Vertical Fashion

Privacy Policy

Dear Customer,

Vertical Fashion S.r.l. takes its responsibilities regarding the privacy of its users very seriously and, in accordance with EU data protection legislation, has prepared this Policy (together with our Terms and Conditions of Use and any other documents referred to herein) which describes how we will use the personal data provided by you, as a user, through the use of our APP and/or our Website.

We ask you to take the right time to read it carefully, as the following Policy explains how we collect, use, disclose, and transfer the personal information that you may provide to us through our APP, our Website, or when you contact our Customer Service by phone, or when you interact with us through social media platforms and/or directly and/or in person.

Each time you use our APP and/or visit our website and/or use our services and/or get in a relationship with us, you accept the terms of this Privacy Policy and the fact that it may be amended from time to time.

1. DATA CONTROLLER AND CONTRACTING PARTIES

Vertical Fashion S.r.l., with registered office in Milano, Italy, at 17^th of San Martino street – registered at the Chamber of Commerce with Tax Code and VAT No. 12233410963, REA MI 2648231 – (hereinafter, “Controller”), as the data controller, informs you that, pursuant to art. 13 of Legislative Decree 30.6.2003 n. 196 (hereinafter, “Privacy Code”) and art. 13 of EU Regulation No. 2016/679 (hereinafter, “GDPR”), your data will be processed for the management, conclusion, and execution of services and/or sales transactions of services, as well as for the management of commercial communications and profiling activities through our web application VF and/or Vertical Fashion, and through our website (the “Purpose”) limited to and for the specific purposes as indicated below.

Your personal data will be stored in a format that allows your identification as long as strictly necessary for the purpose for which they are collected and subsequently processed, and, in any case, within the legal limits. To ensure that your personal data is always accurate, up-to-date, complete, and relevant, please report any changes to the following email address: customercare@verticalfashion.app or to the address: verticalfashion@pec.it

Your data will also be accessible to Data Processors, in compliance with what is indicated in this information notice and for the specific purposes herein indicated.

Your personal data will be stored on servers in compliance with applicable European laws and regulations

Vertical Fashion may also process personal data of third parties directly communicated by its users, for example, when a user intends to communicate a service for sale on the website and/or APP to a friend. In these cases, we will ask you to obtain the consent of the person to whom such data refers before communicating it to us and to inform the person about this Privacy Policy, as only you, as user, will be considered the sole responsible for the communication of such information and data relating to a third party, without the express and explicit consent of the concerned party, and for their incorrect use and/or of any use in violation of legal provisions.

Your data may be disclosed to police or judicial authorities, for example, in the context of the APP and/or website’s anti-fraud services, in accordance with legal provisions, but only when and if strictly necessary. In some other cases, Vertical Fashion S.r.l., within the limits of legal provisions, will have to comply with its obligations and, where necessary, request express consent at the time of registration in its records of the relevant personal data.

In any case, the contracting parties of this Privacy Policy are always and only:

• the data controller, i.e., Vertical Fashion S.r.l., as the owner and manager of the APP “Vertical Fashion” and/or “VF”, the website https://verticalfashion.app and any other WEB services connected and related to the activity of Vertical Fashion S.r.l.
• the user/visitor of the site and/or the user of the APP and/or any related services, namely you and your personal data, subject to processing.
  

2. OBJECT OF THE PROCESSING

When you create an account, purchase a service, or enter into any other form of agreement with Vertical Fashion S.r.l., we will process your personal data concerning that particular purpose. We may also need to process your personal data when you interact with us, for example, by asking a question or requesting information before entering into any agreement with us. The purposes for which your personal data are used are specifically indicated, case by case, in the text of each page where the provision of such personal data is required.

The “Data Controller” will therefore process all those personal data – such as name, surname, company name, address, telephone number, email address, bank and payment references, specific preferences and/or interests, etc. (hereinafter “personal data” or “data”) voluntarily communicated by you at the time of registration and/or conclusion of a contract for the use of the services of the platform/application (a contract which can also be activated by simply using the APP and/or website) or activated by filling out a contact form, subscribing to the newsletter, or filling out the order form for the purchase of a service/product or for any other reason related to the purpose of activating services, advertised and/or offered through the APP and/or the website, legitimately pursued by the Controller and, for any other matter related to the management, according to law, of the contract to which such information refers and for which it was voluntarily provided.

