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Privacy Policy

PRIVACY POLICY

Vivienne Westwood S.r.l. with registered offices at Corso Venezia 25, 20121 Milano (MI), Italy and Vivienne Westwood Ltd., with registered offices at Westwood Studios, 9-15 Elcho Street, London SW11 4AU, England, collectively referred to as “Joint Controllers”, informs users, in accordance with EU Regulation 679/2016 (hereinafter “GDPR”) and the applicable data protection regulation, including national laws that personal data relating to users of the website www.viviennewestwood.com  (hereinafter, “Website”) and collected through cookies (hereinafter, “Cookies”) will be processed in the manner and for the purposes set out in this privacy policy (“Privacy Policy” and/or “Policy”).
 

1.    WELCOME TO VIVIENNE WESTWOOD’S PRIVACY POLICY

This Privacy Policy (“Policy”) provides information on how Joint Controllers (as defined below) collects, use and process your personal data that you provide to us when you visit our Website, including any data you may provide through this Website when you sign up to our e-newsletter, interact with us on social media platforms and/or purchase a product. Moreover, this Policy also applies to purchases and processing of your Shopping Data carried out in one of Our Shops. 
If you are reading this Policy, it is because you are visiting one of Our Pages and/or one of Our Shops, or because you completed one of Our Forms (e.g., Newsletter, Sign-up card etc.).

This Policy will help you better understand how we handle your personal data (also known as “personal information”), for what purposes and how you can control your information. 
Pursuant to statutory requirements including the UK General Data Protection Regulation (GDPR) and Data Protection Act 2018, this Policy also indicates: 
•    The nature of the personal information processed;
•    The purposes of the processing of personal information;
•    The identity and contact details of the data controller(s);
•    Categories of third parties involved in the processing activities; 
•    The retention period of personal information; 
•    The privacy rights of users. 

It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting data or processing personal data about you, so that you are fully aware of how and why we are using your information. 

By registering on the Site, as well as when filling out any forms on the Site or when requesting the subscription to the newsletter service, you confirm that you are 16 years of age or, in any case, that you have reached the age of consent in your country of residence.

At the end of this document, you will find Definitions, referring to more detailed explanations of the capitalised terms. From time to time, we may update this Policy. When we do, we will publish the changes on this platform. 

It is likely that for certain countries where we carry out our business activities, specific and local data protection provisions might apply with regard to the processing of personal data. Hence, where such specification is needed, you can hereunder find the list of those countries that require us to process your Personal Data according to the relevant data protection law applicable therein. 

Specific localised sections

1.    Australia
2.    Austria
3.    Belgium 
4.    China
5.    France
6.    Hong Kong
7.    New Zeland
8.    Switzerland
9.    Thailand
10.    United States

2.    WHO WE ARE AND OUR CONTACT DETAILS
     
Who we are and our contact details

We are Vivienne Westwood S.r.l. with registered offices at Corso Venezia 25, 20121 Milano (MI), Italy and Vivienne Westwood Ltd., with registered offices at Westwood Studios, 9-15 Elcho Street, London SW11 4AU, England, collectively referred to as “Joint Controllers” of your Personal Data and, for the purposes described in this Policy. 

The Joint Controllers and where applicable other Entities part of the Vivienne Westwood Group - are collectively identified below as “Vivienne Westwood” “VW,” “we” or “us”. 

When we collect your Personal Data during your offline purchasing process in Our Shops, we are Joint Controllers of your Shopping Data together with each single Vivienne Westwood directly operated physical shop (“Boutique”) in which you are making an offline purchase for the offline purchases processing activities.  

If you have any questions about this Policy, privacy matters or our data protection practices, please contact the Privacy Department via privacy@viviennewestwood.com. 


3.    WHAT DATA WE COLLECT AND PROCESS
   
What data we collect and process

We may collect, use, store and transfer different kinds of personal data about you from Our Pages, Mobile Applications, when you visit one of Our Shops, and/or when you complete one of Our Forms as follows: 

•    Identity Data – includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. 
•    Contact Data – includes billing address, delivery address, email address and telephone numbers. 
•    Financial Data – includes bank account and payment card details. 
•    Transaction Data – includes details about payments to and from you and other details of products and services you have purchased from us. 
•    Technical Data – includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. 
•    Profile Data – includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 
•    Usage Data – includes information about how you use our website, products and services. 
•    Marketing and Communications Data – includes your preferences in receiving marketing from us and our third parties and your communication preferences. 

We use different methods to collect data from and about you including through direct interactions, automated technologies or interactions and third parties or publicly available sources. The Personal Data collected and the related purposes of processing depend on how you interact with us and how you manage Cookie settings, Browser and the Device you are using. 

Personal Data you provide
To access certain areas of our platform, you might need to register your account with us. During the registration process you will be asked to submit personal information about yourself for the essential purpose of fulfilling purchaser orders (such as your full name, delivery address and payment information required for your order to be actioned) and to enable us to comply with our contractual obligations. It is the case, for example, when you use our Services, make purchases in Our Shops, complete Our Forms or when you ask us questions before or after sale, make requests, interact with our support services or participate in our surveys. 

You can provide us with Personal Data such as your name, phone/mobile number(s), date of birth, gender, e-mail address, postal address, payment and billing information, as well as your preferences (e.g., size or particular colours of your purchase history). You can also choose to provide us with Information about your location if, for example, you want to search for one of Our Shops in a particular location (e.g., London, Milan, Paris, etc.) or when you order our products. 

If you provide us with the personal data of third parties (e.g., postal addresses or payment data of third parties for a gift), you will be held responsible for having shared such information with us. You must be legally authorized to share it (i.e., authorized by the third party to share their information or otherwise permitted). You must fully indemnify us against any complaints, claims or demands for compensation of damages which may arise from the processing of third-party Personal Data in violation of applicable data protection law.

Where we need to collect personal data under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods). In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time. 

Personal Data collected by the Browser and the Device 
When you use Our Pages, we collect information on the Browser and the Device you are using in order to enable and improve user navigation. The processing of such browsing data allows users to access the website and fully enjoy its features and services.  ‘Browsing Data’ includes your IP Address, the date/time of the visit and its length, and the requested URL, Unique Identifiers and other information such as the type of your Browser or Device. Information related to your Browser or Device may also include your operating system, language, network settings, telephone operator or internet provider, installed third-party applications and plug-in lists. 

