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PRIVACY POLICY

 

Welcome to the Reebok website (the “Website”).

 

Please carefully read this Privacy Policy, which applies whenever you access the Website, regardless of whether you purchase the products sold on it. Please also read the General Terms and Conditions of Use, since they contain important information on the Website. 

 

Please note that this Privacy Policy is governed by European Regulation no. 2016/679 (the "Regulation”) together with the reformulated Legislative Decree 196/03 (together, the “Privacy Laws”). The Privacy Laws guarantees that the processing of personal data (i.e. any information relating to an identified or, even indirectly, identifiable physical person) will be carried out in compliance with fundamental rights and freedoms, as well with respect for the dignity of the data subject, with particular reference to confidentiality, personal identification and the right to personal data protection.

  1. DATA CONTROLLER

Please note that the data controller is the entity that determines the purposes and modalities of the processing of personal data, in accordance with the Regulation.

 

The Data Controller of the processing of personal data related to the Website is NGG Beta S.r.l., with registered offices in Via Turati 12, 20121 Milano (hereinafter “NGG Beta” or “Data Controller”)

 

Please also note that the Data Controller has outsourced some activities - related, in particular, to the website performance - to Farfetch Platform Solutions Ltd, which has been appointed as the data processor.

 

  1. TYPE AND PURPOSE OF PROCESSING PERFORMED ON THE WEBSITE

Through the Website, different types of personal data are collected and processed, for the purposes below indicate:

 

 

  1. personal data related to browsing, which is processed both for the purpose of allowing the Website to function properly and for marketing purposes. To this end, please read the “Cookie Policy”;

 

  1. personal data (such as, e-mail address, personal information, contact details, password) for the account registration and to access to the personal account, or used to manage the same and to use all the services associated with it (such as the storage of delivery information and purchases made, to allow easier management of returns, re-orders, and post-purchase activities);

 

  1. personal data (i.e. personal information, contact details, purchase data and data related to the specific requests) addressed to the customer care and/or provided via telephone call to the customer care (it should be noted, in this regard, that upon consent given by the user at the beginning of the phone call, the call will be recorded to enable the NGG Beta to monitor its service offered to customers) or by e-mail, and processed by the Data Controller to respond to the user's requests and to offer the requested services, assistance and information regarding products and the NGG Beta world;

 

  1. personal data (i.e. personal details, size, delivery and contact details, payment preferences and data related to specific pre e post sale requests) as part of the processes of online purchase of products (and relevant interactions for activities necessary for the sale, as well as for any pre- and after-sales activities and assistance, and related services, as well as activities related to return rights, statutory and contractual guarantees and products assistance);

 

  1. personal data (i.e. personal information and contact details) processed for marketing purposes (i.e. information and updates on products, sales, promotional campaigns, events and other initiatives promoted by NGG Beta, using traditional tools as post and telephone calls and by means of telematics, such as newsletters, e-mails, text messages, MMS and smart messages). Said commercial messages also include messages suggesting purchases on hold to be completed (reminders on products viewed and abandoned carts), as well as activities and messages aimed at verifying customer satisfaction and the quality of service provided to them by NGG Beta;

 

  1. personal data (i.e. data related to the purchases and preferences sok thowed by the users) processed for the purpose of studying shopping habits and choices in order to make products and initiatives more responsive to the tastes and needs of its customers and to offer each individual customer the products and experiences most relevant to their preferences;

 

  1. personal data (i.e. identification data, payment data, localization, sales, browsing activities) processed for the prevention and suppression of fraud and illegal behavior and/or contrary to current regulations, applicable contractual provision, as well as the rules of fairness and good faith. Such processing may also be carried out by third parties, such as companies specialized in the identification of online fraud, Public Authorities, Investigative Bodies, police officers and judicial authorities;

 

 

 

 

  1. LEGAL BASIS FOR THE PROCESSING 

Please note that the processing of personal data is based on the following legal basis:

 

PROFESSING REFERENCE AS PER POINT 3. ABOVE

PURPOSE/ACTIVITY

LEGAL BASIS

(a)

Use of cookies

To allow the Website to function properly (legitimate interest, where permitted by the Privacy Laws) 

 

Marketing and analysis (consent)

(b)

Registration, access and use of the user’s personal account on the Website

To provide the customer with an account creation service and related facilities (contractual)

 

For the access to the personal account using social log-in legal basis is the consent 

(c)

Customer care assistance 

To allow the company to provide the users the requested assistance (contractual/service)

 

For the recording of the phone calls the legal basis is the consent 

(d)

Sale and pre-post sale services

Fulfilment of contractual and legal obligations of the seller 

(e)

Marketing and delivery of commercial communication (including the abandoned charts messages)

Consent 

(f)

Study and analysis of the purchases and user’s preferences

Consent

(g)

Anti-fraud activities

Protection of a right (legitimate interest, where permitted by the Privacy Laws) and legal obligation

(h)

Communication of personal data to third parties for their marketing purposes

Consent

  1. SOURCE OF PERSONAL DATA

NGG Beta collects personal data directly from the user (by registration or during the purchase steps) with the exception of:

 

  • data collected with the navigation and purchase as per section 2 (a)-(f);
  • data collected and processed for the purpose of preventing fraud and malfeasance on the Website as per section 2 (g). 