For “personal data,” it is meant – as stated in Article 4 of EU Regulation No. 2016/679 (GDPR) which defines the object of processing as any information concerning an identified or identifiable person (“data subject”) – considering identifiable the individual who can be clearly recognised, directly or indirectly, with particular reference to an “identifier”, such as a name, an identification number, location data, an online identifier or to one or more elements characteristic of their physical, physiological, genetic, mental, economic, cultural, or social identity.

3. PURPOSE OF DATA PROCESSING
   Your personal data is therefore processed:
   

1. without the need or your further consent, i.e., the one you expressed by voluntarily entering your data into our system and/or any other voluntary submission (Art. 24 letters a), b), c) of the Privacy Code and Art. 6 letters b), e) of the GDPR), for the following Service Purposes:
   –  to conclude contracts for the services of the Data Controller for the benefit of the user of this application/website and/or to conclude any other contract entered into between the parties;
   –  to fulfil pre-contractual and contractual obligations arising from existing relationships with the Data Controller, such as workplace hygiene and safety, dispute management, and/or the exercise of other Data Controller’s rights of defence in court, accounting or treasury management – financial services – insurance services;
   –  to comply with obligations required by law, regulations, and EU legislation, as well as instructions issued by authorities empowered by law and supervisory and control bodies, such as, for example, anti-money laundering obligations.
   
2. only with your specific and distinct consent (Arts. 23 and 130 of the Privacy Code and Art. 7 of the GDPR), for the following “other purposes”, marketing, communication, and public relations activities and/or to promote the image of a specific project of Vertical Fashion S.r.l., its affiliates, subsidiaries, and/or products and/or services of the same and/or partner companies, namely;
   
   –  sending you notifications on your mobile phone through the APP, or by email, and/or by SMS and/or contacting you by phone, newsletter, and/or other commercial communications and/or sending you other advertising material about products or services offered by the Data Controller and/or to gauge satisfaction with the quality of services provided by the Data Controller;
   –  sending you notifications on your mobile phone through the APP, email, mail, and/or SMS and/or contacting you by phone, newsletter, and/or other commercial communications and/or sending you other advertising material about products or services offered by third parties who collaborate with the Data Controller, such as business or marketing partners, insurance companies, and/or other companies with which the Data Controller operates in the market.
   
3. PERSONAL DATA WE MAY COLLECT ABOUT YOU
   We inform you that we may collect and process all, or part, of the information you, as a user of our services and/or purchaser of our products, will voluntarily provide by filling out any form on our APP and/or our website, or any information provided at the time of registration, subscription to our service, purchase of a subscription, participation in a contest or promotion, or signing up for a newsletter, or when reporting a problem with our APP and/or our website. In all these circumstances, we may collect information such as name, residential and/or business address, email address, phone number, demographic information such as age, and/or other information that may allow us to identify you as an individual.
   

We remind you that we process any other data you provide to us in relation to the performance of our services, both directly and through our APP and/or our website, as well as information you may send us via social media. Every time you contact us, we may keep a record of that correspondence and track your visits, including, but not limited to, traffic data, location data, and other commercial data. Therefore, we ask you to also carefully read our Cookies Policy too.

In any case, we remind you that all these data is characterized by the fact that you have provided them voluntarily and that, in accordance with GDPR provisions, we will never retain your personal data for a period longer than necessary to fulfil the contractual purposes for which such data must be processed. We use the information collected exclusively for the purposes stated in this privacy policy, and you, as a user, can modify your personal data or object to further processing at any time.

5. PROCESSING METHODS
   The processing of your personal data is carried out by means of the operations indicated in Article 4 of the Privacy Code, No. 2 of the GDPR, and specifically by “processing” is meant any operation and/or set of operations managed, with or without the aid of automated processes, and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, or any use or communication through transmission, dissemination, or any other form of “making available” or processing by comparison or interconnection, or for any operation related to restriction, deletion, or destruction of data.
   
