Privacy Policy

PRIVACY POLICY

This privacy policy describes the personal data collected or generated (processed) during the use of the websites of 25H Holding S.r.l. It also explains how personal data is processed, shared, and protected, what choices are available to the user regarding personal data, and how to contact us.

WHO is responsible for the processing of personal data?

The company “25H Holding S.r.l.”, Via Maddalena n. 3/5, 20122 Milan, VAT no. 11293710965, is responsible for processing personal data depending on the user’s interaction with the Sites and, furthermore, based on the user’s location in the world. In this privacy policy, the related group companies of 25H Holding S.r.l. are referred to as “25H”, “our”, “us”.

WHAT personal data is collected and WHEN?

25H requires certain personal data to provide the requested products or services. For example, when making purchases, when contacting our consumer services, when requesting to receive communications, when creating an account, when participating in our events or contests, or when using our Sites or Apps.

This personal data includes:

  • Contact details including name, email, telephone number, and shipping and billing address;
  • Login and account information, including username, password, and unique user ID;
  • Personal details including gender, hometown, date of birth, and purchase history;
  • Payment or credit card information;
  • Images, photos, and videos;
  • Data on purchases made by the user or generated through our Sites or Apps;
  • Personal preferences including your wish list, as well as marketing and cookie preferences.

We also collect additional personal data to develop certain features within our Sites and Apps. For example, we ask for access to phone location data, contacts to allow you to interact with your friends, calendar or social network credentials to directly post content from an App to a social network. Such personal data includes:

  • Motion data detected by the device’s accelerometer;
  • Photos, audio, contacts, and calendar information;
  • Sensor data, including heart rate data and location data (GPS);
  • Social network information, including credentials and any information from your public posts on 25H or communications with us.

When interacting with our Sites and Apps, some data is automatically collected from your devices or browsers. This data includes:

  • Device ID, call status, network access, memory information, and battery information;
  • Cookies, IP addresses, referrer headers, data identifying the browser and version used, web beacons, and tags.
 

MINORS

In compliance with local legislation, we do not allow registration on our Sites or Apps for those who have not reached the minimum age set by the law of their country of residence. For the participation of minors in 25H experiences and events, parental consent will be required.

TOOLS for managing personal data that is collected

When using our Apps and our Sites, we will promptly communicate or request consent for certain practices. For example, we will ask for consent to use your location and to send push notifications. Consent can be obtained through the Apps or Sites or by using standard permissions available on your devices.

In many cases, your mobile platform or browser provides additional tools that allow you to control the collection or sharing of certain categories of personal data by the device. For example, your mobile device or browser may offer tools that allow you to manage the use of cookies or the sharing of location. We encourage you to familiarize yourself with and use the tools available on various devices.

WHY and HOW personal data is used

We use personal data in the following ways:

To guarantee the best functionality of the sites, apps and services that are requested:

When using our Sites and Apps, we use your personal data to provide the product or service you request. For example, if you make a purchase on 25holding.com, or take part in an event or promotion, we use the information you provide to communicate with you about the purchase, event or promotion. If you contact our Consumer Services, we use certain information about you, such as delivery or payment information, or information about the product you purchased, to help you resolve a problem or respond to a problem. to a question.

In some cases, to use particular features of our Sites and Apps it may be necessary to provide 25H with additional data or additional consent to use certain data in a certain way. For example, to share content on social media, you may be asked to provide your account credentials to log in.

To communicate information about our products, services, events and for other promotional purposes

After obtaining your consent, we will send marketing communications and news about 25H products, services, events and other promotions. This consent may be revoked at any time.

If you are an existing 25H customer (for example, if you have placed an order with us), we may use the contact details provided at the time of purchase to send communications for marketing purposes about 25H products or services or similar, where this is permitted by the applicable law (unless you have opted not to receive such communications). In other cases, consent will be requested to send 25H marketing information. Furthermore, we may use the information you provide and information relating to other 25H products or services, such as your use of the Sites and Apps, visits or purchases made in stores, participation in events and competitions, to personalize product communications and services that may interest you.

