PRIVACY POLICIES

1. WEBSITE PRIVACY POLICY
Regulation (EU) 679/2016 General Data Protection Regulation

Hereby, Entrepreneur Dmytro Zaichenko, ITN 2762719879, Customer Service Department: support@beggani.com intends to inform the users that visit the “www.beggani.com” website (hereinafter, the “Website”) about the policy adopted in Personal Data Protection matters, by emphasising its commitment and attention paid in reference to the protection of privacy for the Website’s visitors. Please read our Privacy Policy carefully, which applies when you access the Website and simply decide to browse it by using our services without purchasing any product, and when you decide to make purchases.

Furthermore, if you have not already done so, please read the www.beggani.com “Website’s Conditions of Use”, since they also enclose significant information on the security systems adopted by the Website.

Browsing the Website is free of charge and does not require any registration, except for some areas within which the user may freely and expressly provide us with some personal data in order to have access to specifically identified services (e.g. to subscribe to our newsletter or to request information through the “Contact us” section, etc.). If the user intends to provide us with his/her personal data to access other services, the same shall be expressly informed, pursuant to Regulation (EU) 679/2016 General Data Protection Regulation (the “Regulation”), with an indication (for instance) of the purposes and the modalities in which Entrepreneur Dmytro Zaichenko, ITN 2762719879, Customer Service Department: support@beggani.com uses the data, as well as his/her right to request, at any time, the deletion or update of the data.

Pursuant to and for the purposes of Article 13 of Regulation (EU) 679/2016 General Data Protection Regulation Entrepreneur Dmytro Zaichenko, ITN 2762719879, Customer Service Department: support@beggani.com provides you with the following information.

1. Identity and contact details of the Data Controller

The www.beggani.com website (hereinafter, the “Website”) is managed by Entrepreneur Dmytro Zaichenko, ITN 2762719879, Customer Service Department: support@beggani.com (BEGGANI®), in its capacity as Data Controller pursuant to the Regulation.

 2. Types of personal data subject to processing

You do not have to register in order to access the Website. However, the Website includes sections that require registration or the use of a username and password or services that require your personal data (e.g. to proceed with the online shop, to access the newsletter services, to contact us, etc.) [1].
With reference to the data relating to browsing on the Website, please also see point 6 below on the Profiling tools used by the Website.

3. Purposes and legal basis of the processing

The data is collected and processed for purposes strictly connected with using the Website, its services and the online purchase of products. The purposes for using the data are specified in detail in the specific policies provided by the Website for all cases of data collection. Therefore, we kindly ask you to read the policies that provide, in each instance, the features of the processing that will be carried out by BEGGANI® (e.g. for the subscription to the newsletter service, for sending requests through the “Contact us” section, etc.) or by the BEGGANI® retail companies (e.g. for the online sale of BEGGANI® branded products). In particular, your data will be processed in order to manage your orders and to guarantee the use of the Services (including post-sale services) requested through the Website, to fulfil the related statutory obligations, to manage our customers’ loyalty activities, to reply to any of your requests, as well as, based on your consent, to start marketing activities and analysis of your preferences.

The processing of your data shall comply with the privacy provisions[2].

4. Providing your personal data is optional

The provision of your personal data is optional in general. Only in certain cases, failure to provide us with your personal data may result in the inability to access specific services and to satisfy your requests (e.g. registration - and the provision of your personal data, email, delivery address, credit/debit card data or banking details and telephone number - is necessary to proceed with the online purchasing of products); failure to provide such data may, therefore, make it impossible for BEGGANI® to permit access to the Website’s services or to satisfy its users’ requests.

The data required in each instance is indicated in the data collection forms on the Website - marked with an asterisk (*) - and the consequences deriving from failure to provide such data are mentioned in the specific data policies on the data collection pages.

5. Data processing procedures and scope of communication

The data maybe processed both electronically and on paper (e.g. for the management of purchases on the Website). BEGGANI® guarantees the lawful and accurate processing of the personal data provided through the Website, in full compliance with the applicable laws, and the utmost confidentiality of the data provided on your registration.

The data shall not be disclosed and shall be processed by staff expressly authorised to manage the Website of the Digital & E-Commerce and CRM Departments.

Exclusively for organisational and operational purposes, we have appointed some service providers for the management of the Website, who act as external processing officers of users’ personal data for purposes strictly connected and related to the performance of the services provided. A complete list of external data processing officers may be requested at support@beggani.com.

Finally, according to the services requested through the Website, the data may be communicated to companies that provide us with services[3] useful in the management of purchases.

6. Connection to other websites

This policy is provided only for the www.fendi.com website and not for other websites possibly visited by the user through links. BEGGANI® shall not be deemed liable for the personal data provided by the users to external parties or to any websites connected to this Website.

7. “Profiling” and/or customisation tools

BEGGANI® does not carry out any promotional and/or advertising communication activity without the user’s prior express consent thereto.

The Website uses “cookies”, both technical cookies (intended to facilitate browsing and using the Website), and profiling cookies (intended to analyse the users and their behaviour and preferences, and to provide them with customised advertising).

For a detailed explanation on the cookies used by the Website and the steps to follow in order to disable them, please read our Cookie Policy.

8. Place of data processing and transfers outside the European Union

The processing related to the services provided by the Website is carried out at the office of Entrepreneur Dmytro Zaichenko, ITN 2762719879, Customer Service Department: support@beggani.com. The data collected and processed through the Website may be subject to transfer to non-European Union.

The applicable provisions establish that your specific consent is not necessary to transfer data to third party countries since the transfer is carried out based on the adoption of adequate guarantees pursuant to Articles 46 and 47 of the Regulation, such as the adoption of standard contract clauses approved by the European Commission as applied to the relations with the retail companies that manage the Fendi stores worldwide and with our service providers.

The transfer of your data to any third party country, where applicable, shall be compliant with the guarantees, measures and rights established under the Regulation. Through a simple request to the references indicated in paragraph j), you may receive further information about the transfer of your data and the guarantees regarding their protection, as well as about the means of obtaining a copy of such data or the place where they were made available.

9. Data storage duration

Your data will be processed for the duration prescribed in the specific disclosures provided on collecting such data (e.g. registration, the use of the contact us services) [4].
As to the duration of storage of relevant data by means of profiling tools (e.g. cookies), please see our Cookie Policy.

