We protect your personal information in the following areas.
▪ Collection, use and provision of personal information
We establish a personal information protection management system for personal information that will be collected in the course of the company's operations, and observes the principles of lawfulness, appropriateness and necessity in the collection, use and provision of personal information.
▪ Implementation of safety systems and measures
In processing personal information, we always comply with applicable personal information protection laws and regulations. To ensure the safety of personal information, we will implement information security measures that comply with applicable standards, manage personal information in accordance with the relevant requirements, restrict the means of external transmission of personal information and prevent unauthorized access, and make efforts to prevent security incidents of personal information.
▪ Respect for the rights of the subjects
When you request the disclosure, correction or deletion of your personal information, or request to refuse the use or provision of personal information, we will respect the rights of the information subject and respond and process the request in a timely manner in accordance with the requirements of the applicable laws and regulations.
本隐私政策不适用于Valextra S.p.A.运营的国际网站以及Valextra S.p.A.及其关联公司在中国大陆以外地区提供的服务。
2. PERSONAL INFORMATION COLLECTED AND PROCESSED, PURPOSES AND LEGAL BASIS FOR PROCESSING
A. When you join our membership program and register as a member of Valextra, we will collect and process the following personal information:
a. Your name: We will collect and process your name for the purposes of establishing membership profile for you and conducting membership management, your consents will be the legal basis of our processing.
b. Your mobile phone number: We will collect and process your mobile phone number for the purposes of contacting with you and providing post-sale services and membership benefits. Your consents will be the legal basis of our processing.
c. Your email address: We will collect and process your email address for the purposes of contacting with you, providing post-sale services and membership benefits, sending newsletters, advertisement, and other marketing communications. Your consents will be the legal basis of our processing.
d. Your address: We will collect and process your address for the purposes of contacting with you and providing post-sale services and membership benefits. Your consents will be the legal basis of our processing.
e. Your payment information: We will collect and process your payment information for the purposes of confirming your payment of the purchases. Necessary for performance of contracts will be the legal basis of our processing.
B. When you visit or purchase products from our official online store by using the mini program on WeChat, we will collect and process the following personal information:
a. Your WeChat Open ID and WeChat profile picture: We will collect and process your WeChat Open ID and WeChat profile picture for the purpose of establishing connection with your WeChat account such that you can purchase products through the online store on WeChat. Your consents will be the legal basis of our processing.
您的微信Open ID、微信头像：为了与您的微信账号建立连接以便您可以通过建立在微信上的在线商店进行消费，我们将收集您的微信Open ID、微信头像。您的授权同意是我们处理的法律依据。
b. Your name: We will collect and process your name for the purposes of identifying you and establishing online store profile for you. Your consents will be the legal basis of our processing.
c. Your mobile phone number: We will collect and process your mobile phone number for the purposes of contacting with you, providing notices with respect to your purchase, and providing post-sale services. Necessary for performance of contracts will be the legal basis of our processing.
d. Your payment information: We will collect and process your payment information for the purpose of confirming your payment of the purchases. Necessary for performance of contracts will be the legal basis of our processing.
e. Your delivery address：We will collect and process your delivery address for the purposes of delivering products to you and providing post-sale services. Necessary for performance of contracts will be the legal basis of our processing.
f. Your transaction information (your purchase history, order information, and other personal information generated during your purchase in our online store.): We will collect and process your transaction information for the purposes of contracting with you with respect to your purchase of products and displaying the orders. Necessary for performance of contracts will be the legal basis of our processing.
g. Your comments and feedback (including the comments you give on the store pages, the feedbacks you provide to us through online store customer services and emails, etc.): We will collect and process your comments and feedback for the purpose of learning your comments on the products and purchase, resolving potential transaction disputes, and protecting consumers’ rights. Your consents will be the legal basis of our processing.
h. Your gender: We will collect and process your gender for the purpose of providing online store membership services. Your consents will be the legal basis of our processing.
i. Your birth date: We will collect and process your birth date for the purposes of recommending products or other information of interest to you and providing promotion related information. Your consents will be the legal basis of our processing.
j. Your use information (records of login, browsing, clicking, search, etc.); device information (device, model, device identifiers, operating system, application version, language settings, resolution, service provider network ID); and location information: We will collect and process your use information, device information and location information for the purpose of providing personalized experience a. (identifying the kind and features of products you prefer or are interested in and recommending products or other information of interest to you). Your consents will be the legal basis of our processing.
Certain sensitive personal information may be involved in above processing activities, including facial information (if any) contained in the WeChat profile picture, personal bank account information (if any) contained in payment information, transaction information, browsing record contained in use information, and precise location information (if any) contained in the location information. We will only process the above sensitive personal information for the necessary processing purposes disclosed and based on your consents or other lawful basis.
