Privacy policy
MinElèn Privacy Policy
In compliance with the provisions of regulation (EU) 2016/679
Most recent update: 02/29/2024
We have the pleasure and duty to provide the following information about the processing of personal data, in accordance with the Privacy Code and Regulation (EU) 2016/679.
1. Type of Personal Data Collected
The following personal data is collected and processed by MinElèn for the purposes outlined below:
a) Personal and identifying data such as your name, surname, date of birth, proof of identity, images recorded during store visits (where CCTV is in place), voice recorded during calls to a MinElèn sales service, payment information in the event of purchases made online or in stores.
b) Data from interactions including information collected during store visits, such as the use of the Wi-Fi system, participation in events, online purchases, sign-ups to loyalty programs (e.g., birthday, age group, dates of family events, profession, hobbies, purchases, use of particular social media or social media ID, phone number, email address, photograph, nationality, gender, language, favorite product categories, details of products purchased, sizes, prices, discounts, statistical spending levels, abandoned shopping carts, ways in which services are used), preferences and interests disclosed by the user during interactions with advisors in-store (including preferences about our collections or other brands, sizes, lifestyle, or basic information about your family), responses to contact activities, and health-related information regarding potential side effects of our products.
c) Data collected when browsing or using media applications, including information about the user's behavior recorded with cookies or similar technology, as described in more detail in the Cookie Policy available online at: [MinElèn Cookie Policy URL], or data contained in your "Wish List".
d) Personal data provided by you to report illegal conduct or violations of the Organization and Control Model pursuant to the applicable legislative decree and/or the Code of Conduct ("whistleblowing"). The lawful basis for such processing includes the Controller's legitimate interest, the need to adhere to legal requirements, and the need to ascertain, exercise, or defend a right in court.
Personal data is collected directly from the user (e.g., when creating an account on our websites/apps, making a purchase, or interacting with our in-store advisors or Client Services), collected passively (e.g., using tracking tools like browser cookies), or collected via third parties (e.g., social media platforms).
2. Processing Purpose
MinElèn processes the data provided by you for the following purposes:
Contractual Purposes, such as managing the sale of its products and providing sale and after-sale services (including fraud prevention, returns, product warranties, and customer support); creating and maintaining your customer account and providing the services offered via its website, including clienteling services and newsletters if subscribed; consulting the production chain of certain items purchased by you, registering or transferring ownership, as well as downloading—and later giving to third parties—possible NFTs associated with said product; and checking your information requests.
Fulfillment of Legal Obligations, including the requirements outlined by "Know Your Customer".
Marketing and Profiling Purposes, i.e., sending you—with your prior consent—marketing communications regarding MinElèn products, services, and exclusive activities via electronic means (such as email, SMS, MMS, mobile, social media, and chats) or in paper format (e.g., traditional post); offers for personalized sales services; satisfaction questionnaires for products and/or services offered; preferences and shopping habits at MinElèn and/or other brands in order to improve the service offered, use of virtual try-on features.
Pursuit of Legitimate Interest, i.e., using data regarding amounts spent, product categories, store where the purchase was made, date of birth, status, and number of family members to provide a service that is more in line with your requirements and send you marketing communications that are of most interest to you.
3. Provision of Data
The provision of personal data for the purposes outlined above is obligatory for contractual services. For marketing and profiling purposes, provision of data is free and optional, subject to the consent of the interested party. Denial thereof would not allow MinElèn to achieve the indicated purposes.
4. Conditions Applicable to the Consent of Minors
Processing the personal data of minors is lawful provided they are at least 16 years of age. If a minor is younger than 16 years of age, processing this data is only lawful if, and where, consent is provided or authorized by the holder of parental responsibility. We do not knowingly collect personally identifiable information from minors without permission from a parent or guardian, unless permitted by law.
5. Processing Methods
Personal data will be processed using IT-based tools and/or manually for the length of time needed to achieve the purpose for which it was collected.
6. Entering Data in the CRM System
The entering of personal data in the CRM system is optional and occurs only if consent is given for marketing and profiling purposes. Once in the CRM system, MinElèn employees across the world, tasked with data processing, will automatically be able to view, change, and revise the information.
7. Scope of Communication, Transfers Abroad, and Data Publication
Personal data may be communicated to subsidiaries, associate companies, companies under the same control, or companies that are part of the same group that MinElèn belongs to, to offer users the same level of services worldwide. We ensure that the Standard Contractual Clauses for data transfers between EU and non-EU countries outlined by the European Commission are applied. Personal data is processed only by authorized personnel.
The user's personal data may also be processed by companies performing services on our behalf, including shipping/delivery services, customer care services, IT system maintenance, and virtual try-on experience management.
Data collected may also be processed by third parties acting as independent data controllers, including banks, payment management companies, legal or professional advisors, and when required to comply with applicable law.
8. Data Retention Period
Personal data will be stored for no longer than is reasonably necessary for achieving the purposes for which it was collected or processed, or as established by current legislation on data retention. Data collected for contractual purposes will be stored for the time period necessary for the performance of a contract. Data collected for marketing and profiling purposes will be stored until the client withdraws their consent, and for no more than ten years.
9. Rights of Data Subjects
Information may be requested at any time regarding the processing of your personal data. It is possible to correct or delete data, limit its processing, object to its processing, and request that the data be sent to another controller. To exercise these rights or request further information, the data subject may send an email to [elitesupport@minelen.com] or send a written request to the Data Protection Officer (DPO) at MinElèn.
10. Personal Data Protection
MinElèn is committed to protecting personal data and complies with current data protection legislation. However, since the internet is not a completely secure environment, we encourage you to be cautious when using the internet to access our websites, apps, or social media.
11. Data Controllers and Processors
The website [www.minelen.com] is managed by MinElèn, acting as the Data Controller for personal data in accordance with Regulation (EU) 2016/679 (GDPR). For processing personal data related to whistleblowing reports, MinElèn and its subsidiaries act as joint controllers.
A complete list of data processors designated by controllers may be requested by sending an email to [elitesupport@minelen.com].