Collection of personal data
PERSONAL DATA YOU PROVIDE DIRECTLY TO US
Varenna collects personal data directly from you in a variety of ways, including when you:
· Register for an account, create a profile, participate in interactive areas of our Services, or fill out forms on our Services or in our stores.
· Request additional information about our products or services or sign up to receive our e-mail newsletters, marketing messages, or coupons.
· Interact with us on social media, such as by tagging us and/or our products or permitting us to follow your social media profile.
· Purchase any product or service from us.
· Provide design or product feedback or make other submissions to us.
· Request information or assistance from us, including correspondence with our customer service team or our store associates for personalized styling.
· Participate in or respond to surveys or requests for opinions, feedback, and preferences.
· Participate in any of our experiential offerings in our stores or at other locations, sponsored by us.
· Participate in or register for our ambassador or membership programs.
· Using other features of our websites that may be offered from time to time, which may require information to utilize the features; and
· Sign up for and participate in events, contests, sweepstakes, promotions, and special programs that we provide.
The types of personal data we collect directly from you may include: your name, username, password, e-mail address, address, telephone number, credit card, and debit card numbers (with expiration dates), demographic information, personal
preferences, clothing size, and any other personal data that you choose to include in your profile or in other communications with us.
PERSONAL DATA WE COLLECT AUTOMATICALLY
We automatically collect personal data when you access and use our Services or shop in our stores. The types of information we collect may include:
· Networking and device information, such as your browser type, IP address, and operating system version, language settings.
· Information about your activity on our Services, such as your access times, pages viewed, the routes by which you access our Services, your use of any hyperlinks available within our Services.
· Information about your purchases or transactions with us, including records of products or services you have purchased, returned, or are considering purchasing from us.
· Information collected via cookies, web beacons, and other tracking technologies, including Internet service provider (ISP), Mobile Advertising ID, media access control (MAC) address, or identifiers associated with browser cookies, web beacons and similar technologies we deploy on our Services;
· Location information in accordance with your device permissions. For more details, please see “YOUR CHOICES” below.
PERSONAL DATA WE COLLECT FROM OTHER SOURCES
We may collect personal data about you from other sources. For example, we may collect personal data about you from:
Third-party social media and communication services, such as Facebook, Twitter, Google, and Instagram, that you use to interact with our Services (e.g., to create an account) or that allow you to share information (e.g., via plugins, widgets, or other tools), but always in accordance with the authorization procedures and privacy settings you establish with such services; and
Unaffiliated parties, such as service providers that we use, analytics companies, advertising networks, consumer data resellers, and other third parties that provide us with information, so we can better understand you and provide you with information and offers that may be of interest to you.
PERSONAL DATA WE DERIVE
We may derive information or draw inferences about you based on the other types of personal data we collect. For example, we may infer your location based on your IP address, or that you are interested in purchasing women’s tops based on your browsing behaviour on our Services.
USE OF PERSONAL DATA
We collect and use personal data for business and commercial purposes, including to:
· Develop, provide and improve our products, events, and services.
· Complete the transactions you request, perform our contractual obligations, and as otherwise anticipated within the context of our ongoing business relationship.
· Create and manage your online accounts, profiles.
· Send notifications related to your account, purchases, exchanges, and returns.
· Respond to your requests and any other communications from you, including to provide customer service.
· Send advertising or marketing communications about products, services, offers, promotions, rewards, and events offered by Varenna and others, and provide news and information that we believe may be of interest to you.
· Offer and administer events, prize draws, sweepstakes, and other promotions.
· Conduct internal research and development.
· Analyze your engagement with our brand and your use of our Services to better understand your interests and behaviours and customize your experience.
· Detect security incidents and protect against malicious, deceptive, or illegal activity, including fraudulent transactions, error, negligence, and breach of contract, and to protect against harm to the rights, property, or safety of Varenna and our users, customers, employees or the public;
· Debug, identify, and repair errors that impair existing intended functionality of our services.
· Comply with our legal obligations, including our tax obligations and those related to the prevention of fraud and money laundering, and those required for you to benefit from rights recognized by law, or any regulatory requirements or provisions; and
· Carry out certain short-term activities and other reasonable internal purposes related to the products or services you purchase from us or your ongoing relationship with us.
DISCLOSURE OF PERSONAL DATA
We share personal data for the purposes described below:
· With our Affiliates and Subsidiaries. Disclosures of your personal data to our holding company, subsidiaries, and affiliates for the purposes described in the “USE OF PERSONAL DATA” section above. Since our holding company, subsidiaries and affiliates are located around the world, please note that these disclosures involve cross-border transfers of your personal data as described in the “DATA TRANSFERS” section below.
· With our Service Providers. We share personal data with unaffiliated companies or individuals we hire or work with that perform services on our behalf, including customer support, web hosting, information technology, payment processing, product fulfilment, fraud control, direct mail, and email distribution, events, contest, sweepstakes and promotion administration, and analytics services. We only share with service providers the personal data that they need to perform services for us. Since our service providers are located around the world, please note that these disclosures involve cross-border transfers of your personal data as described in the “DATA TRANSFERS” section below.
· In Connection with a Corporate Transaction. Personal data may be disclosed or transferred as part of, or during negotiations of any purchase, sale, lease, merger, amalgamation, or any other type of acquisition, disposal, securitization, or financing involving Varenna.
· With our Professional Advisors. We share personal data with our legal, financial, insurance, and other advisors in connection with the kinds of corporate transactions described above or in connection with the management of all or part of Varenna business or operations.
· With Law Enforcement Authorities and Individuals Involved in Legal Proceedings. We disclose personal data when we believe doing so is reasonably necessary to comply with applicable law or legal process (including an enforceable request from authorities), to respond to claims (including inquiries by you in connection with your purchases from Varenna), or to protect the rights, property or personal safety of Varenna, our users, employees or the public.
· With Your Consent or at Your Direction. We share personal data with third parties when we have your consent to do so. For example, if you decide to participate in certain interactive areas or features of our events or Services, such as creating a public profile, you consent to the disclosure of this information to other users of our websites. We may also share your personal data with third parties when you intentionally direct us to do so or when you use our Services to intentionally interact with third parties.
· We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS
For detailed information on the cookies we use and the purpose for which we use them, see the section about Cookies below.
DATA SECURITY, TRANSFERS, AND RETENTION
The transmission of information via the internet is not completely secure or private. If you have any questions about the security of personal data collected by Varenna, please contact: email@example.com
RETENTION OF PERSONAL DATA
We retain personal data in accordance with applicable law. Unless otherwise required by applicable law, Varenna will take reasonable steps to destroy or permanently de-identify personal data it holds if such personal data is no longer needed for the purpose for which it was collected.
The Services are not intended for children under the age of 18. Varenna does not target our Services to children under 18.
Please note that our websites contain links to third-party websites that are not controlled or operated by Varenna. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that Varenna does not accept any responsibility or liability for these policies. Please review these policies before you disclose any personal data when visiting such third-party websites.
You have certain choices with respect to how we treat your personal data, as described below.
You may review and modify your account and profile information by logging into your online account at any time. You can also contact us and request that we update your account or profile information.
You may opt-out of receiving promotional communications from us by following the instructions in those communications or by logging into your online account and changing your communications preferences. If you opt-out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
Like many websites, Varenna uses “cookies” to analyze visits to our website and help us improve our website and services. Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies. Please follow your browser’s process for doing so. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our websites.