DATE: 23rd MAY 2018
Welcome to Annakiki.com
At Annakiki.com we are committed to protecting and respecting your privacy. This notice sets out key information regarding Annakiki.com and how any personal data you provide to us will be processed. For all other information regarding our services, please refer to our Terms & Conditions.
If you would like more information about how we collect, use and store your personal data, you can contact us at any time by emailing firstname.lastname@example.org or writing to the Privacy Team at PGA, Via Bonaventura Cavalieri, 8, 20121 Milan, Italy
The annakiki.com website is run by Poly Global Advisory.
Poly Global Advisory is referred to here as “we”, “our”, “us” or “PGA”). If we use the term “our Group”, this means us and our subsidiaries, our ultimate holding company and its subsidiaries (or any of them). The term “our online services” refers to Annakiki.com our mobile and tablet applications, our pages on third party social media platforms such as Instagram, Facebook, YouTube, Twitter, Google+ and any other websites or apps we own or run from time to time. If you use any of our services, we will refer to you using the terms “user”, “visitor”, “you”, “your”, “yours” in this policy.
WHAT PERSONAL DATA DO WE COLLECT AND WHY?
We collect your personal data when you place an order, call our Customer Care team, sign up for our marketing communications, browse our website or use the other services offered by our website (www.annakiki.com). The data we collect includes details you provide to us, such as your given name and surname and your shipping and billing addresses. We also collect data regarding your shopping habits and the pages and products you have viewed from your use of the website. We use this data to:
- Take your orders, process your payments and deliver the items you have purchased;
- Provide any additional services you have requested, such as our marketing communications;
- Give you access to services reserved for registered users, such as Wish Lists and product notifications;
- Deliver your Annakiki.com POST, if you are a customer or account holder;
- Provide you with help and assistance via our Customer Care team;
- Personalize your visit to the website and ensure that content from our site is presented in the most effective manner for you and for your computer.
Under the Law, we must have a valid legal basis to process your data. In most instances, we will process your data because we have a contract with you e.g. to deliver your purchases or Annakiki.com POST, or to provide you with other services you have requested. We will also use your personal data to send you sales and marketing communications that we believe may be of interest to you if we have your explicit consent for this activity, or if you are an existing customer where we have a legitimate interest in communicating with you. You can opt out of sales and marketing communications from us at any time.
WHO WILL PROCESS YOUR DATA?
Your personal data will be processed by Poly Global Advisory and by Annakiki.com, as the data controllers, and may also be processed by other Group companies acting under our instructions.
We may also retain the services of external suppliers to help meet our business needs and may share your data with these suppliers. These suppliers have been selected after a rigorous evaluation process and chosen for their security, reliability and competence. They will process your data only under our instructions. Some of these suppliers and some Group companies may be based in non-EU countries. Where this is the case, the transfer of your personal data to these countries is carried out in compliance with the guarantees provided by law.
HOW LONG DO WE KEEP YOUR DATA?
We will not retain your personal data for longer than is necessary to fulfil the purposes for which you provided that personal data, unless the law permits or requires that we retain it for longer. The retention period varies depending on the purpose of the processing. For example, the data collected during your purchase of goods on www.Annakiki.com are retained in accordance with local tax law, while those data used to send you our marketing communications are retained until you ask to be unsubscribed.
WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?
Under the Law, you have the right to:
- Know what personal data of yours we are processing, where that data came from and how we are using that data;
- Ask us to update, correct or supplement the data we hold about you;
- Withdraw consent for processing for a specified purpose;
- Ask us to delete or erase your data from our systems;
- Limit or oppose our processing of your data;
- Ask us to supply the personal data we hold about you in an easy readable electronic format or transfer that data direct to a third party nominated by you.
You can exercise these rights at any time by emailing email@example.com or writing to the Privacy Team at PGA, Via Bonaventura Cavalieri, 8, 20121 Milan, Italy
If you believe that the processing of your personal data has been carried out unlawfully, you can file a complaint with the supervisory authority responsible for compliance with the rules on personal data protection in your jurisdiction.
1. Who is the data controller?
Under the data protection law, the data controller is responsible for ensuring that your data is held securely, that you are given accurate information about how your data is used, and that your rights regarding your data are respected.
