HEALTH AND FASHION SHOES ITALIA S.P.A. with registered offices at Milano, via Enrico Caviglia 11, (hereinafter “HFS”) is constantly committed to protecting the online privacy of the users of its websites.
A) Source of personal data and Data Controller
This document has been written under article 13 of EU Regulation 2016/679 (hereinafter, the "Regulation"), in order to allow you to understand our policy regarding your privacy. In this Policy are described the general modalities about the processing of personal data of the website users, cookies and how your personal information will be handled when using our website www.scholl-shoes.com (hereinafter "Website").
The information and data which you may provide, or which may otherwise be collected in the context of your use of HFS’s services – e.g., access to reserved areas in the Website, newsletters, etc. (hereinafter, the "Services") - will be processed in compliance with the Regulation and the confidentiality obligations inspiring HFS activity.
In compliance with the Regulation, any personal data processing carried out by HFS will respect the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimization, accuracy, integrity and confidentiality.
B) Categories of personal data
As you use the Website, we inform you that HFS may process personal data (article 4.1 of the Regulation) hereinafter “Personal Data”.
In particular, Personal Data which may be processed by through the Website are as follows:
1) Browsing Data
Computer systems and software procedures involved in the website operation collect, as part of their routine operation, some Personal Data whose transmission is implied in the use of Internet communication protocols. Even if this information are not collected in order to be linked to specific data subjects it is still possible, by their nature, to identify users after processing and matching with data held by third parties. This category of personal data includes IP address or the domain names of the computer used by users connecting to the website, the URI (Uniform Resource Identifier) addresses of resources requested, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and other parameters related to operating system and IT environment of the user.
These data are used exclusively to compile anonymous, statistical information on the use of the Website, as well as to ensure its correct operation (see cookie paragraph) and identify any faults and/or abuse, and are deleted immediately after processing. Data may be used by authorities to identify responsible parties in the event of cybercrime committed which harms the Website.
2) Data provided voluntarily by the data subject
Apart from what specified for browsing data, user is allowed to submit personal data through forms placed inside the website (eg. register to a newsletter, free registration to the website, purchase, etc.). Failure to provide such personal data can prevent the Data Controller from providing the serivce. In this cases, will be collected the sole information that are necessary to provide the service requested (see the related privacy notices).
By using some of the services of the Website can take place a processing of Personal Data related to other persons you shared with HFS. In such situations you will be considered as an independent data controller, and must assume all inherent legal obligations and responsabilities.
To this end, you fully indemnify HFS against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, initiated by the third parties whose Personal Data is processed via the Website due to your initiative in infringement of the data protection laws. In any case, whenever you provide or process Personal Data related to other persons by using the Website you assure - assuming all inherent legal obligations and responsibilities - that such processing is based on an appropriate legal basis pursuant to article 6 of the Regulation, which may allow for lawful processing of this information.
C) Purpose of the processing and legal basis
HFS intends to process your Personal Data, with your consent where necessary, for the following purposes:
To provide the services of the Website
The legal basis of the processing is the performance of a contract with you, as well as taking steps at your request prior to entering into a contract with you - article 6.1.b. of the Regulation. The processing for this purpose is necessary to provide the Services.
It is not mandatory for you to give your Personal Data for this purpose; however, if you do not, it will not be possible for us to provide any Services of the Website.
D) Recipients of Personal Data
Your Personal Data may be shared for the purposes listed above, with:
• natural persons authorised by HFS to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees and system administrators)
• third parties engaged for the Website management, acting as Data Processors (an up to date list of the Data Processors may be obtained by visiting www.scholl-shoes.com)
• entities, bodies or authorities to whom your Personal Data may be disclosed, in accordeance with the applicable law or binding orders of those entities, bodies or authorities.
E) Transfers of Personal Data
Some of your Personal Data are shared with Recipients who may be located outside the European Economic Area. HFS ensures that your Personal Data are processed by these Recipients in accordance with the Regulation. Under the Regulation, these transfers can be based on an adequacy decision or on the Standard Contractual Clauses approved by the European Commission or on another appropriate legal basis.
F) Data subject rights under articles 15 and following of the Regulation
Under articles 15 and following of the Regulation, you, as a data subject, are entitled to request from HFS, at any time, access to your Personal Data, the correction and erasure of your Personal Data, as well as to object to its processing. You are also entitled to request the restriction of the processing of your Personal Data in the cases set out in article 18 of the Regulation, as well as to obtain the Personal Data you have provided in a structured, commonly used and machine-readable format, in the cases set out in article 20 of the Regulation.
Requests should be made in writing to the Data Controller at: firstname.lastname@example.org.
In any case, you are always entitled to lodge a complaint with the competent supervisory authorities for the protection of Personal Data (article 77 of the Regulation), if you believe that the processing of your Personal Data carried out violates applicable law.
HFS will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website.