PRIVACY POLICY

Wolford AG gives top priority to the protection of users’ personal data processing them only in full compliance with applicable legal provisions and ensuring data security. This Privacy Policy is meant to help users understand the most important aspects ofpersonal data processing while visiting and using services on Wolford Wesite (hereinafter the “Website”) and Users’ rights.

OWNER AND DATA CONTROLLER WOLFORD

WOLFORD AG, an Austrian stock company, whose registered office is at Wolfordstrasse 1 – 6900 Bregenz – Austria, is the Data Controller (hereinafter the “Controller”), i.e. the party which decides why and how your personal data are processed. 

You may contact WOLFORD at any time at the above address or via our Customer Service (link) and for any request relating to the protection of your personal data or to exercise your rights, you can contact WOLFORD’s Data Protection Officer (DPO) at the following email address: dataprotection@wolford.com

CATEGORIES OF COLLECTED AND PROCESSED PERSONAL DATA, PURPOSE AND LEGAL BASIS FOR PROCESSING

Data collected depends mainly on cookies users’ selection and may include connectivity time, location, users’ behavior and interaction with the website. Information about the surfing behavior of website visitors is collected and stored mainly anonymously, exclusively for the improvement of our offer and do not allow any conclusion on users’ personality.

  • We collect the personal data needed as contractual requirements to complete a purchase on our website or in-store, such as first and last name, phone number, email address, province, state, country, ZIP/Postal code (for invoicing and shipping purposes), gender (for salutation purpose), language, payment information, and date of birth (the latter is usually voluntary but may be required by law in specific jurisdictions for completing the online order); Credit card data are only transmitted between users’ internet browser and the server of Wolford payment service provider and may be stored by Wolford only if users register Credit Card Data on their Wolford account;
  • We collect email address, first and last name, and consent for users’ signing up for our newsletter service;
  • We process needed personal data when users contact our Customer Service, in order to provide the requested assistance;
  • We collect and use personal data for our marketing communications when users have either provided a specific consent (Art. 6(1) lit. a) or placed an order where processing serves to pursue WOLFORD legitimate interest to cultivate our commercial relationships with those who have expressed an interest in our products and to inform them of news and discounts. 
  • We collect personal data necessary to identify users’ on their customer account providing them access to their previous and current orders, and enabling them to use the services reserved for registered users. With users’ express consent we can process data for a better definition of users’ interest and preferences with respect to our products and services, in order to communicate offers and proposals in line with our customers’ tastes;
  • We collect information about users’ visit to WOLFORD.com, such as the visited pages and users’ interact with them, and we keep this information on our servers.

METHODS OF PROCESSING

The Controller takes appropriate security measures to guarantee integrity and availability of data and prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In some cases, in addition to the ControllerData may be accessible to third parties appointed as Data Processors for carrying out certain operations of this Website (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) The updated list of these parties may be requested from the Controller at any time.

PLACE

The Data is processed at the Controller's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location or contractual requirements, to which Wolford is bound, data transfers may involve transferring Users’ Data to a specific country (i.e. for shipping ordered products). 

In the case of a transfer of personal data to a country outside the EU, WOLFORD commits to apply all technical and organizational measures to ensure the integrity of the data and the compliance of the data transfer with the applicable regulations on the processing of personal data. 

RETENTION TIME

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for or as long as required by applicable laws (e.g.: Tax Law).

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Controller and the User shall be retained until such contract has been fully performed.

Personal Data collected for the purposes of the Controller’s legitimate interests shall be retained as long as needed to fulfill such purposes and until users request for data deletion. 

The Controller may be allowed to retain Personal Data for a longer period whenever users have given consent to such processing, as long as such consent is not withdrawn. 

Furthermore, the Controller may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon official order by a competent authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Some of the services listed below may use Cookies to identify users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the users’ interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services. In addition to any opt out offered by any of the services below, users may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page available at https://optout.networkadvertising.org/?c=1 

DIRECT EMAIL MARKETING

This Website uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by this Website.

  • Personal Data collected: email address

ANALYTICS

  • The services contained in this section enable the Controller to monitor and analyze web traffic and can be used to keep track of User behavior.

GOOGLE ADS (GOOGLE INC)

Google ADS is an analytics service provided by Google Inc. that connects data from the Google ADS network with actions performed on this Website.

Personal Data collected: Cookies and Usage Data.

  • https://policies.google.com/privacy?hl=en-GB 

FACEBOOK ADS CONVERSION TRACKING (FACEBOOK, INC.)

Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Website.

Personal Data collected: Cookies and Usage Data.

  • https://www.facebook.com/privacy/policy/?entry_point=facebook_page_footer

GOOGLE ANALYTICS (GOOGLE INC.) AND USER ID EXTENSION FOR GOOGLE ANALYTICS (GOOGLE INC.)