10. Rights of the interested parties

By means of notice to be sent to Entrepreneur Dmytro Zaichenko, ITN 2762719879, Customer Service Department: support@beggani.com (BEGGANI®), you may, at any time, exercise your rights[5] under Articles 15 to 22 of the Regulation, which include the right to know what data we are processing, the procedures we are following and the purposes we are using them for, as well as the right to change the data you have provided us with or to delete it, to request us to limit the use of your data, to request us to receive or to transmit your data, without prejudice to your right to change (any of) your consents thereto. Moreover, you may always oppose that your data be processed, in particular, for purposes related to the marketing or analyses of your preferences.

11. Who you may file a complaint with

We hereby remind you that, in case you consider that the processing of your personal data infringes the regulatory provisions, you may file a complaint with the email: support@beggani.com.

12. The Data Protection Officer

The Data Protection Officer appointed by Entrepreneur Dmytro Zaichenko, ITN 2762719879, may be contacted at the email address: support@beggani.com.

13. Applicable law

This Privacy Policy is governed by Regulation (EU) 679/2016, which ensures that the personal data processing be carried out in accordance with the fundamental rights and freedoms, as well as with the dignity of the interested party, with particular reference to the confidentiality, personal identity and to the right to personal data protection.

14. Review clause

BEGGANI® reserves the right to review, amend or merely update, in whole or in part, at its sole discretion, in any way and/or at any time, without prior notice, this Privacy Policy, also in accordance with any statutory or regulatory amendments to personal data protection provisions. The amendments and updates of the Privacy Policy may be, as the case may require, notified to the users by means of (i) emails to users registered with the Website and/or (ii) published on the Website Home Page, and they shall be binding as of their publication and/or notification. Therefore, please visit this section regularly in order to check the latest publication and update of the Privacy Policy or check your email inbox.

Footnotes:

[1] Should BEGGANI® collect information and personal data, it shall, in each instance, inform its users, in advance, about the purposes for which such data are requested and the modalities by which these data will be used. If necessary, BEGGANI® will request the user’s specific consent to the use of the data. By mere way of example, the personal data that may be requested are the name and surname, the telephone number, the email address and other information that the user accepts to provide in order to use the Website services by filling in a specific registration form. BEGGANI® will use the personal data collected online only for the purposes indicated on registration.

The data concerning the connection to, and the browsing of, the Website (such as the URI-Uniform Resource Identifier addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received as reply, the numerical code related to the reply status from the server (successfully completed, error, etc.) and other parameters related to the operating system used by the user’s device) are collected only for gathering anonymous statistical data on the use of the Website and for monitoring its correct operation; such data are deleted immediately after being processed. Such data may be employed to ascertain any liability in case of cyber-crimes against the Website: otherwise, the data shall be deleted as soon as the time needed to provide the services on Website elapses.

[2] The processing of your data shall be carried out:

- pursuant to Article 6, paragraph 1, letters b) and c) of the Regulation in order to manage your orders and to guarantee the use of the Services (including post-sale services) requested through the Website, to fulfil the related statutory obligations, to manage our customers’ loyalty activities through BEGGANI®, to satisfy any of your requests;

- in accordance with your consent, pursuant to Article 6, paragraph 1, letter a) of the Regulation, to carry out activities related to the marketing and analysis of your preferences.

In any case, the processing shall be performed in compliance with the applicable provisions - and the amendments and/or supplements thereto - issued by the Authority for the Personal Data Protection (which include Fidelity cards and guarantees for consumers. The data protection Authority’s rules for fidelity programmes of 24 February 2005 and the Guidelines for promotional activities and against spam of 4 July 2013, as well as the general decision on cookies Identification of the simplified procedures for the policy and acquisition of consent for the use of cookies of 8 May 2014).

[3] Your data will be disclosed to:

payment management companies;
product shipping and delivery companies;
legal, tax and auditing experts.

[4] Your data collected through the “Contact us” section on the Website shall be processed for the time needed to correctly manage your request and shall be deleted afterwards.

Should you decide to create a customer account by registering with the Account section, your data will be processed for as long as your account is active. You may close your account at any time and your request will be managed immediately or, in case of a pending purchase order, immediately after the execution of the same. Should your account be inactive for three (3) years, BEGGANI® will contact you to find out whether you wish to keep your account active or not. In case you decide to close your account, the latter will be closed, and your data will be deleted.

The data concerning the details of your purchases will, however, be processed for promotional analysis purposes for a maximum term of 7 years following the registration of the same (according to the authorisation issued by the Authority for the Personal Data Protection of 22 December 2015; afterwards, the data will be deleted or anonymised.

Your banking details will be safely stored for the time needed to confirm your order and the related payment, and they will be deleted afterwards. In the case of failure to pay, your data will be processed for the duration of the claim and, afterwards, for a period ranging from 3 to 5 years, according to the type of claim.

The data processed for sending you communications on BEGGANI® branded products, news and events will be stored for three (3) years following the collection date or the date of your last contact with BEGGANI®. Upon maturity of such period, BEGGANI® will contact you to find out whether you wish to continue receiving communications on BEGGANI® products, services, offers, news and events. In the event you revoke your consent provided for marketing purposes, your data shall be promptly deleted.

[5] Articles 15 to 22 of the Regulation provide for specific rights, which include:

the right to obtain confirmation of whether or not your personal data are being processed;
the right to be granted access to your personal data and the information indicated by Article 15 of the Regulation;
the right to correct your inaccurate personal data without undue delay or to supplement your incomplete personal data;
the right to delete your personal data without undue delay;
the right to be granted restrictions on the processing of your personal data;
the right to be informed of any corrections or deletion or restrictions concerning the processing carried out in relation to your personal data;
the right to receive your personal data on an automatic device in a structured, ordinary and legible format;
the right to oppose, at any time, for reasons related to a particular situation, the processing of your personal data.
You have the right to revoke, at any time without prejudice, any consents provided for processing and to oppose our analysis-related activities.

Moreover, pursuant to Article 21 of the Regulation, you shall be entitled, at any time, to oppose, for reasons related to your particular situation, the processing of your personal data carried out to pursue the legitimate interest of the Data Controller pursuant to Article 6, paragraph 1, letter f of the Regulation.