C. In addition to the purposes described above, we may also process your personal information for the following purpose:
a. To send you non-marketing communications. Non-marketing communications may be sent upon your request, and/or may be important for your safety and the security of your personal information. You may still receive such communications even when you opt-out from certain marketing communications. The information communicated may be necessary for the correct performance of our contract with you or be mandatory to comply with some of our legal obligations.
b. To conduct our business securely and protect our activities. To deliver our products and services safely to you, perform our contract properly or comply with some of our legal obligations, we will implement fraud prevention measures. Such measures will allow us to adequately perform our contract with you and/or protect our legitimate interests in defending ourselves against fraud.
c. To assess and better understand our business. To manage our businesses, perform our obligations under our contract with you and comply with our legal obligations, we may need to access and use some of your personal information for finance, management or legal purposes, or business-related analytics and market research activities.
d. To comply with laws. To comply the requirements of laws and regulations, to enforce a court order or other legal process, or to respond to a request from an authorized government agency.
3. THE METHODS WE COLLECT YOUR PERSONAL INFORMATION
We mainly obtain personal information directly from you and process them when you interact with us. When you interact with us, either online or in person, we collect your personal information through:
– When you share personal information with our in-store sales consultants or customer services (e.g., by phone or on-line conversation);
– When you fill out information, complete a survey or form in our online store;
– When you purchase products in our online store;
– When you sign up for our membership program and subscribe to our newsletters and notifications.
From time to time, we may also obtain information on you from third-party sources. We will only gather such information when the third parties either have obtained your consent or are otherwise legally allowed to share such information. For example, when you use our official online store deployed on WeChat, we may receive your information from WeChat and Youzan after you give consents for such sharing.
4. SHARING OF PERSONAL INFORMATION
A. Sharing with Our Headquarter
Your personal information may be shared with our headquarter company, i.e., Valextra S.p.A. for the following processing purposes:
a. To manage the Valextra membership program and provide you with member services and after-sales service.
b. To send you newsletters and other marketing communications.
B. Sharing with Third Parties
a. Commissioning: In order to perform the contract with you and provide the products and services, we may commission external providers to assist us in providing relevant services to you. Under commissioning, the third party receiving personal information is authorized to provide services to you on our behalf only at our direction, and we are responsible to you for their actions within the scope of the commission. For example, we may entrust suppliers, service providers and other partners who support our business to provide us with technical infrastructure services, analysis of how our services are used or potential risks, advertising services, shipping, warehousing, payment facilitation, customer service, data storage or data analysis services.
(i) We use the software and SaaS services provided by Salesforces to manage the personal information we collect, and in China the Salesforces services are provided by salesforce.com Information Technology (Shanghai) Co. Ltd.
(ii) In particular, with respect to our official online store, we use technical support provided by Hangzhou Youzan Technology Co., Ltd. to store and process your personal information that we collect when you use the online store. You can visit the Youzan Privacy Statement to learn about their measures and policies related to the protection of your account.
b. Providing to Others: In order to fulfill the contract concluded with you or for other reasonable purposes, we may provide certain of your personal information to third party processors, and we will disclose it to you and obtain your consent in accordance with the law, and such third party personal information processors who receive personal information have the right to process personal information within the scope of the purposes of processing, processing methods and types of personal information that have been notified to you. And if the recipient changes the original purpose or method of processing, it shall obtain your consent again.
5. ASSIGNMENT AND DISCLOSURE
A. We will not assign your personal information to any parties, except for the following:
a. Where the express consent of such assignment is obtained: after obtaining your express consent, we will assign your personal information to other parties.
B. We will only disclose your personal information publicly under the following circumstances:
a. After obtaining your separate consent;
b. Disclosure according to laws: We may disclose your personal information if compelled to do so by law, legal process, litigation or governmental authority.
6. RETENTION PERIOD OF PERSONAL INFORMATION
Our general approach is to retain your personal information only for as long as it is needed.
– When you sign up for Valextra membership program, we generally retain your personal information for 7 years from the date you provide you registration related information.
– When you visit or purchase products from our official online store, we generally retain your personal information for 7 years from the date you authorize us to obtain the relevant information.
– When you subscribe to our newsletters, we retain your personal information for 24 months.
We may retain personal information for a shorter or longer time, for instance, where we are obliged to do so in accordance with relevant legal, tax and accounting requirements.
7. PROTECTION OF PERSONAL INFORMATION
We have adopted specific technical and organizational security measures to protect personal information against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure, or access. For example, whenever personal information is passed between your device and our servers, we ensure that it is encrypted. All your personal information is stored on secured servers.
We strictly control the scope of authorization of our employees who have access to the personal information that we collect and process. We regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorized access and use.
We take commercially reasonable steps to make sure that our business partners and third-party service providers are able to protect your personal information. Our employees and those of our business partners and third-party service providers who have access to your personal information are subject to enforceable contractual obligations of confidentiality and specific contractual privacy provisions.
In the event of a security incident resulting in any breach of personal information, as qualified by law, we have an emergency response plan in place to prevent the expansion of such security incidents. In addition, we will report such personal information breach to the relevant supervisory authority as required by applicable law and inform you via an appropriate channel as and where required by applicable law.
