the time of collection or as set out below in this policy:

a) To improve our understanding of your interests and concerns and your use of our products: We may use your information to optimize our websites, apps and products/services. We may use your information to better customize your experience with us and tailor our marketing to your needs and interests, as we believe it is also in our legitimate interest to better serve you and respond to your needs (Article 6, 1, f, GDPR).

b) To provide our Connected Services, process an order from you, process your requests or answer your questions and for complaint management: for example, we use your information to process your order and deliver your products. We may also use your information to send you requested information or to communicate with you about your account or our business relationship. We may contact you regarding changes to the website or service updates. We may also contact you in relation to feedback, this policy or website terms of use. In this case, your information will be processed for the performance of the contract that exists between you and us (Article 6, 1, b GDPR). If you call bkn customer service and we record the phone call, this will only be done with your consent.

c) For security purposes: We may use information to protect our company, our customers, our partners and our websites or apps against fraud, theft or any misconduct that could affect our business activities, as it is our legitimate interest to ensure the security of our online and offline business activities (Article 6, 1, f, GDPR).

d) To manage potential adverse effects of our cosmetic products in accordance with our legal obligations as a cosmetics manufacturer (Article 6, 1, c, GDPR).

e) For anti-counterfeiting and combating unlawful distribution channels for bkn products that violate bkn's General Terms and Conditions of Sale and bkn's selective distribution network (in particular by monitoring the quantity of products purchased and the frequency of product purchases), as it is our legitimate interest to protect ourselves against online counterfeiting and to secure our distribution network (Article 6, 1, f, GDPR).

f) For marketing purposes: We may use your information to contact you, where necessary subject to your consent, about new products and special offers which we think may be of interest to you (Article 6, 1, a, GDPR).

g) For analytics purposes: We may use your information to analyze the online reputation of bkn or our products and to evaluate the effectiveness of our online or offline campaigns or events, as it is our legitimate interest to maintain bkn's image and optimize our marketing campaigns (Article 6, 1, f, GDPR).

h) Other purposes: We use information to maintain transaction records and other business records for legal, administrative and audit purposes. We also use information to comply with legal, insurance and processing requirements (Article 6, 1, c, GDPR).

3. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?

We do not disclose or otherwise share your personal information that we collect, other than

a) With our parent company and our affiliated companies within the Bikinilista group of companies: Only authorized employees and only to the extent necessary for their duties will have access to the information for the purpose of internal audits, billing or administration and to provide you with the same level of service worldwide.

b) Service providers and agents who perform services on our behalf: For example, we share information with vendors who send emails on our behalf. We may also share personal information with service providers who assist us in operating our website.

c) with banks and other online payment service providers.

d) Our business partners - subject to your consent: For example, we share information with third parties who co-sponsor an event or promotion with us.

e) Third parties - in the context of business restructuring or reorganization (including dissolution or liquidation): This includes a merger of all or part of our business and the transfer, assignment or sale of assets.

f) If we are required to do so in order to comply with applicable law, to comply with a court order or generally to respond to a request from a competent authority.

We may collect certain information using cookies, web beacons and other automated means. A cookie is a text file that is stored in a dedicated area on your device's hard drive, for example when you visit online services, read emails or install or use a mobile app. A cookie enables its sender to identify the device on which it is stored during the period of validity of a given consent, which does not exceed a period of 13 months.

a) Some cookies may be functional cookies that are used to collect information that allows us to make your browsing experience easier, for example by setting your language, saving logins or saving the contents of your shopping cart or wish list.

b) Other cookies collect information about your behavior by collecting so-called referrer URLs (where our visitors come from, which banners they have clicked on and which have led them to our website), pages accessed, times of visits to websites. This information enables us to improve our websites and apps, to gain a better understanding of the products and services you prefer and to offer you personalized messages and/or personalized content on our website or in our apps.

c) We may also use cookies for web analytics to measure website activity and identify the areas of the websites that are visited most frequently. This enables us to improve the visibility of our content.