2. ONLINE SHOP PRIVACY POLICY
Article 13 of Regulation (EU) 679/2016 General Data Protection Regulation

a) Who processes your personal data:

ntrepreneur Dmytro Zaichenko, ITN 2762719879, Customer Service Department: support@beggani.com, which deals with the sale of the BEGGANI® branded products in your country, is the company that, in its capacity as Data Controller, collects and processes your personal data, pursuant to Regulation (EU) 679/2016 General Data Protection Regulation (the “Regulation”).

b) Why we process your personal data:

The data you provide us with by completing your purchase order on the www.beggani.com website is required for:

completing the sale of the products selected by you and for fulfilling the agreement signed with you, as well as for exercising our related rights, even in Court;
fulfilling the statutory obligations, the regulation and the Community provisions regarding your purchase (e.g. in tax, accounting, anti-money laundering, anti-fraud matters);
managing the services related to your purchase at the post-sale stage (e.g. Customers Service).
The legal reference for the processing of your data will be the execution of the sale agreement signed with you and its related services, as well as of the fulfilment of the related statutory obligations pursuant to Article 6, paragraph 1, letters b) and c) of the Regulation.

c) Your consent:

The processing of your data will be performed without the need for your consent according to Article 6, paragraph 1, letters b) and c) of the Regulation.

d) All data requested are necessary:

Please provide us with all the data required as “compulsory” (*), since it is necessary for the management of your purchases and related services (e.g. delivery); in case of missing or incomplete compilation, your purchases cannot be completed. Failure to compile the data indicated as “optional” will have no consequences.

Should you provide us with data of third parties (e.g. your relatives, other customers or potential customers), make sure that said third parties have been informed and have consented to the use of their data in accordance with the provisions under this policy.

e) How we process your data:

Your data will be processed mainly electronically in order to manage your purchases.

Your data will be processed pursuant to the applicable laws and, in any case, in a manner that guarantees their protection and confidentiality and prevents unauthorised disclosure, use, alteration or deletion thereof.

f) Duration of your personal data’s storage:

Your data will be processed for the time necessary to manage your purchases and related services (e.g. Customers Service), as well as - limited to the necessary data - for the time required to fulfil the statutory tax and accounting obligations; subsequently, the data will be deleted or anonymised.

g) Who processes your personal data:

Your personal data will not be disclosed. In order to manage your purchases, your data will be made known (within their respective roles) to the people authorised to process it in the CRM, Digital and E-commerce, Finance and Legal Departments of BEGGANI®, as well as, in case you choose to pick up your purchase at the store, to the appointed sales staff. Moreover, your data may be made known to companies that provide us with services[1] useful to manage your purchases and related services.
 

h) Your data is transferred outside the European Union:

In order to allow us to correctly manage your purchases and related services, your personal data

may be subject to transfer to countries outside the European Union that host BEGGANI® stores, the list of which is published on our website www.beggani.com or to countries where our sales related service providers are established.

The applicable provisions establish that your specific consent is not required to transfer data to third party countries since the transfer is carried out based on the adoption of adequate guarantees pursuant to Articles 46 and 47 of the Regulation, such as the adoption of standard contract clauses approved by the European Commission as applied to the relations with the retail companies that manage the BEGGANI® stores worldwide and with our service providers.

The transfer of your data to any other third party country, where applicable, shall be compliant with the guarantees, measures and rights established under the Regulation. Through a simple request to the references indicated in paragraph j), you may receive further information about the transfer of your data and the guarantees regarding their protection, as well as about the means for obtaining a copy of such data or the place where they were made available.

Your rights:
By means of notice to be sent to the internal Officer of the CRM Department, email support@beggani.com, you may, at any time, exercise your rights[2] under the Articles from 15 to 22 of the Regulation, which include the right to know what data we are processing, the procedures we are following and the purposes we are using them for, as well as the right to change the data you have provided us with or to delete it, to request us to limit the use of your data, to request to receive or to transfer your data to another data controller.

j) Who you can file a complaint with:

We hereby remind you that, in case you consider that the processing of your personal data infringes the regulatory provisions, you may file a complaint with support@beggani.com

Footnotes

[1] Your data will be made known, in their capacity as External Processing Officers, to Entrepreneur Dmytro Zaichenko, ITN 2762719879, Customer Service Department: support@beggani.com and the “Customers Service”, also with the use of external service providers;

Your data will be communicated to:

payment management companies;
product shipping and delivery companies;
legal, tax and auditing experts.

[2] Articles from 15 to 22 of the Regulation provide for specific rights, which include:

the right to obtain confirmation of whether or not your personal data is being processed;
the right to be granted access to your personal data and the information indicated by Article 15 of the Regulation;
the right to correct your inaccurate personal data without undue delay or to supplement your incomplete personal data;
the right to delete your personal data without undue delay;
the right to be granted restrictions on the processing of your personal data;
the right to be informed of any corrections or deletion or restrictions concerning the processing carried out in relation to your personal data;
the right to receive your personal data on an automatic device in a structured, ordinary and legible format;
the right to oppose, at any time, for reasons related to a particular situation, the processing of your personal data. 

3. NEWSLETTER PRIVACY POLICY
Regulation (EU) 679/2016 General Data Protection Regulation

a) Who processes your personal data:

Entrepreneur Dmytro Zaichenko, ITN 2762719879, Customer Service Department: support@beggani.com (BEGGANI®), is the company that, in its capacity as Data Controller, collects and processes your personal data, pursuant to Regulation (EU) 679/2016 General Data Protection Regulation (the “Regulation”).

b) Why we process your personal data:

The data that you provide us with by filling out this electronic form is necessary to allow you to subscribe to the BEGGANI® Newsletter and update you by sending you promotional material (via email) on BEGGANI® branded products, services (e.g. purchase methods, home delivery, etc.), initiatives and events (e.g. next openings of BEGGANI® stores), as well as to carry out market researches (to better know your interests and to improve our offer).

If you indicate your country to us, we will send you communications regarding events and initiatives related thereto.