Some of this information is collected using Cookies, SDK and Other Tracking Technologies that are on your Browser or Device. This helps us, for instance, to avoid malfunctions during the provision of the Services, and allows us to provide you with Content that may be useful to you. You can find the complete list of Cookies and SDK we use here.

You can set your Browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy here.

Personal Data inferred by your activity
We collect information based on your online and offline interactions with our Services in order to improve them and to identify Content that may be useful to you.  This happens, for example, when you are interested in a particular product and you place it in your shopping cart, when you click on a specific section on Our Pages, or when you complete Our Forms. In such cases, we will attempt to provide you with relevant content. To manage your Personal Data, please see the cookie settings here.

In other cases, such as when you contact us by email, mail, telephone or otherwise regarding our products or request other information, we will collect and maintain a record of your contact details, communications and our responses. If you contact us by telephone, more information will be provided during the call. Please note that phone calls may be recorded for security, training or monitoring purposes. 

Information about your location
We process information about your location to allow you to view Our Shops near you, and to provide you with Content that may be useful to you. Your location can be determined by manually entering an address, city or zip code or by checking your IP Address.

Your location is determined - more or less accurately - depending on whether it is collected from the Browser or Device (e.g., IP address, device language or language chosen by the user) and on the privacy settings you have set on them. We make every possible effort to ensure that Information on your location is not used to infer your Sensitive Data.

You can limit our collection of your position by changing your cookie settings, as set out in the “How to control your Personal Data and manage your choices” section below.

You may find further details on the reasons why we process your Personal Data in the “Why we use your Personal Data” section below.

Information about CCTV in Retail Stores 
In our retail stores, we operate CCTV (Closed-Circuit Television) to prevent and prosecute crime, uphold the security and protection of our customers, members of the public, employees and our property and products. CCTV recordings will be accessed only for such limited purposes, and data gathered will not be used for any other purpose. Our legal basis for processing personal data in this context is our legitimate interest in ensuring that there is an adequate level of security in our stores. To the extent that any criminal offence data is processed, our legal basis will be preventing or detecting unlawful acts. We store CCTV footage only for as long as necessary for the maximum period permitted by law. CCTV footage will not be transferred or shared outside of the UK, where it is recorded in the UK, or outside of the EU/EEA where it is recorded in the EU/EEA. 
 

4.    THIRD PARTIES WE COLLECT DATA FROM

Third parties we collect data from
  
We may ask third-party business partners (e.g., social media, network advertisers, co-branding companies, etc.) to send or display our advertisements to their users on the basis of certain criteria/interests, and we may use third party analytics to evaluate and provide us with information about the viewing of ads and our content. These so-called micro-targeting and/or retargeting activities typically do not lead to the direct collection of Personal Data by us. Instead, they usually allow us to obtain Aggregate Information such as statistical or demographic data for any purpose, on the effectiveness of those advertisements or lead to the registration of new users or new followers. In accordance with European legislation, in carrying out these activities both VW and our business partners make reasonable effort to verify the conformity of the data (including joint controllership agreements) before they are used. You can request more information on our list of active commercial partners and the obligations of the respective parties by writing to privacy@viviennewestwood.com. 
Third party tracking technologies are not controlled by us, even if they are associated with our platforms or our ads. Statements regarding our policies do not apply to the methods of collecting information used by the third parties and users are encouraged to read their own policies regarding their collection, storage and sharing practices.

Personal Data collected from public or publicly accessible sources
We may collect or enrich your Personal Data with information obtained from third parties and public sources accessible within the limits of the law applicable to us. These sources may include data brokers, public registers, online newspapers, lists or public directories. Please note that a preliminary check is always carried out on the possibility to use this information, according to the best practices established by the competent Supervisory Authorities to which we are subject. (Mainly the Information Commissioners Office and the Italian Garante)

Lawful Basis for processing

•    Consent - We may rely upon the use of your consent to process your personal information. This lawful basis requires you to provide clear and explicit consent to process your data. This can be found in our cookie setting and sign-up forms.

•    Legitimate Interest – We may rely upon legitimate interest to process your personal information. This lawful basis relies on processing your personal data in order to provide a service to you. This is used to guarantee the best services and on our legitimate interest in avoiding any service disruptions to our customers.

•    Contract – we may rely upon the use of contracts to process personal data. This lawful basis relies upon any agreements or contracts that require us to process your personal data. Contractual obligation may be relied upon to provide a service to our customers or by our vendors to process your data.

•    Legal Obligation – we may be required to process your personal data in line with the legal requirements and legislation. This lawful basis requires us to process and collect personal data in line with legal provisions. We may rely on this for tax and legal purposes. 


For your convenience, we will collectively refer to all Personal Data mentioned here above as "Data".

 5.    WHY WE USE YOUR DATA
 
Why we use your Data

Providing our Services and related support
We use your Data – that you might also communicate to us by completing Our Forms – to offer you our Services; to allow you to create your account; to respond to your requests/suggestions/reports; to process your requests for remote sales appointments, stylist appointments or other boutique services; to verify and process a purchase you have made, using your Personal Data (e.g., name, contact information and information voluntarily provided by you) to communicate with you in connection with any prize draws and contests in which you choose to participate.

This processing is based on the execution of a contractual obligation or pre-contractual measures taken at your request. If you do not provide you Data, we may not be capable to provide you with our Services.

     
Complying with legal obligations
We may use your Data to comply with legal and tax obligations to which we are subject, which form the legal basis of this processing. If you do not provide you Data, we may not be capable to provide you with our Services or fulfil the obligations we are subject to.

     
Detecting anomalies and improving our Services
We use Data you provide, Data collected by the Browser and the Device, Data inferred by your activities and Aggregated Information in order to avoid anomalies in our Services. For example, we may detect anomalies when you open one of Our Pages, access a link, or when a bug is present in our system.

The processing is based on our need to guarantee the best Services and on our legitimate interest in avoiding any service disruptions. If you do not provide you Data, we may not be capable to assure the quality of our Services. 

Customizing our Services including any Content that may be useful to you:
We use your Data, in particular Data inferred by your activities, Shopping Data, Data collected by third parties, Information about your location and Data collected by the Browser and the Device, to improve our Services (e.g., Our Pages, Our Forms), our marketing communications and to show Content that may be useful to you. For example, we may display a specific product according to your clicks, views, follows, tags.  

Content that may be useful to you: 
•    is not created using Sensitive Data such as that which may be derived from Information about your location; 
•    may also be visible on websites and mobile applications other than Our Pages once uploaded to Programmatic Advertising or social media platforms to the extent that you have authorised us and such third parties to do so. 

