Privacy Policy

Fashionista.community by Quentral S.r.l.

Via Durini, 27 C.A.P. 20122 Milano (MI) Italy - P. IVA: 06383360960 - REA 1888893.

In accordance with art.13 of EU Regulation 2016/679 ("GDPR")

Modified on 2/10/2019

This is the Privacy Policy of Fashionista.community(Hereinafter Quentral).

This Privacy Policy was drafted to better explain to data subjects, how their Personal Data is collected and processed by Quentral.

Please carefully read this Privacy Policy to gain a clear understanding of howQuentralcollects, uses, protects or otherwise processes your Personal Data.

Quentral commits to the protection of Personal Data entrusted to it. Therefore, Personal Data processing and security are guaranteed with the utmost care and in accordance with the provisions of the privacy legislation set out in EU Regulation 2016/ 679.

This Policy describes who we are, for what purposes we may use your Personal Data, how the Data is processed, to whom it may be disclosed, where it could be transferred to and what your rights are. Therefore, we invite you to read this document and the information contained therein very carefully.

The terms used in the Privacy policy have the same meaning ascribed to them inGeneral terms and conditions,therefore we encourage you to read also the aforesaid document. Unless otherwise defined and set out in the Privacy Policyall capitalized terms used herein shall have the same meaning as defined in the General Terms and Conditions.

Anything set forth in this document and detailed below refers to the Personal Data processing which will be carried out by Quentralacting as the Data Controller.

With regard to Users' Personal Data, Processing of which is carried out in order to use Quentral's Software and for the provision of the Services, Quentral acts as the Data Processor on behalf of theFashionista.communitywho is and remains the Data Controller of the Personal Data of the end Users of the Service.

Therefore, acting as Data Controller Quentral determines the purposes and the means for the collection of Personal Data of the end Users-Data Subjects of the Service.

Who will process your Personal Data?

Your Data will be processed by the Data Controller:

Quentral srl (hereinafter the "Controller")

Via Durini, 27 C.A.P. 20122 Milano (MI) Italy - P. IVA: 06383360960, REA 1888893.

A detailed list of external Personal Data Processors is available at Quentral's registered office.

Why do we require your Personal Data?

Mobile Application: The User who downloads the APP Fashionista.community on his mobile device provides the authorization to access the data contained therein and consents to the activation of the georeferencing mode which makes his position visible to the other Users registered for the service. The same georeferencing option can be activated with the desktop usage mode.

Quentralwill use the collected Personal Data for the following purposes only:

· Your Personal Data is required to register to the service of Fashionista.community

· Quentral,also uses your Data to monitor the use of the website, check the efficiency of security procedures and compliance with the Terms and Conditions of use of the Service.

Advertising and Marketing: Quentral, or subjects authorized by it, will be able to use personal data published by users for promotional, advertising and / or marketing purposes, carried out with the aid of electronic tools such as the Internet, the website Fashionista.community, electronic mail, the social channels of Quentral (by way of example and not exhaustive facebook and twitter), any other social channels identified by Quentral. Any information publically shared by the user may be indexable by search engines.

Quentral will carry out the Processing:

· based on your specific and express consent;

· it is required:

- in order to comply with contract provisions relating to the services provided (for example, commercial contract and Service management);

- in order to comply with the legal obligations to which Quentral is subject (i.e..: accounting requirements, anti-terrorism inspections, other obligations under the applicable law);

- in order to meet users' requests for a better management of the Service;

- for a legitimate interest pursued by the Controller (i.e.: money laundering checks; fraud prevention).

The provision of Personal Data is therefore mandatory for the purposes specified at point above.

The purpose set forth at point above is not a legal requirement therefore the provision of the related consent is optional.

Any partial provision of or failure to provide Personal Data will result in the partial or total inability to meet the purposes above and provide the services.

Quentralassesses the entity and the adequacy of the Data provided in order to avoid Processing any Data that exceeds the purposes pursued.

We shall not use your Personal Data for any other or further purpose than those described in this Policy, unless we notify you in advance and, if this is necessary, with your prior express consent.

Which Data do we collect?

Upon registration you shall be requested personal and identification Data, that is your e-mail address and a password that will become the access to the service password.

If you choose to register to the service via social login (using your Account for other web applications such as for e.g. Facebook, Twitter) you should know that:

Quentral may receive the following information: full name, date of birth, public profile, list of friends,
Quentral may request authorization to write contents on your wall and/or your friends' wall.
your public profile from the web application used for registration will be visible to other users of the service of Fashionista.community.

Within the scope of the activities of the service provision, including the use by the user of browser and applications’ extensions for Mobile Devices, Quentralcollects information about your data, services used, and how you use the service.

When do we collect your Personal Data?