The Annakiki.com website is run by Poly Global Advisory. For the purpose of the Data Protection Act and the General Data Protection Regulation (the “GDPR” Law), the data controllers for any personal data we hold about you are Annakiki.com and Poly Global Advisory. If we use the term “our Group”, this means us and our subsidiaries, our ultimate holding company and its subsidiaries (or any of them).
2. What personal data do we collect?
We collect and process only the data that is required to allow us to provide our services to you. We collect the following data when you browse or shop at www.Annakiki.com:
- We process the personal data required to complete and dispatch your purchase, including your name, billing address, delivery address, payment details, mobile number, telephone number and email address. We collect your email address in order to send you confirmation of your order; we collect your telephone number so that we can contact you if there are any issues with the order.
- We collect your email address when you sign up to receive Newsletters
- If you register for a Plein.com account, we collect your name, email address, password, country and additional data regarding your marketing preferences.
- When you contact our Customer Care team, we may collect additional data to help us resolve any queries relating to your order, delivery, payments, marketing, the website or any other queries.
- We collect and process data about your browsing on www.Annakiki.com, including the pages you visit and how you interact with these pages. If you have registered for an account, we collect browsing data about your access to the dedicated areas of the website.
- If you are a customer of www.Annakiki.com, or if you have given us your consent, we collect and process your personal data for direct marketing activities.
- If you provide us with someone else’s data – for example, if you purchase a product to be delivered to a friend or as a gift – we will collect and process the personal data required to complete the transaction such as the name, delivery address and other contact details for your friend. If you are receiving an item as a gift, we will process your data only to fulfil the gift request and our contractual obligations.
- When you call our Customer Care team, your call will be recorded for training and fraud prevention purposes.
3. How do we use the personal data we collect?
We collect and process your personal data for the following purposes:
- When you purchase a product from www.Annakiki.com we ask you for the personal data necessary to allow us to fulfil our contract with you including taking payment, any related anti-fraud checks if you choose to pay by credit/debit card, billing, shipping and delivery of the product and possible handling of the return.
- When you visit www.Annakiki.com, we will collect the minimum personal data necessary to allow us to provide you with the services of the website, such as placing and holding items in your shopping bag.
- When you visit www.Annakiki.com, we will use some data about your use of the website to help us improve the website and our promotion of the website. This will include data about how you came to the website; the date and time of your visit; products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
- When you register on www.Annakiki.com, we will collect the data necessary to ensure that we can recognize you on return visits and provide you with the services registration offers, such as creating a Wish List or subscribing to emails. If you would prefer not to continue receiving these emails, you can unsubscribe at any time using the link on the bottom of the email, or by contacting our Customer Care team.
- When you sign up for our marketing communications, we will ask you for your email address. If you would prefer not to receive these emails, you can unsubscribe at any time using the link on the bottom of the email, or by contacting our Customer Care team.
- If you have purchased from www.Annakiki.com, we will use the personal data we hold about you, including your purchase history, to contact you regarding products and services that may be of interest to you. This contact will normally be via email, but in certain circumstances we may contact you via other methods e.g. we may call you if an item we know you have been eager to purchase comes back into stock. If you would prefer not to be contacted in this way, you can unsubscribe from emails at any time using the link on the bottom of the email or update your contact preferences on www.Annakiki.com or by contacting our Customer Care team.
- We analyze contact data, purchase history, web browsing data and lifestyle data to tailor our marketing communications, web site presentation and internet advertising to meet your preferences. For example, if you have been browsing or have previously purchased a particular shoe model we may send you an email to tell you that these are now on sale or display similar products to you as part of our internet advertising.
- When you contact our Customer Care team, we will use the personal data you provide and that we have collected to respond to your requests for help or information.
4. What is our legal basis for processing your personal data?
Under the Law we must have a valid reason for using your personal data and we may not collect, store or use data about you that is not compatible with that reason. There are four valid reasons for our use of your personal data:
- Most of the data we collect from you is necessary to allow us to fulfil our contract with you or to enter into a contract with you e.g. you provide a billing address and email address when your purchase an item from www.Annakiki.com so that we can process your payment and send you your order confirmation.
