Privacy Policy

Privacy Notice FlyTrendy
EU Regulation 679/2016

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FlyTrendy Group S.r.l., tax code and registration number in the Milan Monza Brianza Lodi Business Register 02609800699, REA no. MI - 2556709, with registered office at Via dell'Annunciata 2, Milan (MI) – ("FlyTrendy" or the "Company") is committed to respecting your privacy. Your personal data is processed in accordance with the principles of lawfulness, fairness, and transparency, limitation of purposes, data minimization, accuracy, limitation of storage, integrity and confidentiality, accountability, and in compliance with all other applicable provisions of EU Regulation 2016/679, adopted by the European Parliament and the Council on April 27, 2016.

This Privacy Notice explains our policy in managing personal information collected through the following channels (hereinafter referred to as "Collection Channels"):

1. Our online properties (hereinafter referred to as "Website"), including:
   1.1. Our websites, including but not limited to www.flytrendy.com
   1.2. Any linked website, social media page, internal website, and any FlyTrendy mobile and tablet application, including the FlyTrendy Influencer App;
2. Any other means through which a person provides personal information to FlyTrendy, including both physical and electronic means; and
3. Any other means through which we legally collect information about you.

You can contact us for any questions regarding this Privacy Notice or your personal information by contacting FlyTrendy's privacy agent via email: hello@FlyTrendy.com.

We are committed to safeguarding personal privacy. We acknowledge your right to control how we collect and use your personal information. Providing personal information is an act of trust, and we take it seriously. We will collect and use personal information as defined below, except where we may request permissions to operate differently, on a case-by-case basis.

1. In this Privacy Notice, we refer to your 'personal information,' meaning information or opinions about an identified individual or an individual who is reasonably identifiable regardless of the truth of the information or opinions and regardless of whether the information or opinions are recorded in material form or not. Your full name, gender, date of birth, home address, home phone number, mobile phone number, email address, and work contact details are examples of information that may constitute personal information. Personal information may also include information we may collect about your individual preferences.
2. FlyTrendy has developed and implemented its Privacy Notice regarding personal information to reflect international best privacy policy practices.
3. To stay current with international legislation and best practices, we may review this Privacy Notice at any time without notice. We will publish any changes made to this Privacy Notice on our Websites, so we encourage you to check this Privacy Notice from time to time.
4. In addition to the provisions of this Privacy Notice, there may also be specific and additional privacy and consent provisions that apply to certain Collection Channels. As these specific and additional provisions also relate to the protection of your privacy, we recommend reviewing them wherever they appear. In the event of any inconsistencies between the provisions of this Privacy Notice and other specific and additional provisions, the specific and additional provisions will prevail.

Anonymity and Pseudonymity

1. Where applicable, we allow you to collaborate with us anonymously or under a pseudonym. If this is possible, our Collection Channels will seek information only in this way. However, if not applicable to the purpose for which the information is collected, we will seek the identified information below. For us, it is not practical to collaborate anonymously or under a pseudonym if we want to send you direct marketing materials or if we need to send you requested goods or services.

Types of Personal Information FlyTrendy Collects and Stores

1. The personal information that may be requested includes, but is not limited to:

1. Contact information such as full name, date of birth, phone number, mobile number, current and valid email address, home address, and postal code;
2. Your ID for Apple AppStore and/or Google Play Store and your unique device identifier (UDID);
3. Management and login details of your social media, including the username;
4. Location information;
5. More detailed contact preferences;
6. Sensitive information about you;
7. Photographs of you;
8. Your occupation and information about your professional history and interests;
9. Information about your education and qualifications;
10. Information about your personal interests and interesting and relevant information about you;
11. Financial details, including your bank account details and PayPal details;
12. Your online behavior and interests based on your online browsing activities;
13. Information about your preferences, interests, and experiences with our products or services. This information is collected to personalize our communications with you and continuously improve our products and services;
14. Information about your experience with our products or services or with third-party products or services listed on a Website;
15. Details of your credit card (if you purchase any product or service from us);
16. Contact details of third parties. If you are asked to provide details of other people, please ensure that these people are happy for their details to be provided to FlyTrendy and used for the purposes outlined in this notice (which may include using the details for marketing purposes); and
17. Any other personal information you provide directly. If you provide unsolicited personal information, we will retain this information if it falls within the primary scope of our personal information collection (as outlined in this Privacy Notice).
18. When you use a Website, we may also collect personal information about you in the following general categories:
19. Usage and preference information: We collect information about how you interact with a Website, including the pages you visit, your preferences, and the settings you choose. We may do this through the use of cookies and other similar technologies that uniquely identify you;
20. Device information: We may collect information about your mobile device, such as hardware model, operating system, preferred language, unique device identification, and mobile network; and
21. Other information: We may also collect and store information such as your IP address, your access dates and times, the type of browser, and pages visited when you interact with a Website.

Sensitive Information

1. We will only collect sensitive information with your consent and if you provide it directly to us. If you provide us with sensitive information (including, but not limited to, information about your sexual orientation, political and religious beliefs, medical and/or criminal history), we will use this information only for the stated purpose at the time of collection and share this information with our trusted third parties in the ways stated on the Website or in this Privacy Notice.