Google Analytics uses on this Website User ID, which is a Universal Anlytics feature that can associate multiple users’ sessions and activities within the same session with a unique ID creating a report. 

For Up-to-date information click here: https://support.google.com/analytics/answer/3123668?hl=en#zippy=%2Cin-this-article

The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Controller. Google Analytics Opt-Out information: https://support.google.com/analytics/answer/181881?sjid=14487191695669523258-EU

  • Google Analytics Privacy Policy: https://policies.google.com/privacy?hl=en

WORDPRESS STATS (AUTOMATIC INC.)

Wordpress Stats is an analytics service provided by Automattic Inc.

Personal Data collected: Cookies and Usage Data.

  • Privacy Policy https://automattic.com/privacy/

DISPLAYING CONTENT FROM EXTERNAL PLATFORMS

This type of service allows users to view content hosted on external platforms directly from the pages of this Website and interact with them.

  • This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it depending on the cookies setting

GOOGLE MAPS WIDGET (GOOGLE INC.)

Google Maps is a maps visualization service provided by Google Inc. that allows this Website to incorporate location and content of this kind on its pages with the purpose to provide users with information about nearest stores when users request this kind of service.

Personal Data collected: Cookies and Usage Data.

  • Privacy Policy: https://www.gmapswidget.com/gdpr/

HANDLING PAYMENTS

Payment processing services enable this Website to process payments by credit card, bank transfer or other means. To ensure greater security, this Website shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.

  • Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

ADYEN (ADYEN B.V.)

Adyen is a payment service provided by Adyen B.V.

Place of processing: Netherlands 

  • Privacy Policy: https://www.adyen.com/policies-and-disclaimer/privacy-policy

PAYPAL (PAYPAL INC.)

PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

  • Privacy Policy: https://www.paypal.com/us/legalhub/privacy-full

SOFORT (SOFORT GMBH)

SOFORT is a payment service provided by SOFORT GmbH.

  • Place of processing: Germany – Privacy Policy: https://www.sofort.com/datenschutzhinweise/

KLARNA (KLARNA BANK AB)

Klarna is a Swedish bank that provides online financial services such as payment solutions for online storefronts, direct payments, post purchase payments and more.

  • Privacy Policy: https://www.klarna.com/international/privacy-policy/

BONIVERSUM

Creditreform Boniversum is an agency providing payment risk management services based on data regarding ePayment history of various business clients 

https://www.boniversum.de/en/privacy-policy


MANAGING CONTACTS AND SENDING MESSAGES

This type of service makes it possible to manage a database of email and phone contacts or any other contact information to communicate with Users.

  • These services may also collect data concerning the date and time when Users were viewing the message, interacting with it, such as by clicking on links included in the message.

MARKETING CLOUD SALESFORCE

SALESFORCE supports Wolford in managing newsletter and its delivery as well as the analysis of newsletter reading behavior.

Personal Data collected: address, country, date of birth, email address, first name, gender, last name and Usage Data.

  • Place of processing: Germany– https://www.inxmail.com/data-conditions 

MARKETING CLOUD SALESFORCE- SMS SERVICE

ATTENTIVE- SMS SERVICE

SMS delivery and communication service.

Personal Data collected: phone number and various types of Data as specified in the privacy policy of the service.

Place of processing: US – https://www.attentive.com/legal/privacy. 

All customers have the chance to unsubscribe:

Just send the word "STOP" to the following number: +1 833 262 7255 

Please allow 24 hours for your request to be processed, and note that you will only unsubscribe from SMS/text communications.

If you have any questions, please get in touch with our Customer Service team at https://www.wolford.com/en-us/customer-service.html.

  • At Wolford, we take great care to respect and protect your privacy and contact details. For our full privacy policy, please visit https://www.wolford.com/en-us/data-policy.html.

MANAGING SUPPORT AND CONTACT REQUESTS

  • This type of service allows this Website to manage support and contact requests received via email or by other means, such as the contact form.
  • The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

SALESFORCE SERVICE CLOUD (SALESFORCE.COM, INC.)

Salesforce Service Cloud is a support and contact request management service provided by salesforce.com, inc.

Privacy Policy: https://www.salesforce.com/eu/company/privacy/ 

PLATFORM SERVICES AND HOSTING

  • These services have the purpose of hosting and running key components of this Website, therefore allowing the provision of this Website from within a unified platform. Such platforms provide a wide range of tools to the Controller – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

WORDPRESS.COM (AUTOMATTIC INC.)

WordPress.com is a platform provided by Automattic Inc. that allows the Controller to build, run and host this Website.

  • Privacy Policy: https://automattic.com/privacy/

REGISTRATION AND AUTHENTICATION

  • Registering or authenticating users’ access to their account may be provided bythird parties, which may have access to and store Personal Data, when required for Users’ registration or identification purposes.

