PRIVACY POLICY

FILOBLU SpA

Information on processing of personal data provided pursuant to Art. 13 of Legislative Decree no. 196 dated 30 June 2003 (Privacy Code).
The personal data provided by the user while using the website www.frau.it (the “Website”) will be processed by Calzaturificio Frau Spa con sede in San Giovanni Ilarione (VR), Via Torino 18/20, VAT 03676290269, as the Data Controller, and by FiloBlu S.p.A., with registered office in Santa Maria di Sala (VE), Via Caltana 116/C, VAT number 04274870288 (“FiloBlu”), VAT 04274870288, as the Data Processor appointed by Calzaturificio FRAU to manage the Website and the related services (maintenance, updating, user assistance services, marketing activities) and as the data processor exclusively for sale of the products present on the Website and related activities (such as: delivery of the products purchased, any replacement of them, fulfilment of users' requests for information, etc.).

Processing will be performed using primarily electronic methods (excluding shipping and sending of products). The personal data will therefore be processed using automatic and manual instruments for the time strictly necessary to achieve the purposes for which it has been collected.

Specific security measures are in place to prevent loss of the data, its illegal or incorrect use and unauthorised access.

The personal data collected on the registration forms for the Website services and/or any collected during browsing of the Website will be processed for the following purposes:

(i) to allow registration on the Website, access to and supply of the services reserved to users registered on the Website and sending via the Website of a purchase order for the products available on the Website in a simplified manner, with the consequent conclusion of the related contract of sale with FiloBlu, or to allow FiloBlu to satisfy users' requests for information. If you have registered on the Website through the Facebook Connect application, providing your username (e-mail address) of access to the Facebook social network , you authorise us to access some of your personal data (e-mail address, name, surname, profile picture, age, date of birth, gender), if you have already supplied this data to Facebook. For this reason, we suggest that you should first check the privacy settings of your Facebook account, if you wish to change visibility of said data, and the Facebook privacy policy;

(ii) to allow a purchase order for the products available on the Website to be sent and the related contract of sale with FiloBlu to be concluded and fulfilled and the consequent services and obligations to be satisfied, including administrative and accounting procedures, by FiloBlu;

(iii) to send advertising material and newsletters, to provide commercial information by telephone, SMS, MMS, e-mail, and also using traditional methods (e.g. sending catalogues by post), on promotional and sales initiatives of the Website and Cazaturificio Frau spa, to conduct market research and surveys on satisfaction);

Pursuant to articles 24.1.b) and 43.1.b) of the Privacy Code, your consent is not required for processing relating to the purpose indicated in point (ii). Unless otherwise indicated, the person concerned must express their consent to processing of data for the purposes indicated in points (i), (iii).

Any use of your credit card data for purposes other than to check that the means of payment exist, to charge and manage the payments and to manage any claims and disputes, is excluded. For this purpose, said data will also be processed by the bank which supplies the services connected with management of online payments and by the issuer of the credit card which you enter to confirm your order.

It is not compulsory to provide the data, but failure to do so could mean that the purchase process cannot be concluded or the services offered by the Website you desire supplied to you.

Solely for the aforementioned purposes, the personal data may be disclosed to and processed by:

- companies supplying services,
- employees and consultants of Calzaturificio Frau spa and FiloBlu, other companies of their respective Groups,

who act as representatives or processors duly appointed by the relative data controller. Up-to-date lists of any processors appointed by Calzaturificio Frau spa and/or by FiloBlu are available at the respective registered offices and you may ask for a copy of the lists at any moment, as specified hereunder.

The data may also be transferred abroad, including to non-EU countries. If necessary to achieve the aforementioned purposes, we ensure that transfer of the personal data of the person concerned to non-EU countries which do not guarantee sufficient security levels only takes place when specific agreements have been signed between Calzaturificio Frau spa and/or FiloBlu and said parties, containing appropriate clauses for protection of your personal data, in accordance with the law and applicable regulations.

The data will not be disclosed in any manner other than the above.

If you have indicated a service or a product on sale on the Website to a third party or a product you have purchased is delivered to a third party and FiloBlu is required to process the data of said third party, please inform them of the Privacy Policy of the Website and obtain their consent, since you will be solely and exclusively liable for communication of information and data relating to them, and for incorrect or illegal use thereof. It is understood that FiloBlu, within the limits laid down by the Privacy Code, will satisfy the obligation of informing the user indicated and, where necessary, will request their express consent, on registering the relative personal data in its archives.

Please remember that, as the person concerned, according to art. 7 of the Privacy Code, which is shown below for the sake of completeness, you are entitled to be informed, at any moment, whether or not your data exists and to be told its content and origin, to check it is precise and ask for it to be supplemented, revised or corrected. You are also entitled to ask for the data to be deleted, converted into anonymous form or blocked and to oppose use of your data for the purposes indicated above, in full or in part, at any time. You may exercise these rights and ask for an up-to-date list of the data processors appointed by contacting Calzaturificio Frau spa at the following telephone numbers +39 800 471 999 or by sending an e-mail to com@frau.it and for FiloBlu, at the following telephone numbers +39 041/8380042 or by sending an e-mail to customercare@frau.it.