 

  1. ANALYSIS OF USER'S BUYING HABITS AND SELECTIONS

As indicated in Section 2 (f) above, with the user's explicit consent, NGG Beta may also process the latter's personal data for the purposes of analysing user's buying habits and selections, in order to make the NGG Beta products, services and initiatives more responsive to its customers' tastes and needs.

 

NGG Beta will process, by automatic means the value purchased within a framework of time, the frequency of the purchases (even if the purchases are made during the sales period) and the kind of product purchased (accessories, clothes, shoes). NGG Beta will not proceed with an intrusive study of the users’ behaviour and the study is only intended to propose to clients and users products, services and initiatives more responsive to their tastes and needs.

 

Moreover, please note that as per Section 2 (a), with the user's express consent, NGG Beta can process personal data through an automatic means to study cookies in order to verify the navigation through the Website and too purpose products and services in line with the navigation.

 

  1. PERSONAL DATA PROCESSING METHODS 

The personal data collected through the Website is primarily processed using computer and electronic means, adopting security measures in order to reduce to a minimum the risks of destruction or loss, including accidental loss, of the data itself, unauthorized access or processing without consent, or processing that is not in conformity with the purposes of collection indicated in this Privacy Policy.

 

However, these measures, due to the nature of the online transmission method, cannot limit or absolutely exclude the risk of access without consent, or of dissemination of data. To that end, we recommend that you periodically verify that your computer is equipped with the appropriate software devices to protect from the transmission of incoming and outgoing data on the network (such as up-to-date antivirus systems) and that the Internet service provider has adopted suitable measures to ensure the security of data transmission on the network (such as, for example, firewalls and antispam filters).

 

Each purchase on the Website is made with the utmost security thanks to the use of the most advanced technological systems and coding (SSL).

 

  1. MANDATORY OR VOLUNTARY NATURE OF PROVIDING DATA

With the exception of the navigation data (the provision and collection of which are regulated by the Cookie Policy), the provision to NGG Beta of personal data, both for requests and queries, and for the purposes of marketing and analyzing consumer habits and preferences, is voluntary and optional. Failure to provide such data does not limit the use of the Website, although it may make it impossible for NGG Beta to respond to requests for information and queries, or to propose customized products and services, or to send informational material, updates, newsletters and invites to NGG Beta events.

The provision of the data, especially personal details, e-mail address, postal address, telephone number and bank details in case of credit card payments, is compulsory for executing, through the Website, the product purchase agreement.

 

Moreover, some of said data may be necessary for providing to the user other services made available on the Website in connection with the sales (post sales and pre-sales services such as delivery, exchange, etc.) or for discharging the obligations deriving from the law or regulatory provisions (tax obligations and antimony laundering). Any failure by the data subject to provide us with the data may therefore constitute, as the case may be, a lawful and justified reason for not performing the agreement of the products purchased on the Website and for not providing the related services.

 

The mandatory or voluntary nature of the data to be provided will be, if necessary and as the case may be, indicated by means of a special character (*) placed next to the relevant information or to the data which is necessary to provide for the purpose of performing the services and for purchasing the products on the Website. Any failure to provide those data the provision of which is voluntary, does not entail obligations or disadvantages of whatever type.

 

  1. CATEGORIES OF RECIPIENT OF PERSONAL DATA

NGG Beta will communicate personal data of the Website’s users only as permitted by the law and as indicated below. Further to what indicated in point 2(b) (namely the social log-in) and 2(h) (transfer to third parties upon consent), personal data shall be processed and disclosed to:

  • employees and consultants of NGG Beta, which will process data in their capacity of persons in charge of the processing;
  • other companies of the same Group of NGG Beta acting as data processors (i.e. entities carrying out processing in the name and on behalf of the data controller, and having been appointed for that purpose), in order to carry out contractual activities and services and to carry out specific marketing activities (such as inviting the user to local events); and
  • companies acting in their capacity of data processors (i.e. entities carrying out processing in the name and on behalf of the data controller, and having been appointed for that purpose) and providing NGG Beta with specific technical and organizational services in relation to the Website (logistics services, IT services, customer care services and marketing services).