The legal basis for the processing of your data will be your consent according to Article 6, paragraph 1, letter a) of the Regulation.

c) Your consent:

In order to be able to keep you updated on our products, services, initiatives and events, to send you promotional material, including customised material based on your country, or to carry out market researches, we need your explicit consent (pursuant to Article 6, paragraph 1, letter a) of the Regulation). Should you not provide us with your consent, we will not be able to proceed with your subscription to our Newsletter. You may freely revoke your consent (see letter h) of the policy) without prejudice to the lawfulness of the data processing prior to revocation, by simply following the link enclosed in all our Newsletters or by writing to support@beggani.com.

d) What data is required:

Please provide us with all the data required as “compulsory” (*), since it is necessary for your subscription to our Newsletter; in the case of missing or incomplete compilation, the subscription cannot be completed. If you decide not to indicate your country (an “optional” data), this will simply mean we are unable to send you communications on events and initiatives related to your country.

h) Your data is transferred outside the European Union:

In order to permit us to correctly manage our Website and the Newsletter service requested by you, your personal data may be subject to transfer to non-European Union countries that host BEGGANI® stores, the list of which is published on our website www.beggani.com, or where our sale service providers are established.

The applicable provisions establish that your specific consent is not necessary to transfer data to third countries since the transfer is carried out based on the adoption of adequate guarantees pursuant to Articles 46 and 47 of the Regulation, such as the adoption of standard contract clauses approved by the European Commission as applied to the relations with the retail companies that manage the BEGGANI® stores worldwide and with our service providers.

The transfer of your data to any other third party countries, where applicable, shall be compliant with the guarantees, measures and rights established under the Regulation. Through a simple request to the references indicated in paragraph j), you may receive further information about the transfer of your data and the guarantees regarding their protection, as well as about the means for obtaining a copy of such data or the place where they were made available.

Your rights:
By means of notice to be sent to the internal Officer of the CRM Department, email support@beggani.com, you may, at any time, exercise your rights[2] under Articles 15 to 22 of the Regulation, which include the right to know what data we are processing, the procedures we are following and the purposes we are using them for, as well as the right to change the data you have provided us with or to delete it, to request us to limit the use of your data, to request us to receive or to transfer your data to another data controller, without prejudice to your right to change or to revoke your consents.

Moreover, you may always oppose that your data be processed, in particular, for marketing purposes.

j) Who you may file a complaint with:

We hereby remind you that, if you think that the processing of your personal data infringes the regulatory provisions, you may file a complaint with support@beggani.com

k) The Data Protection Officer:

The Data Protection Officer appointed by Entrepreneur Dmytro Zaichenko, ITN 2762719879 may be contacted at the following email address support@beggani.com.

Footnotes

[1]Your data will be made known to the following recipients, in their capacity as External Processing Officers:

(1) to companies empowered to process, manage and send newsletters and promotional material;

(2) to companies that organise and manage market researches on our behalf;

(3) to companies empowered to manage our website and the related IT archives.

The names of all the External Processing Officers may be requested via email to be sent to support@beggani.com

[2]Articles 15 to 22 of the Regulation provide for specific rights, which include:

the right to obtain confirmation of whether or not your personal data are being processed;
the right to be granted access to your personal data and the information indicated by Article 15 of the Regulation;
the right to correct your inaccurate personal data without undue delay or to supplement your incomplete personal data;
the right to delete your personal data without undue delay;
the right to be granted restrictions on the processing of your personal data;
the right to be informed of any corrections or deletion or restrictions concerning the processing carried out in relation to your personal data;
the right to receive your personal data on an automatic device in a structured, ordinary and legible format;
the right to oppose, at any time, for reasons related to a particular situation, the processing of your personal data.
You have the right to revoke, at any time without prejudice, the consents provided for any processing and to oppose our analysis-related activities.

Moreover, pursuant to Article 21 of the Regulation, you shall be entitled, at any time, to oppose, for reasons related to your particular situation, the processing of your personal data carried out to pursue the legitimate interest of the Data Controller pursuant to Article 6, paragraph 1, sub-para. f) of the Regulation.
e) How we process your data:

Your data will be processed electronically pursuant to the applicable laws, in accordance with the prescriptions under the provisions in force - as subsequently amended and/or supplemented - issued by the Authority for Personal Data Protection (which include Guidelines for promotional activities and against spam issued on 4 July 2013) and, in any case, in a manner that guarantees their protection and confidentiality and prevents unauthorised disclosure, use, alteration or deletion thereof.

f) Duration of your personal data’s storage:

Your data will be processed for the duration of your subscription to our Newsletter service or - in any case - until you revoke your consent (which you may request at any time, also by following the link enclosed in all our Newsletters); subsequently, the data will be deleted or anonymised.

g) Who processes your personal data:

Your personal data will not be disclosed. In order to allow you to receive our Newsletter and to be contacted by BEGGANI®, your data may be made known (within their respective roles) to people authorised to process it in the CRM, Digital and E-Commerce Department of BEGGANI®, as well as to the companies that provide us with services[1] useful for the management of our website or that carry out marketing activities on our behalf.

4. BEGGANI ACCOUNT PRIVACY POLICY
Article 13 of Regulation (EU) 2016/679 - General Data Protection Regulation

By registering with BEGGANI ACCOUNT, Entrepreneur Dmytro Zaichenko, ITN 2762719879, Customer Service Department: support@beggani.com (BEGGANI®), as Data Controller, will process the data you provide us by filling in the present electronic form (e.g. title, name, surname, e-mail, age range, country of residence, nationality), to create your personal area within the BEGGANI® web site, allow you to join our loyalty program and access the services and facilities reserved to the registered members and manage your purchases faster.

Furthermore, if you wish to provide your consent, Entrepreneur Dmytro Zaichenko, ITN 2762719879, Customer Service Department: support@beggani.com may use your data, including those related to your purchases (e.g., boutique where the sale took place, number, type and price of purchased products), those eventually communicated to BEGGANI® by third parties authorized resellers and/or provided by you when visiting BEGGANI® stores (e.g. age, favourite products, colours and materials, style, hobbies, most visited countries, size), in order to:

learn more about your purchase habits and your preferences, so as to customize our offer of products and services in the BEGGANI® world and offer you a tailored treatment at each BEGGANI® store;
contact you, also by sending customized communications (e.g. newsletter, mail, e-mail, calls via operator, text messages, instant messaging such as WhatsApp, WeChat and Social networks in general, posts, messages or communication on initiatives on social networks, etc.) and keep you updated on BEGGANI® brand products, services (e.g. new purchasing methods, home delivery, etc.), initiatives and events), or to have you participate in market surveys.

