Welcome to the Agnona S.r.l - Società con socio unico website (hereinafter 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.

We remind you that this Privacy Policy is regulated by Italian law, and in particular by the Personal Data Protection Code (Legislative Decree No. 196 of 30 June 2003) and by the European General Data Protection Regulation 2016/679 (hereinafter the “GDPR”), which govern the processing of personal data - including data held abroad - that is carried out by any party that is a resident or that has a registered office in Italy. The Code and the Regulation guarantee that the personal data be processed in accordance with fundamental rights and liberties, as well as in respect of the dignity of the interested party, particularly as concerns confidentiality, personal identity and the right to protection of personal data.

Data controller and contact details

The data controller is Agnona S.r.l - Società con socio unico, with registered office in Via Archimede 53, 20129, Milano, Italy (hereinafter referred to as, “Agnona”). Agnona may be contacted at the following email address privacy@agnona.com for any information regarding the processing of your personal data and to exercise the rights that the Regulation guarantees you, as illustrated below in point 9.

Type and purpose of processing performed on the website and legal basis of the processing activities

Through the Website, different types of personal data are collected and processed, for different purposes and with different methods. More precisely:

1. Personal data pertaining to navigation, which is processed both for purpose of allowing the Website function properly, and for marketing purposes. In this regard, please read the “Cookie Policy” on the Website;
2. Personal data provided voluntarily by the user (email address, telephone number, personal details, password provided by completing the registration form) or otherwise provided while using the Website and/ or through other interaction with the services made available by Agnona and processed to respond the user requests and offer the services, support and information requested concerning the products and the word of Agnona. Please note that registration and access through social network profiles involves the disclosure of certain data (including First name, Last name, Email and any other data relating to the user and present on the same social network) by the chosen social network. In any case, this will only occur if you have previously accepted the disclosure of some of your data by the social media platform during the use of the registration function through a social network login and/or if you have authorized the use of analytical and marketing cookies through the methods present on the site. In some cases, social media also requests some feedback and information about the use of log-in. For more information, please refer to the relevant privacy documentation on the social media network;
3. Personal data provided by the user as part of the process of purchasing products on the Website for the conclusion of transactions and for activities functional and instrumental to the sale, as well as for any necessary pre and post sales assistance and for all related legal requirements;
4. with the express consent of the user, Agnona may process the latter's personal data for marketing purposes, in order to send the user, including through newsletters, emails, SMS and MMS, information and updates on products, sales, advertising campaigns, about events and other initiatives promoted by Agnona;
5. with the user's express consent, Agnona may also process the latter's personal data for the purposes of analyzing user's buying habits and selections, in order to make the Agnona products and initiatives more responsive to its customers' tastes and needs.

Pursuant to the GDPR, with the exception if the browsing data, governed by the Cookie Policy, the processing of personal data is based on:

1. the legitimate interest of Agnona in providing the Website services and responding to any customer requests, with reference to points b);
2. the fulfilment of the contract and the obligation to fulfil pre and post contractual obligations referred to in point c), except for activities related to legal obligations that have as their legal basis the regulatory compliance.
3. the specific explicit consent given by the user, with regard to the marketing and analysis purposes referred to in points d) and e).
4. Sources of personal data

The personal data collected by Agnona is provided directly by the user, with the exception of the browsing data referred to in paragraph 2(a) above and data collected during registration and access via social network profiles, as described in paragraph 2(b) above. Please also note that the data used for the analysis of your preferences are, in addition to information requested directly from you, data from purchases on the Website or in Agnona stores.

Research of users’ purchasing habits and choices

As indicated in paragraph 2 d) above, with your express consent, Agnona may also process your Data for the purposes of analysing your habits, buyings and selections, in order to offer you products, services and initiatives more responsive to your tastes and needs.

Agnona will process, by automatic means, the value purchased within a framework of time, the frequency of the purchases and the kind of product purchased. Agnona will also be able to acquire additional Data directly from you regarding your consumption preferences, hobbies, habits or lifestyle.

The sole objective of this research is to offer customers and users products, services and initiatives that are better suited to their tastes and demands. In this respect, please note that research into the behavior of users and customers will be carried out in a non-intrusive manner.

As described in paragraph 2 (a) above and with the express consent of the user, Agnona may process the user's personal data, using automated tools, to study cookies in order to monitor browsing on the Site and to suggest products and services in line with the browsing activity.

Compulsory or option nature of providing data

With the exception of browsing data, the provision and collection of which is regulated by the Cookie Policy (theprovision and collection of which is governed by the “Cookie Policy"), the provision to Agnona of personal data collected through the Website, both to respond to requests and queries from users, and for marketing and research into consumer habits and preferences is free, voluntary and optional. Failure to do so does not prevent use of the Website, but may make it impossible for Agnona to respond to requests for information and queries, or to send information, updates, newsletters and invitations to Agnona events.

The provision of personal data, especially personal details, email 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.

Some of said data, moreover, may be necessary for providing to the user other services made available on the Website in connection with the sales (pre- and post-sales services, such as, for example, the customization service, etc. ..) or, for discharging the obligations deriving from the law or regulatory provision (tax compliance and anti-money laundering ). Any failure to provide 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 not providing the related services thereto.

Where necessary, the compulsory or optional nature of the communication of data will be indicated from time to time, appending an appropriate character (*) to the information necessary for the provision of services and the purchase of products on the Website. Failure to indicate personal data indicated as optional or optional, will not result in any limitation or disadvantage to the user.

Personal Data processing methods

The personal data collected through the Website of Agnona is primarily processed using computer and telematic methods, 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).

