PRIVACY POLICY

 

 Governance program in privacy and personal data protection

NOVEMBER 2022

 

 

PRIVACY NOTICE

 

 

Last update: November 1st 2022

 

We from RIMOWA AMÉRICA DO SUL MALAS DE VIAGEM – “RIMOWA” desires to mantain a trust and tranparency relationship alongside all of our customers. Because of that, we elaborated this Privacy Notice to help you understand which of your informations will be collected, the reason why we are going to collect them, and if we are going to share them. Furthermore, we inform your rights related to these informations and how to exercise them alongside RIMOWA.

For us, the priority is to watch over the privacy and security of your personal data. Any information you provide us will be treated accordingly to the limits hereby established. In case of inquiries regarding your personal data protection, we provide an appropriate contact channel by the end of this notice. Please, do not hesitate to contact us.

 

 

1. WHAT DO YOU NEED TO KNOW BEFORE READING THIS NOTICE?

 

In order for you to completely comprehend this Notice, we indicate below some important terms and concepts:

 

Term/Expression

 

Personal Data

Any information regarding a physical identified person or identifiable. It is considered to be identifiable a person that can be identified, direct or indirectly, especially by reference or some identifier, such as a name, a number, identifiers through electronic meanings or to one or more specific elements of the physical identity, physiologic, genetic, mental or economic, cultural or social of this singular person.

 

Sensitive Personal Data

Any personal data regarding the racial or ethnic origin, religious belief, political opinion, union membership or to a religious organization, philosophical or political, as well data related to the health or sexual activity, genetic data or biometrical.

 

Commissioner

The RIMOWA’s Commissioner of Personal Data Treatment is the person indicated to act as a comunication channel with you and the Autoridade Nacional de Proteção de Dados (ANPD).

 

Third Party

It is related to, but not limited to any and every physical or legal person in which RIMOWA relates to or becomes to be related, service provider, provider, consultant, partner, outsourced contract or subcontract.

 

Holder

Physical person which the personal data refers to.

 

Treatment

It is any activity performed with personal data, as if collection, reception, classification, use, access, reproduction, transmission, distribution, processing, register, storage, elimination, evaluation or information control, modification, update, comunication, tranference, sharing and extraction.

 

2. WHAT PERSONAL DATA RELATED TO YOU WE TREAT?

This Notice informs you about how we handle your personal data treatment, collected through our website (https://www.rimowa.com.br/) and RIMOWA’s physical stores, which will be treated accordingly to the limits hereby established, in compliance to Lei Geral de Proteção de Dados Pessoais – Lei 13.709/2018.

 

Therefore, with the purpose of respecting your privacy, we understand that any and every personal data treatment should be limited to the minimum necessary, pertinent and proportional to enable the intended purpose. Thereupon, the personal data we collect regarding you will be variable, in accordance with the relation you choose to establish with us, that is, customer, consumer, vistor, partner, among others.

 

Down below, grouped by categories, we present your main personal data treated by us:

1. Identification information: such as your full name, date of birth, marital status, e-mail, address, within others with relevancy particularly to your relation to us;

2. Information that helps us to contact you: such as billing address and delivery, landline or cellphone and personal e-mail and/or professional; In this case, stick to informing us only your data or the data of people you are authorized to share in the hypotetic scenario of contact, billing, etc.

3. Financial information: information regarding the payment method, such as data related to your credit card. In the cases of returns and exchanges, the bank transaction could be processed through PIX or bank deposit, opportunity in which we would have access to your PIX code or your bank account data.

4. Attributes associated to your electronic devices: such as cookies and trackers, IP address and connection records.

5. General data: that is, the content you send us under free will and that could be collected by Fale Conosco, e-mail, or any other tool you use to send over contente to our servers, as well along your purchase history, including for the purpose of warranty.

