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Last modified: February 10, 2021
INTRODUCTION
Davines North America, Inc. (“Company” or “We“) respects your privacy and is committed to protecting it through our compliance with this Policy (this “Policy”). This Policy describes the types of information we may collect from you or that you may provide when you visit the https://us.comfortzoneskin.com/ (this “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This Website is intended for use by users located in the United States only and the laws of the United States shall apply to our collection of information on this Website and to Davines North America, Inc.’s use of such information. If you are accessing this Website from outside the United States, please be aware that the laws of the United States and other countries to which your information may be transferred may not provide a level of protection equivalent to the laws in your home country.
This Website is hosted by Shopify. You can read more about how Shopify uses your personal information here: https://www.shopify.com/legal/privacy.
This Policy does not extend to other websites or applications, including our affiliates’ respective country-specific pages intended for non-U.S. users.
This Policy applies to information we collect:
It does not apply to information collected by:
Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use this Website or interact with us on social media. By accessing or using this Website or interacting with us on social media (via direct message or other social media tools), you agree to this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.
CHILDREN UNDER THE AGE OF 16
This Website is not intended for children under 16 years of age. No one under age 16 may provide any Personal Information to us on this Website or through any other platform. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on this Website, make any purchases through this Website, use any of the interactive or public comment features of the blog linked to this Website, interact with us on social media or other platforms, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information (as defined below) from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at contactcz@comfortzone.com.
INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
We collect several types of information from and about users of this Website, including information:
We collect this information:
Information You Provide to Us
The information we collect may include:
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with this Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Click here https://www.shopify.com/legal/cookies for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically is only statistical data and does not include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. This information helps us to improve this Website and to deliver a better and more personalized service, including by enabling us to:
The technologies we use for this automatic data collection may include:
For information about managing cookies, flash cookies, web beacons and other automatic data collection technologies on this Website, please refer to Choices About How We Use and Disclose Your Information and Shopify’s cookie policy at https://www.shopify.com/legal/cookies. We do not collect Personal Information automatically, but we may tie this information to Personal Information about you that we collect from other sources or you provide to us.
THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES
Some content or applications, including advertisements, on this Website may be served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use this Website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see how you can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website. See also Choices About How We Use and Disclose Your Information.
HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any Personal Information:
For pixels within emails
To ensure that you receive messages that you’ll love to receive, are relevant to you and personalised to your interests and shopping experiences, we add a pixel to our emails which helps us understand behaviours and personalise our campaigns. The pixel is a small piece of code - literally, a 1x1 pixel - which gives us insights into what you do with our emails, such as if it is delivered to your inbox, if you open it, mark it as spam or unsubscribe; if you click through to our website or offer. Additionally, it tells us the type of device you use to open the email, where you are in the case of open or click (by IP address and ‘best estimate’ geo location based on that IP). By having these insights, it helps us deliver, what we hope, to be meaningful, engaging and exactly the type of emails you hope to receive from us and when you want to receive them.
Cookies for email marketing
You will see that we use an Ometria cookie, which helps us understand your activity on our website and which of our products you are most interested in. Amongst others, the cookie sends us information about where you are when viewing our site, how long you visited our site, including which pages you land on and leave, the products and categories you viewed on each visit and the type of device and browser used. The cookie is persistent and has a one year time limit, renewed each time you interact with us. So, if you first visit us on 01/02 the cookie will persist until 31/01 in the following year. However, if you subsequently visit us on 01/06, the cookie will then persist until 31/05 in the following year
Cookies for profiling
The information from email pixels, cookies and your purchase history are brought together to give us a unified customer view. When we look at all of our customers we can better understand what they would like to receive from us: for instance birthday well wishes, emails at the beginning of the day rather than in the evening, sales offers, along with insights that help us plan stock control, designs or brands we may hold. Our aim is to ensure that we carry goods that are relevant to our customers and you love to hear from us when we send you messages. By having a unified customer view we endeavour to offer you a personalised shopping experience. We do this by using data brought together by Ometria’s customer data platform. For instance:
● if we know a group of our customers want to hear about our latest products we store that preference and make sure they receive an email when we launch a new season’s goods; or
● if we have special offers for loyal customers (e.g. VIPs) we will send those offers only to that group of customers.