Should you not wish to provide your consent you can still subscribe to BEGGANI ACCOUNT and take advantage of the related services offered by us. Your consent can be freely withdrawn.

In general, personal data will be retained for no longer than is necessary for the purposes for which the data were collected. Your data necessary for managing your purchases and the related services will be processed for the time necessary to reach such purposes and, subsequently, to comply with the related legal requirements (e.g. tax and accounting requirements), after which the data will be deleted or anonymized.

For customer loyalty, your data will be processed for the entire duration of your registration to our loyalty program.

Processing of data collected for the purposes of contacting you, also by sending customized communications on our products, services and events and to participate in market surveys and to know your preferences will be based on the consents you will provide us with, which can be in any case withdrawn at any given time. With limited reference to data collected for purposes of learning about your habits and preferences, data will be retained for a maximum period of 7 years. At the time when consent will be revoked or, as the case may be, when the term above mentioned expires, data will be deleted or anonymized.

Please note that by sending an e-mail to support@beggani.com you will always be able to withdraw from your registration with BEGGANI ACCOUNT, access your personal data, update and delete them, withdraw or modify the consent you provided us with, and receive or ask for the transmission of your data to another data controller. Furthermore you will always be able to object at any time to the processing of your personal data for marketing purposes and/or for analysis of your preference purposes; you will have the right to lodge a complaint with support@beggani.com.

If you would like more detailed information, please read the full text that follows in the BEGGANI ACCOUNT Extended Privacy Policy.

Article 13 of Regulation (EU) 2016/679 - General Data Protection Regulation

a) Who processes your personal data:

Entrepreneur Dmytro Zaichenko, ITN 2762719879, Customer Service Department: support@beggani.com (BEGGANI®), is the company which, as Data Controller, collects and processes your personal data, pursuant to Regulation (EU) 2016/679 General Data Protection Regulation (the "Regulation").

b) How we collect and why we process your data:

The data you are providing to us:

- by filling in the BEGGANI ACCOUNT electronic form

- the data relating to your purchases or data provided by you when visiting BEGGANI® stores (e.g. favourite products, colours and materials, style, hobbies, most visited countries, size)

- those eventually communicated to BEGGANI® by third parties authorized resellers will be processed, as the case, in order:

to allow you to access to all the services and facilities reserved by BEGGANI® to the registered members of its loyalty program, even though the creation of your personal online account, such as: to manage your purchases faster, to take advantage, depending on the initiatives/campaigns undertaken from time to time by BEGGANI®, of benefits and free services (e.g. personal shopping, tailoring, home delivery, gadget and/or discounts on your birthday and/or based on your purchase threshold), check your purchase history, create your Wish Lists and view on your online profile – if you wish – also your purchase history at Fendi stores and the Wish Lists created for you at the stores;
to analyze your interests, preferences and purchase habits, also on the basis of the data provided by you when visiting and purchasing at BEGGANI® stores and on BEGGANI® web site, in order to allow BEGGANI® to customize its offer of products and services and allow you to receive a tailored treatment at each BEGGANI® store;
to keep you updated by sending you promotional material, also customized (e.g. by mail, e-mail, calls via operators, text message, instant messaging, such as WhatsApp, WeChat and Social networks in general), posts, messages or communications on initiatives on social networks, etc.) on BEGGANI® brand products (e.g. clothing, leather goods, accessories, home, etc.), services of BEGGANI® world (e.g. purchasing methods, home delivery, etc.), initiatives and events organized by BEGGANI® or to which BEGGANI® adheres (e.g. new opening of BEGGANI® stores), as well as to have you participate in market surveys (in order to learn more about your interests and to improve our offer);
to send you our Newsletter on BEGGANI® brand products.
The legal basis [1] for the processing of your data will be, depending on the case, the performance of the contract or your consent, if provided.

c) Your consent:

In order to learn more about your interests and purchase preferences (so as to improve our offer of services and products), keep you updated on our products, services, initiatives and events, send you promotional material, even customized, or have you participate in market surveys (purposes no. 2, 3 and 4 paragraph b) we need your explicit consent. Should you not wish to provide your consent you can still subscribe to BEGGANI ACCOUNT and take advantage of the facilities offered to the registered members (purpose no.1 paragraph b). Your consent can be freely withdrawn (as set forth in lett. j) of this Privacy Notice) at any time simply by accessing your personal area in BEGGANI ACCOUNT or even by sending an e-mail to support@beggani.com; the withdrawal of your consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Please note that, in case of withdrawal of your consent for sending updates, promotional communications or market surveys (purposes no. 3 and 4 paragraph b), you will no longer be the recipient of any type of communication. If you wish, you may withdraw your consent only to the receipt of communications via electronic means (e.g. newsletter, e-mail, sms, instant messaging), continuing to receive commercial communications only by mail or calls via operators, if provided and vice versa.

Which data are processed and which ones are mandatory
For the purposes indicated above, BEGGANI® shall process the following categories of personal data:

Personal details (title, name, surname, date of birth and nationality);
Contact details (Country/Region of residence, e-mail address, mobile telephone number);
Data related to the delivery of goods (address, telephone number, gift box);
Data related to the purchases you made (boutique where you made the purchase, number, type and price of products purchased);
Additional personal data useful to carry out marketing and analysis activities (age, favourite product categories, favourite colour, style, other brands purchased, hobbies, most visited countries, as the client knows Fendi, size, measures, marital status, number of children, anniversary, notes related to purchase preferences or special needs expressed by the client – e.g. favourites materials), if you have a Personal Sales Assistant, BEGGANI® events to which you participated.
We ask you to provide all the data requested as “mandatory” (e.g. name, surname, e-mail address, date of birth, address) as needed for your registration and creation of your profile in BEGGANI ACCOUNT; in case of missing or incomplete compilation of such data, your registration will not be completed. Failure to provide the data marked as “optional” (that are the additional personal data useful to carry out the marketing and analysis activities listed above), will simply not allow us to use your data for the purposes no. 2 e 3 paragraph b) for which you have provided your consent; any refusal will have no consequences on your possibility of proceeding with the purchase of our products, but it will not be possible for us to inform you about our products and services, our initiatives and events or analyze your preference and interests.