The customization of our Services and the provision of Content that may be useful to you may be more or less accurate depending on the consent(s) you have given, which you may or may not decide to provide through:

•    the banner that appears when you first visit Our Pages concerning the Data collected by the Browser and the Device, and the Information about your location; 

•    data collection forms, in which we ask you to express your preferences regarding the Data you provide us with, the Data inferred by your activities; 

•    the preferences in your social media accounts. 

If you do not wish to receive personalized Services or Content that may be useful to you, you can change your preferences, as explained in the “How to control your Data and manage your choices” section below. You may still see our ads on content, but they will not be tailored to your interests if you do not provide your Personal Data or consents. 

In other cases, we may rely on our legitimate interest to customize in a minimally privacy impactful manner our communications and Services. This occurs for instance when we know you might not be interested in certain products based on your previous purchase history or to remind you about abandoned charts. 
     
Analysing and improving our Services and creating new services and features
We use your Data and Aggregated Information to measure the performance of our Services and to create new ones. This can be done, for example, through the analysis of your interactions with Our Page, your purchase history and/or marketing communications (if requested).   

Except for your consent to the customization of our Services, measuring the effectiveness of our Services and the creation of new Services is based on our legitimate interest in creating and maintaining Services that are truly useful to our customers.

Sending you marketing communications 
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  

If you decide to sign up to our newsletter and marketing communications, we use the personal data you provide us with and those collected by third parties in order to send you communications about our products and the Services we offer, abandoned carts, our newsletter, information about our initiatives and/or to ask you to participate in our surveys. Users may also be invited to submit personal information in addition to their e-mail address (e.g. gender, country of residence), for the purpose of having their communications personally tailored to their user profile. The main purpose of profiling is to propose products and services and initiatives more suited to the tastes, shopping habits and interests of our customers and this data allows VW to improve the site and personalisation of the products offered. In some cases, communications may include products or service promotions from selected co-branded companies (without sharing your Data with them). Such communications are sent by VW and may also be customized if we have a legal basis such as consent for the customization of Services, including Content that may be useful to you.  

If you have already purchased one of our products, we may send you targeted marketing communications for products in a similar category or price range. This processing is based on our legitimate interest to send promotions pertaining similar products via e-mail (so-called soft opt-in).  

In other cases, no communication will be sent to you without your prior consent, which you can provide through specific tick-boxes for this purpose. If you do not provide you Data, consents or object to this processing, you will not receive any marketing communication. 

You can always easily withdraw your consent from receiving newsletters and commercial communications in the following ways:
•    Through your account settings;
•    By clicking on the ‘unsubscribe’ link in any such email received; 
•    By writing to privacy@viviennewestwood.com; and/or
•    By contacting our Customer Service Team. 
     
Protecting our interests and your interests
We may need to use your Data to detect, react to, and prevent fraudulent and illegal behaviour or activities which could compromise the security of our Services. This could be the case when you use Our Pages in ways other than as permitted. This purpose also includes audits and assessments of our business operations, security controls, financial controls, records and information management program, and otherwise relating to the administration of our general business, accounting, record keeping and legal functions.

These purposes rest on our legitimate interest in safeguarding our interests and protecting our users, including you.  

6.    METHOD OF PROCESSING

Method of Processing
Data collected for the purposes indicated above are processed both manually and via electronic processing, namely, through programs or algorithms that analyse Data inferred by your activities, Information about your location, and Data collected by the Browser and the Device. 

Your Data may also be subject to Combination and/or Crossing, which provides a deeper understanding of your interactions with us. The Combination and/or Crossing of your information for the purposes we process it for (e.g., customizing the Services) can be enabled or disabled as explained in the “How to control your Data and manage your choices” section below.  

7.    DISCLOSURE OF YOUR PERSONAL DATA

Disclosures of your Personal Data     

We may share your personal data with third parties. We require all third parties to respect the security of your personal data and treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes, and in accordance with our instructions. 

We disclose your Data to the following list of persons/entities (“Recipients”): 
•    Persons authorized by us to perform any of the data-related activities described in this document: our employees and collaborators who have undertaken an obligation of confidentiality and abide by specific rules concerning the processing of your Data;
•    Our Data Processors: external companies to whom we delegate some processing activities. For example, fulfilment centres and warehouses, advertising, digital, marketing and social media agencies, IT service providers, customer care service providers, security systems providers, accounting, administrative, legal, tax, financial and debt collection consultants, data hosting platform providers, etc. In such cases, sharing personal information with the Processors is necessary for the Controllers to fulfil their contractual obligations and to improve VW’s products and services. We have signed agreements with each of our Data Processors to ensure that your Data are processed with appropriate safeguards and only under our instruction. The legal basis of the sharing of personal data with our Data Processors will be conditional upon the consent of the user, unless such processing is allowed under an alternative legal basis. 
•    Systems administrators: our employees and those of our Data Processors which assist us with the management of our IT systems and therefore can access, modify, suspend and limit the processing of your Data. These individuals have been previously selected, adequately trained and their activities tracked by systems they cannot modify.
•    Third parties in relation to your purchases: external payment providers, international carriers, couriers and postal operations, who act as autonomous Data Controllers.
•    Our Entities: depending on your jurisdiction, we and some of our Entities will process your Data in compliance and pursuant to the applicable data protection legislation.  
•    Law enforcement or any other authority whose provisions are binding on us: this is the case when we have to comply with a judicial order or law or defend ourselves in legal proceedings. Where a government, being supranational, federal, state or governmental, prefectural or local government, statutory, administrative or regulatory body, court, agency, including a law enforcement agency, or any other authority in any part of the world (also outside of your jurisdiction) whose regulations, directives, Policies, resolutions, orders, decrees, injunctions, warrants, subpoenas, or judgments are binding upon us requires us to disclose your Data, we will not share your Data without your consent, unless we are under a legal obligation to comply with said regulations, etc.

Who can access your Personal Data stored in our CRM
Please note that your Shopping Data stored in our CRM is worldwide accessible by VW and by Our Shops (and their personnel), acting as Joint Data Controllers of your Shopping Data.

8.    INTERNATIONAL TRANSFERS

International Transfers     
Vivienne Westwood is a global brand and Our Shops are available in multiple jurisdictions worldwide.
This means that your Data may be stored, accessed, used, processed, and disclosed outside your jurisdiction, including within the European Union, and the United States of America, or any other country where our Entities, Our Shops, service providers, Data Processors and sub-processors are located, or where their server or cloud computing infrastructures may be hosted. 

