Privacy notice – Website
Last update: 15th November 2022
The website www.fashionleapforclimate.com (hereinafter “Website”), operated by Quantis (hereinafter “Quantis”) on behalf of Zalando, Yoox Net-a-Porter and About You acting as co-publishers (hereinafter individually “Publisher”, collectively “Publishers”).
While you are accessing, browsing and using the Website and its services, you communicate your personal data to Quantis acting on behalf of the Publishers.
Please read this privacy notice carefully as it explains how Quantis, acting on behalf of the Publishers, uses your personal data and how to exercise your rights to your personal data. This privacy notice supplements any document or notice that may refer to this privacy notice.
Should you have any question, you may directly contact Quantis, acting on behalf of the Publishers, by sending an email to info@fashionleapforclimate.com
1. Who are the data controllers of your personal data?
- As co-publishers of the Platform, the Publishers are independent data controllers regarding the personal data collected for the administrative, operational and commercial management of the Platform and its services.
- Quantis is data processor, acting on behalf of the Publishers, regarding the personal data collected for the administrative, operational and commercial management of the Website and its services.
2. What kind of personal data is processed?
Quantis, acting on behalf of the Publishers, processes the personal data provided by you via the Website, namely:
| Type of data | Examples of data |
|---|---|
| Identification data | Your first name, last name, Fashion LEAP for Climate platform login |
| Contact details | Your email address |
| Data related to your exchanges with the Publishers | Date and subject of your contact request, information communicated in your contact request, exchanges with Quantis, acting on behalf of the Publishers, related to your contact request |
The provision of certain types of personal data may be necessary or optional, depending on the services you request. Mandatory data will be marked as such at the moment of collection of your personal data. If you refuse to provide mandatory data, Quantis, acting on behalf of the Publishers, may not be able to process your request.
3. For what purposes do the publishers use your personal data?
As data processor acting on behalf of the Publishers, Quantis processes your personal data for the following purposes:
| Purposes | Examples of use of your personal data | Legal bases |
|---|---|---|
| Managing your contact requests | • to complete your request • to recontact you if needed | Legitimate interest of the Publishers to manage the contact requests |
| Logging on the Fashion LEAP for Climate platform | • to let you access the Fashion LEAP for Climate platform | Performance of the Terms of Use of the Platform |
| Customizing your user experience | • to customize the Website contents and your navigation | Your consent |
| Improving the Website, its services, and your user experience | • to evaluate and improve the Website and its services • to facilitate your navigation on the Website • to take steps designed to protect the security of the Website | Legitimate interest of the Publishers to improve the Website, its services, and your user experience |
| Pre-litigation or litigation management | • to take action against any identified breach • to manage any dispute or litigation | Legitimate interest of the Publishers in defending their rights and interests |
| Compliance with legal and regulatory obligations | • to comply with legal and regulatory obligations • to process your requests to exercise your rights | Legal and regulatory obligations to which the Publishers are subject |
4. Who can access your personal data?
Your personal data may be transmitted by Quantis, acting on behalf of the Publishers, to the following recipients when you access, browse and use the Website and its services:
| Recipients | Purposes |
|---|---|
| Quantis and its authorized employees | For operating the Website and its services on behalf of the Publishers |
| The Publishers and their respective authorized employees | In aggregated form only, for the managing the Website and its services and for statistical purposes |
| Service providers (hosting provider, IT service providers, backup provider, etc.) | For administrative, operational, technical and/or marketing purposes related to the Website and its services |
| Administrative or judiciary authorities | Exclusively to comply with legal and/or regulatory obligations or in the cases of an express and justified request or in case of an alleged violation of legal or regulatory provisions |
| Lawyers and all interested parties | Exclusively in the case of the management of possible disputes and other legal matters where appropriate |
| Other third parties | Following or during a restructuring, reconstitution, acquisition, debt financing, merger, sale of assets of the Publishers or a similar transaction, as well as in case of insolvency, bankruptcy or receivership where personal data are transferred to one or more third parties as assets of the Publishers |
5. Will your personal data be transferred outside of the EUROPEAN UNION/EUROPEAN ECONOMIC AREA?
As far as possible, your personal data are processed within the European Union (EU)/European Economic Area (EEA). However, with some of the service providers being located outside of the EU/EEA, your personal data may therefore be processed in third countries.
When your personal data are transferred outside the EU/EEA or a third country without an adequacy decision, Quantis, acting on behalf of the Publishers, implements appropriate measures in accordance with adequate instruments such as european standard contractual clauses. A copy of such safeguards can be obtained by sending an email directly to Quantis, acting on behalf of the Publishers, at info@fashionleapforclimate.com.
| Name of the recipient | Third country | Adopted safeguards |
|---|---|---|
| Zendesk | USA | European standard contractual clauses for the transfer of personal data |
| Amplitude | USA | European standard contractual clauses for the transfer of personal data |
| Zoom Video Communications, Inc. | USA | European standard contractual clauses for the transfer of personal data |
6. How do the publishers protect your personal data?
Quantis, acting on behalf of the Publishers, has implemented technical and organizational measures in order to protect your personal data, in particular against potential personal data breaches likely to cause, either by accident or unlawfully, the destruction, loss, modification, unauthorized access or divulgation of your personal data. These measures will guarantee a level of security adapted to the data and will take into account the state of the art and the cost of implementation in relation to the risks and nature of the data to be protected.