To operate, improve and maintain our business, products and services

We use the data you provide to run our business. For example, when you make a purchase, we use this information for accounting, auditing and other internal functions. We may use personal data relating to the use of our products and services to improve your experience with 25H, to diagnose technical and service problems and to better manage our Sites and Apps.

To secure our rights, property or safety

Additionally, we may use personal data in connection with your use of our Sites and Apps to prevent or detect fraud, abuse, illegal use, violations of our Terms of Use, and to comply with court orders, government requests or comply with applicable legal provisions.

For general research and analysis purposes

We use data about visitors’ use of our Sites, Apps and services to understand customer behavior or preferences. For example, we may use information about how visitors to 25holding.com search for and find products to understand how to best organize and present products in our stores.

Other purposes

We may also use personal data in other ways and we will provide specific notice and request your consent where necessary at the time we collect it.

Legal reasons

We process personal data in the terms required by law depending on the type of interaction with our Sites and Apps.

When you purchase 25H products and services from our Sites and Apps, personal data is necessary to allow us to fulfill the contract we have entered into with you. For example, payment and contact details are necessary to proceed with the delivery of the order.

When you use our Apps, we use your consent for processing and for limited purposes to fulfill the contract we have with you (for example, for purchases from the App).

For legal reasons, such as our legitimate business interests, to comply with legal obligations or to protect your vital interests.

SHARING of personal data

The sharing carried out by 25H

25H shares your personal data with:

– companies belonging to the “25H” group for the purposes and under the conditions described above;

– service providers who process personal data on behalf of 25H, for example to process credit card and payment data, shipping and deliveries, hosts, to manage data, to send emails, to research and analytics, to manage product and brand promotions, and to administer certain services and features. When we use third-party service providers, we stipulate agreements that require them to adopt suitable technical and organizational measures for the protection of personal data;

– other third parties to the extent necessary to: (i) comply with a government request, court order or to comply with applicable laws; (ii) prevent illegal uses of our Sites and Apps or violations of the terms and conditions of use of the Sites or Apps or our internal policies; (iii) defend against third party claims; and (iv) facilitate fraud prevention or investigation (e.g. counterfeiting).

– other third parties, where consent has been given.

We may also transfer personal information we hold about you in the event of a sale or transfer of all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).

Your sharing

When you use certain social features on our Sites or Apps, you may create a public profile that may include information such as your name, profile picture and hometown. Additionally, you can share content with friends or the public, including information about your 25H activity. We encourage you to use the tools we provide for managing 25H social sharing to control what information is made available through 25H social features.

PROTECTION and MANAGEMENT of personal data

Cryptography and security

We use a variety of technical and organizational security measures, including encryption and authentication tools, to ensure the security of your personal data.

International transfers of personal data

The personal data we collect (or process) in the context of our Sites and Apps will be stored in Italy and other countries. Some of the data recipients with whom 25H shares your personal data may be located in countries other than the country in which your personal data was originally collected. The laws of the above countries may not provide the same level of data protection as the country in which you initially provided your data. However, when we transfer personal data to recipients in other countries, including the United States, we protect that personal data as described in this privacy policy and in accordance with applicable law.

We take measures to comply with legal requirements applicable to the transfer of personal data to recipients located in countries outside the EEA or Switzerland that do not provide an adequate level of data protection. We take various measures to ensure that personal data transferred to such countries is adequately protected under data protection provisions; this includes signing European Union Standard Contractual Clauses, verifying that the recipient has adopted Binding Corporate Rules or adheres to the EU-US and Swiss-US Privacy Shield. For data transferred within 25H, we use an intragroup data transfer agreement.

Storage of personal data

We retain personal data for as long as necessary for the purposes set out in this privacy policy (unless otherwise required by law). Generally speaking, this means that we will retain your personal data for as long as you have a 25H account. Personal data relating to the purchase of products are kept for longer to fulfill legal obligations (for example those required by tax and sales legislation and for warranty purposes).

RIGHTS relating to personal data

The user has the right to request: (i) access to their personal data; (ii) an electronic copy of your personal data (portability); (iii) the correction of personal data if incomplete or inaccurate; or (iii) the deletion or restriction of personal data in certain circumstances provided for by applicable law. These rights are not absolute. You have the right to withdraw your consent to us processing your personal data at any time.