We collect your Data when you register for the service, whenever you use the service and whenever you enter information by accessing the service.

How will we use your Data?

We may use the collected Data when:

for example:

- you register, subscribe to our newsletter, participate in a survey or marketing and/or commercial communication, visit the Site, use the features on the website that hosts our Community in the following ways:

- To customise your user experience with information and contents more in line with your interests.

- To communicate with you (e-mail or telephone requests) and to send periodic e-mails relating to the Service and/or other services, to follow the correspondence with the users (live chats, e-mails or telephone requests).

How do we protect your Data?

Quentral's objective is the protection of its users' Data, by basing the processing on the principles of correctness, lawfulness and transparency.

We inform you, therefore, that your Personal Data will be processed, through the use of tools and procedures suitable to ensure maximum security and confidentiality, through archives and paper support, with the aid of digital support and computer and telecommunications means.

Your Personal Data is protected by a secure network which is accessible to a limited number of people who are expressly authorized and instructed to that effect. Every person authorized to be involved with the Processing is bound to confidentiality.

Is your Data shared with any third parties?

We do not sell, trade or otherwise transfer your Personal Data to any third party, except where specified below:

Quentral received your express consent to share the Data with third parties.
Only public authorities can access stored Data, in accordance with cases and modalities under the applicable laws, in the event of legal disputes.
When Quentral deems it necessary to remedy and/or prevent any damage and/or fraud and in any other event deemed necessary in order to protect the Platform, Software and Services.
When Quentral deems it necessary for the security of other Users of the Service.

Rights of the Data Subject (your rights).

At any time, you shall have the right to request:

i) confirmation about the existence of your Personal Data;

ii) access information about the purpose of processing, the categories of personal data, the recipients or categories of recipients to which Personal Data has been or shall be communicated and, where possible, the storage period;

iii) access to your Personal Data;

iv) update of your Personal Data in case of inaccuracy;

v) the erasure;

vi) processing restriction;

vii) the right to its portability, that is to receive the Personal Data you have provided in a structured, commonly used and machine-readable format.

viii) Withdraw consent at any time, without prejudice to the lawfulness of any processing based on consent before withdrawal;

Furthermore, you shall have: the right to object Data processing for the following purposes:

· if processed in the pursuit of a legitimate interest of the Controller;

· if processed for direct marketing purposes.

We shall treat your request with the utmost care in order to guarantee you the effective exercise of your rights.

You shall also have the right to submit a complaint to the Garante Privacy for the protection of Personal Data, or to the competent Authority that is the one of the place of habitual residence or domicile of who is bringing an action for the infringement of their rights, by following the procedures and instructions published on the Authority's official website www.garanteprivacy.it .

Unless you indicate otherwise, you shall have the option to exercise your right to object to both traditional as well as automated communications.

How long do we keep your Data for?

Your Personal Data shall be stored since receipt/update and for an adequate period of time consistent with the processing purposes above.

The Data that Quentralrequests upon registration will be stored for the term period of the relationship between you and Quentral.

In the logic of maximum transparency, we also wish to point out that, even once the relationship with you terminates, Quentral has the legal obligation to store a copy of some Data for a specific period of time, in compliance with the provisions of the applicable laws governing the subject matter.

Can I withdraw my consent after I gave it?

Yes, you can withdraw your consent at any time, without prejudice to: i) the lawfulness of processing based on consent before withdrawal; ii) further processing of the same data based on other legal bases (i.e.: contractual or legal obligations which Quentralis subject to).

For any further questions or doubt about this Privacy Policy:

support@quentral.com

Summary on the rights of the data subject and modalities for the exercise of rights.

Right of access of the data subject, Right of rectification, Right to erasure ("right to be forgotten '), Right to restriction of processing, Notification obligation regarding rectification or erasure of personal data or restriction of processing, Right to data portability, Right to object, Right to object an automated individual decision-making, including profiling, Right to object Processing for the pursuit of a legitimate interest of the Controller.

For ease of reference the following is the link to the GDPR from the Garante Privacy website to articles 15 to 23 on the data subjects' rights.

For any further questions and clarifications, you can contact us.

For more information about this Policy or any privacy issue, or if you wish to exercise your rights or withdraw your consent, you can contact us directly at support@quentral.com

Changes to this Privacy Policy

Quentralmay decide to review this Privacy Policy and the rules contained therein. IfQuentral decides to make any change to this Privacy Policy, at its sole discretion, and if it represents an essential change, Quentralshall notify such changes by publishing them on the websitethat hosts our Communityand/or by email to the email address provided to us, stating the "last update" date to indicate the date from which the changes shall take effect. By continuing to access or use thewebsite that hosts our Communityafter the entry into force of such changes, the user agrees to be bound by the provisions of the amended Privacy policy.

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Revisions list