6. DATA DISCLOSURE 

Without the need for express consent (Art. 24 letters a), b), d) of the Privacy Code and Art. 6 letters b) and c) of the GDPR), the Data Controller may disclose your user data for the purposes outlined in Art. 3.A) to supervisory bodies, judicial authorities, or insurance companies for the provision of insurance services, as well as to those subjects to whom the communication is obligatory by law for the purposes and for the fulfilment of said purposes. These subjects will process these acquired data by virtue of the above obligations, in their capacity as autonomous data controllers.

7. DATA TRANSFER 

Personal data is stored on the Data Controller’s servers located within the European Union. It is understood that the Data Controller, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller ensures that the transfer of data outside the EU will take place in accordance with applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.

8. PROCESSING DURATION 

The data controller guarantees you, in compliance with Art. 17 of the GDPR, that the retention of personal data will be accomplished on paper support and/or electronic/IT format and for the time strictly necessary to achieve the purposes referred to in point 3, and always in full compliance with your privacy and current regulations.

For different purposes of analysis, development, improvement, provision of the service, personal data may be subject to different retention periods, such as:
– for administrative purposes, i.e., invoices, accounting records, tax records, and transaction data will be retained for 10 years;
– for direct marketing and profiling purposes, data will be retained for a maximum period provided by applicable law   (respectively 24 and 12 months). in case of exercising the right to be forgotten through the explicit request for deletion of processed personal data, such data will be retained in a protected form and with limited access only for the purpose of detection and prosecution of crimes, for no more than 12 months from the date of the request, and will subsequently be securely deleted or anonymized, irreversibly;
– for the same purposes, electronic traffic data, excluding the content of communications, will be retained for a period not exceeding 6 years from the date of communication, pursuant to Art. 24 of Law No. 167/2017, which implemented EU Directive 2017/541 on anti-terrorism;
– if the user does not take any active action (e.g., browsing, searches, and/or any other use of the service) on our APP and/or website for a period of 24 months, they will be classified as inactive and personal data will be automatically deleted.

9. LINKS TO OTHER WEBSITES
   Vertical Fashion does not control or perform monitoring operations on the APP and/or websites of partners and their content. Therefore, Vertical Fashion S.r.l. cannot be held responsible for the content and services resold by third parties on its APP or websites and the rules they adopt regarding your privacy protection and the processing of your personal data while browsing. Therefore, please pay attention when connecting to other websites through links on our APP and/or website and read their terms of use and privacy policies carefully, as our APP and website Privacy Policy does not apply to third-party web applications and websites, nor can Vertical Fashion be held responsible in any way for the privacy policies applied by these third parties on their web applications.

If our APP and/or website provides links to other web applications, it does so solely for the purpose of facilitating the user in searching and browsing and to facilitate hyperlinks. The enabling of links does not imply any recommendation or notification by Vertical Fashion S.r.l. for access and browsing of these web applications or any guarantee regarding their content, services, or goods provided and sold to Internet users.

10. FAILURE TO PROVIDE PERSONAL DATA AND CONSEQUENCES
    Providing your personal data to Vertical Fashion S.r.l. may be necessary in order to achieve the purposes of the relationship between the parties, and some of these data may be indispensable to comply with the obligations required by laws or regulations and requested by the user using our APP and/or website and/or purchasing services and/or product(s) sold by Vertical Fashion.
    

Failure to provide certain data, identified with the character (*), could result in the impossibility of executing the contract for the purchase of services and/or products or the inability to properly fulfil legal obligations. Therefore, the lack of data may constitute, depending on the circumstances, a legitimate and justified reason for the non-execution of the contract for the use of our APP and/or for the purchase of products or the provision of services on your web devices.

