With reference to the personal data collected for the use of the services available on the Website, and in stores, the Data Controller is OVS S.p.A. with registered offices at Via Terraglio, 17 - 30174 Venezia Mestre, Tax ID Code and VAT No. 04240010274 (hereinafter "OVS"). 

Below you will find a complete list of all the purposes for which we collect your personal data: you can click on each section for more information.

WEBSITE NAVIGATION

Purposes of processing: to enable Website navigation; to carry out aggregate statistical analyses aimed at measuring the correct operation of this Website.

The data could be used to verify responsibility in the case of alleged IT crimes to the detriment of the Website and of the users of same:

Data processed: data relative to the user’s connection to and browsing on the Website (such as the URI-Uniform Resource Identifier addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relative to the user’s operating system and IT environment) are only collected for the purpose of gathering anonymous statistical information about the use of the Website and to check that it works correctly, and these are erased immediately after processing. 

Legal basis of processing:

▪ provision of services to enable users to navigate the Website (Art. 6, 1, b of the Regulation);

▪ legitimate interest of OVS to ensure the proper functioning of its IT systems;

▪ legitimate interest in investigating possible offences (also on the basis of the existence of a possible legal obligation).

Retention period: 

With the exclusion of the case in which data are used to ascertain responsibility in cases of potential cyber crimes against the Website or its users, these data will be deleted after the useful time for the provision of the services specified on the Website.

30 (thirty) days after the date of collection, unless a different retention period is required by law or by public authorities in connection with investigations related to possible cybercrime.

CUSTOMER CARE

Purpose of processing: the data you provide us with (by telephone, e-mail, online form, etc.) will be used for the purpose of responding to your report, your request for information, complaints, product warranty issues, and the use of our services.

Personal data processed: data needed to respond to requests you make to our Customer Care (e.g. for online form assistance, we will ask you to provide your name and e-mail address). You are free to choose whether or not to provide us with your personal data but if you choose to provide us with these data, please complete the form with all the data requested. since they are needed to reply to your message or request for information. If your data is missing or your form incomplete, we will not be able to reply to your message or provide the information you requested.

Legal basis of processing:

▪ performance of the contract of sale of products or pre-contractual measures taken following your request (Art. 6, 1, b of the Regulation);

▪ for the chat support service, execution of the requested service (Art. 6, 1, b of the Regulation)

Retention period: the data communicated to us will be kept for the period necessary to reply to you or provide you with the information requested. This is without prejudice to the different retention period necessary for judicial protection.

PURCHASING PRODUCT ONLINE (E-COMMERCE)

Purpose of processing

▪ to enable you to proceed with the purchase of the products, fulfil your obligations and exercise your rights arising from the concluded contract (dispatch of goods, invoicing of said goods and management of payments, tracking the shipment, delivery of the goods, possible returns and refunds, etc.); 

▪ to comply with legal, regulatory, EU, tax or accounting obligations (invoicing, record keeping and accounting entries).

Personal data processed: contact data (e.g. name, surname, e-mail address, telephone number) and shipping address of the goods. Data relating to the means of payment indicated by the customer (e.g. credit card number, credit card security CVV code, etc.) are not processed by OVS. These data are collected by the operator of the chosen payment service.

You are free to choose whether or not to provide us with your personal data but if you choose to do so, please complete all the “mandatory” fields (*) because they are needed for purchasing products. If your data are missing or your form is incomplete, we will not be able to process your purchase. Failure to provide the data indicated as 'optional' will have no effect on your purchase.

Legal basis of processing

▪ performance of the purchase contract (Art. 6, 1, b of the Regulation).

▪ legal obligation (Art. 6, 1, c of the Regulation => we are obliged process the data needed for the purpose of fulfilling the legal obligations, regulations, and EU rules concerning taxation and accounting (invoicing, written undertakings and accounting entries).

Retention period: 

▪ time needed to fulfil contractual obligations;

▪ to comply with the legal obligations regulations, and EU rules concerning taxation and accounting, (invoicing, written undertakings and accounting entries), the data will be retained for the period required by law.

GAP ADVANTAGES SCHEME

Purpose of processing: management of participation in the GAP Advantages Scheme The Data will be used to issue the loyalty card and thus enable you to access the benefits reserved for cardholders and described in the rules and information material (e.g. discounts, promotions, etc.). 

Personal data processed: personal and contact data (first name, last name, postal address, e-mail address, telephone number), indicated in the online registration form, or, in the case of registration at "GAP" shops, requested by our sales assistants; data relating to points and discounts awarded.

You are absolutely free to choose whether or not to provide us with your personal data, but if you do, please complete this form by filling out us all the “mandatory” fields (*) needed for the operation of the card. If your data is missing or your form incomplete, we will not be able to issue you a card. Failure to provide the data indicated as 'optional' will have no effect on your purchase.

Legal basis for processing: execution of the contract for enrolment in the GAP Advantages Programme (art. 6, 1, b of the GDPR) GAP Advantages Scheme Regulations).

Retention period: 

▪ time needed to manage your participation in the loyalty programme. 