Quantis, acting on behalf of the Publishers, ensures that all members of its personnel and any other person processing your personal data will respect the internal policies related to the processing, including the technical and organizational security measures put in place to protect your personal data. In this context, Quantis, acting on behalf of the Publisher, reviews and updates its practices regularly to enhance your privacy and ensure that its internal policies are followed.
If you have found a vulnerability or would like to report a security incident, you may directly contact Quantis, acting on behalf of the Publishers, by sending an email to info@fashionleapforclimate.com.
7. For how long are your personal data stored?
As a general rule, your personal data will only be retained for the period necessary for the accomplishment of the purposes for which said data was collected, or as necessary to fulfill legal or regulatory obligations.
In the absence of applicable exceptions:
- the data collected via your contact request will be kept until the complete processing of your request;
- your traffic data will be kept for a period of thirteen (13) months from the collection date.
In addition to this, your personal data will be kept for:
- three (3) years for the data retained for follow-up purposes;
- five (5) years for the data retained for evidence purposes.
8. What are your rights regarding your personal data?
If you are based in the EU/EEA/UK, you have the following rights over your personal data:
| Your rights | Scope of you rights |
|---|---|
| Right to access | You have the right to request: • the confirmation on whether the Publishers process your personal data or not; • a copy of such personal data; and • information on the use of your personal data in a clear, transparent and understandable way (as provided in this Privacy Notice). |
| Right to rectification | You have the right to request the rectification of your personal data, in order to obtain the modification of your personal data if they are obsolete, inaccurate or incomplete. |
| Right to delete | You have the right to request the deletion of your personal data (or right to be forgotten), when one of the following conditions applies: • you object to the processing of your personal data and there are no overriding legitimate reasons justifying to maintain the processing of your personal data (e.g. legal obligation involving the retention of documents); • you object to marketing activities; • you decide to withdraw your consent on which the processing is based; • your personal data are no longer useful for the original purposes for which they were collected or for any other type of processing; • the use that is made of your data does not comply with the applicable legal or regulatory provisions. |
| Right to restriction of processing | You have the right to request the restriction of the processing during a limited period of time, in particular in order to carry out some verifications, where one of the following applies: • you contest the accuracy of your personal data, the processing of which is thus restricted for the period necessary for the Publishers to verify the accuracy of such personal data; • the processing is unlawful and, rather than requesting their deletion, you prefer to restrict their use; • the Publishers no longer need your personal data for the purposes of the processing, but you need them for the establishment, exercise or defense of legal claims; • you have objected to the processing, which is thus restricted pending the verification of whether the compelling legitimate grounds of the Publishers may override your interests, rights and freedoms. |
| Right to data portability | You have the right to request a copy of your personal data in a structured, commonly used and machine-readable format and also can request their transmission to another data controller where technically feasible. This right is not exercised in all circumstances, it applies only if it fulfils all the following conditions: • your request is only related to your personal data (excluding anonymous or third party data); • your request does not adversely affect the rights or freedoms of others, in particular those of the Publishers (including trade secrets or intellectual property); • the processing is carried out by automated means (paper files are therefore not included); • the processing is based on consent or the performance of a contract (to check if it is the case, you can see the Section 3 of this notice). |
| Right to object | You have the right to object to our processing of your personal data at any time if: • the processing is based on our legitimate interest; or • your personal data are processed for direct marketing purposes. The Publishers will no longer process your personal data, unless they demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, such as the respect of a legal obligation (e.g. legal obligation involving the retention of personal data), or for the establishment, exercise or defense of legal claims. |
| Right to withdraw your consent | You have the right to withdraw your consent when it has been obtained, without this withdrawal affecting the lawfulness of the personal data processing operations previously carried out. |
It is specified that the exercise of these rights is based on the legal basis of the processing as indicated in Section 3 of this policy, as follows:
| Access | Rectification | Erasure | Restriction | Data portability | Objection | |
|---|---|---|---|---|---|---|
| Consent | Yes | Yes | Yes | Yes | Yes | Withdrawal of consent |
| Steps prior to entering into a contract | Yes | Yes | Yes | Yes | Yes | No |
| Contract | Yes | Yes | Yes | Yes | Yes | No |
| Legitimate interest | Yes | Yes | Yes | Yes | No | Yes |
| Legal obligation | Yes | Yes | No | Yes | No | No |
Depending on your country of residence, you may have additional local rights with respect to our processing of your personal data.
Under certain circumstances, Quantis, acting on behalf of the Publishers, may ask you for specific information in order to confirm your identity and ensure the exercise of your rights. This is another appropriate security measure to ensure that personal data is not disclosed to an individual who does not have the right to receive it.
If you have any question or wish to exercise your rights, you may directly contact Quantis, acting on behalf of the Publishers, by sending an email to info@fashionleapforclimate.com.
If needed, you may also lodge a complaint with your national data protection authority. This right may be exercised at any time and free of charge, at the exclusion of potential postal fees or expenses related to legal representation or assistance should you choose to engage third party assistance for the procedure.
9. Changes to this notice
This privacy notice may be amended from time to time, in particular to reflect the changes in the services provided by the Website or the applicable regulations. We will notify you about any update by using the most appropriate way.