This privacy policy (the "Privacy Policy") applies to the website (the "Website") and refers to the personal data processing activities performed by Seven for all Mankind International SAGL (“7FAM”), who owns and operates the Website. The user's personal data will be processed by 7FAM when the user visits the Website and when the user interacts with the services and functionalities offered by the Website. The Privacy Policy specifies the identity of the data Controller that controls and manages the personal data collected and processed through the Website, specifies what is the personal information collected, the data processing purposes and conditions, the extent of personal data communication to third parties, the data security measures adopted in order to protect and safeguard data and the ways in which the user may verify the processing of data relating to the user and enforce the user's rights as acknowledged under the Privacy Law.

The Data Controller and the Controller's Privacy Representative

The Controller of the personal data processing is: Seven for all Mankind International SAGL (7FAM),via Penate 4, 6850 Mendrisio, Switzerland Seven for all Mankind Netherlands BV is acting as Privacy Representative of 7FAM in Europe. The updated list of Processors and addresses of data communications is at your disposal at 7FAM. Other companies of the 7FAM group may be involved in the processing relating to the activities that may be performed on the Website (for example for accounting activities in case of purchase of products, for personnel selection activities) as specified in the Privacy Policy; they will act according to applicable privacy laws for the purposes herein specified.

What Kind of Data are processed; what are the purposes of the data processing

In general, the visit and consultation of the Website does not imply collection and processing of the user's personal data.

Information for the maintenance and Improvement of our Website and Services

The processing of the user's personal data who visits and consults the Website is limited to the sonamed surfing data, namely the data whose transmission to the Website is implicit in the functioning of the information systems in charge of the managing of the Website and in the use of 2 communications protocols peculiar to the Internet. Surfing data are, for example, the IP addresses or the domain names of the computers employed by the user who connects to the Website and other parameters relating to the type and the information operating system employed by the user. Surfing data, such as these above specified and for example the number of visits, the time spent on the Website are collected and processed by 7FAM exclusively for statistical purposes and in anonymous form in relation to the access and use of the Website for purposes of monitoring the correct functioning of the Website and enhancing the Website functioning and content. Due to the nature itself of surfing data, these data may lead to identification of the users if they are associated with data held by third parties; however, 7FAM does not collect surfing data in order to associate them with identified the users. Surfing data are deleted after the processing in anonymous form; said data may be used for purposes of assessing possible responsibilities in case of information crimes realized against the Website or through the Website. With the exception of the aforementioned circumstance, 7FAM keeps the user's surfing data only for the maximum period of time allowed under applicable laws and then makes said data anonymous.

Information for Processing Your Purchases and for Customer Support and Inquiries

Furthermore, 7FAM collects and processes personal data voluntarily provided by the user when the user interacts with the Website functionalities and requests the services offered by the Website, for example upon the user's subscription to the Website; the user's subscription to the newsletter or mailing list; the user's purchase of products through the Website, which includes all activities relating to the purchase of goods, such as for example delivery of goods, billing issues, returning and exchanging of goods, receiving refunds, purchase and use of gift cards and e-gift cards, as applicable, payment related activities, including fraud prevention, and customer support and interaction with our call centre; the user's participation in promotions and other initiatives realised through the Website such as for example competitions and sweepstakes, the user requests information from 7FAM or the user sending 7FAM a question, communication or feedback through traditional mail or through the Website. We will process the user's personal data to comply with laws, regulations and Community legislation, and to assess and defend a legal right. We may process the user's personal data also when the user contacts our customer support and call centre, which may communicate with the user and thus process the user's personal data through email, chat and telephone. The user may finalise the purchase of our products through telephone by contacting our call centre, following the procedure specified in our Terms and Conditions of Sale. For the processing of your personal data when you make a purchase on our Website, please see our relevant privacy Statement. The call centre will assist the user in closing transactions over the phone and processing the user's order on the user's behalf and for said purpose it will collect the user's personal data and credit card details. The call centre will also register the user's phone number for the purpose of call-back and back-office services in order to provide the user with the requested support and information. Marketing, statistical and profiling activities as above specified 3 may also be performed by the call centre, with the user's consent. In some cases, for purposes of internal training, quality control and verification, the call may be recorded and the emails may be saved to the extent not prohibited by applicable laws. The user will always be informed in advance of the recording of the communication, and the user will have the opportunity to object to such recording, save when this is necessary for verification purposes in relation to your purchase or other reasons, as allowed under applicable laws.

