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User’s personal data will be processed by FWT when user visits the Website and when user interacts with the services and functionalities offered by the Website.
The Controller of the personal data processing is:
FWT Management SA – Voisinand 9 1095 Lutry, Switzerland.
What kind of data are processed; what are the purposes of the data processing
In general, the visit and consultation of the Website does not imply collection and processing of user’s personal data. The processing of user’s personal data who visits and consults the Website is limited to the so-named surfing data, namely the data whose transmission to the Website is implicit in the functioning of the information systems in charge of the managing of the Website and in the use of communications protocols peculiar to the Internet.
Surfing data are, for example, the IP addresses or the domain names of the computers employed by the user who connects to the Website and other parameters relating to the type and the information operating system employed by the user.
Surfing data, such as these above specified and for example the number of visits, the time spent on the Website are collected and processed by FWT exclusively for statistical purposes and in anonymous form in relation to the access and use of the Website for purposes of monitoring the correct functioning of the Website and enhancing the Website functioning and content. Due to the nature itself of surfing data, these data may lead to identification of users if they are associated with data held by third parties; however, FWT does not collect surfing data in order to associate them with identified users.
Surfing data are deleted after the processing in anonymous form; said data may be used for purposes of assessing possible responsibilities in case of information crimes realized against the Website or through the Website. With the exception of the aforementioned circumstance, FWT keeps the user’s surfing data only for the maximum period of time allowed under applicable laws and then makes said data anonymous.
Furthermore, FWT collects and processes personal data voluntarily provided by user when user interacts with the Website functionalities and requests the services offered by the Website, for example upon user subscription to the Website; user subscription to newsletter or mailing list; user purchase of products through the Website, which includes all activities relating to the purchase of goods, such as for example delivery of goods, billing issues, returning and exchanging of goods, receiving refunds, as applicable, payment related activities, including fraud prevention, and customer support and interaction with our office; user participation to promotions and other initiatives realized through the Website such as for example contests and sweepstakes, user request of information to FWT or user sending to FWT a question, communication or feedback through traditional mail or through the Website. We will process user’s personal data also to comply with laws, regulations and Community legislation, and to assess and defend a legal right.
We may process user’s personal data also when user contacts our offices, which may communicate with user and thus process user’s personal data through e-mail, chat and telephone. For the processing of your personal data when you make a purchase on our Website, please see our relevant privacy Statement.
With the user’s consent, that is optional, FWT may further process user’s personal data for survey purposes; for marketing purposes, that is for sending to user, also through e-mail or other electronic communications means such as SMS, MMS, fax, etc., promotional information and material on products and services of FWT, on special initiatives on prices and promotions of FWT and on initiatives such as events, exhibitions and fairs organized by FWT or to which FWT takes part; and for profiling purposes.
User will always have the opportunity to object, at any time and for free, to the processing of his/her personal data for the sending of promotional information and material; in each communication there will be a specific section in which are specified the conditions (easy to perform and free of charge) of revoking the consent.
Personal data that FWT collects and processes include name, and contact details such as street address, telephone number, e-mail address and further possible information of an optional nature provided by user.
In the relevant sections of the Website where data are collected it is published a specific information statement. When requested under the Privacy Law, FWT requires the user’s consent before proceeding to processing his/her personal data.
Personal data collected through the Website will be processed by FWT.
Personal data are processed only through specifically authorized staff designated to access and process the data, including staff/processors designated for performance of non-routine maintenance operations of the Website. All processors are acting on behalf and under the instructions of FWT.
Personal data collected by FWT are mainly processed through electronic and automated means but also without the same (paper processing), under procedures and logics that comply with the data processing purposes as herein specified.
Personal data of user are processed according to applicable privacy laws, including security and confidentiality issues, and are kept only for the time strictly functional to achieve the specific data processing purpose from time to time pursued and according to applicable laws.
FWT is committed to protect security of the user’s personal data. Personal data are processed by FWT in compliance with the security provisions as set forth by applicable laws in order to prevent loss and destruction, even accidental, of data, unauthorized access to data, unlawful or unfair use of data.
Moreover, information systems and software programs are configured so that personal and identification data are used only when necessary to achieve the specific processing purpose from time to time sought.
