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Privacy Policy

Identity and contact details of the controller

This is the privacy and cookie policy for http://www.neilbarrett.com, the e-commerce website (“Site”) of White S.r.l., VAT number 06226750963, whose registered office is at Via Ceresio, 7 – 20154 Milan (Italy) (“we", "us" and "our”) for the sale and purchase of our products. For the purposes of EU Regulation 2016/679, and any applicable national implementing legislation (GDPR), we are the data controller.

We are committed to protecting your privacy on-line and here we explain how we collect data, what we do with it and which rights you can exercise. 

You acknowledge that, after your use of the Site, we will collect and use your data in accordance with this privacy policy.

We reserve the right to change this privacy policy from time to time by publishing the changes on the Site. In case of amendments which might have a significant impact on the nature of the processing or otherwise have a substantial impact on you, we will provide you with prior notice by means of a pop-up on the Site before the revised version of the privacy policy becomes effective.

Data we may collect from you

We may collect and process the following data about you:

  • data (such as your name, email address, postal address and telephone number) that you provide by completing forms on the Site, including if you register as a user of the Site, subscribe to any service, upload or submit any material via the Site, request any information, or enter into any competition or promotion we may arrange;
  • data in connection with an account sign-in facility, such as your log-in and password details;
  • details of any transactions made by you through the Site;
  • communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Site or its content; and
  • data from surveys that we may, from time to time, run on the Site for research purposes, if you choose to respond to, or participate in, them.
  • You are under no obligation to provide any such data. However, if you should choose to withhold requested data, we may not be able to provide you with certain services.

We may, from time to time, run referral programmes or similar initiatives, such as a "Tell a Friend" programme, that invite you to provide us with the contact details of someone who is known to you who may find our products or services to be of interest. We will only use those contact details for the purpose of the relevant initiative (and not for general marketing purposes). By providing us with their details, you confirm that you have their permission to do so, and undertake to make them available this Privacy and Cookie Policy on our behalf. You must not provide us with the personal details of anyone from whom you do not have such permission. We reserve the right to identify you as the person who has made the referral in the message that is sent to them.

When you visit the Site, we may automatically collect additional data about you, such as the type of internet browser you use, any website from which you have come to the Site and your IP address (the unique address which identifies your computer on the internet) which is automatically recognised by our web server. You cannot be directly identified from this data and it is only used to assist us in providing an effective service on the Site and to collect broad demographic information for aggregate use.

Cookies

We use technology such as "cookies" to collect data and store your online preferences. Cookies are small pieces of information sent by a web server to a web browser, which allows the server to uniquely identify the browser on each page.

We use the following categories of cookies on our Site.

  • CATEGORY 1: NECESSARY COOKIES
    These cookies are essential in order to enable you to navigate the Site and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided.
     
  • CATEGORY 2: PERFORMANCE COOKIES
    These cookies collect anonymous data on how people use our Site. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies never contain personal details from which your individual identity can be established.
     
  • CATEGORY 3: FUNCTIONALITY COOKIES
    These cookies remember choices you make such as the country you visit our Site from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The data these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
     
  • CATEGORY 4: TARGETING COOKIES OR ADVERTISING COOKIES
    These cookies collect data about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, we use third party companies such as Criteo to provide you with more personalised adverts when visiting other websites.
     
  • CATEGORY 5: SOCIAL MEDIA COOKIES
    These cookies allow you to share what you’ve been doing on the Site on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work.

If you want to delete any cookies on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.

Information on deleting or controlling cookies is available at www.AboutCookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.

To opt out of being tracked by Google Analytics across all websites visit Google Analytics Opt-out Browser Add-on.

If you'd like to opt out of other third party cookies relating to behavioural advertising, please go to www.youronlinechoices.eu. Opting out does not mean you will no longer receive online advertising. It does mean that the websites from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

Uses made of your data and legal basis for the processing

We will use the data you provide upon the following legal basis, and for the following purposes:

  • when the processing is necessary to carry out our contractual obligations, in particular to:

- enable us to process your orders and to provide you with the services
  and information offered through the Site and which you request;

- administer your account with us;

- identify visitors to the Site;

  • when the processing is necessary under the law, for instance to verify and carry out financial transactions in relation to payments you make online, to comply with any applicable law, or the requests of the competent authorities;
     
  •  on the basis of our legitimate interest, for instance to:

- audit the downloading of data from the Site;

- improve the layout and/or content of the pages of the Site and
  customise them for users;

- carry out research on our users' demographics and tracking of sales
   data;

- in the event that we undergo re-organisation or are sold to a third
  party, in order to smoothly manage the transfer.

  • on the basis of your consent: 

You can choose not to provide your consent for receiving communications regarding our products and services when such data is collected on the Site. Where you do not wish us to continue to use your data for these purposes, you shall follow the unsubscribe instructions on any communications sent to you. You can also exercise the opt-out right at any time by contacting us using the Contacting us details at the end of this privacy policy.