Information for Marketing and Promotional Purposes

With the user's consent, which is optional, 7FAM may further process the user's personal data for survey purposes and for marketing purposes, that is for sending the user, through email or other electronic communications such as SMS, MMS, fax, etc., promotional information and material on products and services of the 7FAM group, on special initiatives on prices and promotions of the 7FAM group and on initiatives such as events, exhibitions and fairs organized by the 7FAM group or to which the 7FAM group takes part; and for profiling purposes. For the marketing and profiling activities above defined the user's personal data may also be shared with other 7FAM companies. The user will always have the opportunity to object, at any time and for free, to the processing of his/her personal data for the sending of promotional information and material; in each communication there will be a specific section in which are specified the conditions (easy to perform and free of charge) of revoking the consent. Personal data that 7FAM collects and processes includes name and contact details such as street address, telephone number, email address and further possible information of an optional nature provided by the user. In the relevant sections of the Website where data is collected a specific information statement is provided. When requested under the Privacy Law, 7FAM requires the the user's consent before proceeding to process his/her personal data. Where you have provided us with personal data about another person, (for example when using the function email a friend, gift card functionalities or other purposes) to the extent permitted by applicable laws you hereby confirm that said communication and further processing by us as set out in this Privacy Policy complies with applicable privacy laws, so for example you should inform said person and as requested obtain his/her consent to the processing of his/her personal data for the purposes set out in this Privacy Policy.

Cookies, pixels and web beacons

This website may also collect cookies, pixels and web beacons subject to our Cookie Policy. You can always change your cookie preferences using your web browser and the instructions in the Cookie Policy.

Legal Basis for processing

Our collection and processing of personal information is based on the following:
(a) need to carry out the above processing of information, which is in anticipation of entering into commercial engagements or as part of the performance of existing engagements with you, for example for providing you the goods and items that you ordered through our website.
(b) To the extent that we use the personal information for advertising or promotional activities, including direct mailing and targeted advertising, we will request your specific, freelygiven, unbundled, informed and separate consent to such uses.
(c) To the extent that we use the personal information to improve this website or for analyzing statistics, the basis for collection of data is our legitimate interest to conduct such improvements and analysis.

Places where your data is stored

Personal data collected through the Website will be controlled and processed by 7FAM. 7FAM uses third party service providers and sub-processors for the purposes set forth in this Privacy Policy. the company Rackspace Ltd provides for 7FAM hosting services for the web site and related database. 7FAM Europe BVBA acts as Privacy Representative of 7FAM in Europe. The updated list of Processors and addresses of data communications is at your disposal at 7FAM. Personal data is processed only through specifically authorised staff designated to access and process the data, including staff designated for performance of non-routine maintenance operations of the Website. Furthermore, other companies of the 7FAM group are involved in the processing of personal data in relation to the functioning of the Website and performance of the services and functionalities offered through the Website, for example in relation to purchase of products, customer support and call centre activities, and also for marketing and profiling activities as above specified. The user is invited to check the section of this Privacy Policy relating to Extent of personal data communication. All processors are acting on behalf and under the instructions of 7FAM.

Condition and Features of the Personal Data Processing

Personal data collected by 7FAM is mainly processed through electronic and automated means but also without the same (paper processing), under procedures and logics that comply with the data processing purposes as herein specified. Personal data of the user is processed according to applicable privacy laws, including security and confidentiality issues, and are kept only for the time strictly functional to achieve the specific data processing purpose from time to time pursued and according to applicable laws.

Security and Quality of Personal Data

7FAM is committed to protect the security of the the user's personal data. Personal data is processed by 7FAM in compliance with the security provisions as set forth by applicable laws in order to prevent loss and destruction, even accidental, of data, unauthorised access to data, unlawful or unfair use of data. Moreover, information systems and software programs are configured so that personal and identification data is used only when necessary to achieve the specific processing purpose from time to time sought. 7FAM deploys a variety of advanced security technologies and procedures to help protection of the user's personal data against the risks outlined above. For example, personal data provided by the user is stored on secured servers placed in controlled locations. Moreover, for the transmission of some data through the Internet are deployed encryption techniques such as Secure Socket Layer (SSL) protocol. The user may help 7FAM to update and maintain accuracy of the personal data provided by the user to 7FAM by notifying 7FAM of any amendment relating to the user's address, title, telephone number or electronic mail (email) address. Registered users may perform the foregoing online following the instructions reported on relevant user profile pages of the Website.