- In certain circumstances we will ask for your permission or consent to use your personal data e.g. if we would like to send you marketing information about items we believe may be of interest to you via email. If you have given your consent to our use of your personal data, you are entitled to withdraw this consent at any time.
- We may also have a legitimate interest in using your personal data e.g. to ensure that the content of our website is presented to you and your device as effectively as possible, or to ensure that our marketing communications are relevant to your interests. If this is our reason for using your data, we must make sure that our interests do not override yours and you are entitled to object to this use of your data.
- Lastly, we may be required to use your data to meet a legal obligation or to protect your interests e.g. we may exchange data with other specialist organizations for the purposes of fraud detection and credit risk reduction and we will retain financial data long term to meet our statutory obligations.
The legal basis for each of the ways in which we use your personal data is as follows:
Our use of your data / Our legal basis for processing
- When you purchase a product from www.Annakiki.com we ask you for the personal data necessary to allow us to fulfil our contract with you including taking payment, completing any related anti-fraud checks if you choose to pay by credit/debit card, billing, shipping and delivery of the product and possible handling of the return. The provision of your personal data for these activities is a contractual obligation. You are free to communicate your data or not, but in the absence of the requested data it will not be possible to finalize or execute the contract and your requests. This means that while you will continue to be able to browse www.Annakiki.com, you will not be able to purchase products and you will not be able to use the services of our website such as the Wish List.
- When you make a purchase at www.Annakiki.com, we are required to process your personal data to meet our legal obligations in accordance with the tax provisions and other statutory rules which apply.
You are free to decide whether or not to purchase from us, but if you do make a purchase this use of your data will be necessary to meet our legal obligations.
- When you make a purchase at www.Annakiki.com, we will use some of your personal data to carry out anti-fraud activities: we have a legitimate interest in carrying out this activity to prevent and prosecute any fraudulent activity.
- When you visit www.Annakiki.com, we will collect the personal data necessary to allow us to provide you with the services of the website, such as placing and holding items in your shopping bag. Our use of your data is necessary for our legitimate interest in ensuring that the service we provide to you is managed correctly.
- When you visit www.Annakiki.com, we will use some data about your use of the website to help us improve the website and our promotion of the website. This will include data about how you came to the website; the date and time of your visit; products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. Our use of your data is necessary for our legitimate interest in ensuring that the service we provide to you is managed correctly.
- When you register on www.Annakiki.com, we will collect the data necessary to ensure that we can recognize you on return visits and provide you with the services registration offers, such as creating a Wish List or subscribing to emails. If you would prefer not to continue receiving these emails, you can unsubscribe at any time using the link on the bottom of the email, or by contacting our Customer Care team. The provision of your personal data for these activities is a contractual obligation. You are free to communicate your data or not, but in the absence of the requested data it will not be possible to finalize or execute the contract and your requests. This means that while you will continue to be able to browse www.Annakiki.com, you will not be able to use the services of our website such as the wish list or alerts about new arrivals
- When you sign up for our marketing communications, we will ask you for your email address to enable delivery of our marketing communications. If you would prefer not to receive these emails, you can unsubscribe at any time using the link on the bottom of the email, or by contacting our Customer Care team. You have given your consent and asked us to send you our marketing communications.
- If you have purchased from www.Annakiki.com, we will use the personal data we hold about you, including your purchase history, to contact you regarding products and services that may be of interest to you. This contact will normally be via email, but in certain circumstances we may contact you via other methods e.g. we may call you if an item you have been eager to purchase comes back into stock. If you would prefer not to be contacted in this way, you can unsubscribe from emails at any time using the link on the bottom of the email or update your preferences via www.Annakiki.com or by contacting our Customer Care team. Our use of your data is necessary for our legitimate interest in ensuring that you receive information about goods and services that may be of interest to you.
- We analyze contact data, purchase histories, web browsing data and lifestyle data to tailor our marketing communications, web site presentation and internet advertising to meet your preferences. For example, if you have been browsing or have previously purchased a particular shoe, we may send you an email to tell you that these are now on sale or display similar products to you as part of our internet advertising. Our use of your data is necessary for our legitimate interest in ensuring that you receive information about goods and services that may be of interest to you.
- When you contact our Customer Care team, we will use the personal data you provide and that we have collected to respond to your requests for help or information. The provision of your personal data for these activities is a contractual obligation. You are free to communicate your data or not, but in the absence of the requested data it will not be possible to finalize or execute the contract and your requests.