We take steps and have safeguards in place to ensure that the processing of your Data by our Recipients is compliant with the applicable data protection laws, including the UK and the Italian laws to which we are subject. Where required by UK or EU data protection law, transfers of your Data to Recipients outside of the EU will be subject to adequate safeguards (such as the EU standard contractual clauses for data transfers between EU and non-EU countries), and/or other legal basis according to the EU and the UK legislation. For more information on the adequate safeguards we have implemented with regard to Data that is transferred to third countries, please write to: privacy@viviennewestwood.com

9.    DATA RETENTION: HOW LONG WE STORE YOUR DATA

Data Retention: How long we store your Data    

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Data processed for the purposes indicated above will only be kept for the period deemed strictly necessary to fulfil such purposes. Data collected for marketing and customization of Services will be retained for seven years based on our legitimate interest as a luxury brand. 

Data processed in compliance with the legal obligations to which we are subject will be kept for the period required by law. Data processed to protect our interests, and our users' interests, is kept until the time indicated by applicable law (typically no longer than 10 years).  

Once the relevant retention period/criteria has expired, your Data is erased pursuant to the VW retention policy. We will promptly delete or anonymize personal information that is no longer needed or retained according to the retention period/criteria.
You can request more information on our data retention criteria and policy by writing to: privacy@viviennewestwood.com


10.    YOUR DATA PROTECTION RIGHTS 

Your data protection rights    

At any time, you can ask to: 
•    Access your Personal Data: you have the right to ask us for copies of your personal data. Depending on your use of our Services, we will provide the Data we have about you, such as your name, age, IP Address, Unique Identifiers, e-mail and preferences expressed, together with the Policy you received when you provided them, and the source of the Personal Data if available (if, for example, they were provided to us by one of our business partners);  
•    Exercise your right to the portability of your Personal Data: in respect of information you have given to us, you have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. According to your use of our Services, we will provide you with a structured, commonly used and machine-readable format containing your Data; 
•    Correct your Data: you have the right to ask us to rectify personal information you think is inaccurate and to complete information you think is incomplete. For example, you can ask us to modify your e-mail address or telephone number if they are incorrect;
•    Limit the processing of your Data: You have the right to ask us to restrict the processing of your information in certain circumstances for example, when you think that the processing of your Data is unlawful or that processing based on our legitimate interest is not appropriate;
•    Delete your Data: you have the right to ask us to erase your personal data in certain circumstances. For example, when you do not want to use our Services and do not want us to retain your Data any longer; 
•    Update your preferences for processing based on your consent. According to your use of our Services, you may request us to not send you marketing communications and/or to not personalize our Services including any Content that may be useful to you.
•    Withdrawal of Consent: If you have provided us with your consent to process your data, you have the right to withdraw your consent at any time unless there is a restriction of the withdrawal of consent by law, or the contract that benefits you. The withdrawal of your consent does not affect the legality of the processing carried out based on the consent until the withdrawal.
•    Right to Objection: if we are processing personal data that concerns you on the lawful basis of legitimate interest or for direct marketing purposes, you have the right to object to the processing of your personal data carried out by us or on our behalf.
•    Right to File a Complaint: If you believe that we have not complied with the requirements of the GDPR concerning your personal data, you have the right to lodge a complaint with the GDPR.

Please note that there are some exemptions to the above rights, which means you may not always receive all the information we process, or we may not otherwise have to comply with your request to exercise your right(s).

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

In accordance with EU and UK data protection law, we try to reply to all legitimate requests within one month of its receipt (extendable for two further months in case of particular complexity or if you have made a number of requests). Please remember that some of your rights may be subject to restrictions if the applicable law allows.

You can exercise any of the rights listed above against: 
•    VW by writing to privacy@viviennewestwood.com 
•    One or more Entities, which process your Data by sending a communication to the contact details you will find in their communications;
•    Third parties who shared your Data with us (e.g., business partners, data brokers) via their e-mail address or your account settings on their platforms.

At any time, you can also contact the VW Legal Representative appointed within your jurisdiction. 
•    If you are based in the EU: Vivienne Westwood S.r.l. with registered offices at Corso Venezia 25, 20121 Milano (MI), Italy;
•    If you are based in UK: Vivienne Westwood Ltd., with registered offices at 9-15 Elcho Street, London, SW11 4AU 
         Contact the competent Supervisory Authorities (or the one of your country of residence) whose contact details are available here.


11.    HOW WE PROTECT YOUR DATA

How we protect your Data    
We take reasonable precautions from the physical, technological and organizational points of view to prevent the loss, misuse, or modification of Data under our control. For example:
•    We ensure that your Data is only accessed and used by, transferred or disclosed to Recipients that need to have access to such Data for the purposes for which it was collected and you were informed about.
•    We also limit the amount of Data which is accessible, transferred or disclosed to Recipients to what is strictly necessary to fulfil the purposes or specific tasks performed by the Recipient.
•    The computers and servers where your Data is stored are kept in a secure environment, are password-controlled with limited access, and have industry standard firewalls and anti-virus software installed.
•    Paper copies of any documents containing your Data (if any) are kept in a secure environment as well. For example, depending on the sensitivity of the information in question, your Data may be stored in a locked filing cabinet that can only be accessed by our employees who require the information, as described above.
•    When destroying paper copies of documents containing your Data that is no longer needed, we ensure that such documents are shredded or incinerated. 
•    When destroying Data recorded and stored in the form of electronic files that are no longer needed, we make sure that a technical method (for example, low level format) ensures that the records cannot be reproduced.
•    Laptops, USB keys, mobile phones and other electronic wireless devices used by our employees who have access to your Data are password protected. We encourage employees not to store your Data on such devices unless it is reasonably necessary for them to do so to perform a specific task as outlined in this Policy.
•    We train our employees to comply with our obligations as detailed in this Policy and periodically conduct audits and other monitoring activities to ensure ongoing compliance and to determine the effectiveness of our privacy management practices.
•    Any Data Processor that we use is contractually required to maintain and protect your Data using measures that are substantially similar to those set out in this Policy or required under applicable data protection law.
•    In cases required by the applicable legislation, if a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Data transmitted, stored or otherwise processed, will be notified to you and to the competent data protection authority as required (for example, unless Data is unintelligible to any person or the breach is unlikely to result in a risk to your rights and freedoms and those of others).