PRIVACY POLICY
CALZATURIFICIO FRAU SPA

Described in this page are the website management rules in relation to the processing of personal data of users who navigate it. This is a disclosure notice issued also in accordance with Art. 13 of Legislative Decree No. 196/03 to those who interact with the services accessible online from the address www.frau.it.

The disclosure notice is issued only for the above-mentioned website and not for other websites that may be viewed by a user through links. The disclosure notice draws inspiration also from Recommendation No. 2/2001 that the European Authorities for the protection of personal data, gathered in the Group established by art. 29 of Directive No. 95/46/EC, adopted on May 17th, 2001 to identify some minimum requirements for the online collection of personal data and, in particular, the modes, the timelines and the nature of the information that the data controllers must provide users when the latter connect to web pages, irrespective of the purposes of the connection.

Data controller and supervisors for data processing
Following the navigation of this website, the data of people who are identified or identifiable, may be subjected to processing. The "data controller" is Calzaturificio Frau Spa, a Company with head office in San Giovanni Ilarione (VR), Via Torino 18/20.

The data controller has appointed data supervisors as a result of the activity generated through this website. The names of such appointees are available at the head office.

Data processing place
The data processing connected to the web services of this website takes place at the above-mentioned head office of the data controller and is handled only by the staff charged with the processing. If required, some data may be processed by the staff of the company charged with the maintenance of the technological part of the website at the company’s head office.

Types of data being processed


(i) Navigation data
The computer systems and software procedures used to operate this website acquire, during normal operations, some data whose transmission is implicit in the use of Internet communication protocols. This information is not collected for the purpose of being associated with identified interested parties, but, due its very nature could, through processing and associations with data held by third parties, allow the identification of users. This data category includes IP addresses or domain names of the computers used by users who connect to the website, the Uniform Resource Identifier addresses of the resources required, the time required, the method used to submit the request to the server, the size of the file obtained in reply, the number code indicating the status of the reply provided by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s computer environment. This data could be used for the sole purpose of gaining anonymous statistical information about the use of the website and checking its proper operation and is deleted immediately after processing. The data could be used to determine liability in the event of hypothetical computer crimes against the website: except for this case, data regarding web contacts currently do not last for more than seven days.

(ii) Data voluntarily provided by a user
The optional, explicit and voluntary sending of emails to the addresses mentioned in this website entails the acquisition of the sender’s address which is required to reply to requests as well as of any other personal data included in the letter. Specific disclosure notices may be posted in the pages of the website set up for special services on user’s request.

(iii) Cookies
Cookies are code portions installed inside the browser that the websites visited by users send to their terminals where they are stored to be forwarded back to the same websites upon subsequent visits. The only cookie which is present in this website is the cookie that identifies the user name of the person who has accessed an e-commerce site and the number of items in his/her shopping cart (the type or selected items are stored in the online shop – see the relevant privacy policy). This application is a technical cookie that saves preferences and optimizes the process and that does not require the consent of the interested party. Therefore, it is automatically installed upon the website being accessed. The interested party may nevertheless disable this application by changing the settings of his/her browser. However, if the user blocks or cancels this cookie, the functions described above may be impaired. An interested party should contact the data controller, Calzaturificio Frau Spa, for further information on this topic.

(iv) Optionality of data provision
In addition to that which was specified for navigation data, a user is free to provide the personal data shown in the request forms in order to expedite the sending of information material or other communications. Failure to provide such data may result in the impossibility to receive what was requested.

(v) Processing modes
Personal data is processed with specific tools for the time strictly necessary to achieve the goals for which it was collected. Specific security measures are complied with in order to prevent the loss of data, unlawful or improper uses and non-authorized access.

(vi) Interested parties’ rights
The persons whom personal data refers to have the right at all times to obtain confirmation of the existence or otherwise of said data and to know the contents and origin, check its accuracy and request that it be integrated or updated or corrected (article 7 of the Personal Data protection Code). In accordance with said article, an interested party has the right to demand the deletion, the transformation into anonymous form or the blocking of the data that has been processed in breach of the law as well as object, for lawful reasons, to such data being processed. Any such requests should be addressed:

by email to: com@frau.it
or by mail to: Via Torino, 18/20 37035 S. Giovanni Ilarione (VR) – Italy

COOKIE POLICY

Pursuant to Provision no. 229 http://www.garanteprivacy.it/web/guest/home/docweb/- /docweb-display/docweb/3118884 issued by the Personal Data Protection Authority on May 8, 2014, www.manilagrace.com provides the following information on cookies and on their functions, as well as instructions on how to disable them.

What are cookies?

