Please read this privacy policy (“Privacy Policy”) carefully to understand our policies and business practices regarding your Personal Data and how it will be processed by us. By using the website, you agree to this Privacy Policy. If you do not agree to this Policy or if you fail to provide us with the necessary Personal Data (we will indicate when this is necessary, for example, by making such request explicit in our registration forms), (a) you will not be able to use our Internet sites and (b) we may not provide you with our goods and/or services. This Policy may change from time to time (see Section 10). By continuing to interact with us after changes to the Policy have been implemented is tantamount to accepting those changes, so please check the Policy periodically for updates. This Privacy Policy provides important information in the following areas: Scope of this Privacy Policy. This Privacy Policy explains how your Personal Data is collected, used and disclosed by the Unico Relais Srl entities listed in the section on data controllers and contact information (Section 11) (“Unico Relais Srl “, “We”, “Us”). The Notice also informs you how you can access and update your Personal Data and make certain choices about the way we use your Personal Data. This Notice governs our online and offline data collection activities, including the Personal Data we collect through our various channels such as websites, social networks, point of sale and events. Please note that the Personal Data we collect through one method (e.g., the website) is combined with the Personal Data we collect through another method (e.g., an offline Unico Relais Srl event ). In this regard, we may combine Personal Data that was originally collected by different Unico Relais Srl entities. Please see Section 8 for more information on how you can object to this practice.

1. Sources of Personal Data.

This Privacy Policy applies to Personal Data that we collect from or about you, through the methods described below (see Section 2), from the following sources: website, email, text messages or other electronic messages. Electronic communications between you and Unico Relais Srl , Stores operated by Unico Relais Srl. Offline registration forms. Registration and other similar printed forms that we collect for example through ordinary correspondence, in-store display booths, contests, and other promotions or events. Data from other sources. Social networks, publicly available information.

2. Personal data we collect about you and how we collect it

Depending on how you interact with Unico Relais Srl (online, offline, over the phone, etc.), we collect various types of information from you in the ways described below. Personal Contact Information. This information includes any information you provide us that will allow us to contact you, such as your name, mailing address, email address, social network details, or telephone number. Account Access Information. Any information necessary to provide you with access to your specific account profile. For example, your login ID/email address, username, unrecoverable type passwords, and/or security questions and answers. Demographic Information. Any information that describes your demographic or behavioral characteristics. For example, your date of birth, age or age range, gender, geographic location (e.g., zip code), favorite products, hobbies and interests, and household or lifestyle information.

Technical information about your computer/mobile device. Any information about the computer system or other technological device you use to access one of our Internet sites, such as the IP address used to connect your computer or device to the Internet, the type of operating system, Internet browser type and version. If you access a Internet site via a mobile device such as a smartphone, the information collected will also include, where permitted, your mobile device’s unique identifier, advertising ID, geolocation, and other similar mobile device data.

Internet site usage/communication information. When you browse and interact on our Internet sites, we use automatic data collection technologies to collect certain information about your actions. This includes information regarding which links you clicked on, what pages or content you viewed and for how long, and other similar information and statistics regarding your interactions, response times to content, download errors, and length of visits to certain pages. This information is collected using automated technologies such as cookies (browser cookies, flash cookies) and web beacons, and is also collected using third-party tracking services (such as Double Click, Google Analytics, Adobe Dynamic Tag Management and/or Omniture). You have the right to object to the use of these technologies, for more details please see Section

Consumer Feedback. These include information about your experience using our products and services that you voluntarily share with us.

Consumer Generated Content. This refers to any content that you create and subsequently share with us on a social network or by uploading it to one of our websites, including the use of network applications such as Facebook. This for example includes photos, videos, personal stories, or other similar media or content. Where permitted, we collect and post customer-generated content in connection with a variety of activities, including contests and other promotions, from community functions of Internet sites, user participation, and third-party social events.

Social networking information. This refers to any information that you share publicly on a social network or information that is part of your profile on a third-party social network (such as Facebook) and that you allow the third-party social network to share it with us. Examples include basic account information (e.g., name, email address, gender, date of birth, city of residence, profile photo, user ID, friend list, etc.) and any other information or activity that you allow the third-party social network to share. We receive your social network profile information (or parts of this information) each time you download or interact with a Internet application on a social network such as Facebook, each time you use a feature integrated with a Internet site (such as Facebook Connect) or each time you interact with us through a social network. To learn more about how your information is obtained by a third-party social network from Unico Relais Srl, or to stop sharing such social network information, please visit the website of the social network in question.

3. Cookies/similar technologies, log files and web beacons

Cookies/similar technologies. Please see our Cookie Policy to find out how you can manage your cookie settings and to get detailed information about the cookies we use and why we use them.

Log Files. We collect information in the form of log files that record your activities on the Internet site and collect statistical information about your browsing habits. These records are generated automatically, and help us to eliminate errors, improve performance, and ensure the security of our Internet Sites.