You can choose not to provide your consent for receiving communications regarding our products and services when such data is collected on the Site. Where you do not wish us to continue to use your data for these purposes, you shall follow the unsubscribe instructions on any communications sent to you. You can also exercise the opt-out right at any time by contacting us using the Contacting us details at the end of this privacy policy.

Recipients or categories of recipients of the personal data

We may disclose aggregate statistics about visitors to the Site, customers and sales in order to describe our services to prospective partners, advertisers, sponsors and other reliable third parties and for other lawful purposes, but these statistics will include no personally identifiable information.

We may disclose your personal data to any of our affiliates, or to our agents or contractors who assist us in providing the services we offer through the Site, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks, from time to time.

We have subcontracted the operation of certain aspects of the Site to Farfetch UK Limited (company number 06400760, VAT number GB 204 0769 35, registered in England and Wales and with registered office at The Bower, 211 Old Street, London, EC1V 9NR, UK) and Farfetch.com US LLC (company number 10994099, registered in the United States and with registered office at East 7th Street, Suite A-250 Los Angeles, California, 90023) (both “Farfetch”). Services provided or procured by Farfetch include, but are not limited to, payment processing, customer service, hosting and delivery logistics. Our agents and contractors will only use your information to the extent necessary to perform their functions.

We may share your data with other companies and organisations for identity verification and fraud protection purposes to the extent permitted by applicable laws. In particular, when you make a purchase from the Site, we may make searches about you at credit reference agencies for such purposes. The agencies will record details of any search. This data may be used by other subscribers for similar purposes.

In the event that we undergo re-organisation or are sold to a third party, any personal data we hold about you necessary to the re-organisation may be transferred to that re-organised entity or third party.

We may disclose your personal data if required to do so by law or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect the Site or the rights, property or personal safety of any person.

Public forums

The Site may, from time to time, make chat rooms, message boards, news groups and/or other public forums available to its users. Any information that is disclosed in these areas becomes public information and you should exercise caution when using these public forums and never disclose your personal data.

External links

The Site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

Payment processing

Payment details you provide will be encrypted using secure sockets layer (SSL) technology before they are submitted to us over the internet. Payments made on the Site are sometimes made through our payment gateway provider. You will be providing credit or debit card information or any other payment information directly to such payment provider which operates a secure server to process payment details, encrypting your credit/debit card information or any other payment information and authorising the payment. Information which you supply to such payment providers is not within our control and will be subject to their own privacy policy and terms and conditions. For more information please contact us.

Security

We place great importance on the security of all personally identifiable information associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal data under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal data. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.

You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of data you submit via the Site whilst it is in transit over the internet and any such submission is at your own risk.

It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal data if you use a shared computer or a computer in a public place.

Storage of your data

We will keep your personal data as long as we have a relationship with you and, following the deletion of your account, or your last purchase, for the time necessary to be able to manage possible requests or claim regarding the products purchased by you. We may also retain your data for a longer period, when requested by applicable law.

International data transfers

Your personal data may be transferred to, and stored at a destination outside of the European Economic Area including the US. The US and other non-EEA countries do not have similar data protection laws to the EEA, and you should be aware in particular that the law and practice in the United States in respect of law enforcement authority access to data is significantly different from Europe.  Where we transfer your data we will take all reasonable steps to ensure that your rights regarding the protection of personal data continue to be safeguarded consistent with our obligations under applicable law, for instance by ensuring that the EU Commission issued an adequacy decision with respect to the country of the exporter, or by entering into with the exporter the Model Clauses drafted by the EU Commission. For more information on the transfers we might carry out, and the guarantees in place, please contact us at the contacts indicated below.

Your rights

You have certain rights regarding your personal data. These include the following rights to:

  • access your personal data;
  • rectify the information we hold about you;
  • subject to specific requirements, erase your personal information, or restrict our use of your personal information, or object to our use of your personal information, when the processing is based on our legitimate interest;
  • withdraw the consent at any time to our processing for marketing purposes, without affecting the lawfulness of processing based on consent before its withdrawal;
  • receive your personal data in a structured and commonly used and machine-readable format and transmit it to a third party (right to data portability);
  • lodge a complaint with your supervisory authority.

If you would like to discuss or exercise such rights, or you need any information in this respect, please contact us at the details below. We encourage you to contact us to update or rectify your data if it changes or if the personal data we hold about you is inaccurate. We will contact you if we need additional information from you in order to honour your requests.

Contacting us

Please submit any questions, concerns or comments you have about this privacy policy or any requests concerning your personal data by email to customercare@neilbarrett.com, by telephone on 1 518 – 351 – 2667  (US) or 44 (0) 20 3962 0747 (UK) between 9am and 5pm (GMT), Monday to Friday or write to us at:

White S.r.l.
Via Ceresio, 7
20154 Milan (Italy)

This Privacy and Cookie Policy will be effective from 19th September 2018.

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