If you wish to request a copy of your personal data or exercise your rights, please use the 25H Privacy Web Form.

Opt-out for direct marketing

If you have a 25H account you can stop receiving marketing communications by changing your preferences in the “view and edit my profile” section of our Sites. The opt-out can also be exercised by changing your subscriptions via email or SMS or through the appropriate procedure identified. Alternatively, you can contact us using the contact details provided in the “Questions and Feedback” section below.

USE of 25H Sites and Apps with third-party products and services

Our Sites and Apps allow you to interact with a wide variety of other digital products and services. For example, our Sites and Apps may integrate with third-party activity tracking devices, social networks, music streaming services and other digital services.

If you choose to connect your 25H account to a third-party device or account, your rights regarding the processing of personal data on third-party platforms will be governed by their respective privacy policies. For example, if you choose to share your 25H activity on social media platforms, data collection on those platforms will be governed by their policies.

Our Sites and Apps may provide links to other (third party) websites and apps for your convenience or information. Linked Sites and Apps have their own privacy policies or policies, which we strongly advise you to review. To the extent any linked websites or apps are not owned or controlled by us, we are not responsible for their contents or any use of the websites or apps or the privacy practices of such sites Web or app.

CHANGES to our privacy policy

Applicable law and our practices change over time. If we decide to update our privacy policy, we will post the changes on our Sites and Apps. If we change the way we process personal data, we will provide you with advance notice or, where required by law, we will ask for your consent before implementing such changes. We strongly advise you to read our privacy policy and stay informed about our practices. This privacy policy was last modified in April 2021.

QUESTIONS and feedback

We welcome questions, comments and concerns regarding our privacy policy and our privacy practices.

If you wish to provide feedback or if you have any questions or concerns or wish to exercise your rights regarding your personal data, you can use the 25H Privacy Web Form.

The contact details of our Data Protection Officer are: 25H Holding S.r.l., Via Maddalena n. 3/5, 20122 Milan, C.F./P.Iva 11293710965 – Tel. +39 348 572 2280 / email: driss@25holding.com).

Privacy complaints will be evaluated in order to resolve the issue in a timely and effective manner. Furthermore, the user has the right to lodge a complaint with the Guarantor Authority of his country of residence.

COOKIE POLICY

Cookies are small aggregates of text recorded locally in the temporary memory of your browser, and therefore in your computer, for periods of time that vary depending on the need and generally between a few hours and a few years, with the exception of profiling cookies. whose maximum duration is 365 calendar days.

Using cookies it is possible to semi-permanently record information relating to your preferences and other technical data which allow easier navigation and greater ease of use and effectiveness of the site itself. For example, cookies can be used to determine whether a connection has already been made between your computer and our sites to highlight new features or maintain “login” information. To guarantee you, only the cookie stored on your computer is identified.

In order to make your visit to our website as convenient as possible and for the presentation of our product range, we use cookies or equivalent computer codes. We also use usability analysis tools that by tracking user actions allow us to understand how our sites are used and improve their functionality and design.

TYPES OF COOKIES

Cookies are divided into two families:

– Those installed by the owner or manager of the site, called first-party cookies;

– Those installed by managers unrelated to the site, called third-party cookies.

The responsibility and management of first-party cookies is assumed directly by the Owner.

The responsibility and management of third-party cookies falls instead on their respective owners and managers who must offer adequate refusal mechanisms in their privacy policies.

On this site or product there may be cookies belonging to six different types:

Technical, session and analytical cookies

These cookies are necessary for the correct functioning of the site and allow you to manage access operations (so-called login) to the sites, record configuration preferences where available or integrate plug-ins necessary for viewing certain contents.

Cookies used for statistical and performance analyzes are also considered technical cookies, provided they are configured to collect data in aggregate and anonymous form which offer a general picture of the performance of the sites and contents.

Traffic and performance analysis cookies

These cookies allow us to know how visitors use a site, what content they access and which geographical regions they come from in order to evaluate and improve the functioning of the site and favor the production of content that best meets the information needs of users. These cookies are subject to consent by users and refusal can be expressed directly to the respective managers.

