The present privacy policy (“Privacy Policy”) represents the principles and procedures of the use, collection and storage of the information, which we, “PRIVATO-CB” SRL (“Privato Dress ” “we”, “our” or “us”), receive from you (“User”, “Customer”, “you”) during the following actions from your and our part:

1. Browsing or visiting the website www.privatodress.com (“Website”, “Site”).
2. Using or interacting with the website www.privatodress.com, namely:
   • Purchasing a product (including customized dresses and accessories)
   • Contacting the Website Customer Support
   • Signing up for the newsletters
   • Providing personal data to us for any other purpose
3. Collection, processing and use of the Personal Data by our service providers and suppliers.

Privato Dress team highly appreciates your trust and respects your privacy. This is why we made sure to create our Website in compliance with the best practices in user privacy standards. Make sure to familiarize yourself with the present Privacy Policy. This will help you get the idea of the practices we have implemented into the entire process of Personal Data use.

First off, the notion of Personal Data covers any type of information, which we can use, separately or in conjunction with any other information, in order to identify any person, who has provided such information to us.

Contents of this Privacy Policy:

1. Information that we collect, reasons for its collection and the purposes of its use;
2. Protection and storage of your personal information;
3. Sharing of your personal information;
4. Other information about access to your personal information;
5. Your rights regarding personal information;
6. Use of the Website by children;
7. Ways to contact Privato Dress team.

We can change the present Privacy Policy from time to time without previous notice to the site users. It is your responsibility to check the Privacy Policy back periodically for the latest version of the, as indicated below. If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. What information we collect, why we collect it, and how it is used

Data we collect

Information You Give Us: Privato Dress collects information that you provide to us online, through completion of registration and other forms in our retail stores, or through other means.

For example:

• If you join our registry or request an appointment through the Service, we will collect your first and last name, postal address, e-mail address and telephone number, specific bridal party and wedding information, and other preferences and demographic information you provide.
• If you make a purchase through the Service, we will ask you to register with us, and we will also ask you for your credit card number, a shipping address and a telephone number for that shipping address, and for any additional information that may be required to personalize the product you purchase.
• If you contact our customer service, we will ask you for your name, postal address, e-mail address, telephone number, order number and such other information as you wish to submit to us to allow us to assist you.
• If you submit a wedding, prom or special occasion story through the Service, we will ask you for your e-mail address, the names of the bride and groom or the subject of the story, the date and location of the wedding, prom or celebration of the special occasion, and such other information as you may include in the story and photos that you submit to us.
• If you send us a text message, we will collect the mobile phone number you use to send us a text message, the content of the message, and we will log the wireless telecommunications service provider associated with the number and the date and time of the message.
• Please note that registration is required to use certain features of the Service.

Social Networks:

If you are a member of Facebook or another social network or service, and you use functionality available through the Service or otherwise authorize us to associate your Service account with that social network or service, both we and the social network or service will gather information about your behavior on the Service, and may associate that information with personal information we and the social network or service already have about you.

Public Conduct:

If you engage in behavior at or through the Service that is intended to be viewed by other users (collectively, “Public Conduct”), such as participating in forums, message boards and chat rooms; using your Facebook page, Twitter® account or other functionality available through the Service to share product preferences, comment on products and other content; creating an event page, or posting stories about your wedding, prom or other special occasion to the Service, we and others may collect information about you as a result of your Public Conduct, and all such information will be publicly available to anyone visiting or using the Service.

Automatic Gathering of Information:

We and other companies and individuals we select to provide us with goods and services (each, for the purposes of this Privacy Policy, a “Website Analytic Service Provider”) collect non-identifying information about your visit to or use of the Service, your Web browsing movements across the Internet (not just on the Service), and your interaction with our advertisements at the Service and elsewhere. For example, we may keep track of how many of our advertisements you saw before visiting the Service, how you were directed to the Service, how you navigate around the Service, which products you browse, as well as your purchasing activities through the Service.

To do this, we and our Website Analytic Service Providers use technology (e.g., cookies, action tags, Web beacons, and GIF tags), placed at various sections within the Service and in our advertisements delivered by e-mail or served during your Web browsing session. Some of this technology may be disabled by changing your Web browser settings. Please consult the documentation for your Web browser on how to manage the information gathering and storage aspects of this technology on your computer.

We and our Website Analytic Service Providers do not collect any personal information through the use of this technology.

If you use the mobile application portion of the Service, we and our Website Analytic Service Providers may also use various technology (e.g., anonymous identifiers, flash cookies, HTML5 software, local storage, and mini-databases) to track your Web browsing movements at the Service and across the Internet, and may store such information on your mobile device. Many mobile devices have this technology pre-loaded or incorporated in the Web browser, or the technology may be included in the mobile application you download and use on your device. Please consult your device documentation on how to manage the information gathering and storage aspects of this technology.

We and our Website Analytic Service Providers do not collect any personal information through the use of this technology.