However, you should be aware that no service can be completely secure, and you play a key role in keeping your personal information safe. For the best possible protection of your personal information outside the limits of our control, your devices should be protected (e.g., by updated antivirus software) and your internet service providers should take appropriate measures for the security of personal information transmission over the network (e.g., with firewalls and anti-spam filtering). You accept the inherent security implications of interacting over the Internet and will not hold us or our partners responsible for any security incident or breach of personal information unless it is due to our negligence.
8. STORAGE LOCATION AND CROSS-BORDER TRANSFER
In principle, personal information collected and generated by us in Mainland China will be stored in the Mainland China in accordance with the requirements of the applicable laws.
However, because Valextra group manages the Valextra membership program globally, if your sign up for Valextra membership program, your membership information (your name, mobile phone number, email address and address) will be transferred to our headquarter company, i.e., Valextra S.p.A. (in Milano, Italy), and will be stored and processed there. Valextra S.p.A. will only process your membership information for the purpose of membership management and providing the membership services to you.
If you do not agree to the above cross-border transfer, please do not sign up the Valextra membership program.
然而，由于Valextra集团在全球范围内统一管理Valextra会员计划，如果您注册了Valextra会员计划，您的会员信息（您的姓名、手机号码、电子邮件地址和地址）将被传输到我们的总部，即Valextra S.p.A.（位于意大利米兰），并将在那里存储和处理。Valextra S.p.A.将只为会员管理和向您提供会员服务之目的处理您的会员信息。
9. YOUR RIGHTS
In accordance with the prevailing practices of applicable laws, regulations and standards in Mainland China, we will endeavor to protect your rights in our personal information processing activities, including but not limited to：
A. Accessing, copying and transferring your personal information
a. You have the right to access, copy and transfer your personal information through your WeChat account on our official online store deployed on WeChat mini program.
B. Correcting and supplementing your personal information
a. If you discover that your personal information is inaccurate or incomplete, you have the right to correct and supplement it by yourself following the path indicated in section 9.A.a above.
C. Deleting your personal information
b. In addition, if we do not voluntarily delete your personal information in the following cases, you may make a request to us to delete your personal information by using the contact details described in this policy:
i. the purpose of processing has been achieved, cannot be achieved, or is no longer necessary to achieve the purpose of processing;
ii. we cease to provide the product or service, or the retention period has expired;
iii. you withdraw your consent;
iv. we process your personal information in violation of laws or administrative regulations or in breach of the contract with you;
v. Other circumstances stipulated by laws and administrative regulations.
c. We will respond to your request for deletion of personal information within fifteen business days of receipt. If we decide to respond to your request for deletion, we will also simultaneously notify the entities from which we obtained your personal information and request their prompt deletion, unless otherwise provided by law or regulation or unless such entities have your independent authorization.
d. When you delete information from our online store, we may not immediately delete the corresponding information in our backup system but will delete it when the backup is updated.
e. If the retention period stipulated by laws or administrative regulations has not expired, or if deletion of personal information is technically difficult to achieve, we will stop processing other than storing and taking the necessary safety protection measures.
D. Withdrawing your authorization
a. Certain services require some basic personal information in order to be completed, and if you withdraw your consent, the corresponding services will no longer be available.
b. With respect to the information provided to us through our online store deployed on WeChat mini program, you can give or withdraw your consents by fill in or delete the information on the online store interface, or by changing your setting in WeChat account.
d. When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of personal information previously carried out on the basis of your authorization.
E. Deregister your Valextra membership account
b. After you deregister your membership account, we will stop providing you with membership services and, at your request, delete your personal information or anonymize your personal information, except where otherwise provided by law or regulation.
F. Turning off personalized services
You can turn on or turn off personalized recommendation services by turning on or off the corresponding button in the settings of the mini program on WeChat.
G. Responses to your requests
a. For security purposes, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.
c. In principle, we do not charge a fee for your reasonable requests, but we will charge a cost fee for repeated requests that exceed reasonable limits, as appropriate. We may deny requests that are unwarrantedly repetitive, require excessive technical means (for example, requiring the development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, or are highly impractical.
d. As required by law or regulation, we will not be able to respond to your request in the following cases:
i. related to the personal information processor's fulfillment of obligations under laws and regulations;
ii. directly related to national security, national defense security;
iii. directly related to public safety, public health, and significant public interests;
iv. directly related to criminal investigation, prosecution, trial and execution of judgments, etc.
v. where the processor of personal information has sufficient evidence of subjective malice or abuse of rights by the subjects of personal information;
vi. when it is necessary to protect the life, property and other significant legitimate rights and interests of the subjects of personal information or other individuals but it is difficult to obtain their consents;
vii. Where responding to your request would result in serious damage to the legitimate rights and interests of the subject of personal information or other individuals or organizations;
viii. Where commercial secrets are involved.
11. CONTACT US
If you have any questions, comments, or suggestions, you can contact us by the following means, and we will normally reply within fifteen business days.
Address: R 2H09, Building 20, No.1440 Yan’an Middle Road, Jing'an District, Shanghai