1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 You can specify whether you would like to receive direct marketing communications and limit the publication of your information contacting us at firstname.lastname@example.org.
1.5 If you want to delete your account, you can contact us at email@example.com
1.6 In this policy, "we", "us" and "our" refer to WE MAKE-UP S.R.L.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data;
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services.
2.3 We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the consent and/or our legitimate interests, namely the proper administration of our website and business.
2.4 We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is the consent and/or our legitimate interests, namely the proper administration of our website and business.
2.5 We may process your personal data that are provided in the course of the use of our services ("service data”). The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the consent and/or our legitimate interests, namely the proper administration of our website and business.
2.6 We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent and/or our legitimate interests, namely the proper administration of our website and business.
2.7 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is the consent and/or our legitimate interests, namely the proper administration of our website and business.
2.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
2.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the consent and/or our legitimate interests, namely the proper administration of our website and business.
2.10 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping.
2.11 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.12 Please do not supply any other person's personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. Retaining and deleting personal data
4.1 This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.3 Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5.1 We may update this policy from time to time by publishing a new version on our website.
5.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
5.3 We may notify you of changes to this policy by email or through the private messaging system on our website.
6. Your rights
6.1 In this Section we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
6.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
6.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting https://wemakeup.com/profile.php when logged into our website.
6.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
6.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
6.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
6.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
6.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
6.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
6.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
6.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.12 You may exercise any of your rights in relation to your personal data by written notice to us.
7. About cookies
7.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
7.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
7.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
8. Cookies that we use
8.1 We use both session and persistent cookies on the website.
The Cookies that we use permit us to:
- establish statistics and volume of frequency and use for various items included on our Website (pages and content visited, browsing history) permitting us to improve the interest and ergonomics of our services;
- adapt the presentation of our Website to the display preferences of your device (language, display resolution, operating system, etc.) during your visits to our Website, in accordance with the hardware and display or browser software included on your device;
- adapt our advertising to the display preferences of your device (language, display resolution, operating system, etc.), in accordance with the hardware and display or browser software included on your device;
- adapt the advertising content displayed on your device in accordance with the browsing history of your device on our website;
- adapt the advertising content displayed on your device in accordance with the location data (longitude and latitude) transmitted by your device with your prior consent;
- associate personal data, to the extent you have furnished us with such data when you registered for or accessed one of our services, in particular your digital coordinates, with the browsing information with respect to your device in order to send you, for example, digital offers or display on your device, within the advertising spaces included on our Website, personalised advertising specifically intended for you that is likely to be of particular interest to you;
- memorise information with respect to a form that you have filled out on our Website (registration for or access to your account) or products, services or information that you have selected on our Website (services subscribed for, content of an order basket, etc.);
- permit you to access reserved and personal spaces on our Website, such as your account, through the use of your username or data that you have previously provided us with;
- implement security measures, for example when you request to connect to new content or a service after a certain lapse of time.
9. Third Party Cookies on our website
9.1 We may include third party software applications on our Website, which permit you to share the content of our Website with other people or inform other people of the content you have consulted on our Website and of your opinion on it. These third party applications include the "Share" and "Like" buttons used by social networks (such as "Facebook", "Twitter", etc.). The social network that has furnished the application button is capable of identifying you thanks to this button, even if you have not used the button when you visited our Website. In fact, these types of application button permit the social network in question to follow your browsing history on our Website, whenever your social network account is active on your Device (an open session) when you are browsing our Website. We have no control as to the procedures employed by the social networks for the collection of information with respect to your browsing history on our Website and the related personal data that they hold. Please consult the privacy policies of the social networks in question to discover the purposes, including advertising, for which they use browsing data that they are able to collect using these application buttons. These privacy policies are required to permit you to exercise your choices with respect to such social networks, in particular through your account settings for the use of each of these networks.
9.2. Our website may contain third party cookies (from advertising agencies, audience research companies, targeted advertising service providers, etc.) which permit these third parties during the period of these cookies are valid to:
- collect browser information with respect to the Devices consulting our Website.
- determine the advertising content for the promotion of products and/or services offered solely on our Website and likely to correspond to your interests as deduced by the prior browsing history of the device in question.
10. Cookies used by our service providers
10.3 We use Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.) to analyse the use of our website. The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)
Hotjar is an analytics service provided by Hotjar Ltd.
Hotjar honors generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data collected: Cookies and Usage Data.
Heat Mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
10.4 Remarketing e Behavioral Targeting. These services allow this application and its partners to communicate, optimize and serve ads based on the use history of this application by the user.
AdWords Remarketing (Google)
AdWords Remarketing is a service of Remarketing and Behavioral Targeting provided by Google Inc. that connects the activity of this application with the Adwords advertising network and Cookie Doubleclick.
Facebook Custom Audience is a service of Remarketing and Behavioral Targeting provided by Facebook, Inc. linking the activity of this application with the advertising network Facebook.
Personal data collected: Cookies and Emails.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a service of Remarketing and Behavioral Targeting provided by Facebook, Inc. linking the activity of this application with the advertising network Facebook.
Personal data collected: Cookies and data usage.
11. Managing cookies
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
12. Our details
12.1 This website is owned and operated by WE MAKEUP S.R.L.
12.2 We are registered in Italy under registration number VAT IT01621270196 and our registered office is at Chieve, Cremona, Italy.
12.3 Our principal place of business is at SS 235, 15 I/ km 45, 26010 Chieve, Cremona, Italy.
WE MAKEUP S.R.L.
Address:SS 235, 15 I/ km 45, 26010 Chieve, Cremona, Italy.
Phone: +39 0373.648460