Privacy Policy

Information note
This privacy policy is provided pursuant to article 13 of Legislative Decree No. 196/2003 – Italian Personal Data Protection Code (hereinafter, the “Privacy Code”) to those who interact with web services accessible via internet at the address: www.henrycottons.com. The privacy policy is relevant only to the Web Site in question and not to other web sites which the user might access via links. Specific summary policies shall be progressively reported or displayed on the web pages dedicated to particular services on request (e.g., newsletter, please contact the customer service, etc.).

Data controller
Browsing the web site www.henrycottons.com may require the processing of data relevant to identified or identifiable subjects. The Data Controller for such data is Industries Sportswear Company S.r.l., a company incorporated under Italian law, with registered office in Italy, at Via Bruno Maderna, 11 30174, Venice Mestre (VE), Tax-payer’s Code 08410230968 at the Company’s Register C.C.I.A.A. VE , VAT number 08410230968 fully paid capital Euro 1.650.000 (hereinafter, “ISC”), which may, at its own discretion, delegate its functions wholly or partly to third-party technical partners, that shall be required to comply with the confidentiality of the information received and to refrain from using it for purposes which differ from those accepted by the user through this privacy policy. More information about the Data Processors may be obtained by sending an e-mail to info@henrycottons.com. ISC reserves the right not to respond to illegal requests or to requests that are not based on the rights set out in the Privacy Code.

Navigation data
Some personal data, the transmission of which is implied in the use of communication protocols of the Internet, is captured by the software and systems that enable the operation of this website during normal operation. This data is not collected to be associated to individuals, but it could, through processing and connections with information held by third parties, allow users to be Identified. For example, the data in question may be: the addresses provided by the ISP, the domain names of computers used by users connecting to the website, URI (Uniform Resource Identifier) of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the reply by the server (successful , error, etc.) and other parameters regarding the operating system and the environment of the user. The use of longer available data is limited to the purpose of obtaining anonymous statistical information on the site and to check its correct operation and is deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the website: except for this possibility at present data concerning web contacts does not persist for more than 6 (six) months.

Cookies
Cookies are small text files that are stored on your computer when you visit a website. In the course of each subsequent browsing they are then sent back to the original website (first-party cookies), or to a different website which is able to recognize the specific cookie (third-party cookies). Cookies are useful as they allow a website to recognize the User’s device. They serve different purposes, for example allowing a more efficient use of the Web, saving favorite websites, and, generally speaking, offering an enhanced browsing experience. They also help guarantee that advertising content is more customized to User’s interests. According to their function and purpose, cookies can be divided into technical cookies, profiling (behavioral) cookies, and third-party cookies.. More details at List of Cookies.

Log files and their storing
The log files will be tracked for security reasons requiring the registration and maintenance of log files and their accessibility to the judicial police in the event that the latter request it. To this end, the file access log will be maintained for a period not exceeding 6 months/-1 year. Any access controls will be carried out in a gradual way and in full compliance with the law, particularly the principles of necessity and proportionality.

Data provided voluntarily by the user
The submission by users of email addresses indicated on this website entails their subsequent acquisition by the sender, necessary to respond to requests, and of any other personal data included in the message. Except as specified above with respect to navigation data, the user is free to provide personal data reported in forms for inclusion in the database of curricula or the sending of informative material or other communications. Their non-submission can make it impossible to fulfill the request.

Method of processing
Personal data is processed by automated tools by ISC and other parties (previously selected for their reliability and professionalism), for the time strictly necessary to achieve the purposes for which it was collected by the web site (read more on the “Subjects or categories of subjects to whom information may be disclosed” section).
During the data processing that may directly or indirectly identify the user, ISC tries to respect the principle of strict necessity. For this reason ISC has created the Website in such a way that the use of the user’s personal information is kept to a minimum: therefore the processing of the user’s personal data is excluded when the purpose of the specific activity can be achieved through the use of anonymous data (such as, for example, market research aimed at improving services) or through other means that allow for identification of the individual only when necessary or at the request of the authorities and police forces (such as, for example, data relevant to traffic and to time spent on the website or to user’s IP address).
Personal information shall be disclosed to third parties only with the express consent of the concerned subject, except for the cases where the disclosure is required by law or the law requires an express consent or is instead required for purposes envisaged by law or for the carrying out of the activities requested by the user.
Personal data shall not be transferred abroad to countries other than those that are part of the European Union, which do not provide a sufficient level of privacy protection. Should this be necessary in order to provide the services, ISC guarantees to the user that the transfer of personal data to countries that are not part of the European Union and that do not ensure an adequate level of protection shall be carried out only after the execution, between ISC and such entities, of specific agreements in accordance with applicable law and regulations.
ISC reserves the right to eliminate the accounts and all related data in case illicit content, possibly damaging the image of ISC and/or of its products or of any third party, or otherwise offensive content or that promotes illegal or defamatory activities, pornographic content, that incites violence, promotes discrimination based on race, sex, religion and sexual orientation, is discovered.