Cookies are small text files that the sites visited by the user send and record on his/her PC or on any other device, even mobile, to be sent back to the original sites on the next visit.
Cookies are used for various purposes, for instance, to remember the user’s actions and preferences (such as, for instance, login data, selected language, font size, other display settings, etc.) so that they must not re-entered when the user returns to the same site or surfs from one of its pages to another; or to perform computer authentications, to monitor sessions and store information on the activities of user who access a site, and it can also contain a unique ID code that allows keeping track of the user’s surfing within the site for statistic or advertising purposes.
Cookies can be sent by www.frau.it or also by different sites (the so-called “third party” cookies). Some operations cannot be carried out without using cookies that in some cases are technically necessary for the site to work.

Types of cookies found on the site www.frau.it and relevant functions

There are various types of cookies, according to their characteristics and functions:

- Technical cookies, which are used for the sole purpose of sending a communication on an electronic communication network, or in the measure strictly necessary to provide a service explicitly requested by the user. In other words, these cookies are indispensable to make www.manilagrace.com work, or necessary to perform activities that you have requested. This type of cookie can be found in our site;
- Navigation or session cookies, used to allow you to login in the reserved area of www.manilagrace.com or to make a purchase on our site. This type of cookie can be found in our site;
- Analytics cookies, used to collect information, in an aggregate form, on the number of users of www.manilagrace.com and of the displayed pages (for instance, Google AdWords, Google Analytics and Mailchimp). Please, refer to the relevant policies that can change from time to time and that we recommend consulting every now and then, where you will find more detailed information:
http://www.google.com/policies/technologies/ads/;
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage;
http://mailchimp.com/legal/privacy/).
This type of cookie can be found in our site;
- Function cookies, which allow you to surf www.manilagrace.com at your best, according to already selected criteria and options (such as, for instance, your preferred language) so that you won’t have to select such option or the products you have chosen at every access, and they can be stored in the virtual trolley until your next visit to our site. This type of cookie can be found in our site;
- cookies of third parties, used by partners of www.manilagrace.com, in order to display advertising banners of www.manilagrace.com when you are on other sites, showing you the latest products that you have looked at on www.manilagrace.com. While you browse on www.manilagrace.com, these cookies are used also to show you products that you might like or similar to those you have previously browsed, based on your previous navigation chronology. The use of these cookies does not imply personal data treatment, but it can enable your computer or other devices to connect and track down saved data: these cookies connect to the browser installed on your computer or on other devices used while browsing on www.manilagrace.com;
- profiling cookies, used to create user profiles in order to send advertising messages consistent with the preferences shown by the user during his/her navigation. Our site contains third party cookies that access user data only at aggregate level. Please, find here below the links to the privacy policies and relevant consent forms of such third parties, which can change from time to time and that we recommend consulting every now and then, where you will find more detailed information:

http://www.google.com/intl/en/policies/technologies/ads/;
http://www.google.com/intl/en/policies/privacy/.
http://www.google.com/intl/it/policies/technologies/ads/;
http://www.google.com/intl/it/policies/privacy/ .
http://legal.yandex.com/privacy/
https://www.adroll.com/about/privacy
http://www.criteo.com/privacy/
https://twitter.com/privacy?lang=it
https://support.twitter.com/articles/20170514-twitters- use-of- cookies-and- similar-technologies#
https://www.youtube.com/static?template=privacy_guidelines
https://www.linkedin.com/legal/privacy-policy;
https://www.linkedin.com/legal/cookie_policy
https://www.facebook.com/help/cookies/?ref=sitefooter
All the above-described types of cookies can stay in your computer or mobile device for different times, according to their function.
The cookies stored in your computer or mobile device cannot be used to recall any of the data stored in your hard disk, transmit viruses, identify and use your e-mail address, or for purposes other than those described above.

How to modify cookie settings

Find here below the path to follow to manage the cookies from the following browsers:

Internet Explorer: http://windows.microsoft.com/it-it/windows7/block- enable-or- allow-cookies 

Safari: http://support.apple.com/kb/PH19255   

Chrome: https://support.google.com/chrome/answer/95647?hl=it-IT&hlrm=fr&hlrm=en  

Firefox: http://support.mozilla.org/it-IT/kb/enable- and-disable- cookies-website- preferences

For more information and details on the various types of cookies, their functions and Analytics characteristics, visit the free access sites, independent from www.manilagrace.com - www.AllAboutCookies.org and www.youronlinechoices.com.
To disable analytics cookies and prevent Google Analytics from collecting data on your navigation you can download the browser additional Component for disabling Google Analytics: tools.google.com/dlpage/gaoptout.
We will store your cookie preferences thanks to a dedicated technical cookie with the characteristics specified in the previous table.
We inform you that blocking or cancel, totally or partially:

- technical cookies, could make it impossible to use our site, see its contents and use the relevant services;

- function cookies, could make some services or site functions unavailable or working incorrectly, forcing you to modify or manually enter some information or preferences every time you visit the site.

- of other cookies (analytics and profiling), will not affect the site efficiency.