- When you call the Customer Care team, your call will be recorded for training and fraud prevention purposes. Our use of your data is necessary for our legitimate interest in ensuring that our employees receive adequate training and for fraud prevention.
5. Who will process your data?
Your personal data will be processed by the internal staff of Poly Global Advisory and Annakiki.com who have been specifically trained and authorized for this processing.
Your personal data will also be transmitted to third parties that we use to provide our services; these parties have been rigorously assessed and offer a guarantee of compliance with the legislation on the processing of personal data. These parties have been designated as data processors and carry out their activities according to the instructions given by Poly Global Advisory and Annakiki.com and under our control.
The third parties in question belong to the following categories: banking operators, internet providers, companies specializing in IT and telematics services; couriers; companies that carry out marketing activities, including social media organizations; companies specializing in market research and data processing; companies offering contact center services; companies providing publishing and distribution services.
Under some circumstances we may be required to disclose or share your data without your consent, for example if we are required by the police, the courts or for other legal reasons. Your data may be transmitted to the police, judicial and administrative authorities, in accordance with the law, for the investigation and prosecution of crimes, the prevention of and protection from threats to public security, to allow Poly Global Advisory and Annakiki.com to ascertain, exercise or defend a right in court, as well as for other reasons related to the protection of the rights and freedoms of others.
6. Data transfer outside the European union
Some of the third parties listed in the previous paragraph ‘Who will process your data?’ may be located in countries outside the European Union that nevertheless offer an adequate level of data protection as offering adequate levels of protection will be performed only:
- after the completion between Poly Global Advisory and Annakiki.com and said parties of specific agreements containing safeguard clauses and appropriate guarantees for the protection of your personal data (known as “standard contractual clauses” and approved by the European Commission), or
- if the transfer is necessary for the completion and execution of a contract between you and Poly Global Advisory and Annakiki.com (for the purchase of goods offered on our website, for registration on the website or use of services on the website), or for the management of your requests.
7. How long do we keep your data?
- We keep your personal data for a limited period of time in line with our data retention policy. The specific retention period will vary according to the reason for processing your personal data. After this period, your data will be permanently erased or otherwise irreversibly rendered anonymous.
- Your personal data are retained in accordance with the following criteria: When you have purchased goods from www.Annakiki.com, we will retain the billing data until the end of the relevant accounting period.
- When you make a payment, we will retain your payment details up to the certification of the payment and the completion of the relevant administrative-accounting formalities regarding your right of withdrawal and the terms applied for the disputing of the payment;
- When you provide us with personal data in order to use the services of www.Annakiki.com, such as marketing communications, we will keep your data for this purpose until the termination of the service or until you cancel your subscription to the service;
- When we use your personal data and browsing history to analyze your behavior in order to customize the website and to show you personalized sales offers, we will keep the data for analytical purposes until you ask us to delete it;
- When we use personal data for market research and satisfaction surveys, we will keep the data until you ask us to stop.
- When you contact our Customer Care team, we will keep any additional personal data you provide that is specific to your enquiry for as long as you remain an active customer of www.Annakiki.com.
- When you contact our Customer Care team, we might keep the call recording up to 3 Moths. Credit card details are not recorded as part of the call.
8. Your rights
You have the right to request a copy of the data that we hold about you (and we will provide this to you free of charge once we have confirmed your identity).
If you would like a copy of some or all of your personal data, please email or write to us using the contact details in this policy.
If we do hold data about you we will:
- give you a description of it
- tell you why we are holding it
- tell you who it could be shared with
- tell you how long we will keep the data
- if the data was not provided by you, we will give you any available information such as the source of the data
- tell you if the data has been used for automated decision making
- tell you if the data is stored outside of the European Economic Area, and if so what safeguards are in place to protect your personal data
You have the right to ask us to correct any inaccuracies in the personal data we hold about you and to stop us using your data until it has been corrected. We want to make sure that your personal data is accurate and up to date and we will be happy to correct or remove data you think is inaccurate.
If you have given us your consent to use your personal data for marketing, you have the right to withdraw your consent at any time by calling our Customer Care team, clicking “unsubscribe” on a marketing email. You may receive a small number of further communications immediately after unsubscribing but we will implement your request as quickly as possible.