12.    WHAT IS NOT COVERED BY THIS POLICY

What is not covered by this Policy    
This Policy explains and covers the processing operations that we carry out as Joint Data Controllers through this website or through the stores. 

The Policy does not cover processing carried out by parties other than Joint Data Controllers and in particular does not cover: 

•    the processing carried out by our business partners as autonomous data controllers including those carried out by social media platforms within Our Pages;
 
With respect to such, we do not assume any responsibility for the processing of your Data not covered by this Policy.

13.    CHANGES TO THE POLICY

Changes to the Policy    
This Policy entered into force on the date indicated at the beginning of this document. We reserve the right to modify or update this Policy, in full or in part, at our discretion or as a consequence of changes in applicable law or regulations.  Any future changes to this Policy will be posted on this platform and where appropriate, notified to users by email. Users are encouraged to read this Policy frequently to check for any updates or changes.

14.    LICENSE

License    
The icons illustrated in this Policy are “Data Protection Icons” by Maastricht University European Centre on Privacy and Cybersecurity (ECPC) CC BY 4.0.


15.    DEFINITIONS

Definitions    
Aggregated Information: refers to statistical information about you that does not contain your Personal Data. We use this information for analysing and improving our Services and creating new services and features and to create statistical reports for Our Shops. 

Browser: refers to programs used to access the internet (e.g., Safari, Chrome, Firefox, etc.).

Combination and/or Crossing: this is the set of fully automated and non-automated operations which we combine with the Information about your location, the Data inferred by  your activity, the Data collected by the Browser and the Device, the Data you provide used to provide the Services, analysing and improving our Services and creating new services and features, as well as to offer Content that may be useful to you. We may also combine and/or cross information from different sources, such as information collected from Our Pages, Data collected from public or publicly accessible sources and Data collected by third parties.

Content that may be useful to you: for example, if you search for a particular product, we may display similar products on Our Pages or through Programmatic Advertising. Customization of the content may occur through the Combination and/or Crossing of Data. 

Cookie: A cookie is a small text file that is downloaded onto your Device (e.g., smartphone, computer, iPad) when you access Our Pages. It allows websites to recognize your device and store information about your preferences or past actions (e.g., the fact that you visited the site, your language and other information). The information collected via cookies may be about you, your preferences or your Device and is mostly used to make Our Pages work as you expect. Information collection via cookies does not usually directly identify you, but it can give you a more personalized experience on Our Pages you are visiting, as they might be used to record your preferences regarding the use of Cookies (technical cookies), analyse and improve our Services and create new services and features or Customizing our Services, including Content that may be useful to you.

Data Controller or Joint Data Controller: refers to the legal person, public authority, service or other entity which, individually or jointly, determines the purposes and means for processing your Personal Data. With regard to the processing of customers’/clients’ personal data,  the Joint Controllers are Vivienne Westwood S.r.l. and Vivienne Westwood Ltd. With regard to online purchases and with reference to the relevant Shopping Data (e.g., transactional data), Vivienne Westwood S.r.l. and Vivienne Westwood Ltd will be Joint Controllers together with all the Entities around the world. 

Data Processor: refers to an entity that we engage to process your Personal Data solely on behalf of and pursuant to the written instructions provided by us.

Device: refers to the electronic device (e.g., iPhone) which you use to visit Our Pages.

Entities: refers to, Latimo S.A., having its legal office in Luxembourg, 8 Rue du Marchè-aux-Herbes, L-1728, Luxembourg, Rio Bravo Inc., having its legal offices in Los Angeles, 8320 Melrose Avenue, Los Angeles CA 90069, California, Vivienne Westwood Asia Ltd., having its legal offices in Shanghai, 26 Floor, No. 828-838, Zhang Yang Road, Pudong District, China (Shanghai), Vivienne Westwood France Sarl, having its legal offices in Paris, 175, Rue Saint Honorè, 75001, Vivienne Westwood Ltd (R.O. Thailand), having its legal offices in Chiang Mai, Kad Suan Kaew, 21 Huay Kaew Rd., T. Suthep. A. Muang Chiang Mai, Chiang Mai 50200 Thailand. More information is available by writing to: privacy@viviennewestwood.com.  

IP Address: is a unique number used by your Browser or your Device in order to connect to the internet. The internet service provider provides this number allowing identification of the provider and/or the approximate area where you are located. Without this data, you cannot connect to the internet and use our Services or use Content that may be useful to you. 

Other Tracking Technologies: pixel tags (tracers used with Cookies and embedded in images on web pages to track certain activities, such as the viewing of Content that may be useful to you, or to see if an e-mail has been read) or Unique Identifiers embedded in links to marketing communications that send us information when clicked on.

Our Forms: any form through which we can collect your Data (e.g., Sign-up Cards etc.). 

Our Pages: includes our Site (https://www.viviennewestwood.com/) also our social network pages. 

Our Shops: these include Vivienne Westwood e-commerce and our directly operated physical shops present worldwide. 

Personal Data: means any information relating to an identified or identifiable natural person whether directly or indirectly, as well as any information that is linked or reasonably linkable to a particular individual or household. For example, an e-mail address (if it refers to one or more aspects of an individual), IP addresses, and Unique Identifiers are considered Personal Data. 

Programmatic Advertising: these are platforms that share the information they collect about you, such as your IP Address and the data collected by Cookies, SDKs and Other tracking technologies, with entities who have an interest in showing you Content that may be useful to you. In our case, if you look at a particular product on Our Pages, we will ask participants in Programmatic Advertising to grant us an advertising space on one of the websites you visit in order to display Content that may be useful to you. On this point, we would like to reiterate that the communication of your Data to participants in Programmatic Advertising is based on your prior and specific consent provided on the banner when the first visiting Our Pages. If you want to know how you can object to such communications, please follow the instructions in the “How you can control your Personal Data and manage your choices” section above.

SDK: are software libraries that are installed together with a mobile application. They allow the collection of Data in the same way as the Cookies do on the Browser. Depending on the settings of your Device, SDKs can collect Information about your location, Unique Identifiers, and Data inferred by your activity. 

Sensitive Data: means Personal Data that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and the processing of genetic data, biometric data aimed at uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Services: collectively, this means all the services available on Our Pages and Our Shops including sales, booking an appointment with our stylists and aftersales services. 

Shopping Data: this category of data includes both information about the customer (e.g., first and last name, address, e-mail address, date of birth) and information on the transaction (e.g., goods, article numbers, purchase price and similar information).