 

3. HOW DO WE USE YOUR PERSONAL DATA?

The personal data RIMOWA collects regarding you are used for the following purposes: a) To allow you to create a customer “MyRIMOWA" account at our website; b To answer your questions and inquiries send through “Fale conosco” form, available at our website, or through e-mail or through our customer care central, to collect your comments or if you wish to participate in our surveys; c) To send information about our offers, products, news and events (newsletters, invitations to events organized by RIMOWA, including private sales and other news publications; d) To manage and process your purchases and orders; e) To benefit from the repair services from our managing repairing team; f) For marketing purposes; g) To save your details preferences of use on our website, with the purpose of optimizing your browsing; h) To be in compliance to the legal requirements according to the applicable legislation; and i) In order for you to exert your regret of purchase rights, exchange, assistance or warranty. The personal data that are indisposable to the fulfillment of the purposes described above are assigned with an asterisk mark in several pages of the website. If you choose not to fill out these mandatory boxes, we will not be able to process your requests and/or provide the products and/or the requested services. The additional personal data are optional and allows us to getting to know you better, with the purpose of improve our communications and services.

4. HOW DO WE COLLECT YOUR PERSONAL DATA?

The information we treat regarding you might be provided directly by you to RIMOWA, or even collected automatically, legally, through our platform and other channels.

When accessing our website, we collect and treat your data, accordingly to the purpose into which were provided voluntarily by yourself.

Furthermore, by visiting one of our stores, we might collect and treat your personal data in the occasion one of our sales representative is setting up a customer profile in our intern system behalf your name.

Your personal data might be treated, nevertheless, in the case you send over a RIMOWA product to one of our repairing service centers or bring it over to one of our repairing service centers. In those cases, your data will be inserted in our managing repairing system so it can be possible to inform you about this process.

We also might receive some personal data through third parties. For example, information available through outsourced RIMOWA’s contracts, such as consultants, service providers, providers that help us offer products and services that are improved constantly for you, or even, in the process of credit services and fraud prevention, such as, for exemple, ClearSale.

 

 

5. TO WHOM WE SHARE YOUR PERSONAL DATA?

It is possible RIMOWA performs the sharing of your personal data, which will be restricted to the adequate minimum and necessary for the fulfilling of any of the purposes specified and previously informed to you.

We might share your personal data in the following occasions:

 

1. Transfer of your data treatment by service providers

Based on the terms of a contract set with a service provider, we might treat your personal data for achievement of the purpose of the intended treatment.

The personal data will be shared for:

• News releasing (newsletter, invitations and other publications);

• Media agencies responsible for monitoring the performance of RIMOWA in social media; and

• Technical services to ensure the website operationality, as such, for example, service providers for software maintenance, data process operations and hosting.

 

2. Transfer for treatment of your data to other providers not mentioned above:

• Payment service providers: in order to execute your orders we transmit payment information to payment service providers; • Direct marketing companies and publicity: in order for it to be possible, in determined cases, send you personalized communications in diferent platforms;

• Logistics companies: within necessary, we provide your contact data for transport and order companies and in order to deliver the products you purchased;

• Service providers: These providers include external companies used to help out and operate our business. The service providers and its employees are only authorized to access your personal data under RIMOWA’s name for specific tasks, within the terms required and based on our direct instructions. These providers are contractually obligated to keep your personal data confidential and safe, and in cases of violations will solidarily answer for the damage caused accordingly to the current legislation;

• Fraud prevention agencies and credit analysis, billing debt collection and financial services: Following the applicable law, we can use credit analysis and/or debit collection, that are used to help us verify yor current credit situation and with the purpose of fraud prevention;

 

3. Transfer of your personal data abroad

Considering RIMOWA is an organization of global presence, the recipients of your personal data could be hosted abroad. In this case, further than ensuring the security and protection of personal data by contract, RIMOWA will use of one of the legal international hypothesis transfer.