Purposes
The specific purposes for which the data is processed are summarized from time to time, under article 13, Privacy Code, which is presented to the user when he/she discloses personal data.
In general, data is processed to provide the following services available on our Website:
1. registration with the Website, to enjoy the relevant services;
2. adherence to additional and specific services, such as our newsletter and other similar information services about our business, inviting the user’s friends to join ISC’s world, allow the users to be known by other users by sending their photos and comments;
3. handling of the user’s requests: concerning technical, commercial issues, the progress of their orders and requests for information in a broader sense;
4. contact with the managers of our services (Press Office, Business Development, Web Marketing, Purchasing, Customer Service);
5. request for an evaluation concerning the recruitment of the user by ISC by the sending of CVs.

In addition, if in the interest of the user, data may be used for:

1) direct marketing initiatives (sending of advertising, giveaways, communications, promotions, events and prize competitions), also by means of communications sent by e-mail, text message, video message or phone;

2) carrying out of market and surveys analysis on buying and consumption habits (creation of customer profiles) in order to, among others, better meet the tastes of the user.

Optional or compulsory data communication
The conferment to ISC of the user’s personal information is required in several collection occasions, from time to time, in order to achieve the purposes identified in the relevant policy, or can be freely chosen by the user who wants to access the services offered by the Website.
The mandatory or optional nature of the conferment is specified from time to time – with reference to the specific data requested – at the time of the single data collection, by using a special character (*) next to the compulsory information.
The eventual refusal to disclose to ISC certain information marked as compulsory, may make it impossible to achieve the main purpose of the specific collection: such refusal might, for example, make it impossible for ISC to provide other services available on the website (support services – Contact Customer Service, send the news). The conferment to ISC of additional data, other than those designated as essential, is instead optional and shall not have any consequence in order to achieve the main purpose of collection (for example, depending on the circumstances, the use of the Website and its services).

Subjects or categories of subjects to whom the information may be disclosed
In order to perform the services requested by the user at the time of indication of personal data to ISC, the same notifies that it may also make use of external companies that carry out activities strictly connected with and instrumental to the completion and execution of agreements and supply of services such as: management of customer records, third-party companies for market analysis’ purpose, marketing and communication’s activities.
The data processing from these subjects aims at the implementation of the orders received from customers and/or storage on data carriers.
ISC could share data with other Emerisque group’s companies so that they can save it centrally as data controller.
The data may also be communicated to all subjects to whom the communication is due for legal obligations.
The list of subject that process personal information is always available by submitting a specific request to Industries Sportswear Company S.r.l., via Bruno Maderna, 11 30174, Venice, Mestre (VE), Italy, also by e-mail at: info@henrycottons.com. No data deriving from the web service is disclosed.

Duration of the processing
User’s data shall be stored by ISC for the period which shall be strictly necessary to ensure the proper supply of the required services – without prejudice to the obligation of data’s conservation for a longer period in compliance with applicable regulations, including accounting regulations.
It is understood that the data shall be stored and processed by ISC for the purposes of profiling for the longest term allowed by applicable law. At the end of this term, ISC may ask the user to renew the consent to the processing of personal data, or render the same data anonymous and keep it only for statistical or chronological purposes.
The user shall always have, at any time, the opportunity to revoke his/her consent to the processing of data for marketing purposes: in every commercial communication there must be a section that allows the user to easily revoke the consent given.
The data transmitted to service providers shall be processed for the time strictly necessary for the performance of the relevant entrusted tasks.

Rights under Article 7 of Legislative Decree No. 196/2003
The subjects to whom the personal data refer may at any time exercise, against the Data Controller, the rights provided for in Article 7 of Legislative Decree 196/2003, including the right to obtain the confirmation of the existence or not of personal data concerning them, to know the content and the origin of the data, the purposes and methods of the processing. They also have the right to verify the correctness, request the updating, correction or, if they have interest, the integration of data, the deletion, transformation into anonymous form or the blocking of data that has been unlawfully processed, including data whose conservation is not necessary in relation to the purposes for which the data has been collected or subsequently processed, and to object to the processing, for legitimate reasons, of their personal data, even if pertinent to the purposes of collection, as well as the processing of personal data for the sending of advertising materials or direct selling purposes or for the carrying out of market researches or of information, promotional and commercial communication.
The data subject is free to refuse, now or at any time in the future, to supply data for the direct sale of ISC products.

To exercise the rights hereto, to obtain an updated list of the subject to whom the data is disclosed and for any further information relevant to the processing of personal data carried out by ISC through the Website the user may contact us at the following address:

Industries Sportswear Company S.r.l., Via Bruno Maderna, 11 30174, Venice, Mestre (VE), Italy

e-mail: info@henrycottons.com

Updating of the Privacy Policy
This information may be changed over time to adapt to any changes in the law or for reasons of commercial convenience. Any material change to this address will be published, and the user agrees to periodically monitor this website to inquire about the validity or the modification of these conditions.

Governing Law
This Privacy Policy is governed by Italian Law and in particular by the Privacy Code which governs the processing of personal data – also held overseas – carried out by anyone who is domiciled or has registered offices in Italy. The Privacy Code guarantees that the processing of personal data shall be performed in light of the respect of the rights and fundamental freedoms, as well in light of the user’s dignity, particularly with regard to confidentiality, personal identity and the right of protection of personal data.