Namely, providing data for the purposes referred to in Art. 3.A) is mandatory if you intend to proceed with the purchase of a service and/or product from Vertical Fashion. In the absence of your consent, it will not be possible to execute the obligations under the service use contract you signed and/or the purchase, of which this information is an integral part. Providing data for the purposes referred to in Art. 3.B) is also optional. You can therefore decide not to provide any data or to later deny the possibility of processing data already provided: in that case, you might be unable to use part of the service provided by us and you will not be able to receive newsletters, commercial communications, and advertising material related to the services offered by the Data Controller. Failure to provide consent for the purposes indicated in Article 3.B) or the subsequent revocation of consent will not affect the rights acquired through the signing of the contract and the right to receive the services indicated in Article 3.A).

11. SOCIAL NETWORKS
    Our APP and website offer social “plug-in” (or social log-in) from various social networks. If you choose to interact with us through a social network such as Facebook, Instagram, and Twitter, your activity on our APP and website will also be available to that social network.

Please note that if you are logged into one of these social networks during your visit to our website and/or when you choose to log-in to our APP by any of your “social networks profiles” the social networks may add this information to your profile. If you interact with one of these social “plug-ins”, this information may be transferred to the social network’s site. Therefore, if you do not approve of this data transfer, we invite you not to use the “social log-in” and/or to log out of your social network before accessing any of our web applications.

Since we cannot prevent the collection and transfer of data through social plug-ins, we encourage you to carefully read the privacy policies of your social networks to obtain detailed information about their data collection and transfer practices, your rights, and how you can manage your privacy to your best satisfaction.

12. STORAGE AND SECURITY MEASURES
    Our company, as the data controller, adopts all appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of the personal data provided by the data subject, fully complying with the protection – by design and by default – defined by the legislator through EU Regulation No. 2016/679 “GDPR”.

Despite our company’s best security efforts to minimize the risk of data destruction or loss – even accidental – or unauthorized access, or processing not permitted or not in accordance with the purposes of collection defined in our Privacy Policy, we inform you that it is not possible to guarantee that the security measures we adopted for the APP and website and for the transmission of data and information on the APP and website exclude any risk of unauthorized access or data loss. Therefore, we invite you to ensure that your device is equipped with up-to-date antivirus software for data transmission protection, both incoming and outgoing, and that your Internet Service Provider has adopted suitable firewall and anti-spam filters for secure data transmission over the web.

We inform you that our company may use third parties to collect your personal information and/or may use third-party data processors to collect and manage your personal data. However, in these cases, any data processor engaged by Vertical Fashion S.r.l. will process your personal data exclusively in accordance with Vertical Fashion’s Privacy Policy. Vertical Fashion ensures that all third parties used will be legally obligated to adhere to our strict data security and management procedures.

Unless otherwise provided in this document, your personal data will not be disclosed to third parties for purposes not permitted by law or without your explicit consent.

If we have provided you with, or if you have chosen, a password (or login credentials) that allows you to access certain parts of our APP and/or website, you are responsible for ensuring that this password remains confidential. We ask you not to share your password or login credentials with anyone else.

Despite our best efforts to protect your personal data, the transmission of information over the Internet cannot be completely secure. Therefore, we remind you that any transmission of personal data is done at your own risk.

13. DATA SUBJECT RIGHTS
    If you have provided us with your personal data, you have done it completely voluntarily. Also, if you choose not to provide the requested information, it may not be possible to guarantee you certain advantages/services provided to our customers. In some cases, only those who have sent us the requested personal data are able to use certain services and to benefit from the activities of Vertical Fashion S.r.l.