Unique Identifiers: consist of information that can uniquely identify you through your Browser and Device. On the Browser, your IP Address and Cookies are considered Unique Identifiers. On your Device, advertising identifiers provided by manufacturers, such as Apple’s IDFA and Android’s AAIG, which we use for analysing and improving our Services and creating new services and features including Content that may be useful to you, are considered Unique Identifiers. Please note that for these purposes and in line with the opinions of the European Supervisory Authorities, we do not use other Unique Identifiers such as MAC Addresses and IMEIs as they are not resettable by you.  

Last Updated: February 2024

LOCALIZATION SECTION 
IF YOU HAVE RESIDENCE IN ONE OF THE COUNTRIES LISTED BELOW, PLEASE CHECK IN THE RELEVANT SECTION IF ANY SPECIFIC CLAUSE SHALL BE APPLIED. THE CLAUSES NOT MENTIONED BELOW REMAIN UNAFFECTED.
1.    AUSTRALIA
2.    AUSTRIA
3.    BELGIUM 
4.    CHINA
5.    FRANCE
6.    HONG KONG
7.    NEW ZELAND
8.    SWITZERLAND
9.    THAILAND
10.    UNITED STATES

AUSTRALIA 
IF YOU HAVE RESIDENCE IN AUSTRALIA, THE FOLLOWING CLAUSES WILL BE APPLIED: If you are in Australia, in addition to the rights and protections provided elsewhere in this Policy, you also have the:

  • right to anonymity and pseudonymity. While this means that you may withhold giving us your name, or use a fictitious name, it also means that we may not be able to provide a Service to you, or to fulfill a request, such as when you ask for access to your Data.

You can make a complaint under the Australian privacy law to the:

If you are in Australia, you should acquaint yourself with Australian telecommunication and data surveillance laws that operate independently of VW and limit your right to privacy.

AUSTRIA
IF YOU HAVE RESIDENCE IN AUSTRIA, THE FOLLOWING CLAUSES WILL BE APPLIED: 
You can always easily withdraw your consent from receiving newsletters and commercial communications inter alia in the following ways:

  • Through your account settings;
  • By clicking on the ‘unsubscribe’ link in any such email received; 
  • By writing to privacy@viviennewestwood.com; and/or
  • By contacting our Customer Service. 

BELGIUM
IF YOU HAVE RESIDENCE IN BELGIUM THE FOLLOWING CLAUSES WILL BE APPLIED: 

Welcome to Vivienne Westwood’s Privacy Policy: 

This Policy will help you better understand how we handle your data, for what purposes and how you can control your information. 
Pursuant to statutory requirements including the General Data Protection Regulation (GDPR) and the Belgian Personal Data Protection Act of 30 July 2018, this Privacy Policy also indicates: 

  • The nature of the personal information processed;
  • The methods used for obtaining the personal data; 
  • The purposes of the processing of personal information;
  • The identity and contact details of the data controller(s);
  • Categories of third parties involved in the processing activities;
  • The retention period of personal information; 
  • The privacy rights of users and the possibly to file a complaint; 
  • The protection of the personal data. 

(…)

The Services are generally not intended for persons under the age of majority in your country or for adults under guardianship. If you are under this age or you are an adult under guardianship, by using the Site you represent and warrant that you have obtained the consent of a parent or legal guardian to place orders and, in general, to use the services offered through the Site.

This means that if you are under 18, you need permission from a parent or guardian to use our website and services. If you are a minor when you visit our Website, we will assume that you have obtained this consent prior to your visit.

(…)
Why we use your Data:

If you are already an existing customer and have already purchased one of our products, we may send you targeted marketing communications for products in a similar category of products. This processing is based on our legitimate interest to send promotions pertaining similar products via e-mail (so-called soft opt-in). Existing customers will be informed of their rights and the possibility to withdraw their previously given consent to receive such communications at any time and in the ways mentioned below.

International Transfers:
 
We take steps and have safeguards in place to ensure that the processing of your Data by our Recipients is compliant with the applicable data protection laws, including the UK, Italian and Belgian laws to which we are subject. Where required by EU data protection law, transfers of your Data to Recipients outside of the EU will be subject to adequate safeguards (such as the EU standard contractual clauses for data transfers between EU and non-EU countries), and/or other legal basis according to the EU and the UK legislations. For more information on the adequate safeguards we have implemented with regard to Data that is transferred to third countries, please write to: privacy@viviennewestwood.com. 

Your data protection rights: 

At any time, you can ask to: 

  • Access your Personal Data: you have the right to access to all personal information we hold about you as well as to ask us for copies of your personal data. Depending on your use of our Services, we will provide the Data we have about you, such as, for example, your name, age, IP Address, Unique Identifiers, e-mail and preferences expressed, together with the Policy you received when you provided them, and the source of the Data (if, for example, they were provided to us by one of our business partners). 
    However, note that you must specify for which processing activities you would like to have access to your personal data. If you make the same request repeatedly or is clearly unfounded or excessive, we are allowed to refuse granting you these requests or charge an administrative fee covering the expenses. We can also refuse granting you a right to access your personal data, or only grant it partially, if such access would risk disproportional detriment to our rights and freedoms, including those of others; 
  • Object to the processing of your Personal Data: you can object to the processing of your personal data and to direct marketing.
  • Correct your Data: you have the right to ask us to rectify information you think is inaccurate or outdated and to complete information you think is incomplete. For example, you can ask us to modify your e-mail address or telephone number if they are incorrect;
  • Limit the processing of your Data: you have the right to ask us to restrict the processing of your information in certain circumstances: 
    - during the time we are assessing your request for correction of your personal data;
    - during the time we are assessing your objection to the processing of your personal data;
    - when such processing was unlawful but you prefer restriction to erasure;
    - we no longer need your personal data, but you require them for the establishment, exercise or        defence of a legal claim;
     
  • Delete your Data: you have the right to ask us to erase your personal data in certain circumstances:
    - when you do not want to use our Services and do not want us to retain your Data any longer; 
    - if our collection of them was illegitimate; 
    - if you have successfully exercised your right to withdraw your consent or your right to object to the processing of your personal data; 

When one of these circumstances applies, we will immediately delete your personal data unless the law, regulatory obligations or administrative or judicial orders prohibit us to delete your personal data; 

  • Exercise your right to the portability of your Personal Data: in respect of information you have given to us, you have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. According to your use of our Services, we will provide you with a structured, commonly used and machine-readable format containing your Data;
  • Withdraw consent: if we asked for your consent to collect and use your personal data, you have the right to withdraw that earlier given consent; 
  • Update your preferences for processing based on your consent. according to your use of our Services, you may request us to not send you marketing communications and/or to not personalize our Services including any Content that may be useful to you; 
  • Lodge a complaint: you shall have the right to lodge a complaint with us or with a supervisory authority, in particular the Belgian data protection authority (https://www.dataprotectionauthority.be/), if you consider a breach has been made in the processing of your personal data.

