Flair Plc’s Website Privacy Policy

Flair Leisure Products Plc (“Flair”), a Giochi Preziosi SpA subsidiary, with registered offices at Anne Boleyn House 9-13 Ewell Road, Cheam, Sutton, Surrey, SM3 8BZ, is committed to protecting the online privacy of the users of this website. As such, this Privacy Policy has been written in order to allow you to understand Flair’s policy regarding your privacy, as well as how your personal information will be handled when using the Website. This Privacy Policy will also provide you with information so that you are able to consent to the processing of your personal data in an explicit and informed manner, where appropriate.

In general, any information and data which you provide to Flair over the Website, or which is otherwise gathered via the Website by Flair, in the context of the use of Flair’s services, as better defined in Section 3 below, will be processed by Flair in a lawful, fair and transparent manner. To this end, and as further described below, Flair takes into consideration internationally recognised principles governing the processing of personal data, such as purpose limitation, storage limitation, data minimisation, data quality and confidentiality.

CONTENTS

1.        Data controller

2.        Personal Data processed

a.        Name, contact details and other Personal Data

b.        Special categories of Personal Data

c.        Other persons’ Personal Data

d.        Browsing data

e.        Cookies

3.        Purposes of processing

4.        Grounds for processing and mandatory or discretionary nature of processing

5.        Recipients of Personal Data

6.        Transfer of Personal Data

7.        Retention of Personal Data

8.        Data subjects’ rights

9.        Amendments

1. Data controller

Flair, as identified at the top of this Privacy Policy, is the Data Controller regarding all personal data processing carried out through the Website.

2. Personal Data processed

When you use the Website, Flair will collect and process information regarding you (as an individual) which allows you to be identified either by itself, or together with other information which has been collected. Flair may also be able to collect and process information regarding other persons in this same manner, if you choose to provide it to Flair.

This information may be classified as “Personal Data” and can be collected by Flair both when you choose to provide it (e.g., when you contact us through the addresses provided on the Website or give us a Feedback in the specific form) or simply by analysing your behaviour on the Website.

Personal Data which can be processed by Flair through the Website are as follows:

a. Name, contact details and other Personal Data

When you contact us via an email address provided in our website, you may submit information about yourself, such as your name and your email address and you can write us a message that may contain further information.

In addition, whenever you communicate with Flair through the contact details provided in the Website, such as the Consumer Helpline, Flair may collect additional information which you choose to provide.

b. Special categories of Personal Data

The email addresses you find in the “Contact Us” part of the Website allow you to communicate some information to Flair.

Where an email has completely free fields (blank heading and body message), you might use it to disclose (inadvertently and indirectly or not) more sensitive categories of Personal Data, such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The content you email across to Flair in these fields may also (inadvertently or not) include other types of sensitive information relating to you, such as your genetic data, biometric data or data concerning your health, sex life or sexual orientation.

Flair asks that you do not disclose any sensitive Personal Data via email, unless you consider this to be strictly necessary. As it is totally optional to provide this information, if you nonetheless choose to do so, please mind that Flair requires your explicit consent to process this sort of Personal Data (which can be provided, e.g., by declaring in message that you “explicitly consent to the processing of my special categories of personal data”).

c. Other persons’ Personal Data

As mentioned in the previous section, where you can write an email to Flair. These messages and content may (inadvertently or not) include Personal Data related to other persons.

In any situation where you decide to share Personal Data related to other persons, you will be considered as an independent data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify Flair against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, brought by the third parties whose information you provide through the Website/Email.

As Flair does not collect this information directly from these third parties (but rather collects them, indirectly, from you), you must make sure that you have these third parties’ consent before providing any information regarding them to Flair; if not, then you must make sure there is some other appropriate grounds on which you can rely to lawfully give Flair this information.

d. Browsing data

The Website’s operation, as is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While Flair does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information must also be considered Personal Data.

This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on.

These data are used to compile statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website. Save for this last purpose, these data are not kept for more than 7 business days.

e. Cookies

- Definitions, characteristics, and application of standards

Cookies are small text files that may be sent to and registered on your computer by the websites you visit, to then be re-sent to those same sites when you visit them again. It is thanks to these cookies that those websites can “remember” your actions and preferences (e.g., login data, language, font size, other display settings, etc.), so that you do not need to configure them again when you next visit the website, or when you change pages within a website.

Cookies are used for electronic authentication, monitoring of sessions and storage of information regarding your activities when accessing a website. They may also contain a unique ID code which allows tracking of your browsing activities within a website, for statistical or advertising purposes. Some operations within a website may not be able to be performed without the use of cookies which, in certain cases, are technically necessary for operation of the website.

When browsing a website, you may also receive cookies from websites or web servers other than the website being visited (i.e., “third-party cookies”).

There are various types of cookies, depending on their characteristics and functions, which may be stored on your computer for different periods of time: “session cookies”, which are automatically deleted when you close your browser, and “persistent cookies”, which will remain on your device until their pre-set expiration period passes.

According to the law which may be applicable to you, your consent may not always be necessary for cookies to be used on a website. In particular, “technical cookies” – i.e. cookies which are only used to send messages through an electronic communications network, or which are needed to provide services you request – typically do not require this consent. This includes browsing or session cookies (used to allow users to login) and function cookies (used to remember choices made by a user when accessing the website, such as language or products selected for purchase).