Profiling cookies aimed at marketing and advertising

These are cookies used to deliver advertising content within a site or application. These cookies are used, for example, to track the position of the advertisement and check whether a user has already seen the advertising message but also to follow the user during his navigation to define his profile and present him with advertisements linked to personal interests and preferences. its sociodemographic characteristics.

Widgets and other tools for interconnection with external sites and functions

These are cookies, often associated with a graphic element of the site such as an action button or a specific logo (for example the Facebook “like” button), used to integrate the functions of other sites within the one you are using. sailing. These cookies are the responsibility of the respective managers and it is possible to oppose their use directly on the information pages of the respective manager.

Tracking pixels or web beacons

These are application code (script) and/or images that do not interfere with the aesthetics of the site but which allow a third party to track traffic trends. For example, they are used by advertisers to independently measure the progress of an advertising campaign and directly collect information that is otherwise not available. These cookies are also subject to the user’s consent and their renunciation is possible within the information of the respective managers.

Usability tools

They are functions written in application code that allow the site manager to analyze the way in which users interact with the contents and functions in order to verify ease of use, the quality of the design and plan improvements. These scripts are configured not to capture elements typed by the user that would undermine their privacy and are subject to explicit consent. The refusal of consent, when present on the pages of this site, is managed directly by the Owner.

WHICH COOKIES ARE INSTALLED ON THIS SITE?

The Owner tries to limit the use of cookies to what is strictly necessary to offer you the services of this and its other sites and products. In particular, we have the cookies indicated in the next paragraphs.

COOKIES NOT SUBJECT TO CONSENT
Technical, session and analytical cookies
Facebook Pixels

COOKIES SUBJECT TO CONSENT

The following cookies are subject to obtaining your consent. You can express your consent in a simplified way in the ways indicated in the information banner that you saw when you first accessed this site, or selectively using our Consent Management Tool.

To help you manage your consent preferences, we provide you with the tool that can be invoked with the button below through which you can selectively refuse individual cookies or entire categories of purposes for which cookies are collected, as well as obviously being able to deny or provide consent to all cookies managed with a single click.

Its operation is simple: activate or deactivate the purposes for which you give consent or, alternatively, select the individual subjects you want to authorize or prevent from operating, then click on the “Save preferences” button to record your choices . All the Owner’s partners are committed to respecting your choices.

You will be able to access the tool at any time through this cookie policy and, if it is the first time you visit this site or you have recently deleted the cookies installed on your browser, through the warning banner that appears at the top or bottom of the page you are visiting .

THIRD PARTY COOKIES UNRELATED TO 25H HOLDING

For all cookies installed by third parties not known to the Data Controller who, subject to your consent, process personal data also through this site, you can exercise your right to object by accessing the site https://www.25holding.com .

In case you have further doubts or concerns regarding the use of cookies, you can always intervene to prevent them from being set and read, for example by changing the privacy settings within your browser.

Since each browser – and often different versions of the same browser – also differ significantly from each other, if you prefer to act independently via your browser preferences you can find detailed information on the necessary procedure in your browser’s help. For an overview of the modes of action for the most common browsers, you can visit https://www.25holding.com.

DURATION OF TREATMENT

The cookies managed by the Owner have a maximum duration of 365 days, unless voluntarily renewed by you reiterating your consent.

The profiling cookies managed by the Owner are anonymous and, once expired, remain within the statistical systems and profiling platforms in aggregate form and not attributable to your browser for exclusive general statistical purposes.

Cookies managed by third parties have the durations indicated in the respective Cookie Policies.

MORE INFORMATION ON THE EXERCISE OF YOUR RIGHTS

Any request for information or clarification or to exercise rights can be addressed to the Data Controller at the following addresses:

– 25H Holding S.r.l., Via Maddalena n. 3/5, 20122 Milan

– or by sending an email to the address: driss@25holding.com

Furthermore, you always have the right to lodge a complaint with the Personal Data Protection Authority, which can be contacted at garante@gpdp.it or via the website https://www.gpdp.it.