You can exercise any of the rights listed above towards: 

  • VW by writing to privacy@viviennewestwood.com
  • one or more Entities, which processed your Data by sending a communication to the contact details you will find in their communications; 
  • third parties who shared your Data with us (e.g., business partners, data brokers) via their e-mail address or your account settings on their platforms.

At any time, you can also contact the VW Legal Representative appointed within your jurisdiction:

  • If you are based in the EU: Vivienne Westwood S.r.l. with registered offices at Corso Venezia 25, 20121 Milano (MI), Italy;
  • If you are based in UK: Vivienne Westwood Ltd., with registered offices at 9-15 Elcho Street, London, England, SW11 4AU.

A request should clearly state and specify which right you wish to exercise. Always indicate the context in which we have obtained your personal data so that we may handle your request swiftly and diligently. Your request should also be dated and signed and accompanied by a digitally scanned copy of your valid identity card proving your identity. We may need to request other specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

In accordance with EU and Belgian data protection law, we try to reply to all legitimate requests within one month of its receipt (extendable for two further months in case of particular complexity or if you have made a number of requests). Please mind that some of your rights may be subject to restrictions if the applicable law allows to do so. If you have any complaint regarding the processing of your personal data, you may always contact us via the e-mail address mentioned above. 

If you remain unsatisfied with our response, you may file a complaint with the competent data protection authority, i.e. the Belgian data protection authority (https://www.dataprotectionauthority.be/).

What is not covered by this Policy: 

This Policy explains and covers the processing operations that we carry out as Joint Data Controllers through this website or through the stores. 

The Policy does not cover processing carried out by parties other than Joint Data Controllers and in particular does not cover: 

  • the processing carried out by our business partners as autonomous data controllers including those carried out by social media platforms within Our Pages.
  • the processing carried out by third-party websites linked to this website.  

 
With respect to such hypothesis, we do not assume any responsibility for the processing of your Data not covered by this Policy. We cannot guarantee that these parties will handle your personal data reliably or securely. We therefore recommend that you read the privacy statement of these third parties before using them.

CHINA

IF YOU HAVE RESIDENCE IN CHINA, THE FOLLOWING CLAUSES WILL BE APPLIED: 
You understand that your personal data are collected directly by Vivienne Westwood S.r.l. and Vivienne Westwood Ltd. as joint controllers, and your personal data will be stored and processed by foreign processors outside of China. If you do not agree, please do not provide your personal data to us.

FRANCE
IF YOU HAVE RESIDENCE IN FRANCE, THE FOLLOWING CLAUSES WILL BE APPLIED: 
When we collect your Personal Data during your offline purchasing process in Our Shops in France, we are Joint Data Controllers of your Shopping Data together with Vivienne Westwood France SARL.

HONG KONG
IF YOU HAVE RESIDENCE IN HONG KONG, THE FOLLOWING CLAUSES WILL BE APPLIED: 

Welcome to Vivienne Westwood’s Privacy Policy

This Policy will help you better understand how we handle your data, for what purposes and how you can control your information. Pursuant to statutory requirements including the General Data Protection Regulation (GDPR), Data Protection Act 2018 and the Personal Data (Privacy) Ordinance of Hong Kong, this Privacy Policy also indicates…

Why we use your Data -- Sending you marketing communications
If you decide to sign up to our newsletter and marketing communications, we use the personal data you provide us with and those collected by third parties (including your name, e-mail, and/or address) in order to send you communications about VW’s fashion products and other related products and the Services we offer, abandoned carts, our newsletter, information about our initiatives and/or to ask you to participate in our surveys, but we can only do so if you consent to this. Users may also be invited to submit personal information in addition to their e-mail address (e.g. gender, country of residence), for the purpose of having their communications personally tailored to their user profile. The main purpose of profiling is to propose products and services and initiatives more suited to the tastes, shopping habits and interests of its customers and this data allows VW to improve the site and personalised the products offered. In some cases, communications may include products or service promotions from selected co-branded companies (without sharing your Data with them). Such communications are sent by VW and may also be customized if we have a legal basis such as consent for the customization of Services, including Content that may be useful to you.  

You can always easily withdraw your consent, free of charge, from receiving newsletters and commercial communications in the following ways:

  • Through your account settings;
  • By clicking on the ‘unsubscribe’ link in any such email received; 
  • By writing to privacy@viviennewestwood.com; and/or
  • By contacting our Customer Service. 

Your data protection rights

You can exercise any of the rights listed above towards: 

  • VW by writing to privacy@viviennewestwood.com
  • one or more Entities, which processed your Data by sending a communication to the contact details you will find in their communications;
  • third parties who shared your Data with us (e.g., business partners, data brokers) via their e-mail address or your account settings on their platforms.

NEW ZELAND

IF YOU HAVE RESIDENCE IN NEW ZELAND, THE FOLLOWING CLAUSES WILL BE APPLIED: 

If you are in New Zealand, in addition to the rights and protections provided elsewhere in this Privacy Policy, you also have the right to a response in relation to your request for access to, or correction of your Data within 20 working days of us receiving the request (this doesn’t include public holidays and the period between 25 December and 15 January).

Asking for your information

You can request your information via email, letter, phone, or in person. You can also use our easy AboutMe (https://www.privacy.org.nz/tools/aboutme-request-my-info-tool/) tool to ask for your personal information. You should keep a record of what you asked for, when you asked, and who you asked for it from. 

In limited circumstances, we may legitimately extend the 20-working day timeframe, and if we do we will tell you why and when we will give you the information. We can also withhold information about you in limited circumstances, and we will tell you why if this case applies.

You can make an urgent request, but you must explain why it is urgent. We may also refuse the request for urgency. If we do, we will give reasons why. We may also transfer your request for information if we aren't the right place to help you. If we do this, the agency or person to whom we direct the request must inform you within 10 working days of receiving the request. 