• Categories of personal data recipients

Agnona only discloses the personal data of Website users to the extent permitted by law and in accordance with the provisions set out below. In addition to that stated in point 2 b. above (i.e. Social media login), personal data may be disclosed to:

1. Agnona employees and consultants, who act as authorized processors for the purposes of the internal organization of the company's activities;
2. companies that carry out specific technical and organizational services related to the Website (IT services and marketing services) for Agnona, as data processors.

Personal data may also be disclosed to:

a) third parties, solely for the purpose of performing the agreement of the products purchased on the Website (such as, for example, the credit institution for the execution of remote electronic payment services by credit/debit card, the courier responsible for deliveries and collections);

b) the police or the courts, in accordance with the law and following a formal request by such parties, or where there are substantial grounds to believe that the provision of such data is reasonably necessary in order to (1)investigate, prevent, or take action regarding suspected illegal activities or assist the government's supervisory and monitoring authorities,(2) defend against any claims or allegations made by any third party, or protect the security of its website and the company; or (3) exercise or protect the rights, property, or security of Agnona, customers, employees, or any other party.

The data will not be disclosed and will be transferred abroad only if adequate levels of data protection and safeguarding are guaranteed, in accordance with current legislation, such as “Standard Model Clauses” approved by European Commission. For more information about the location of data, you may contact Agnona at the following e-mail privacy@agnona.com.

Data storage period

The data provided and linked to the purchase are stored for period of time not exceeding 10 years from the purchase, in accordance with tax and civil law and except for special needs of defense in court that may require storage for a longer time. The data provided to request assistance, information and feedback are stored for the time necessary to provide the requested response and any subsequent activity of further interaction with you necessary to fully manage the problem and / or request.

The Data provided for marketing purposes and to study consumption habits and choices are stored for the period necessary for the specific processing, also in consideration of the particular sector of business (luxury goods) and in consideration of the interest shown by the customer to receive updates on products, events and fashion shows organised by Agnona, always in compliance with the privacy legislation and the permission you provided and for a period not exceeding 7 years, unless you provide further confirmation of your interest to receive communications from Agnona.

To find out about the retention period and persistence of cookies, please see the Cookie Policy.

User rights acknowledged by the privacy law

Pursuant to the GDPR, users have the right to make the following request regarding their personal data processed and held by Agnona:

1. confirmation as to whether or not personal data concerning them is being processed even if not yet recorded, and its communication in an intelligible form;
2. information concerning the origin of their personal data, the purposes and methods of processing the logic applied in the case of processing performed with the support of electronic instruments, the details of the data controller and data processors, an indication of the subjects and categories of subjects to whom the personal data may be reported or who may be informed thereof in their capacity as data processors or in any event parties authorised to process the data;
3. the updating, rectification or, where interested, the integration of the personal data;
4. the erasure, the transformation into anonymous form or the blocking of personal data processed against the law, including those for which storage is not necessary in relation to the aims for which the data were collected or subsequently processed, as well as certification of the fact that the operations mentioned above were brought to the awareness of those to whom the data were communicated, except for the case in which such action is impossible or implies use of means that are clearly disproportionate with respect to the protected right;
5. the portability of their own data;
6. the restriction of the processing of their personal data.

Users also have the right to object all or in part, on legitimate grounds, to the processing of personal data concerning them, even if it is relevant to the purpose of the collection, and to revoke consent provided previously. The right to objection and the revocation of consent may also be exercised specifically, with respect to one or more methods of sending marketing communications.

The rights listed above may be exercised by contacting Agnona, by writing to privacy@agnona.com.

Lastly, please recall that users always have the right to make a complaint to the Supervisory Authority (Autorità Garante per la protezione dei dati personali – Italian Regulatory Authority for the Protection of Personal Data).

CHILDREN UNDER THE AGE OF 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us privacy@agnona.com.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This section supplements the information contained in our Privacy Policy and applies solely to the processing of Californian consumers' personal information (it does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals). This section is intended to address the relevant notice requirements of the California Consumer Privacy Act of 2018 (the "CCPA"), and uses certain terms having the meaning given in the CCPA.

Your information, sources and purposes: please refer to the sections in the Privacy Policy above explaining 1) what data we collect, 2) how such personal data is used, and 3) the cookies collected, for a description of the personal information we may collect about you (or have collected in the preceding 12 months) and the sources of such information. Sources may include information acquired directly from you and your devices, or through certain third parties. In the Privacy Policy you will also find the purposes for which we may use or have used such information.

As more fully described in the Privacy Policy, we may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes such purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Selling your information: we have not sold personal information in exchange for monetary compensation. We may allow certain third parties (such as certain advertising partners) to collect your personal information via automated technologies on our platforms in an effort to serve you content and advertisements that may be of interest to you. You have the right to opt out of this disclosure of your information, as described in the cookie policy.

Your rights: subject to exceptions under applicable law, you may have certain choices regarding our use and disclosure of your personal information, as described below:

Access: you have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected about you during the past 12 months and details regarding our collection, use, disclosure of such information.

Deletion: you have the right to request that we delete the personal information we have collected from you subject to certain exceptions.

Opt-Out: You have the right to manage the activation of the cookies as described in the cookie section.

To exercise your rights, described above, you can:

write to Customer Care customercare@agnona.com of the Website; or contact us directly at the address indicated above. If you exercise your rights, we may require you to provide certain information to verify your identity (such as your name, email address, phone number and/or address).

No discrimination: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.

Personal, family and household clients: California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email message to our email address below [ insert mail] with "Request for California Privacy Information" in the subject line. You may make such a request up to once per calendar year. If applicable, we will provide you with a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the preceding calendar year, along with the third parties' names and addresses. Please note that all the rights granted by the GDPR remains not affected.