d) We use cookies to ensure the security of online transactions/purchases via device fingerprinting, which enables us to identify certain characteristics of the device used for an order.

e) Our websites or apps may contain third-party cookies (delivered by advertising agencies, analytics service providers, etc.) that allow them to collect information about browsing on your devices, including measuring the effectiveness of our advertising campaigns on third-party websites. Third party cookies are subject to the privacy policies of said third parties. We hereby inform you about the purpose of these cookies and how you can manage them, insofar as we are aware of them.

f) On our website or in our apps, we may offer the option of sharing content with third parties or informing other people that you have visited our website. This is the case, for example, with "Like" and "Share" functions of social networks (Facebook, Twitter, etc.).

Social networks that offer these functions can identify you even if you do not use these functions on our website. In fact, these features allow social networks to track information about your browsing behavior on our website whenever your social network account is activated while browsing our website.

We cannot control how these platforms collect your personal data while you browse our website. We encourage you to read the privacy policies of these social networks to learn how they usethe information collected through the buttons (including for advertising purposes). The privacy policy should provide you with information on how to manage your settings in your social network account.

Except in the case of functional and security cookies, the use of cookies on a device depends on the user's choice, which can be freely made and changed at any time.

You can manage cookies either here or by setting your browser to accept or reject cookies on your device, either for all cookies equally or cookie by cookie. The settings you make may affect your browsing performance and sometimes your ability to access certain services that require the use of cookies.

This is the case if we or one of our business partners can no longer recognize which browser type your device is using, e.g. with regard to language, display settings or connection country or region. We are not liable for any reduced access to our services resulting from your prior deletion or rejection of cookies.

Each browser has its own management system for cookies, which is described in the "Help" menu item of your browser and in which you will find all the necessary information on how to make settings.

1. go to "Internet options" in the "Tools" menu

2. click on "Privacy"

3. select your desired data protection level

1. go to the menu button and then to "Settings"

2. click on "Privacy & Security"

3. select your desired cookie option under "History" and "Create according to user-defined settings"

1. go to the menu button and then to "Settings"

2. click on "Privacy & Security"

3. select your desired option

1. click on the button at the top right

2. go to "Settings" and then to "Privacy & Security"

3. select your desired option

1. go to "More" in the menu and then to "Settings"

2. select "Privacy & security settings"

3. select your desired option in the "Cookies" menu

1. go to the "Safari" menu and then to "Settings"

2. go to "Allow cookies" under "Privacy"

3. select your desired option

1. click on the Chrome menu in the browser toolbar

2. select "Settings" and then click on "Show advanced settings"

3. click on the "Content settings" button under "Privacy"

4. in the "Cookies" section, you can change the settings for cookies

If you share your device with other people and use different cookies on the device

browsers are used on the device, we cannot guarantee that personalized services and advertising designed for your personal use of the device (if personalized services and advertising are available) will correspond to your own use and not that of another person.

Information we collect about you may be transferred to, stored and processed in countries/regions where a bkn company is located to ensure that you benefit from better service in all our locations and for the purposes defined in this Policy.

We may also transfer your personal information to service providers involved in the maintenance of our websites, apps or social networks or other tools for processing information about our customers or potential customers.

Some recipients are located in third countries or regions that do not have the same level of data protection as the EU country in which you have provided your information.

When we transfer your information, we will protect it by entering into data transfer agreements with the recipients based on the European Commission's standard data protection clauses (as amended from time to time or supplemented by additional measures where necessary) or other transfer mechanisms applicable in the future, thus ensuring adequate protection when transferring your personal information to recipients in these countries/regions (Article 46, GDPR).

Upon request, we will provide you with a list of the relevant third countries or regions and a copy of these safeguards.

Your personal information will be kept in a form which permits identification for no longer than is reasonably necessary for bkn to achieve the purposes for which it was collected or for which it is processed, or for longer than is set out in applicable laws through retention periods (Article, 13, 2, a, GDPR).

The retention period for your personal data collected by us is determined by the purpose of the data processing based on the following criteria:

Data collected for the specific purposes defined in Article 2 will only be stored as follows:

- For three (3) years from the last contact if you are a potential customer (i.e. you have not made a purchase from us but are interested in bkn).