 

6. HOW LONG DO WE STORE YOUR PERSONAL DATA?

We will retain your personal data for as long necessary to reach the purpose in which they have been collected, unless a longer retention period is necessary to fulfill legal obligation, preserve our rights or fulfill judicial/extrajudicial agreements, as well to ensure your rights of warranty regarding our products.

To determine the period of retention of your personal data, we are based on the following criteria:

• If we do have a legal obligation, contractual or another for personal data retaining or if they are necessary for purposes of investigation or litigation/disagreement; and

• If they are necessary to keep comercial and financial records accurate; By the end of your personal data treatment, these will be deleted in the sphere of technical limits of activities, authorized to conservation in the predicted applicable legislation

 

7. HOW DO WE PROTECT YOUR PERSONAL DATA?

RIMOWA applies technical measures and security protocols according to the best practices, particularly to what regards the security of your information system.

Therefore, RIMOWA makes an effort to take all the necessary measures to protect the confidentiality and security of your personal data and avoid them to be altered, damaged, destroyed or accessed by third parties not authorized. RIMOWA will ensure, in this regard, that its service providers that treat personal data on behalf of RIMOWA present technical security and organizational insurances adequate and similar.

All data is encrypted, using a SLL (Secure Socket Layer) certificate, that consists in a standard method used on internet to protect the information transmitted between web users and websites.

Your credit card information is not registered in our systems and the data processing for approval is done directly by the credit card administrators and banks.

Aspiring your security, all orders are analyzed, and, in case some divergency is identified between the registration information and payment information, a specialized company will reach out for data confirmation before the order’s approval. This procedure ensures the security of the transaction. Therefore, keep your data updated and stay aware when using cards with several card holders, or PIX or joint accounts, because the data of these individuals also might be treated, as well registered phone.

On the eventual report of any incident involving personal data, we will communicate it to the Autoridade Nacional de Proteção de Dados – ANPD on the scenarios determined, and, if that is the case, to the data’s holder.

 

8. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM WITH RIMOWA?

Which ever it may be the relationship you choose to establish with RIMOWA, you have all your rights related to your personal data ensured accordingly to the law, including, but not limited to:

1) To know if we treat some of your personal data;

2) To know what personal data will be treated by us;

3) To correct incomplete data, inaccurate or not up to date;

4) To request the anonymization, block or elimination of unnecessary data, excessive or that, somehow, have been treated not compliantly to the law;

5) To request the portability of the data to other service provider or product; 6) To ask for the review of decisions uniquely automated that affect your interests;

7) To request the elimination of the data treated with your consent; revoking the authorization for treatment of data provided;

8) To obtain information about public or private entities with whom we share your data; and

9) When the activity of treatment requires your consent, you can deny consenting it. In that scenario, we will inform you about the consequences of not performing such activity.

If you do consent, you can revoke the consent at any moment. To exercise your rights, you can get in contact with the person in charge for personal data processing, OPICE BLUM office, BRUNO & VAINZOF ADVOGADOS ASSOCIADOS, via the e-mail privacidade@rimowa.com. In certain circumstances, it is possible that your request might not be fulfilled. In those scenarios, we will explain to you the reasons for such decision.

Request that involves personal data and/or documents of a third party will not be fulfilled, except when authorized by a proxy or letter of attorney that gives you the right to such request.

 

9. WHAT ARE COOKIES AND HOW WE USE THEM?

Cookie is a small text file that is created by the website, sent to the browser and recorded to the hard drive of your device (computer, laptop, cellphone, tablet etc.) and that contains information related to the browsing of such device in the website (such as browsed pages, data of browsing, time etc.).

Pixel tags (or clean GIFs, web beacons or pixels) are small code blocks in a webpage that allow it to read and store cookies and shared information with RIMOWA and/or partner companies, such as Facebook.

The connection might include IP address of a device, the time that the person has activated the pixel, an identifier associated with the browser, or the device and the type of browser being used.