If you provide personal data of third parties (e.g. your family members, other customers or potential customers) you must ensure that such third parties are informed and have consented (if necessary) for their data processing according with this Privacy Notice.

e) How do we process your data:

Your data will be processed with and without the aid of electronic tools and stored on servers located in Italy. In particular, if you provide us with your consent to use your data for the purposes no. 2 and 3 paragraph b) above, your data will be organized and processed using automated methods based on your preferences, enabling us to know your interests and propensities to purchase (e.g. by checking which products you purchased), adjust our products and services offer and update you on our products (e.g. new collections), services (e.g. purchase methods, home delivery, etc.), initiatives and events (e.g. invitations to events organized by BEGGANI® or to which BEGGANI® adheres), send promotional material that can also meet your tastes and interests (e.g. if you have purchased women's footwear in the past, we could send you our new women's catalogue, or send you promotions related to matching products or the same style), or contact you to participate in market surveys (e.g. through interviews, telephone contact, e-mail, etc.).

We specify that none of our analysis activities of your data and preferences will be based solely on automated processing, but will always involve the intervention and evaluation of our persons in charge of the processing.

The data will always be processed in compliance with the current legislation and, in any case, in order to guarantee their security and confidentiality and prevent their disclosure or unauthorized use, alteration or destruction.

f) Data entry into our CRM (Customer Relationship Management) system:

The insertion of your data into BEGGANI® CRM system – for the purposes no. 2), 3) and 4) of paragraph b) above - is optional and will only take place if you provide us with your consent to the processing of your data. The insertion of your data into our CRM system, will entail the possibility of reading, inserting and amending them by employees and staff (at the offices and stores) of BEGGANI® and other retail companies of BEGGANI® brand products in Italy and abroad (each for its respective field of competence) specifically authorized to data processing, pursuant to art. 29 of the Regulation.

g) How long do we store your data:

In general, personal data will be retained for no longer than is necessary for the purposes for which the data were collected. For the purposes No. 1, 2 and 3 paragraph b) your data will be processed, as the case may be, for the entire duration of your registration to our loyalty program and on the basis of the consents you will provide us with, which can be withdrawn at any given time (as set forth in lett. j) of this Privacy Notice). With limited reference to data collected for purposes No. 2 paragraph b) data will be processed for a maximum period of 7 years (pursuant to the Data Protection Authority’s decision dated 22 December 2015). At the time when consent will be revoked or, as the case may be, when the term above mentioned expires, data will be deleted or anonymized.

Your data necessary to send the Newsletter on BEGGANI® brand products (purpose No. 4 paragraph b) will be processed until your request for cancellation from our Newsletter; after which they will be deleted or anonymized.

h) By whom your data are processed:

Your data will not be disseminated. To manage your registration with BEGGANI ACCOUNT and, if you give your consent, to pursue the further purposes no. 2, 3 and 4 paragraph b), your data will come to knowledge (limited to the respective field of competence) of the persons in charge of the processing at BEGGANI® CRM Department and of the companies acting as external Data Processors which provide us with services useful for the management of our website, of the purchases or that carry out marketing activities on our behalf[2].

i) Your data are transferred to Extra EU Country:

To allow us to provide you with a tailored service also in the event of purchases made at BEGGANI® stores abroad, your personal data may be transferred to the extra-EU countries where BEGGANI® stores are located.

The transfer of your data will take place in full compliance with the safeguards, measures and rights provided by the privacy legislation [3]. By simple request to be made to the contacts indicated in paragraph j), you will receive more information on the transfer of your data and on the safeguards provided for their protection.

j) Which are your rights:

By sending an email to BEGGANI® CRM Department, e-mail support@beggani.com, Entrepreneur Dmytro Zaichenko, ITN 2762719879, you will be able to exercise at any time the rights [4] provided for by articles from 15 to 22 of the Regulation, such as access which data we are processing, with which methods and for what purposes we process them, rectify the data you provided to us or delete them, ask us to restrict the processing of your data, request to receive or ask for the transmission of your data to another data controller, without prejudice to the possibility of changing or withdrawing your consent.

In particular, you have the right to withdraw at any time the consents provided to the processing and to object to the processing of your personal data especially for marketing purposes and/or for the analysis of your preference.

We remind you that, by sending an e-mail to support@beggani.com you will be able to withdraw your registration with BEGGANI ACCOUNT.

k) Who you can contact to lodge a complaint:

We remind you that, should you consider the processing of your data infringes the Regulation, you may in any event lodge a complaint with support@beggani.com.

Data Protection Officer (DPO):
You can contact the Data Protection Officer appointed by Entrepreneur Dmytro Zaichenko, ITN 2762719879 at the e-mail address support@beggani.com.

Footnotes

[1] The processing of your data:

- for purposes listed under point 1 paragraph b) shall take place without your consent, pursuant to art. 6, paragraph 1, letter b) of the Regulation;

- for purposes listed under points 2, 3, and 4 paragraph b) shall take place based on your consent, pursuant to art. 6, paragraph 1, letter a) of the Regulation.

[2] Your data may become to knowledge, as external Data Processors, of the following recipients:

retail companies which manage BEGGANI® stores in Italy and abroad (if you have made purchases in our stores);
companies which carry out the analysis of your purchases on our behalf;
companies responsible for managing BEGGANI® "Customer Service" on our behalf;
companies in charge of processing, managing and sending newsletters and promotional material;
companies that organize and manage market research and surveys on our behalf;
companies entrusted with the management of our website and the related databases;
companies that deal with the management and technical maintenance of the CRM system.
The names of all the external Data Processors can be requested via email to support@beggani.com.

[3] Pursuant to the applicable legislation, we do not need your specific consent to transfer your data to third countries since the transfer is made on the basis of appropriate safeguards pursuant to articles 46 and 47 of the Regulation, such as the adoption of the standard data protection contractual clauses adopted by the EU Commission as it happens in the relationships with the retail companies that manage the BEGGANI® stores in the world.

The transfer of your data to any additional third countries, if necessary, will take place in full compliance with the safeguards, measures and rights as provided for by the Regulation. By simple request to be made to the contacts indicated in paragraph (j), you will receive more information on the transfer of your data and on the safeguards provided for their protection as well as on the means to obtain a copy of the data or the place where they were made available.