User may help FWT to update and maintain accuracy of the personal data provided by user to FWT by notifying FWT of any amendment relating to user’s address, title, telephone number or electronic mail (e-mail) address.
User personal data may be communicated to institutions, authorities, public entities, banks and financial institutions, professionals, independent consultants, also in associate form, business partners and third party service providers to which FWT may revert to for performance of professional, technical and organizational services functional to the managing of the Website and the activities therein performed, such as for example the sales of goods and related activities, the managing of functionalities offered by the Website and of the initiatives and services that user may subscribe to and require through the Website, and for services strictly functional to achievement of the other processing purposes herein specified.
For purposes functional to the managing of the Website and related activities, for example for the purchase of goods through the Website, user’s personal data may be also communicated to other companies of the FWT group within the European Economic Area, that will process them according to applicable privacy laws for the purposes above specified, including marketing and profiling activities. With specific reference to the purchase of goods, data will be processed by the relevant local FWT entity established in the place where delivery has to take place, acting as controller of your personal data in accordance with applicable privacy laws, for the following purposes: billing issues, dispatch of goods, returning and exchanging of goods, receiving refunds, payment related activities, including fraud prevention.
The activities of customer support and managing of our customer service are performed by FWT Management SA. Moreover, for closing transactions and payment processing we revert to third party service providers for managing and support of the e-com platform. These service providers are bound by contract obligations so that they will implement adequate security measures to protect security and confidentiality of user’s personal data and credit card information.
The third parties receiving user’s personal data as above specified will process data as Data Controllers (FWT local entities), as the case may be, according to applicable data protection laws and for the same purposes above specified. Personal data may also be communicated to third parties in case of mergers, acquisitions, transfer of any of our assets, products, websites or operations.
These third parties will be provided only with the information necessary to performance of their respective functions; they agree to use the information received only for the processing purposes above specified, to keep it confidential and secure and to comply with applicable law and the instructions received by FWT.
Except for the foregoing, user’s personal data will not be shared with third parties, natural persons or legal entities, that are unrelated to, or that do not perform a business, professional or technical function for FWT.
User’s personal data may further be communicated to whoever is the legitimate addressee of communications as provided by applicable laws and regulations, thus for example in case of judicial processes, request by competent courts and authorities or other legal obligation, to protect and defend the rights and property of FWT and the Website. User’s personal data will not be communicated to third parties for their own marketing purposes and will under no circumstance be spread.
Except for the foregoing description in relation to the surfing data (please refer to the above section ‘The nature and kind of data processed‘), providing of personal data by user is necessary for performance of the services and functionalities offered by the Website and required by user, such as the user subscription to the Website, to newsletters or mailing lists, the managing of the user purchase of products through the Website and related activities, the managing of user participation to promotions and other initiatives realized through the Website such as for example contests and sweepstakes, replying to and managing of user’s request of information, questions, communication or feedback to FWT and other information sent by the user.
Providing of user’s personal data for the activities necessary to comply with applicable legislation is mandatory. In the above referenced circumstances, denial of providing personal data by user would make it impossible for FWT to comply with contractual obligations or to provide user with the requested services, products or information as above specified.
Providing of data by user for the survey purposes, the marketing purposes, and the profiling purposes as above specified is optional; denial of providing personal data by user in said circumstances will have no consequences on compliance by FWT with its contractual obligations and on the providing user with the services, products or information requested as above specified.
User is entitled at any moment to enforce the rights as provided by applicable privacy law, including but not limited to the right to obtain at any moment confirmation that user’s personal data exist or do not exist, verify their content, origin and accuracy, ask for their integration, updating, amendment, deletion, and user may oppose for legitimate reason the data processing (including objecting, at any time and for free, to the processing of his personal data for direct marketing purposes).
For any query or request relating to the personal data processing by FWT and to enforce the rights under the Privacy Law, user may contact FWT Management SA, as follows:
Phone: +41 21 791 35 27, by traditional mail to “FWT Management SA –E-commerce Customer Service, Voisinand 9 1095 Lutry, Switzerland;
or by sending an e-mail : email@example.com