On the other hand, “profiling cookies” – i.e., cookies used to create profiles on users and to send advertising messages in line with the preferences revealed by users while browsing websites – typically require specific consent from users, although this may vary according to the applicable law.

- Types of cookies used by the Website

The Website uses the following types of cookies:

• Browsing or session cookies, which are strictly necessary for the Website’s operation, and/or to allow you to use the Website’s content and Services.

• Analytics cookies, which allow Flair to understand how users make use of the Website, and to track traffic to and from the Website.

• Function cookies, which are used to activate specific Website functions and to configure the Website according to your choices (e.g., language), in order to improve your experience.

• Profiling cookies, which are used to observe the preferences you reveal through your use of the Website and to send you advertising messages in line with those preferences.[ICTLC1] [SJ2] 

Flair also uses third-party cookies – i.e. cookies from websites / web servers other than the Website, owned by third parties. These third parties will either act as independent data controllers from Flair regarding their own cookies (using the data they collect for their own purposes and under terms defined by them) or as data processors for Flair (processing personal data on Flair’s behalf). For further information on how these third parties may use your information, please refer to their privacy policies:

• Google

• https://www.google.com/policies/privacy/partners/

• https://tools.google.com/dlpage/gaoptout[ICTLC3] [SJ4] 

- Cookies present on the Website

In detail, the cookies present on the Website are as follows:

- Cookie settings

You can block or delete cookies used on the Website via your browser options. Your cookie preferences will be reset if different browsers are used to access the Website. For more information on how to set the preferences for cookies via your browser, please refer to the following instructions:

• Internet Explorer

• Firefox

• Chrome

• Safari

You may also provide set your preferences on third-party cookies by using online platforms such as AdChoice.

CAUTION: If you block or delete technical and/or function cookies used by the Website, the Website may become impossible to browse, certain services or functions of the Website may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Website.

Flair uses Google Analytics on the Website. This is a tool developed by Google and used to collect information, which permits evaluation of the use of the Website, analysis of your behaviour and improvement of your experience with the Website. You can obtain more information about how to opt out of Google Analytics at:

https://tools.google.com/dlpage/gaoptout.

 3. Purposes of processing

Flair intends to use your Personal Data, collected through the Website\Emails, for the following purposes:

• To answer to any request or feedback you may send us and to provide any other Services which you may request (“Service Provision”);

• For compliance with laws which impose upon Flair the collection and/or further processing of certain kinds of Personal Data (“Compliance”);

• ·To prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website (“Misuse/Fraud”).

4. Grounds for processing and mandatory / discretionary nature of processing

Flair’s legal bases to process your Personal Data, according to the purposes identified in Section 3, are as follows:

• Service Provision: processing for these purposes is necessary to provide the Services and, therefore, is necessary for the performance of a contract with you. It is not mandatory for you to give Flair your Personal Data for these purposes; however, if you do not, Flair will not be able to provide any Services to you.

• Compliance: processing for this purpose is necessary for Flair to comply with its legal obligations. When you provide any Personal Data to Flair, Flair must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.

• Misuse/Fraud: Information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potentially criminal purposes).

5. Recipients of Personal Data

Your Personal Data may be shared with the following list of persons / entities (“Recipients”):

• Persons, companies or professional firms providing Flair with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services and which act typically as data processors on behalf of Flair;

• Entities engaged in order to provide the Services (e.g., hosting providers or e-mail platform providers);

• Persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks);

• Persons authorised by Flair to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of Flair);

• Other companies within the Flair Group for internal administrative purposes, including the processing of clients' or employees' Personal Data; and

• Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;

6. Transfers of Personal Data

Considering Flair’s holding company: Giochi Preziosi S.p.A. worldwide presence and business operations, your Personal Data may be transferred to Recipients located in several different countries. Flair implements appropriate safeguards to ensure the lawfulness and security of these Personal Data transfers, such as by relying on adequacy decisions from the European Commission, standard data protection clauses adopted by the European Commission, or other safeguards or conditions considered adequate to the transfer at hand.

Where we use your personal information based on your consent, you have the right to change your mind and you can always unsubscribe from our direct marketing to you, by simply clicking unsubscribe in a marketing email.

7. Retention of Personal Data

Personal Data processed for Service Provision will be kept by Flair for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of the Services, Flair may continue to store this Personal Data for a longer period, as may be necessary to protect Flair’s interests related to potential liability related to the provision of the Services.

Personal Data processed for Compliance will be kept by Flair for the period required by the specific legal obligation or by the applicable law.

Personal Data processed for preventing Misuse/Fraud will be kept by Flair for as long as deemed strictly necessary to fulfil the purposes for which it was collected.

8. Data subjects’ rights

As a data subject, are entitled to exercise the following rights before Flair, at any time:

• Access your Personal Data being processed by Flair (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;

• Correct or update your Personal Data processed by Flair, where it may be inaccurate or incomplete;

• Request erasure of your Personal Data being processed by Flair, where you feel that the processing is unnecessary or otherwise unlawful;

• Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing;

• Exercise your right to portability: the right to obtain a copy of your Personal Data provided to Flair, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller;

• Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent Flair from processing your Personal Data; or

• In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through the Website is unlawful.

9. Amendments

This Privacy Policy entered into force on 24/08/2020.

Flair reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. Flair will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website. Flair therefore invites you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how Flair collects and uses Personal Data.