[4] The articles from 15 to 22 of the Regulation recognize specific rights including:

obtaining confirmation as to whether or not personal data concerning you is being processed;
obtaining access to your personal data and to the information set out in Article 15 of the Regulation;
obtaining the rectification of the inaccurate personal data that concern you without undue delay or the supplementing of incomplete personal data;
obtaining the erasure of the personal data that concern you without undue delay;
obtaining the restriction of processing the personal data that concern you;
being informed of any rectifications or erasures or restrictions of processing in relation to the personal data that concern you;
receiving in a structured, commonly used and machine-readable format the personal data that concern you;
objecting at any time, on grounds associated with your specific situation, to the processing of the personal data that concern you.
In particular, you have the right to withdraw at any time the consents provided to the processing and to object to our market analysis activities.

5. LOCALISE ME PRIVACY POLICY
Article 13 of Regulation (EU) 679/2016 General Data Protection Regulation

a) Who processes your personal data:

Entrepreneur Dmytro Zaichenko, ITN 2762719879, Customer Service Department: support@beggani.com (BEGGANI®), is the company that, in its capacity as Data Controller, collects and processes your personal data, pursuant to Regulation (EU) 679/2016 General Data Protection Regulation (the “Regulation”).

b) Why we process your personal data:

We process the data related to your location through our website www.beggani.com in order to allow you to identify the nearest BEGGANI® stores.

The legal basis for the processing of your data will be your consent according to Article 6, paragraph 1, letter a) of the Regulation.

c) Your consent:

The recognition of your geographical location requires your consent that will be requested for when activating the “Localise me” service on the BEGGANI® website.

d) How, and for what duration, we process your personal data:

Your data will be processed electronically pursuant to the applicable laws and, in any case, in a manner that guarantees their protection and confidentiality and prevents unauthorised disclosure, use, alteration or deletion thereof.

In order to permit you to use the “Localise me” service, namely the possibility to identify the location of the nearest BEGGANI® stores, our website will access the data related to your location in real time (geolocalisation data), without accessing any other personal data stored on your device. The data found will be deleted once you have finished browsing our website.

e) Who processes your personal data:

Any data related to your geographical location during the use of the “Localise me” service will not be disclosed or communicated to third parties. No party appointed by BEGGANI® may access such data, neither in real time or subsequently.

f) Your rights:

By means of notice to be sent to the internal Officer of the CRM Department, email support@beggani.com Entrepreneur Dmytro Zaichenko, ITN 2762719879 you may, at any time, exercise your rights[1] under Articles from 15 to 22 of the Regulation, among which is the right to know what data we are processing, the procedures we are following and the purposes we are using them for, as well as the right to change the data you have provided us with or to delete them, to request us to limit the use of your data, to request us to receive or to transmit your data to another data controller, without prejudice to your right to change or to revoke your consents.

g) Who you may file a complaint with:

We hereby remind you that, if you think that the processing of your personal data infringes the regulatory provisions, you may file a complaint with support@beggani.com.

h) The Data Protection Officer:

The Data Protection Officer appointed by the Data Protection Officer appointed by BEGGANI® may be contacted at the following email address support@beggani.com.

Footnotes

[1] Articles 15 to 22 of the Regulation provide for specific rights, which include:

the right to obtain confirmation of whether or not your personal data are being processed;
the right to be granted access to your personal data and the information indicated by Article 15 of the Regulation;
the right to correct your inaccurate personal data without undue delay or to supplement your incomplete personal data;
the right to delete your personal data without undue delay;
the right to be granted restrictions on the processing of your personal data;
the right to be informed of any corrections or deletion or restrictions concerning the processing carried out in relation to your personal data;
the right to receive your personal data on an automatic device in a structured, ordinary and legible format;
the right to oppose, at any time, for reasons related to a particular situation, the processing of your personal data.
You have the right to revoke, at any time, the consent provided for any processing.

Moreover, pursuant to Article 21 of the Regulation, you shall be entitled to oppose at any time, for reasons related to your particular situation, the processing of your personal data carried out to pursue the legitimate interest of the Data Controller pursuant to Article 6, paragraph 1, letter f) of the Regulation.

6. CONTACT US PRIVACY POLICY

Art. 13 of the Regulation (EU) 2016/679 General Data Protection Regulation

a) Who processes your personal data:

Entrepreneur Dmytro Zaichenko, ITN 2762719879, Customer Service Department: support@beggani.com (BEGGANI®), is the company which, as Data Controller, collects and processes your personal data, pursuant to Regulation (EU) 2016/679 General Data Protection Regulation (the "Regulation").

b) How we collect and why we process your data:

The data you provide to us by filling in the electronic form available in the section “Contact us” (title, name, surname, date of birth, e-mail address, mobile phone number, country of residence) or by using the contact services through e-mail or phone available on www.beggani.com will be processed in order to:

1. reply to and handle your request or claim.

The legal basis for the processing of your data will be the management of your requests pursuant to art. 6, paragraph 1, letter b) of the Regulation.

c) Your consent:

Your consent is not required in order to manage your request or claim pursuant to art. 6, paragraph 1, letter b) of the Regulation.

Which data are processed and which ones are mandatory
For the purposes indicated above, BEGGANI® shall process the following categories of personal data:

- Personal details (title, name, surname, date of birth);

- Contact details (Country/Region of residence, e-mail address, mobile telephone number);

- Data related to the purchases you made, only in case the request relates to the purchases you made (boutique where you made the purchase, number, type and price of the purchased products).

We ask you to provide all the data requested as “mandatory” (e.g. title, name, surname, e-mail address, mobile telephone number, Country of residence) as needed in order to better manage your request; in case of missing or incomplete filling in of such data, we could not be able to process your request.