If you choose to reject all cookies, anonymous identifiers or similar technology, you may be unable to use some of the functionality of the Service.

Unless we associate non-identifying information that we gather through use of technology with your personal information, we will NOT treat such information as personal information.

Text/SMS message consent:

If you choose, you can provide your mobile phone number to receive text message alerts containing product and/or event information, products tips or promotions that may be sent using automated dialing systems (“Text Messages”). You agree that by providing your mobile phone number you expressly consent to receive automated marketing text messages from us to the mobile phone number provided. Consent is not required to purchase goods or services. Message and data rates will apply and you should check the rates of your mobile carrier.

We may share your mobile phone number with service providers with whom we contract to assist us with the above activities, but we will not share your mobile phone number with third parties for their own purposes without your consent. You acknowledge that Text Messages are distributed via third party mobile network providers and, therefore, we cannot control certain factors relating to message delivery. You acknowledge that, depending on the recipient’s mobile carrier, it may not be possible to transmit the Text Message to the recipient successfully; nor is content available on all carriers. We do not claim or guarantee availability or performance of this service, including liability for transmission delays or message failures.

Information from Other Sources:

We may also collect information (including personal information) about you from our Service Providers and other third parties and add it to the personal information we maintain.

How does Privato Dress use the information it collects?

Request Fulfillment:

We use your personal information to confirm, fulfill and ship your orders, to set up appointments that you request, and to otherwise respond to your requests. We may also use your personal information to contact you if we want to communicate with you about your order, appointment or other request.

We may match personal information we have collected from your prior on-line or in-store interactions with us (i.e., completion of a survey or sweepstakes entry) with the personal information you enter when you complete our in-store electronic registration form to speed up the registration process and improve your in-store and on-line experience with us.

Promotional Messages:

We may also use your personal information to send you newsletters, information about special events, e-mail offers, text message offers, and other savings opportunities; to notify you of changes to the Service; to provide you with up-to-date information on the newest Privato Dress products and services that may be of interest to you; to handle billing disputes with you; and to tailor our online offerings and advertisements to your preferences.

We may also use non-identifying information about your visits to the Service and other Web sites in order to provide you with special offers about goods and services of interest to you, make sure you are not shown the same content repeatedly on the Service, deliver information that is specific to your interests, and to save your password so you don’t have to re-enter it each time you visit the Service.

Rewards Programs and Advertisements:

We may also participate in rewards programs with other business organizations where our customers who are also members of these programs receive a reward from the other businesses for their purchases from Privato Dress. We also place advertisements for our products on other Web sites that include a link enabling visitors to click on the link to be taken to the Service and purchase the products featured in the advertisement. In these situations, we share your personal information about your purchases with the other member organizations or Web sites under the contracts these entities have with us.

Optional Features:

If you choose to participate in certain other features or functions available through the Service, such as customer service, product reviews, wish-lists, and special occasion stories or other Public Conduct, we will use your personal information to administer and operate those features and functions. We may also aggregate information we gather from your Public Conduct with other information we collect from your use of the Service.

Other Business Purposes:

We may also use personal information, on-identifying information, and aggregated information about our customers ‘access and navigation of the Service and their browsing and purchasing activities that we and our Website Analytic Service Providers obtain from our use of technology, to improve the Service, and for other business purposes, such as marketing, advertising and research.

What is the legal bases of our collection and processing?

We only collect or process your data based on the following legal bases:

• Where the processing of your Personal Information is in our legitimate interests (such as to improve our products and services and the content of our websites, prevent fraud, and for administrative purposes as described in this Privacy Policy);
• When we perform our obligations under a contract with you (for example, if you are a consumer we will use your Personal Information to carry out our obligations under the contract that we have with you);
• When we have a legal obligation to do so (for example, to comply with the law or respond to legal process or lawful requests, including from law enforcement and government agencies); or
• When we have your consent to use your Personal Information.

Will Privato Dress disclose my personal information?

Retail Stores:

Our retail stores share with us the personal information they collect from your completion of a registration or other form, and we combine it with the information we collect from you through the Service, so that the Service will be able to provide you with relevant information regarding special events and offers. We share the personal information we collect from you through your use of the Service with our retail stores so that they can provide you with relevant information regarding special events and offers.

Service Providers:

We engage Service Providers from time to time to perform business functions on our behalf, such as fulfilling orders, delivering packages, sending postal mail and e-mail, maintaining customer lists, analyzing data, providing marketing assistance including brand and product promotions, processing debit and credit card payments, providing customer service, as well as administering certain services and features. We furnish personal information to our Service Providers as required to perform these business functions on our behalf.

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

We also engage advertising agencies and other Service Providers and share non-identifying information and aggregated information with them for purposes of analysis and improvement of the Service. In addition, we have carefully selected certain Service Providers to provide us with digital analytics and marketing optimization services. These Service Providers use technology, such as cookies and anonymous identifiers, to collect information on our behalf that will educate us on such things as search engine referral, how you navigate around the Service, unique visitor identification, and product browsing and purchasing information. These Service Providers are not permitted to collect credit card, username or password information.