Our aim is always for you to have a fabulous experience with us and we work hard to make sure that our analysis and use of your data are in harmony with your expectations. We regularly review the information we hold to ensure that it is relevant and accurate.
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose Personal Information that we collect or you provide as described in this Policy:
We may also disclose your Personal Information:
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
California residents may have additional rights and choices with respect to their Personal Information. Please see our Privacy Notice for California Residents for more information.
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: contactcz@comfortzone.us. However, please know we do not currently sell data triggering that statute's opt-out requirements.
ACCESSING AND CORRECTING YOUR INFORMATION
You can review and change your Personal Information by logging into your [ comfort zone ] account on this Website and visiting your account profile page.
If you delete your User Contributions from this Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on this Website, including User Contributions, is governed by our terms of use.
California residents may have additional rights and choices with respect to their Personal Information. Please see our California Privacy Notice for more information.
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information. Please visit our privacy notice for California residents for more information.
DATA SECURITY
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of this Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of this Website like message boards. The information you share in public areas may be viewed by any user of this Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to this Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on this Website.
LINKS TO THIRD PARTY SITES AND SOCIAL LOGIN
This Website may from time to time contain links to and from the websites of our partner networks, advertisers, affiliates or social media sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we are not responsible or liable for these policies. Please check these policies before you submit any Personal Information to these websites.
We may also offer you the opportunity to use your social media login. If you do so, please be aware that you share your profile information with us depending on your social media platform settings. Please visit the relevant social media platform and review its privacy policy to understand how your personal data is shared and used in this context.
PROFILING DATA
The personal data collected from data subjects are subject to processing for profiling purposes with regards to purchasing habits and/or preferences to services and/or products supplied by the company.
For more information, write to the relevant e-mail address or to contactcz@comfortzone.us.
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Purpose and legal basis for processing (GDPR - Art.13, par. 1, c) |
The information collected identifies data subjects for profiling purposes, that is, in relation to their purchasing habits and/or preferences, browsing or other identifying data generated by the devices, applications, tools and protocols used, such as IP addresses, temporary markers (cookies) or other identifiers, in order to analyse this data and propose marketing and remarketing services. |
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Scope of communication (GDPR - Art.13, par. 1, e, f) |
Le categorie di incaricati che tratteranno i dati per le predette finalità sono gli addetti alla gestione del sito, del servizio clienti, delle attività di marketing, dei sistemi informativi nonché da società terze che effettuano il relativo trattamento dei dati per conto della scrivente (GDPR Art. 28); i dati raccolti possono infine essere comunicati alle autorità legittimate a riceverli. I dati sono trattati esclusivamente da personale regolarmente autorizzato e istruito al trattamento (GDPR Art. 29) e non saranno comunicati a soggetti esterni, diffusi o trasferiti in paesi extra-UE. In casi differenti verrà specificato nel relativo form. |
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Processing methods (GDPR C. 39) |
I dati personali sono trattati con strumenti automatizzati. Specifiche misure di sicurezza sono osservate per prevenire la perdita dei dati, usi illeciti o non corretti ed accessi non autorizzati. |
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Retention period (GDPR - Art.13, par. 2, a) |
I dati sono conservati fino a 12 mesi in seguito alla raccolta, per poi rinnovare il consenso se di interesse per i soggetti interessati. |
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Provision (GDPR - Art.13, par. 2, f) |
I dati sono conferiti facoltativamente dagli interessati relativamente alla proposta di profilazione in ambito promozionale/commerciale. |
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Legal basis (GDPR - Art.6, par. 1). |
Il trattamento è facoltativo per l’attivazione del servizio di profilazione, quindi in seguito alla relativa espressione di consenso. |
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Focus: Retargeting / Remarketing / Advertising Information |
This website uses remarketing technologies to communicate, optimize and process advertising based on the visit of the data subjects to this website. In particular, the information collected (IP address and email address) is transmitted to the following partners with whom the remarketing activities are associated in order to classify the users of the website into user groups. Based on the different user groups, personalized advertisements for DAVINES SpA products and services are proposed to users on other websites or applications. The processing is carried out on the legal basis of the user's consent (art. 6 c. 1 letter a of the GDPR), which can be revoked at any time. Users may also opt out of certain advertising features through the corresponding device configuration options, such as the mobile advertising configuration options or the general advertising configuration.