Web beacons. Web beacons (also known as “web bugs”) are small strings of code that produce a graphic image on an Internet page or in an email for the purpose of relaying data back to us. Information collected through web beacons could include technical information such as your IP address, as well as information about how you respond to an email campaign (e.g. at what time the email was opened, which links contained in the email you clicked on, etc.). We may use web beacons on our Web Sites or include them in emails we send you. We use the information obtained through web beacons for a variety of purposes, including but not limited to site traffic reporting, unique visitor counts, advertising, email monitoring and reporting, and personalization.

4. Uses of Your Personal Data

The following sections describe the various purposes for which we collect and use your Personal Data, and the different types of Personal Data that are collected for each purpose. Please note that not all uses below will be relevant to each person.

Customer Support. We use Your Personal Data for customer support purposes, including answering to your questions. This usually involves the use of certain personal contact information and information related to the reason for your question (e.g., order status, technical issues, product-related questions/complaints, general questions, etc.).

Contests, marketing and other promotions. With your consent (where required), we use your Personal Data to provide you with information about goods or services (e.g., communications or marketing campaigns or promotions). This may be done through email, advertisements, text messages, phone calls or regular mail to the extent permitted by applicable laws. Some of our campaigns and promotions may appear on third-party Internet sites and/or social networks. This use of your Personal Data is voluntary, which means that you may object to the processing of your Personal Data for this purpose. For more information about our contests and other promotions, please see the rules or official details posted with each contest/promotion.

Social media. We use your Personal Data when you interact with third-party social network features, such as “Like” features to offer you advertising and engage you on our social networks. By consulting the privacy policies of the relevant third-party social networks, you can learn more about how these features operate, the profile data we obtain about you, and you can find out how to opt out.

Personalization (offline and online). With your consent (where required), we use your Personal Data (i) to analyze your preferences and habits, (ii) to anticipate your needs based on our analysis of your profile, (iii) to improve and personalize your experience on our websites and applications; to ensure that the content of our websites/applications is optimized for you and your computer or device; and (iv) to enable you to participate in interactive features when you choose to participate. For example, we remember your login ID/email address or username so that you can immediately log in the next time you visit our Internet site. Based on this type of information, and with your consent (where required), we show you specific Unico Relais Srl content or promotions tailored to your interests. The use of your Personal Data is voluntary, which means that you may object to the processing of your Personal Data for this purpose. For detailed information on how to opt out, please refer to the Section below

Other General Purposes (e.g. internal research, analytics, security). Subject to applicable laws, we use your Personal Data for other general business purposes, such as conducting internal demographic and marketing studies, measuring the effectiveness of advertising campaigns. We reserve the right, where you have multiple Club Member accounts, to reconcile these accounts into a single account. We also use your Personal Data to ensure our security. Legal reasons or merger/acquisition. In the event that Unico Relais Srl or its assets is/are acquired by, or merged with, another company including by bankruptcy, we may share Your Personal Data with any of our legal successors. We may also disclose Your Personal Data to third parties (i) when required to do so by applicable law; (ii) to respond to legal process; (iii) to respond to a request from an appropriate law enforcement agency; (iv) to protect our rights, privacy, safety or property, or the public; or (v) to enforce the terms of any contract or the terms of our Website.

5. Disclosure of Your Personal Data

We share your Personal Data with the following types of third party organizations: Service Providers. These are external companies that we use to help us run our business (e.g., order fulfillment, payment processing, fraud detection and identity verification, debt collection, website operation, support services, promotions, website development, data analysis, etc.). Service providers, and their selected personnel, are only permitted to access and use your Personal Data on our behalf and for the specific tasks they have been requested to perform, based on our instructions, and are obligated to ensure the confidentiality and security of your Personal Data. Where required by applicable law, you will be able to obtain a list of the suppliers that process your Personal Data.

Third-party companies that use Personal Data for their own marketing purposes. Except for situations where you have given your consent, we do not license or sell Your Personal Data to third party companies for their own marketing purposes.

Third-party recipients using Personal Data for legal or merger/acquisition purposes. We will disclose Your Personal Data to third-parties for legal reasons or in the context of an acquisition or merger (see Section 4 for more details).

6. Preservation of Your Personal Data

In compliance with applicable laws, we will use Your Personal Data for as long as necessary to fulfill the purpose for which Your Personal Data was collected (as described in Section 4 above) or to meet applicable legal requirements. Personal Data used to provide you with a personalized experience (see Section 4 above for more information) will be retained for as long as permitted by applicable laws.