These Service Providers analyze the information collected on our behalf and return it to us through a secure web connection for our use in understanding your use of the Service and how to better serve you. These Service Providers are contractually prohibited from using our information for any other purpose and are required to maintain all information collected and their analyses in strictest confidence. You may choose to continue to benefit from the improved experience with the Service that such analyses provide to you, but maintain your anonymity. You may also choose to deactivate the ability of these Service Providers to analyze your browsing and purchasing behavior at the Service by setting your Web browser to reject cookies and other technology.

Third Parties:

Unless you elect or instruct us otherwise, Privato Dress may share your personal information with our information partner, for direct marketing purposes. Privato Dress may also choose to share, sell, trade, or rent your personal information to other third parties for direct marketing purposes (i.e., offering goods and services that we believe would be attractive to our customers). We require all third parties with whom we share information (including personal information) that we collect to handle that information in accordance with this privacy policy and all applicable laws.

However, these third parties may also have additional or different privacy practices that you may find on their respective Web sites. You may also go to their Web sites to find out more about technology they use to collect information while providing us with services.

We also may share non-identifying and aggregate information with third parties that advertise at or through the Service. For example, we may tell an advertiser that X-number of individuals visited a certain area of the Service, or that Y-number of women who filled out our registration form are from the USA, but we will not disclose anything that could be used to identify those individuals.

Optional Features:

If you use optional features or functions available through the Service to engage in Public Conduct, any personal information that you post or submit may also be collected and used by other users of these features to send you marketing messages and for other purposes.

In addition, we may forward the information you provide as a part of Public Conduct to other Web sites as a part of an RSS feed, API, or other format. We are not responsible for editing or removing any personal information that you post or submit as a result of your Public Conduct.

Additionally, we share personal information about you when you voluntarily use certain optional features of the Service. For example, if you include personal information in a product review that you submit, the content of that review will be posted on the Service and may be distributed and posted to other Websites

Law Enforcement:

From time to time, we may be required to disclose your personal information in response to a court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to share information i) with law enforcement agencies concerning any activities that we, in good faith, believe to be unlawful. (ii) to prevent illegal uses of our websites and applications or violations of our Terms of Use and our policies; (iii) to defend ourselves against third party claims; and (iv) to assist in fraud prevention or investigation (e.g., counterfeiting).

Business Transfers:

We may also share personal information with third parties in relation to planned or potential corporate sales, mergers, reorganizations, consolidations, dissolutions, bankruptcies or similar events. As a part of any such transaction, we will treat your personal information as an asset and transfer it to the purchaser.

How long does PRIVATO DRESS keep my personal data?

We retain your personal data for as long as necessary to fulfill the purposes described in this policy, unless otherwise required by law. For example, we keep your account profile information for as long as you keep your Privato Dress account, but, we may keep your order history longer to comply with legal obligations.

How we protect and store your information

Security.

We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

Retention of your Personal Data.

In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

How we share your personal information

In addition to the recipients described in Section ‘Will Privato Dress disclose my personal information?’, we may share your information as follows:

To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order.

If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.

Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

Additional information regarding transfers of personal information

Access to the Personal Data is allowed under the Commission Decision of 31 January 2011 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequate protection of personal data by the State of Israel with regard to automated processing of personal data.

Where we transfer your Personal Data outside of the EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States.

Your rights

The following rights (which may be subject to certain exemptions or derogations), shall apply to certain individuals (some of which only apply to individuals who are protected by the GDPR):

• You have a right to access information held about you. Your right of access is normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
• You have the right to request that we amend any Personal Data we hold that it is inaccurate or misleading;
• You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
• The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
• The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
• You have the right to object to profiling;

You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority/

The right to withdraw your consent.

Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.

You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.

You can exercise your rights by contacting us at privatodress@gmail.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

Use by children

We do not offer our products or services for use by children. If you are under 18, you may not use the Website. We do not knowingly collect information from, and/or about children.

Links to and interaction with third party products

The Site may enable you to interact with or contain links to your Third Party Account and other third party websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the Terms and Conditions and Privacy Policy of each Third Party Service that you choose to use or interact with.

Log files

We may make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic information.

Cookies and other tracking technologies

Our Site may utilize “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Site and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Site. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. You can read more in our Cookies Policy.

Google analytics

The Site may use a tool called “Google Analytics” to collect information about use of the Site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. We use the information we get from Google Analytics to maintain and improve the Site and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service, available at https://www.google.com/analytics/terms/us.html, and the Google Privacy Policy, available at https://www.google.com/policies/privacy/.

You may learn more about how Google collects and processes data specifically in connection with Google Analytics at https://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

Contact us

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privatodress@gmail.com.