The cookies and other technologies used don’t gather information that identify the user. However, if you’re a RIMOWA client, we can monitor your visits to our website if your browsing was started by RIMOWA, as the sending of an e-mail.

Cookies and other Technologies also gather generic information, specifically the way you get to and use RIMOWA’s website – location from where you access the website etc. It is important to highlight cookies and other technologies retain only information related to your preferences.

Cookies and other technologies do not cause any damage to your device and do not contain any virus.

• What are the types of cookies and other technologies that might be used?

Session cookies: are temporary, therefore, disappear when the user leaves the website; and Permanent Cookies: remain at the terminal up until the expiration date expires (will be stored up until 2 (two) years); or until they are deleted by certain browser’s functionalities.

 

• What are the cookies categories and other technologies?

The specific names and other technologies may vary according to our online services improve and update, but they gererally are restricted to the following categories.

 

Necessary/Essentials: considered fundamental to the website’s functioning. Allows website’s navigation and the use of its applications, such as accessing safe areas of the website through login. Without these cookies, the services that demand them cannot be provided.

 

Optional: Offer you other functionalities (such as the register of preferences in the exhibition of determined website, registering, for example, the type of device and the size of the font to the correct page exhibition), statistic tracking capacity etc.

 

Performance: These cookies are used to analyze the way in which you use the website, as well monitoring its performance. It allows us to provide a high-quality experience by personalizing our offers and quickly identify and correct any problems that may happen. Still, based on website’s use, RIMOWA can use these cookies to highlight articles or services of the website that might be of your interest, as well to identify the sales link use provided to the customer by sales representatives. These cookies are only used to creation and statistic analysis purposes, that is, information is not collected regarding your personal affairs.

 

Functional: These cookies are used to allow RIMOWA to remind your preferences – for example, cookies avoid the name of the user to be typed down every time it accesses our website. We also use cookies functionalities to provide advanced services to the user, as for example leave comments in an article. In summary, functionality cookies keep the user’s preferences related to the using of the website, in a way it is not necessary to reconfigurate the website every time you visit it.

 

Marketing: These cookies help analyze your browsing behavior, with the purpose of transmitting and measuring advertises/publicities, to make them more relevant to you and to analyze the content and use of products. That is, they are used to direct the publicity accordingly to your interests and the number of visits, allowing to limit the amount of times of the advertise exhibition.

 

Third Parties: Along with cookies and RIMOWA’s other technologies, it might allow that contracted third parties use cookies and other technologies of its ownership, as Facebook and Instagram, to identify your browser and device, as to offer RIMOWA’s related direct publicity when you access websites or third party apps. This third parties might, also, provide RIMOWA information around developed marketing campaigns. Some of this companies might use cookies and other RIMOWA’s proper technologies, such as Facebook and Instagram.

• Why RIMOWA uses cookies and other technologies? Cookies and other technologies help to provide, protect, and improve your experience, personalizing content, measuring and improving advertising/publicities or promoting a safer experience. In addition to that, it is possible to improve the providing of our products through the creation of audiences throughout pixels (for example, website visits in the last 30 days, users that have placed a purchase in the last 60 days, and lookalike) to direct brand and products releasing campaigns.

• What are the cookies used by RIMOWA?

- RIMOWA’s cookies, mentioned above;

- Third Parties chosen carefully by RIMOWA, with the purposes of reaching the achievements described above; and

- Social media cookies;

 

• How to manage/reject cookies?

Your browser or device might have settings that allow you to choose to define cookies or not to, and delete them.

To know more about these controls, check out the support material of your browser or device.

 

10. QUESTIONS?

In case of any questions, you can contact our Commissioner for Personal Data Treatment, the OPICE BLUM, BRUNO E VAINZOF ADVOGADOS ASSOCIADOS office through the e-mail: privacidade@rimowa.com

 

11.UPDATE

It is possible that some of the information hereby provided are updated or altered. Therefore, we advise you to check out this Privacy Notice periodically.