Disclosure, storage and/or transfer of your Personal Data. We use a variety of reasonable measures (described below) to ensure the confidentiality and security of Your Personal Data. However, please note that these protections do not apply to information that you have chosen to share in public areas such as social networks. People Who May Access Your Personal Data. Your Personal Data will be processed by our authorized personnel on a need-to-know basis, depending on the specific purposes for which your Personal Data was collected (e.g., our personnel responsible for matters concerning customer care will have access to your customer profile). Measures taken in operational environments. We store your Personal Data in an operational environment that uses reasonable security measures to prevent unauthorized access. To protect Personal Data, we observe reasonable standards. Transmission of information over the Internet is unfortunately not completely secure, and although we will do our best to protect Your Personal Information, we cannot guarantee the security of the data during transmission through our Internet sites/applications. Measures we expect you to put in place. It is important that you also play a role in keeping your Personal Information safe and secure. When you join an online account, please choose a password for the account that is difficult to guess and never reveal your password to anyone. You must ensure the confidentiality of this password and any use you make of your account. If you use a shared or public computer, never choose to remember your login ID/email address or password and be sure to log out of your account each time you leave the computer. You should also use any security settings or controls that we may provide to you on our website/application.

Transfer of Your Personal Data. The storage and processing of Your Personal Data described above may ultimately require the transfer/transmission of Your Personal Data to, and/or storage at, a destination outside of Your country of residence, likely Switzerland and Luxembourg. Where permitted by law, by agreeing to the terms of this Privacy Policy, you consent to such transfer, transmission, storage and/or processing. You also agree that such activities may take place in countries that offer a lower level of data protection than your country of residence.

Access to your personal data

Access to Your Personal Data. Where permitted by law, you, your successors, representatives, and/or proxies have the right to access, review, and request a physical or electronic copy of information maintained about you. You may also have the right to request information about the source of your Personal Data. Please note that any identifying information you provide to us will only be processed in accordance with and to the extent permitted by applicable laws. Modification and Deletion of Personal Data. Where required by law, you, your successors, representatives, and/or proxies may (i) request the deletion, correction, or revision of your Personal Data; (ii) object to the processing of your data; (iii) restrict the use and disclosure of your Personal Data; and (iv) withdraw consent to all of our data processing activities. Please note that, in certain circumstances, we may not be able to delete your Personal Data without deleting your user account at the same time. We may be required to retain some of your Personal Data after you request deletion in order to meet our legal or contractual obligations. We may also be authorized by applicable laws to retain some of Your Personal Data to meet our business needs. Please note that any identifying information you provide to us will only be processed in accordance with and to the extent permitted by applicable laws.

Your choices on how we use and disclose your Personal Data.

We put forth all necessary efforts to offer you choices regarding the Personal Data you provide to us. The following mechanisms give you the following control over your Personal Data: Cookies/similar technologies. You can set your browser to reject all or some browser cookies, or to alert you when cookies are used. Please see Section 3 above.

Advertising, marketing and promotions. If you would like your Personal Data to be used by Unico Relais Srl to promote its products or services, you may indicate such willingness by checking the relevant box(es) located on the registration form or by answering the question(s) submitted by our Sales Demonstrators, or boutique representatives. If you decide you no longer wish to receive such communications, you may unsubscribe from receiving marketing communications at any time by following the instructions provided in each such communication. To withdraw from marketing communications sent by any means, including third-party social networks, you may withdraw at any time by accessing the websites/applications and changing your user settings on your account profile, unchecking the relevant boxes. Please note that even if you were to withdraw from receiving marketing communications, you may continue to receive administrative communications from us, as well as confirmations of orders or other transactions, notifications regarding activity with your account (account confirmation, password changes, etc.), and other important announcements.

Personalization (offline and online): Where required by law, if you wish for Your Personal Data to be used by Unico Relais Srl to provide you with a personalized experience, you may indicate this wish by checking the relevant box(es) located on the registration form or by answering the question(s) submitted by our Sales Demonstrators, boutique representatives. If you decide you no longer wish to benefit from this, you may withdraw at any time by logging into the websites/applications and changing your user preferences on your account profile by unchecking the relevant boxes.

Interest-based advertising. We may partner with advertising networks and other advertising service providers (“Advertising Providers”) who provide advertising on our behalf and other unaffiliated companies on the Internet. Some of these advertisements may be tailored to your interests based on information collected over time on or non-affiliated Internet sites.

Changes to our privacy policy. If we change the way we handle your Personal Data, we will update this Privacy Policy. We reserve the right to make changes to our business practices and this Privacy Policy at any time, please check back frequently for updates or changes to our Privacy Policy.

Data Processors and Contact Information. To ask questions or make comments about this Privacy Policy and our privacy-related business practices or to file a complaint regarding our compliance with applicable privacy laws, please contact us at: Unico Relais Srl Corso Umberto I, No. 22 – 80138 Naples or by calling +39 3337544925.

We will acknowledge and investigate any complaint regarding the way we handle Personal Data (including a complaint about our violation of your rights under applicable privacy laws).


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