▪ the data relating to purchases will in any case be retained for a maximum period of 24 (twenty-four) months from registration (or for any different period provided for by current legislation or provisions by the protection authority) for the purposes of direct marketing and profiling (only in the event you have given consent to these processing purposes), after which they will be destroyed or anonymised.

▪ for accounting purposes, personal data will be kept for the period required by law.

SENDING OF COMMERCIAL COMMUNICATIONS (so-called direct Marketing)

Purpose of the processing: to contact you - via telephone, mail, e-mail, sms, push notifications, social networks and other digital channels - for advertising or commercial communications, as well as carrying out market research to find out your degree of satisfaction with our services. The sending of advertising or commercial communications may also concern the various brands owned by OVS and which can be consulted on the website, in updated list form, at www.ovscorporate.it.

Personal data processed: contact data (e.g. name, surname, e-mail address, telephone number).

Legal basis for processing: for direct marketing purposes we will only process your data with your consent. You may revoke your consent at any time by writing to customercare@gap-italia.it or by accessing your private area.

Retention period: until your consent is revoked.

PROFILING

Purposes of processing: we will use your personal data for analysis and, therefore, for profiling purposes, in order to improve our commercial offers thanks to better knowledge of our customers at our stores and on our Website, and your consumer habits. 

Personal data processed: data relating to your purchases, personal data such as your country of origin, gender and age, your interaction with OVS through our Site and through our social media channels. We may examine data relating to your (possible) participation in the GAP Advantages Scheme. 

Legal basis for processing: for direct marketing purposes we will only process your data with your consent. You may revoke your consent at any time by writing to customercare@gap-italia.it, accessing your reserved area or using the contact form available on the website.

Retention period: data relating to your interactions with OVS will be kept for a maximum period of12 (twelve) months from the date of collection; data relating to purchases will in any case be kept for a maximum period of 24 (twenty-four) months from registration (or for any different period provided for by current legislation or provisions of the Data Protection Authority).

ANTIFRAUD

Purpose of processing: to verify the correspondence between the person purchasing products from the Website and the holder of the selected payment method.

Personal data processed first name, last name, e-commerce order details and information on the type of payment method used to make the purchase.

Legal basis of the processing OVS's legitimate interest in preventing and combating fraud.

Retention period: 5 (five) years following the collection of the data, without prejudice to the different retention period for the protection of OVS's rights in court.

REGISTRATION FOR THE RESERVED AREA

Purposes of processing: (i) to allow you to register on the Website by creating a reserved area ("account"); (ii) to allow you to proceed with the purchase of products, fulfil obligations and exercise rights arising from the contract concluded, to save certain content (e.g. the "wishlist" for the list of your favourite products, purchase history, etc.); (iii) to comply with legal obligations, regulations, EU legislation, tax or accounting matters (invoicing, bookkeeping and accounting entries).

Personal data processed: personal and contact data indicated in the online form relating to registration for the reserved area. You are absolutely free to choose whether or not to provide us with your data, but if you do so, we ask you to complete this form, providing all the data requested as "mandatory" (*) as it is necessary for registration; if you do not fill in the form, or if it is incomplete, you will not be able to proceed with registration. Failure to provide the data indicated as 'optional' will have no effect on your purchase.

Legal basis of processing: 

▪ performance of the contract for registration on the Site (Art. 6, 1, b of the Regulation).

▪ legal obligation (Art. 6, 1, c of the Regulation => we are obliged process the data needed for the purpose of fulfilling the legal obligations, regulations, and EU rules concerning taxation and accounting (invoicing, written undertakings and accounting entries).

Retention period: 

▪ your account and related data will be deleted if you do not use your account for more than 5 (five) years.

▪ for accounting purposes, personal data will be kept for the period required by law.

SAVING ACCOUNT ACCESS CREDENTIALS (restricted area) after the end of the session ('Persistent login')

Purpose of processing: to make the user experience easier when using your account (reserved area) by allowing you to remain logged in to your account after the end of your browsing session (to be able to view any promotions active on your account, recommended products, access to the Wishlist, etc.).

Personal data processed: your access credentials for the reserved area.

Legal basis for processing: your consent which is expressed through the acceptance of a cookie (please also see our Cookie Policy).

Retention period: the cookie enabling you to save your login credentials will remain active for a period of 3 months.

You can deactivate cookies at any time by accessing the Cookie Settings section available in the Cookie Policy document.

Purpose of processing: to facilitate the user experience on the Website in using the section e-commerce of OVS allowing you to receive a reminder by e-mail.

PURCHASE OF PRODUCT AT THE POINT OF SALE WITH DELIVERY AT HOME OR IN STORE

Purpose of processing: if the product you want is not available, you can order it in our sales outlets and receive it at home or at your favourite 'GAP' store. Personal data will be collected for the purpose of processing your purchase order and carrying out related activities (e.g. dispatch, tracking of shipment, and delivery of products, payment management, any returns, etc.).

Personal data processed: personal and contact data (name, surname, shipping address, e-mail address, telephone number), information about the product purchased (e.g. size). 