- For the period of your business relationship with bkn and for 10 years thereafter if you are a customer (i.e. you have purchased our products or used our services).

Your personal data will then be archived for use: In the event of a dispute or litigation, for the period of the statute of limitations applicable to the relevant purpose; if legal proceedings are initiated, the personal information may be stored until the end of such proceedings, including any appeal periods, after which it will be deleted or, to the extent permitted by applicable law, archived.

Your personal data will then be anonymized or deleted.

You can request information about the personal information we process about you. If you request such information, we will provide you with all legally required information on the processing purposes, categories of personal data being processed, categories of recipients, data retention periods, etc. (Article 15 GDPR).

You may also obtain a copy of the personal information we hold about you in our records in a compatible and structured format that enables you to exercise your right to data portability if the processing is based on your consent or on the performance of a contract between you and us (Article 15, 3°, GDPR).

Furthermore, you may request that we rectify, amend or erase information that is incomplete, outdated or inaccurate (Articles 16 and 17, GDPR).

You may request the erasure of your personal information if (i) your personal information is no longer necessary for the purpose of the data processing, (ii) you have withdrawn your consent to the data processing based solely on that consent, (iii) you have objected to the data processing, (iv) the processing of the personal information is unlawful, (v) the erasure of the personal information is necessary for compliance with a legal obligation to which bkn is subject. bkn will take reasonable steps to inform the other companies in the bkn group of companies of such erasure (Article 17 GDPR).

You may request the restriction of processing (i) if you contest the accuracy of your personal information in order to allow bkn to verify its accuracy first, (ii) if you wish to restrict the use of your personal information instead of erasing it, even though the processing is unlawful, (iii) if you want bkn to retain your personal information because you need it for the defense of legal claims, (iv) if you have objected to processing but bkn is verifying whether there are legitimate grounds for processing which override your rights (Article 18 GDPR).

You also have the right to lodge a complaint with the competent supervisory authority (Articles 77 and 78 GDPR).

Our data protection officer can be contacted at personaldata@bikinilista.com . If the processing of your information is based on your consent (e.g. if you consent to receiving marketing materials), you can withdraw any consent you have given us at any time without affecting the lawfulness of processing based on your consent before its withdrawal (Article 17, 1, b, GDPR).

If your information is processed to protect our legitimate interests, you can object to this processing if your interests and your freedom outweigh our legitimate interest (Article 21 GDPR).

To exercise these rights, please contact us at personaldata@bikinilista.com and we will get back to you as soon as possible.

We will provide an adequate level of protection of personal information and ensure that appropriate technical and organizational security measures (including training and education of relevant employees) are in place to protect personal information against destruction, loss or alteration, whether accidental or unlawful, unauthorized disclosure or access and against all other unlawful forms of processing.

However, as the Internet is not completely secure, we cannot guarantee that your personal information stored or transmitted to us is completely secure. We ask you to exercise caution when using the internet to access our websites, apps or social networks.

Our websites and apps are not intended for children. We do not knowingly collect personal information from children without parental or guardian consent, unless permitted by law.

You must be at least sixteen years old to provide us with your personal information and eighteen years old to participate in transactions on our websites or in our apps. By transacting with us, you confirm that you are at least eighteen years of age, have full legal capacity and are legally bound by such transactions.

If we are notified (via a contact in the "Contact Us" section) or become aware that a minor has provided us with personal information through our media or otherwise, we will delete that personal information.

We may link to third-party websites or services that we do not control and that are subject to their own privacy policies. This Policy does not apply to these third party websites. We strongly advise you to review the privacy policies of any third party websites you visit to understand how they treat your personal information.

Our policy may change from time to time to reflect changes in our processing of your personal information. As required by law, we will notify you of any material changes. We will publish an updated version on the Website.

If you would like us to update the information we hold about you or your preferences, or if you have any questions about the protection of your personal information, please contact us by email: personaldata@bikinilista.com