DIRECT REGISTRATION (THIS WEBSITE)

  • The User registers by filling out the registration form and providing the Personal Data directly to this Website or in-store.

REMARKETING AND BEHAVIORAL TARGETING

This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.

This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.

  • In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

REMARKETING AND BEHAVORIAL TARGETING

This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.

This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.

  • In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

TAG MANAGEMENT

This type of service helps the Controller to manage the tags or scripts needed on this Website in a centralized fashion.

  • This results in the Users' Data flowing through these services, potentially resulting in the retention of these Data.

TIK TOK

TIK TOK is a social platform that collects data from users who are part of the platform. Wolford publishes information on TIK TOK for marketing purposes. More information here:

https://www.tiktok.com/legal/page/us/privacy-policy/en 

  • https://www.tiktok.com/legal/page/eea/privacy-policy/en 

INSTAGRAM

INSTAGRAM is a social platform that collects data from users who are part of the platform. Wolford publishes information on INSTAGRAM for marketing purposes. More information here:

  • https://help.instagram.com/155833707900388

GOOGLE TAG MANAGENT

Google Tag Manager is a tag management service provided by Google LLC.

Personal Data collected: Cookies and Usage Data.

Privacy Policy: https://policies.google.com/privacy?gl=AT&hl=en

USER DATABASE MANAGEMENT

This type of service allows the Controller to build user profiles by starting from email address, personal name, or other information that the User provides to this Website or in-store, as well as to track User activities, including User’s purchase history, through analytics features. These Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Controller can display and use for improving this Website and Wolford whole services including marketing.

  • Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Website or in-store.

SALESFORCE SALES CLOUD (SALESFORCE.COM, INC.)

See above

FURTHER INFORMATION ABOUT PERSONAL DATA

PERSONAL DATA COLLECTED THROUGH SOURCES OTHER THAN THE USER

  • The Controller of this Website may have legitimately collected Personal Data relating to Users by reusing or sourcing them from third parties.

AUTOMATED DECISION-MAKING

Automated decision-making means that a decision is taken solely by technological means without any human intervention. This Website may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. This Website adopts automated decision-making processes both for providing users with tailored product recommendations, or as far as necessary to enter or perform a contract between User and Controller, or on the basis of the User’s explicit consent, where such consent is required by the law.

Automated decisions are made by technological means, mostly based on algorithms subject to predefined criteria, and which may be provided by third parties.

The rationale behind the automated decision-making is:

  • to enable or otherwise improve the decision-making process;
  • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
  • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
  • to reduce the risk of User;s failure to meet their obligation under a contract.

CONSEQUENCES OF AUTOMATED DECISION-MAKING PROCESSES FOR USERS AND RIGHTS OF USERS SUBJECTED TO IT

Users subject to such processing are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.

Users have the right to:

  • Obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
  • Challenge a decision by asking the Controller to reconsider it or take a new decision on a different basis;
  • Request and obtain from the Controller human intervention on such processing. To learn more about the User's rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.


ANALYSIS AND PREDICTIONS BASED ON THE USER’S DATA (“PROFILING”)

The Controller may use the Personal and Usage Data collected through this Website to create or update User profiles. This type of Data processing allows the Controller to evaluate User choices, preferences and behavior for the purposes outlined in the respective section of this document.

User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more, about the profiling activities performed, Users can check the relevant sections of this document.

  • The User always has a right to object to this kind of profiling activity contacting the Controller at dataprotection@wolford.com. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

THE RIGHTS OF USERS

Users may exercise certain rights regarding their Data processed by the Controller.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Controller, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Controller will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Controller.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
  • Users must know that, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. 


HOW TO EXERCISE THESE RIGHTS

Any requests to exercise User rights can be directed to the Controller through the contact details provided in this document. The Controller will provide users requesting information with a copy of their personal data free of charge. However, a reasonable fee can be charged for further copies. 

For exercising Users’ rights described above, please, contact dataprotection@wolford.com 


COOKIE POLICY

This Website uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.


LEGAL ACTION

The User's Personal Data may be used for legal purposes by the Controller in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.

The User declares to be aware that the Controller may be required to reveal personal data upon request of public authorities.


SYSTEM LOGS AND MAINTENANCE

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) and process other Personal Data (such as the IP Address) .


HOW “DO NOT TRACK” REQUESTS ARE HANDLED

This Website supports “Do Not Track” requests via Usercentrics – more information available at https://usercentrics.com/ 


CHANGES TO THIS PRIVACY POLICY

The Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Controller. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Controller will collect new consent from the User, where required.


LEGAL INFORMATION

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to Wolford Website and Wolford stores, if not stated otherwise within this document.