You are free to choose whether or not to provide us with your personal data but if you choose to do so, please complete all the fields indicated as “mandatory” (*) because they are needed for providing you with the service you require. If your data are missing or your form is incomplete, we will not be able to provide you with the service you require.

Legal basis of processing

▪ performance of the purchase contract (Art. 6, 1, b of the Regulation).

▪ legal obligation (Art. 6, 1, c of the Regulation => we are obliged process the data needed for the purpose of fulfilling the legal obligations, regulations, and EU rules concerning taxation and accounting (invoicing, written undertakings and accounting entries).

Retention period: 

▪ time needed to fulfil contractual obligations;

▪ to comply with the legal obligations regulations, and EU rules concerning taxation and accounting, (invoicing, written undertakings and accounting entries), the data will be retained for the period required by law.

To enable us to achieve the purposes listed above, we may disclose your data:

 - to OVS personnel in the course of their work duties;

 - suppliers of OVS (e.g. (i) companies and consultants who carry out computer filing and processing services on our behalf, and other suppliers of IT services and platforms; (ii) companies in charge of mailing and/or sending or dispatching promotions and advertising or carrying out promotional activities (limited to name, surname and address for sending generic mail; e-mail address for sending electronic mailings; telephone/cell phone number for tele-marketing activities); (iii )companies in charge of managing warehouse logistics, shipping of purchased products; (iv ) our affiliated companies that manage points of sale in connection with loyalty programmes (e.g. "OVS Friends"); (v )any companies appointed to carry out customer care activities on behalf of OVS): these parties will act as external Data Processors pursuant to Art. 28 of the Regulation;

 - Credit institutions (for handling the payment of your purchases): these entities act as autonomous data controllers and their involvement is necessary for operations related to the use of our services (e.g. making payments).

OVS uses cookies in some areas of the Website. Cookies are usually strings of text that websites (so-called publishers or 'first parties') visited by the user or different websites or web servers (so-called 'third parties') place and store within a terminal device available to the user. Please read our Cookie Policy which should be consulted in conjunction with this policy.

You may also find icons from social media on the Website (e.g. Google, Facebook, Amazon, etc.) that allow the user browsing the Website to interact directly with social media by means of a click that will enable the latter to acquire data relating to the visit. In some areas of the Website there is also a so-called 'social login' (i.e. authentication via social media), which will allow you to access your reserved area via the account of the relevant social media channel. Please note that when you log in, you accept the terms and conditions of use and the privacy policy of the social media channel itself.

Personal data may be transferred outside the European Union. In this case, the transfer will take place in compliance with the provisions of the EU Regulation 2016/679 ("GDPR") (in particular, the data will only be transferred after signing the Standard Contractual Clauses approved by the EU Commission by Decision No. 2021/914/EU or to countries that can guarantee an adequate level of protection of personal data and therefore recipients of an Adequacy Decision adopted by the EU Commission).

Some personal data collected may be transferred abroad to locations outside the European Union. This transfer will in any case be carried out in compliance with the guarantees prescribed by the GDPR for this type of activity (Articles 45 to 49). These include: transfer to companies located in countries for which the existence of personal data protection guarantees comparable to those of the GDPR is recognised (White List countries); or to companies with which specific personal data protection contractual clauses approved by the Data Protection Authority or binding corporate rules approved by the Data Protection Authority have been signed, or the transfer takes place on the basis of specific exceptions. For more information, you can contact the Data Controller as indicated in the section below entitled 'Your rights, the possibility to lodge a complaint, and contact details'.

OVS S.p.A. has appointed a Data Protection Officer, also known by the acronym DPO (Data Protection Officer), who is in charge of supervising compliance with the regulations on the protection of personal data and who acts as a point of contact for requests from the data subjects,

If you would like to contact our Data Protection Officer, you can do so by sending an e-mail to responsabileprotezionedati@ovs.it, or by calling +39 041 239 7500.

In accordance with the provisions of current legislation (Articles 15 to 22 of the Regulation), you have the right to obtain access to your information (Art. 15), their rectification or integration (Art. 16), their erasure (the so-called right to be forgotten, Art. 17), restriction of processing (Art. 18) the right to the portability of your data (Art. 20), the right to object to the processing of your data on particular grounds (Art. 21) and that you are not subject to an automated decision-making process (art.22); we also remind you that you always have the right to lodge a complaint with the Data Protection Authority (www.garanteprivacy.it).



To exercise these rights, you may (i) write using the contact form available on the Website, (ii) send an e-mail to customercare@gap-italia.it, or (iii) write to OVS S.p.A., via Terraglio n.17, 30174, Mestre (VE), to the attention of the Data Protection Officer - DPO.



We remind you that you also have the right:

(i)               to revoke your consent to carrying out contact activities for advertising/promotional communications. In this case you will no longer be the recipient of any kind of electronic or hard copy communication. If you wish, you may revoke your consent limited to the receipt of communications by e-mail, sms, mms, etc., and continue to receive commercial communications only by mail or telephone contact with an operator, if any.

(ii)             to revoke your consent to carry out profiling activities.

We reserve the right to update the content of this page from time to time. Please consult this policy regularly so that you can stay up-to-date with any changes since your last consultation.



Last update 20 February 2024