Extent of Personal Data communication

7FAM communicates the user's personal data within the limits and under the circumstances specified in this Privacy Policy and in the information statement published on the Website in the sections where data is collected, in any case in full compliance with the consent given by the the user upon collection of data, when required by the Privacy Law. The user's personal data will be accessible within 7FAM organisation by internal and external personnel that need to access them because of their duties in relation to the processing purposes herein specified, our Processors if appointed and by our European Privacy Representative Seven for all Mankind Netherlands BV. The updated list of Processors and of the subjects to which data may be communicated will remain at the user's disposal free of charge upon request from 7FAM.

The user's personal data may be communicated to institutions, authorities, public entities, banks and financial institutions, professionals, independent consultants, also in associate form, business partners and third party service providers to which 7FAM may revert to for performance of professional, technical and organizational services functional to the managing of the Website and the activities therein performed, such as for example the sales of goods and related activities, the managing of functionalities offered by the Website and of the initiatives and services that the user may subscribe to and require through the Website, and for services strictly functional to achievement of the other processing purposes herein specified. For purposes functional to the managing of the Website and related activities, for example for the purchase of goods through the Website or by telephone through our call centre, the user's personal data may be also communicated to other companies of the 7FAM group, that will process them according to applicable privacy laws for the purposes above specified, including marketing and profiling activities. With specific reference to the purchase of goods, data will be processed by the relevant local 7FAM entity established in the place where delivery has to take place, acting as controller of your personal data in accordance with applicable privacy laws, for the following purposes: billing issues, despatch of goods, returning and exchanging of goods, receiving refunds, purchase and use of gift cards and e-gift cards as applicable, payment related activities, including fraud prevention. Moreover, for closing transactions and payment processing we revert to third party service providers for managing and support of the e-commerce platform. These service providers are bound by contractual obligations so that they will implement adequate security measures to protect security and confidentiality of the user's personal data and credit card information. The third parties receiving the user's personal data as above specified will process data as Data Controllers, for example 7FAM local entities, or Processors for example third party services providers, as the case may be, according to applicable data protection laws and for the same purposes above specified. Personal data may also be communicated to third parties in case of mergers, acquisitions and transfer of any of our assets, products, websites or operations. These third parties will be provided only with the information necessary to perform their respective functions; they agree to use the information received only for the processing purposes above specified, to keep it confidential and secure and to comply with applicable law and the instructions received by 7FAM.

For the above purposes, personal information may be transferred to recipients in countries around the world (which may be located outside the EU/EEA, European Economic Area) which in some cases may have a lower level of protection than that within the EU/EEA. When transferring personal data to countries outside the EU/EEA, to jurisdictions that did not receive an adequacy decision by the European Commission, we use standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your personal information. The standard contractual clauses can be found via the following link: international-transfers/transfer/index_en.htm.

Except for the foregoing, the user's personal data will not be shared with third parties, natural persons or legal entities that are unrelated to, or that do not perform a business, professional or technical function for 7FAM. The user's personal data may further be communicated to whoever is the legitimate addressee of communications as provided by applicable laws and regulations, thus for example in case of judicial processes, request by competent courts and authorities or other legal obligation, to protect and defend the rights and property of 7FAM and the Website. The user's personal data will not be communicated to third parties for their own marketing purposes and will under no circumstance be spread.

Data Retention

7FAM stores the personal information as long as it is necessary to fulfil the purpose for which the data has been collected. This means that 7FAM deletes your personal information when such information is no longer necessary, unless we have a legitimate interest to retain such data for longer periods or are required to do so by any applicable law. Statistics which has been anonymised may be saved thereafter.

The Users's Privacy Rights

The user is entitled at any moment to enforce their rights as provided by applicable privacy laws, including but not limited to the right to obtain at any moment confirmation that the user's personal data exists or does not exist, verify their content, origin and accuracy, ask for their integration, updating, amendment, deletion and the user may oppose for legitimate reasons the data processing (including objecting, at any time and for free, to the processing of his personal data for direct marketing purposes). 8 For any queries or requests relating to the personal data processing by 7FAM and to enforce their rights under the Privacy Law, the user may contact Seven for all Mankind International SAGL (7FAM), via Penate 4, 6850 Mendrisio, Switzerland by clicking on contact us This Privacy Policy is subject to updating and amendment by 7FAM. The version published on the Website is the version actually in force. If 7FAM changes this Privacy Policy, 7FAM will notify the user of such changes by posting a link on the home page of the Website to the amended privacy policy that reads "Newly Revised Privacy Policy". 7FAM invites the user to periodically review the Privacy Policy in order to be informed of any relevant change. If you are a resident of the EU/EEA, and have a complaint regarding the processing of your personal data by 7FAM you are entitled to report such dissatisfaction to the applicable supervisory authority in your country of residence. The Effective Date of this Privacy Policy is: May 25, 2018

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