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Privacy Policy 2002.5

PRIVACY POLICY

MDreams Global is aware of the importance of your personal data and, therefore, will provide you with full disclosure concerning its processing and requires your permission before any use thereof. 

1. Data Controller and Data Protection Officer 

The Data Controller is MDreams Global, with registered office at Unit 206A, 2/F, Block B, Sea View Estate, 2-8 Watson Road, Hong Kong, Hong Kong SAR.

MDreams Global has appointed a Data Protection Officer, who may be contacted at the following email address info@mdreamsglobal.com for any information regarding the processing of personal data and the exercise of the rights described below. 

2. Purposes and processing methods 

Your personal data (hereinafter also “Data”) shall be processed:

(i) for purposes strictly connected to the sales activities (payments, orders, deliveries), including pre and post sales services provided by MDreams Global (tailoring, shipments, repairs), even indirectly, and for any other legal purpose arising from the sales agreement (i.e. accounting, tax and legal obligations including statutory guarantees); and, after you provide your permission, 

(ii) for commercial and marketing purposes, such as to send promotional offers, marketing initiatives and advertising material for products and services offered by MDreams Global or by the companies of the same Group; through communications using automated methods (including SMS, instant messaging, e-mail, etc.) as well as traditional methods (including paper mail, phone calls); 

(iii) to study and analyse your habits, preferences and consumption choices, to propose products, services and events that respond more to the tastes and personal needs of customers as well as their necessities. The Data will be processed using mainly automated and traditional means; in fact, some processing may use hard copies. Specific security measures will be followed to prevent the loss of Data, illicit or incorrect use and unauthorised access. 

3. Study of customer habits and consumption choices 

As indicated in paragraph 2 (iii) above, with your express permission, MDreams Global may process your Data for the purposes of studying your habits and consumption choices, to make products and initiatives more responsive to your tastes and needs. 
With the help of automated tools, MDreams Global may process Data relating to the value and frequency of purchases (even if these were made during the sales period) as well as the type of products purchased over a fixed period of time. 

MDreams Global will also be able to acquire additional Data directly from you regarding your consumption preferences (brands and products), hobbies, habits, lifestyle and favourite sports. This information could also be acquired through some social platforms or from the use of cookies on the website. These Data will complete and enrich your profile and your customer information sheet allowing MDreams Global to know you better. In any event, this will only occur if you had previously accepted communicating some of your Data through the social platform when logging on to register and/or authorised the use of analytical and marketing cookies, through website procedures. This study has the sole objective of offering customers products, services and initiatives in line with their tastes and needs and will be carried out using non-invasive methods. 

Furthermore, at any time, you may request to analyse your profile and update or modify it as you wish. 

4. Legal basis of processing and Data storage period

With reference to the processing carried out for the purposes referred to under the previous Clause 2: 

- paragraph 2 (i), the legal basis lies in the fulfilment of the agreement and the pre and post contractual obligations, as well as to fulfil specific legal obligations arising from the agreement (such as, for example, fiscal and accounting obligations, and statutory guarantee) or for defence in court; 

– paragraph 2 (ii), (iii) and (iv) (marketing purposes and profiling), the legal basis of the processing lies in the respective consents you have provided. 

Data collected for sales purposes - paragraph 2 (i) - are stored for a period not exceeding what is required by law for civil and tax purposes. These Data may also be kept for a further period of time, to comply with the terms of the contractual guarantee granted to the customer. 

The Data provided for marketing purposes and to study consumption habits and choices paragraphs 2 (ii) and 2 (iii)) are stored for the period necessary for the specific processing, also in consideration of the particular sector of business (luxury goods) and in consideration of the interest shown by the customer to receive updates on products, events and fashion shows organised by MDREAMS GLOBAL, always in compliance with the privacy legislation and the permission you provided and for a period not exceeding 7 years, unless you provide further confirmation of your interest to receive communications MDreams Global. 

5. Mandatory or optional nature of the Data 
The provision of Data is not mandatory, however with regard to the purpose referred to in paragraph 2 (i), failure to provide certain Data may make it impossible for MDreams Global to execute the sales agreement and/or related services; with regard to the purposes set out in paragraphs (ii) and (iii), failure to provide your Data may make it impossible to receive invitations, information and commercial proposals, even more responsive to your needs, but will not affect the sales agreement and its related services. 

6. Categories of recipients of personal Data 

The Data may be known and processed by: 
- other companies of the Group, 
- suppliers of technical, technological, mailing and essential core service for sales, 
- employees and consultants of MDreams Global, and 
- third parties such as banks, public authorities, payment service management companies (with reference to the processing referred to in paragraph 2(i) acting as data processors appointed by MDreams Global or as authorised parties to the processing of Data by the Data Controller and for these purposes instructed, or as independent data controllers. 

7. Your rights 

We remind you that Articles 15, 16, 17, 18, 20 and 21 of the General Data Protection Regulation No. 2016/679 of the European Parliament and Council grant several rights, including the right to: (a) access your personal data; (b) obtain the correction and updating of your data, request the limitation of the processing performed on your personal data (including, where possible, the right to be forgotten and cancellation); (c) object to the processing of your data for legitimate purposes and to exercise your right to data portability; (d) submit a complaint to the competent Supervisory Authority; (e) ask to know the logic applied to the studies and to request the modification of the results of the study activities on your consumption habits and choices. 

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