You have the right at any time to oppose our processing of your personal data on the basis of our legitimate interest. You will need to explain the reasons behind your request and allow us to consider your request and respond.
You have the right to request the deletion of your personal data. After receiving and reviewing your request, if legitimate it will be our responsibility to cease processing promptly and to delete your personal data.
You have the right to receive a copy of your data that we process based on your consent or on the basis of a contract with you in a standard format. If you wish, where technically possible, we can transfer your data directly to a third party indicated by you.
To exercise any of these rights, you can sign in to your account, contact our Customer Care team at firstname.lastname@example.org or write to the address mentioned above.
To ensure that the data of our users are not subject to breaches or illegitimate use by third parties, we will ask you to confirm your identity before carrying out your request.
We protect your personal data with specific technical and organizational security measures aimed at preventing your personal data from being used illegitimately or fraudulently.
In particular, we use security measures that guarantee: encryption or pseudonymization of your data; the confidentiality, integrity, and availability of your data as well as the resilience of the systems and services that process them; the ability to restore data in the event of a data breach. Furthermore, Poly Global Advisory and Annakiki.comundertake to test, verify and regularly evaluate the effectiveness of technical and organizational measures in order to guarantee continuous improvement in the safety of processing.
9. CHANGES TO THIS NOTICE
HOW THIS INFORMATION MAY BE USED
Whenever you give us your personal information we will use it in accordance with applicable privacy laws and for the purposes set out in this policy, on the data entry forms you complete, in any relevant terms and conditions and on pages or emails which link to the data entry forms.
When you use our services:
If you use any of our services, register for or attend one of our events, set up, look at or change your account details or contact your personal shopper or a member of our Customer Care team, we will record your personal details. Your information will be used in the first place to provide the products, services or information you have asked for and to provide you with a personalized shopping experience. We keep the information you provide and may use it for several purposes, including: (i) accounting, billing, reporting and audit; (ii) credit checking or screening; (iii) authentication and identity checks; (iv) credit, debit or other payment card verification and screening; (v) debt collection; (vi) safety, security, health, training, administrative and legal purposes; (vii) data matching and dedupe, statistical and market analysis, and marketing information; (viii) advertising and marketing for us, our Group and third parties; (ix) developing, testing and maintaining systems; (x) studies, research and development; (xi) customer surveys; (xii) customer care and to help us in any future dealings with you, for example by identifying your requirements and preferences; (xiii) where required by law or in connection with legal proceeding or disputes; and (iv) any other uses set out in the terms and conditions for use of our services. For these purposes we may disclose your information to one or more of the other organizations listed in the section called “who we will share your personal information with”.
Saved payment card details will only be shared with our payment partner and not with any other third parties and will only be used to process your order, using our payment partner’s systems.
We may also use your personal information to send you marketing updates, as detailed in the next section.
Tracking how our online services are used:
CUSTOMIZATION OF OUR ONLINE SERVICES AND ADVERT TARGETING:
If you give us feedback, we may use it to improve our services and we may publish it online or offline to promote our business and our services. We will ask for your permission before we publish it.
Comments and reviews submitted to our online services:
If you wish to submit a comment or feedback on a blog or article featured on our services, we may (but are not obliged to) publish your comment online or offline to promote our business and our services. We will collect your name or username which will be displayed next to your comment and e-mail address, which will not be published, but which we may use to contact you in relation to your comment.
For information on how we may market to you, please read the section called “marketing opt-in and opt-out provisions”.
WHO WE WILL SHARE YOUR PERSONAL INFORMATION WITH
From time to time, we may engage third party business partners to provide information about you or to collect personal information on our behalf. We may also share or match your data with third party business partners to provide you with the products, services or information you ask for or for interest-based advertising. We may pass your information onto one or more of the following organizations: (i) data processing companies, mailing houses and other third party suppliers working on our Group’s behalf; (ii) ad-serving agencies and other advertising intermediaries; (iii) credit reference or fraud prevention agencies, which may keep a record of that information; (iv) research students, universities and other research and development organizations; (v) regulatory bodies, government and enforcement agencies, such as the police.