If you provide personal data of third parties (e.g. your family members, other customers or potential customers) you must ensure that such third parties are informed and have consented (if necessary) for their data processing according with the this Privacy Notice.

e) How do we process your data:

Your data will be processed with and without the aid of electronic tools and stored on servers located in Italy.

f) How long do we store your data:

In general, personal data will be retained for no longer than is necessary for the purposes of duly handle your request.

g) By whom your data are processed:

Your data will not be disseminated. For the purposes of managing your request (within the limits of their respective tasks) data will come to knowledge of the persons in charge of the processing at BEGGANI® CRM Department, Retail Department and other Departments in charge of handling your requests, your purchase and relevant services; your data will also be processed by companies that provide us with services[1] to manage our web site, the clients services, the purchases or that carry out related services on our behalf.

h) Your data are transferred to Extra EU Country:

To allow us to provide you with a tailored service also in the event of purchases made at BEGGANI® stores abroad, your personal data may be transferred to the extra-EU countries where BEGGANI® stores are located.

The transfer of your data will take place in full compliance with the safeguards, measures and rights as provided for by the data protections laws [2]. By simple request to be made at the contacts indicated in paragraph i), you will receive more information on the transfer of your data and on the safeguards provided for their protection.

i) Which are your rights:

By sending an email to BEGGANI® CRM Department, e-mail support@beggani.com, Entrepreneur Dmytro Zaichenko, ITN 2762719879 you will be able to exercise at any time the rights [3] provided for by articles from 15 to 22 of the Regulation, such as access which data we are processing, with which methods and for what purposes we process them, rectify the data you provided to us or delete them, ask us to restrict the processing of your data, request to receive or ask for the transmission of your data to another data controller.

In particular, you have the right to withdraw at any time the consents provided to the processing (if any) and to object to the processing of your personal data especially for marketing purposes and/or for the analysis of your preference.

j) Who you can contact to lodge a complaint:

We remind you that, should you consider the processing of your data infringes the Regulation, you may in any event lodge a complaint with support@beggani.com.

k) Data Protection Officer (DPO):

You can contact the Data Protection Officer appointed by BEGGANI® at the e-mail address support@beggani.com.

Footnotes

[1]

Your data may become to knowledge, as external Data Processors, of the following recipients:

retail companies which manage BEGGANI® stores (if you have made purchases in our stores);
companies which carry out the analysis of your purchases on our behalf;
companies responsible for managing BEGGANI® "Customer Service" on our behalf;
companies entrusted with the management of our website and the related databases;
companies that deal with the management and technical maintenance of the CRM system.
The names of all the external Data Processors can be requested via email to support@beggani.com.

[2]

Pursuant to the applicable legislation, we do not need your specific consent to transfer your data to third countries since the transfer is made on the basis of appropriate safeguards pursuant to articles 46 and 47 of the Regulation, such as the adoption of the standard data protection contractual clauses adopted by the EU Commission as it happens in the relationships with the Retail companies that manage the BEGGANI® stores in the world.

The transfer of your data to any additional third countries, if necessary, will take place in full compliance with the safeguards, measures and rights as provided for by the Regulation. By simple request to be made to the contacts indicated in paragraph i), you will receive more information on the transfer of your data and on the safeguards provided for their protection as well as on the means to obtain a copy of the data or the place where they were made available.

[3] The articles from 15 to 22 of the Regulation recognize specific rights including:

obtaining confirmation as to whether or not personal data concerning you is being processed;
obtaining access to your personal data and to the information set out in Article 15 of the Regulation;
obtaining the rectification of the inaccurate personal data that concern you without undue delay or the supplementing of incomplete personal data;
obtaining the erasure of the personal data that concern you without undue delay;
obtaining the restriction of processing the personal data that concern you;
being informed of any rectifications or erasures or restrictions of processing in relation to the personal data that concern you;
receiving in a structured, commonly used and machine-readable format the personal data that concern you;
objecting at any time, on grounds associated with your specific situation, to the processing of the personal data that concern you.
In particular, you have the right to withdraw at any time the consents provided to the processing (if any) and to object to our market analysis activities.

7. LEGAL GUARANTEE

(1) BEGGANI® shall be liable for any lack of conformity in accordance with the legal provisions illustrated below.

BEGGANI® responsibility refers to the so named “legal guarantee” of the seller, which applies to any lack of conformity of the products provided that (1) such lack of conformity appears within two years from the date of delivery of the products and, (2) the lack of conformity is communicated to BEGGANI® within two months from the appearance of the same lack of conformity.

To request the enforcement of the legal guarantee, the Customer shall be entitled to contact BEGGANI® through its Customer Services: support@beggani.com.

BEGGANI® shall evaluate the products on the basis of the information collected as sent by the Customer (written description, pictures etc.) and shall give to the Customer a prompt feedback also informing the latter on any additional investigation is necessary to be performed on the products in order to ascertain any lack of conformity;
or,
go to any BEGGANI® Boutique, with the relevant product and the sale receipt.
In this second case (as occurs in the scenario described in point 1 above, when BEGGANI® carries out further investigation and analysis on the product) BEGGANI® shall perform all the necessary investigation to the purpose of ascertaining the extent of the lack of conformity and, as a consequence thereof, shall give its feedback to the Customer also informing the latter on any lack of conformity and, to the extent applicable, on the enforcement of the Legal Guarantee and of the possible remedies as illustrated below and on the relevant timelines.

In particular, should a lack of conformity be ascertained, the Customer shall be entitled to request, at his/her discretion, one of the following remedies:

the repair of the products,
or alternatively,

the replacement of the products,
to the extent that the elected remedy is neither objectively impossible nor disproportionate compared to the other.

A remedy shall be considered “disproportionate” if it imposes to the seller costs which, compared with the alternative remedy, are unreasonable taking into account: (1) the value of the product without the lack of conformity; (2) the significance of the lack of conformity; (3) the possibility that the alternative remedy could be enforced without significant inconvenience to the Customer.

Furthermore, where:

the repair or the replacement of the products are impossible or disproportionate; or
the repair or the replacement already performed have caused significant inconvenience for the Customer; or
the seller has not repaired nor replaced the product within a reasonable time;
the Customer shall be entitled to request at his/her sole discretion:
the termination of the contract, with the subsequent return of the product to BEGGANI® and the reimbursement by the latter of the price paid by the Customer; or the reduction of the price paid by the Customer for the product.
The Customer shall not be entitled to the legal guarantee where:
the products have been previously repaired or impaired by a third party, or
the lack of conformity of the products appeared later than the fourteen (14) days term from the delivery and/or the request of repair or replacement of the product or products has been communicated to BEGGANI® later than the fourteen (14) days period from the appearance of the same lack of conformity.