The Customer Match function allows advertising messages to be displayed to the user even after visiting this website and authenticating (logging in) to Google services, as well as searching Google, YouTube or using Gmail through the Google Adwords service. The user information provided to Google is stored as part of the Google Adwords service and is only used to provide the service to DAVINES SpA. Users can disable the use of cookies by Google by installing the plug-in provided at the following link:www.google.com/settings/ads/plugin.
This website uses Facebook counting pixel to measure conversion. Tracking pixels are small, pixel-sized pieces of software on this website that create a connection between the user's visit to the website and Facebook. When the pixel is loaded, Facebook installs a so-called "fr" biscuit on the user's computer, which helps Facebook to offer more personalised advertising, but also to measure and improve advertising. When the "fr" biscuit is installed, Facebook can track the user's browsing behaviour through other websites that have used a Facebook Pixel or a Facebook Social plugin. For more information, please visit the following links:https://www.facebook.com/policies/cookies/ andhttps://it-it.facebook.com/help/568137493302217. To deactivate, please visit the following link:https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen (after logging in).
For further information, please refer to the Cookie Policy. |
DATA FOR REGISTRATION AT EVENTS
The personal data provided by the data subjects when filling out specific forms for registering at events of various form and interest are subject to processing with the purpose of registering users with these events.
For more information, write to the relevant e-mail address or to contactcz@comfortzone.us.
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Purpose and legal basis for processing (GDPR, Art.13, par. 1, letter c) |
Personal data are requested to data subjects to follow up the request for registration at the event concerned. The email address will be used solely to complete registration in the events you have chosen, as well as to send you reminders related to the event you have registered in. The other data collected are requested to complete the subscription and registration at the event concerned, and to receive any items intended for participants. |
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Scope of communication (GDPR, Art.13, par. 1, letters e and f) |
The categories of people authorised to process data for the above purposes are the people in charge of organizing and managing the events, customer service, IT systems, as well as third companies who provide support in some specific cases, such as, by way of example, IT maintenance services, event organization, etc.); data may be communicated to the authorities entitled to receive them. The data collected shall not be notified to external subjects, disclosed or transferred to countries outside the EU. Any other case will be specified in the relevant form. |
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Retention period (GDPR, Art.13, par. 2, letter a) |
The collected data shall be stored solely for the time necessary to allow us to provide the requested services associated with the digital events. |
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Provision (GDPR, Art.13, par. 2, letter f) |
The provision of personal data is mandatory for the purposes given above solely to be able to complete the registration at the events proposed by the company. |
CHANGES TO OUR PRIVACY POLICY
It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on this Website home page. If we make material changes to how we treat our users' Personal Information, we will notify you through a notice on this Website home page requesting you to provide your click-through consent. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this Website and this Policy to check for any changes.
CONTACT INFORMATION
To ask questions about or comment on this Policy and our privacy practices, contact us at
Email:
contactcz@comfortzone.us
Toll-free Phone Number:
+1 (212) 924-2470 during regular business hours (Monday through Friday, 9:00 am to 5:30 pm ET)
Postal Address:
Davines North America, Inc.,
Attn: Customer Care,
61 North 11th Street, 2nd Fl,
Brooklyn, NY 11249