Every now and again, we receive requests for information from government departments, the police and other enforcement agencies. If this happens, and there is a proper legal basis for providing your personal information, we will provide it to the organization asking for it.
We collate information about site traffic, sales, wish lists, and other commercial information which we may pass onto third parties, but this information does not include any details which can identify you personally.
WHERE WE PROCESS YOUR PERSONAL INFORMATION
When we use your information as described in this policy, this may involve sending your information outside the European Economic Area (EEA). When we do this, we make sure that appropriate steps are taken to protect your personal information and your rights. By providing us with your personal information, you agree that we may transfer, store and process your information outside the EEA. Governments in certain countries such as the USA have broad powers to access data for security, crime prevention and detection and law enforcement purposes.
MARKETING OPT-IN AND OPT-OUT PROVISION
We offer you the chance to receive news and updates which, depending on your preferences, we will discuss with you by phone or live chat or send to you via email, SMS and/or direct mail. These include alerts for new products, features, enhancements, special offers, upgrade opportunities, contests, events of interest, and one-off marketing promotions. You can opt-out of receiving these updates, if you wish.
We, or our third-party business partners, may also ask you if you want to receive marketing if you enter a promotion or attend an event thrown or sponsored by us. Other companies in our Group may also pass your personal information to us for marketing use.
Marketing communications you subscribe to will only be sent by our Group.
You have the right to ask us not to use your personal information for marketing. At all times, we will offer you the opportunity to unsubscribe from any service or update to which you have subscribed, if you change your mind. Whenever you receive direct marketing from us, we will tell you how to unsubscribe or by email at email@example.com
If you tell us that you do not want to receive direct marketing, we will still contact you in order to provide you with products and services you request and for administration purposes.
SAFEGUARDING YOUR PERSONAL INFORMATION
We will take reasonable care to maintain appropriate safeguards to ensure the security, integrity and privacy of the information you have provided to us. We have put in place technology and security policies which are designed to protect the personal information we hold about you. We also follow the security procedures that applicable privacy laws require. These covers storing, using and releasing any information you have provided and, as well as measures designed to prevent unauthorized access or use. When you place an order or access your account information, we use a Secure Socket Layer (SSL) encryption which encrypts your information before it is sent to us to protect it from unauthorized use.
HOW WE CAN MAKE CHANGES TO THIS POLICY
If you require more information, please contact our privacy officer at firstname.lastname@example.org
What is a cookie and what is its purpose?
A cookie is a small file that is sent to the browser and saved on your device when you visit a website like plein.com (“the website”).
Cookies allow the site to function efficiently and improve its services, in addition to providing information to the site owner for statistical or advertising purposes, primarily to personalize your navigation experience by remembering your preferences (for example, remembering the language and currency you set, in order to recognize you at the next visit, etc.)
Which cookies do we use and for what purposes?
Our website uses various types of cookies and similar technologies, each of which has a specific function. Below is a table explaining them.
Type of cookie function
- Navigation cookies
From the first access these cookies allow the website to function correctly and allow you to view content on your device by recognizing the language and market of the country from which you’ve chosen to connect. If you are a registered user, they will allow you to be recognized and to access the services offered from the dedicated areas. Navigation cookies are technical cookies and are needed for the functioning of the website.
- Functional cookies
These cookies allow, based on your express request, for you to be recognized when you subsequently access the website, so that you do not have to enter your information each time (for example: Remember me”).
If you have added items into your Shopping Bag and closed the session without completing the purchase and without eliminating those items, these cookies allow you to continue the shopping experience the next time you access the website (within a limited period,) finding the same articles that were selected.
Functional cookies are not essential to the functioning of the website, but rather improve navigation quality and experience.
- Analytical cookies
These cookies are used to prepare statistical analyses on the navigation methods of our website’s users. Annakiki.com and Poly Global Advisory treats the results of these analyses anonymously and exclusively for statistical purposes only if the service provider uses the cookies to connect to the browser used or other devices used to navigate on the website. The website uses certain third-party services which, entirely independently, install their own cookies.
Our own and third-party marketing and profiling cookies
- Social Network cookies
These cookies are necessary to allow your social account to interact with our website. For example, they are used to express your appreciation and to share it with your social networking friends. The social network cookies are not needed for navigation.