As a data subject, you have the rights outlined in Article 7 of the Privacy Code and Article 15 of the GDPR, that are specifically:

• the right to obtain confirmation of the existence or non-existence of personal data concerning you, even if not yet recorded, and the right to obtain their communication in an intelligible form.
• the right to obtain information regarding:
  a) the origin of personal data;
  b) the purposes and methods of processing;
  c) the logic applied in case of processing carried out with the aid of electronic instruments;
  d) the identification details of the data controller, data processors, and the designated representative as per Article 5, paragraph 2 of the Privacy Code and Article 3, paragraph 1 of the GDPR;
  e) the subjects or categories of subjects to whom personal data may be communicated or who may become aware of them in their capacity as designated representatives, data processors, or persons in charge of processing.
• the right to obtain:
  a) the updating, rectification, or, when interested, the integration and/or modification of data;
  b) the erasure, transformation into anonymous form, or blocking of data processed in violation of the law, including data that do not need to be retained for the purposes for which they were collected or subsequently processed;
  c) the certification that the operations referred to in letters a) and b) have been notified to those to whom the data were communicated or disseminated, except where such fulfilment proves impossible or involves a manifestly disproportionate effort compared to the protected right.
• the right to object, in whole or in part:
  a) for legitimate reasons, to the processing of personal data concerning you, even if relevant to the purpose of collection;
  b) to the processing of personal data concerning you for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication, through the use of automated calling systems without the intervention of an operator via email and/or through traditional marketing methods via telephone and/or paper mail.

Please note that the right of objection of the data subject, as indicated in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that the data subject retains the possibility of exercising the right to object even only in part. Therefore, the data subject can decide to receive only communications through traditional methods or only automated communications or none of these types of communication. Where applicable, you also have the rights set out in Articles 16-21 of the GDPR (rectification, erasure, restriction of processing, data portability, objection), as well as the right to lodge a complaint with the Supervisory Authority.

14. METHODS OF EXERCISING YOUR RIGHTS
    You can exercise your rights at any time by sending a specific communication to the Data Controller/Processor via:

• sending a specific communication to the Data Controller/Processor through its Registered mail addressed to the legal office of Vertical Fashion S.r.l. – via San Martino 17 – 20122 Milan (MI) – ITALY or through its “certified email” (PEC) to the address – verticalfashion@pec.it 
• filing a complaint regarding the processing to the competent authority at:
  Data Protection Authority, Piazza Venezia n. 11 – 00187 Rome Fax: (+39) 06.69677.3785, Telephone switchboard: (+39) 06.696771, Email: rpd@gpdp.it  PEC protocollo@pec.gpdp.it 

15. SCOPE OF APPLICATION
    This Privacy Policy applies to all users of the services of Vertical Fashion S.r.l. worldwide, the Vertical Fashion APP and/or VF, and the website https://vertical.fashion.app, including users of the features or other services of Vertical Fashion S.r.l., except where and when “specific privacy policies” apply to those other services.

All individuals subject to this Policy are referred to as “users.”

The practices described in this Policy are subject to the laws applicable in the places where we operate, meaning that the activities described in this Policy are carried out in a particular state or nation only if permitted by local laws and/or international regulations as adopted in those areas.

16. DATA CONTROLLER, PROCESSOR AND DESIGNED OFFICERS
    The Data Controller is Vertical Fashion S.r.l. with legal headquarters at via San Martino, 17 – 20122 Milan (MI) – ITALY.
    The updated list of data processors and designated officers is kept and available for consultation – in accordance with the law – at the legal headquarters of the Data Controller.

17. JURISDICTION
    This Privacy Policy is defined based on the GDPR. The GDPR ensures that the processing of personal data is carried out respecting the fundamental rights and freedoms, as well as the dignity of the data subjects, with specific reference to the confidentiality and protection of personal data.

This Privacy Policy of Vertical Fashion S.r.l. will be governed and interpreted in accordance with Italian laws, without resorting to conflict of law provisions. Any disputes, including those relating to the validity, interpretation, execution, termination, and resolution of the clauses of this Privacy Policy, will be subject to the exclusive jurisdiction of the Court of Milan.

18. CHANGES AND UPDATES TO THE WEBSITE PRIVACY POLICY
    Any changes made to our Privacy Policy in the future will be promptly posted on this page and will be effective upon publication, as indicated by the “Last Reviewed” date noted in the amended Policy.

Continued use of our APP and website after such changes are posted will be considered acceptance of those changes by the user. In certain circumstances, we may also choose but we are not required, to notify such changes via email or by posting a notice on our APP or website.

Last modified on June 1, 2024

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