 

Personal data may also be disclosed to:

 

  • third parties for the sole purpose of performing the purchase agreement (the financial institutions in charge of providing remote card payment services through credit/debit cards;
  • third parties specialized in the prevention of computer and online payment-related fraud in order to protect the company from unlawful acts and damages;
  • police officers and judicial authorities, in compliance with the law and upon their request, or in case there are good reasons to believe that such disclosure is reasonably necessary to (1) investigate, prevent or take initiatives in relation to suspected unlawful activities, or assist national supervisory authorities; (2) prepare a defence against third party claims or charges, protect the security of its own website and of the company; (3) exercise or protect the rights, property or security of NGG Beta, the NGG Group, their affiliates, customers, employees and third parties.

 

  1. CROSS-BORDER DATA TRANSFER

Personal data will not be disseminated and will be transferred abroad only and if adequate levels of protection and sufficient safeguards, as provided for by the law, are guaranteed. 

 

NGG Beta mainly process personal data using data centers located in EEA and UK.

 

You can always contact NGG Beta to learn more about the location of your data and the measures applied to protect it.

 

  1. STORAGE PERIOD

Personal data collected and processed by the Website will be stored for the period of time indicated here below, after which the data are technically deleted or rendered totally anonymous using means that prevents it to be recovered. 

 

PROFESSING REFERENCE AS PER POINT 3. ABOVE

PURPOSE/ACTIVITY

 

DATA RETENTION

(a)

Use of cookies

 

Please see the Cookie Policy to have a clear picture of the cookie data retention

(b)

Registration, access and use of the user’s personal account on the Website

 

The time of use and activation of the account. It will be deleted when unused for 1 year

(c)

Customer care assistance 

 

The time strictly necessary and any follow-up with the customer (records of phone calls will be kept for a maximum time of days after recording, except for specific needs for in-depth and subsequent analysis and evaluation of the phone call) 

(d)

Sale and pre-post sale services

 

Up to a maximum of 10 years to comply with Italian tax and civil laws. 

 

Moreover, the data linked to the purchase may be stored for a longer period of time in order to (i) establish or manage a legal claim and (ii) comply with the special contractual product guarantees granted to the client due to the type of goods sold by NGG Beta and relevant services to be provided.

(e)

Marketing and delivery of commercial communication (including the abandoned charts messages)

 

4 years 

(f)

Study and analysis of the purchases and user’s preferences

 

4 years

(g)

Anti-fraud activities

 

Storage for a period of 10 years, unless it is necessary to hold it for longer time due tothe handling of an individual case, investigation and possible judicial procedure.

 

  1. USER RIGHTS RECOGNIZED BY THE PRIVACY LAW

You have always the right to obtain from NGG Beta confirmation of whether or not your personal data exists, even if it is not yet recorded, and to have it communicated in an intelligible form. 

You also have the right to obtain information about the source of personal data; the purposes and methods of its processing, the logic applied in the event of processing that is performed with the aid of electronic instruments; the identification details of the data controller and data processors; and indication of the persons or categories of persons whose personal data may be communicated, or who could end up being known by, for example, data processors or agents as data supervisors or data processors. 

You have also the right to request an update, correction or, when you have an interest in doing so, an inclusion of personal data, deletion, conversion to an anonymous form or the blocking of personal data, that has been processed in violation of the law, including data which it is not necessary to keep in relation to the purposes for which it was collected or subsequently processed; a statement that the above operations were disclosed, including in terms of their content, to those parties to whom the data was communicated, except in the case in which such performance proves impossible or entails the use of methods that are clearly disproportionate to the right protected. 

You can also ask for the portability of your data. 

Moreover, you have the right to ask restriction of processing of your personal data.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

You can exercise the above rights and ask for information and raise further questions about the processing of your personal data by contacting the Data Controller, writing to privacy@reebok.eu

[…] (please note that the delivery of a request sent by e-mail entails the subsequent acquisition of the sender's address, necessary to answer to requests and to keep track of them, as well as any other personal data included in the electronic communication, for legal purposes). You can also write by mail to NGG Beta, at via Filippo Turati 12, 20121 Milano, at the attention of […].

 

Please finally note that you have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali), based in Piazza Venezia, 11, 00187 Rome (www.garanteprivacy.it), or with another data protection supervisory authority in the Country in which you reside.

 

NGG Beta S.r.l. has appointed a Data Protection Officer (DPO), who can be contacted writing to: privacy@reebok.eu

 

Last update: November 2023