Consumer rights related to Personal Information Processing

While the New Zealand Privacy Act makes sure your personal information is kept safe and secure online and offline, you also have the following related rights and protections as an individual data subject under New Zealand consumer laws. These protect you when buying from, or sharing your information with, businesses selling in New Zealand and online.

Problem with a product or service - You are covered by the Consumers Guarantee Act if there's a problem with a product or service you bought.

Problems with borrowing money or using credit - The Credit Contracts and Consumer Finance Act protects you when you borrow money or buy products or services on credit.

When a business acts in an unfair or misleading way - If a business acts in an unfair or misleading way, including sales tactics and selling unsafe products, you can be protected by the Fair Trading Act.

Being safe online
There are online safety laws and rules for e-signatures and electronic transactions, plus laws against spam and upsetting digital messages.

Complaints

You can make a complaint to the Information Commissioner of New Zealand here - https://www.privacy.org.nz/your-rights/making-a-complaint-to-the-privacy-commissioner/

SWITZERLAND

IF YOU HAVE RESIDENCE IN SWITZERLAND, THE DATA PROCESSING HAS ANY EFFECTS IN SWITZERLAND OR SWISS DATA PROTECTION LAWS APPLY FOR OTHER REASONS, THE FOLLOWING CLAUSES WILL BE APPLIED 

In addition to the statutory requirements of the GDPR and Data Protection Act 2018, this Privacy Policy is also made pursuant to statutory requirements under the Swiss Data Protection Act of 25 September 2020 ("Swiss DPA") and to the extent data is disclosed abroad, includes information on the name of the state and the safeguards or the applicability of one of the exceptions under the law.

International Transfers: 
VW is a global brand and Our Shops are available in multiple jurisdictions worldwide. This means that your Data may be stored, accessed, used, processed, and disclosed outside your jurisdiction, including within the European Union, United Kingdom and the United States of America. We take steps and have safeguards in place to ensure that the processing of your Data by our Recipients is compliant with the applicable data protection laws, including the UK and the Italian laws to which we are subject and to Swiss law to the extent it is applicable. We have put in place the following safeguards for the disclosure of data to the countries listed above: [Standard Contractual Clauses (SCC’s)]

Your data protection rights: In addition to the information above, please note that to the extent Swiss law applies, the fee mentioned will be raised, if the effort involved is disproportionate.

Also, to the extent Swiss law applies, in accordance with the Swiss DPA we try to reply to all legitimate requests as mentioned above under "Your data protection rights" within thirty days. Please mind that some of your rights may be subject to restriction.

The Swiss supervisory authority is the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, CH - 3003 Bern.

Definitions: 
To the extent Swiss law applies, terms contained in the Definitions section of this Privacy Policy that are also defined in Art. 5 of the Swiss DPA (Personal Data, Data Controller, Data Processor, Sensitive Data) shall have the meaning as defined in Art. 5 of the Swiss DPA.

THAILAND
IF YOU HAVE RESIDENCE IN THAILAND, THE FOLLOWING CLAUSES WILL BE APPLIED

Definitions:
“PDPA” means the Personal Data Protection Act B.E. 2562 (2019).
“PDPC” means the Personal Data Protection Committee, which acts as the supervisory authority responsible for overseeing the protection of personal information in Thailand.

International Transfers
If you have residence in Thailand, we may transfer your personal data outside Thailand when it meets one of the following conditions in accordance with the PDPA:

  • The destination countries that receive your personal data have an adequate level of data protection as prescribed by the PDPC.
  • The privacy policy regarding transferring your personal data to a foreign-affiliated company or group of undertakings, known as Binding Corporate Rules, has been put in place and certified by the PDPC.
  • The data controller has implemented appropriate protection measures that enable the execution of your rights under the PDPA, including appropriate remedial measures as prescribed by the PDPC.
  • The transfer is for compliance with Thai law.
  • Your consent has been obtained, authorizing the transfer of your personal data to a destination country that have inadequate personal data protection standards.
  • The transfer is necessary to fulfil contractual obligations with you.
  • The transfer is necessary for a contractual agreement between two entities for your benefit.
  • The transfer is required to ensure your safety to prevent further harm to your health when you cannot provide consent at the time.
  • The transfer is necessary for substantial public interest.

Your Data Protection Rights
Apart from the data protection rights mentioned in section “Your Data Protection Rights” above, which include access to your personal data, right to portability, correcting your data, limiting the processing, deleting your data and updating your preferences for processing based on your consent, you also have additional rights concerning your personal data under the PDPA, which are outlined below:

  • Withdrawal of Consent: If you have provided us with your consent to process your data, you have the right to withdraw your consent at any time unless there is a restriction of the withdrawal of consent by law, or the contract that benefits you. The withdrawal of your consent does not affect the legality of the processing carried out based on the consent until the withdrawal.
  • Right to Objection: if we are processing personal data that concerns you on the lawful basis of legitimate interest or for direct marketing purposes, you have the right to object to the processing of your personal data carried out by us or on our behalf.
  • Right to File a Complaint: If you believe that we have not complied with the requirements of the PDPA concerning your personal data, you have the right to lodge a complaint with the PDPC.

At any time, you can also contact the VW Legal Representative appointed within your jurisdiction at privacy@viviennewestwood.com

UNITED STATES

IF YOU HAVE RESIDENCE IN THE UNITED STATES, THE FOLLOWING CLAUSES WILL BE APPLIED: 

If you reside in the United States, the following provisions supplement the Privacy Policy provisions above if and as applicable.

What data we collect and process. 
Identity data, contact data, and other data you provide may include identifiers, such as name, email address, address, and phone number as well as any account information. Data you may provide may also include employment and education data, such as if you apply for a job, and we use the data to review job applications. Transaction data may include commercial data, such as products or services purchased or considered, financial information, and data under, for example, California Civil Code section 1798.80(e). All processed data are protected and supported in line with an applicable lawful basis for processing. This may include consent, legitimate interest, legal obligations or contracts. 

For technical and device data, namely data collected through cookies and tracking technologies, you may change your cookie settings in your internet browser and update settings on your device to manage your privacy controls. For more information and ways to opt out of these practices, see our Cookie Policy here.

We do not knowingly collect any personal information about children under the age of 13. If we obtain actual knowledge that we have collected such information, we will delete it. We have no such information to report under the Children’s Online Privacy Protection Act (“COPPA”). We do not have actual knowledge of selling or sharing personal data of consumers under the age of 16.