How FlyTrendy Collects and Stores Personal Information

1. We will collect or monitor personal information about you only with your consent, as outlined in this Privacy Notice, or otherwise as permitted by law. The only personal information collected by us is that provided or collected by us in accordance with this Privacy Notice or legally provided to us by third parties.

Active Collection of Information

1. Personal information may be collected (and combined) through our Collection Channels if you:

1. Provided us with personal information before this Privacy Notice came into effect, both directly from you and through third parties;
2. Signed up and/or registered to become a member of any Collection Channel;
3. Downloaded and used a mobile and/or tablet application, including the FlyTrendy Influencer App;
4. Submitted Content or participated in any way in a Collection Channel, including engaging with other users or participating in Campaigns;
5. Subscribed to any newsletter, update, notice, or news and media services, or requested information on launches or events or information about our products or services or other information and also information about third-party products or services;
6. Completed and submitted any form or request to us;
7. Contacted us directly in person or through communication channels, including mail, phone, social media, and commercial electronic messaging (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging), and email), including contact details listed on a Website;
8. Participated in any offer, promotion, or marketing activity;
9. Interacted with a Website for a specific purpose;
10. Interacted with or navigated on a Website in general; or
11. If you are a business we deal with, completed a credit application.

2. Personal information is requested to allow you to participate in a Collection Channel, to facilitate or provide you with certain Content, products or services, and information about such Content, products or services (including uploading, accessing, and receiving Content on a Website and purchase transactions on a Website), commercial materials (including direct marketing materials), newsletters, electronic newsletters (e-newsletters), news, and information releases/media launch information, and also to alert you to other opportunities and products, services, offers, competitions or events of FlyTrendy or third parties that may interest you. No one is obligated to provide personal information. However, if you do not, you may not be able to participate in the Collection Channels, and FlyTrendy may not be able to allow or provide you with certain Content, products or services, information about products or services, upcoming opportunities and promotions, information about competitions, offers, or events, or accept your submissions of material for competitions or other Content.

3. We may obtain personal information about you from authorized third-party sources, including social media channels, intermediary lists, and other data providers or organizations that share data in circumstances where it is legal to do so and/or where you have given them permission to do so. If you represent a business we do business with, we may also obtain information about you regarding loans from a credit analysis agency and information about your business history through references you provide.

Minors

1. The collection of personal information is neither intended nor directed at individuals under the age of eighteen (18). Personal information will not be collected from anyone FlyTrendy knows to be under eighteen (18) without the consent of a parent or legal guardian. Persons under eighteen (18) may use our Websites only with the involvement and consent of a parent or legal guardian. For the purposes of this document, downloading the Flytrendy App assumes the User's legal age or the parent's knowledge of the minor's use.

Passive Collection of Information

1. Like many commercial websites and mobile and tablet applications, we may also collect information that tells us more about the visitors to our Websites. For example, we may collect information about the date, time, and duration of visits and which pages of a Website receive the most traffic. This information is generally not linked to the identity of visitors, except in cases where a Website is reached through links in an email we have sent or when we can uniquely identify the user's device or access to a Website. By accessing a Website through links in an email we sent you and/or accessing a Website in general, even when you log in to an account, you consent to the collection of such information if it is personal information.
2. When you browse our Websites, some information may be collected passively (i.e., collected without you actively providing the information) using various technologies, such as Unique Device Identifiers (UDIs), cookies, Internet tags, or web beacons, and browsing data collections (log files, server logs, clickstream). This depends on the device used and the method by which the person connects to the Internet. Your Internet browser automatically transmits to the Website you are currently visiting some of this anonymous information or personal information, such as the URL of the website you just came from, the Internet Protocol (IP) address, the UDI (if applicable), and the browser version that your device is currently using. Our Websites may also collect anonymous information or personal information from your device through cookies and Internet tags or web beacons. You can set your browser to notify you when a cookie is sent or to reject all cookies, but some Website functions may not work without cookies, and this may limit the services provided by a Website. Cookies and other technical methods may include the transmission of information both directly to us and to another party authorized by us to collect information on our behalf.
3. Our Websites may use and combine such passively collected anonymous or personal information and/or from various third-party sources, including those described above, and may combine this passively collected anonymous or personal information with other personal information collected from you to provide better service to Website visitors and users, to personalize a Website based on your preferences, to compile and analyze statistics and trends, to provide you with relevant advertising when you visit a Website or a third-party website, and to otherwise administer and improve a Website for your use. We may combine information about your visit sessions or other information collected through tracking technologies with personally identifiable information from time to time to understand and measure your online experiences and to determine which products, promotions, and services are likely to be of interest to you. By accessing a Website, you consent to the collection, processing, and use of information about you in this way.
4. For more information about cookies and the choices you can make, visit http://www.youronlinechoices.com.au/.

Purposes for which FlyTrendy collects, stores, uses, and discloses personal information:

1. The personal information collected will be used for the following primary purposes:

1. For the purposes listed in the privacy statement of the collection on a specific Collection Channel.
2. To maintain the functionality of a website, including providing information about the Content available on the website and e-commerce transactions conducted through the website.
3. To fulfill obligations under all Terms of Use on uploads, sales and purchase contracts, and/or any other contract between you and FlyTrendy.
4. To send you important technical, administrative, or legal notices for our websites.
5. To allow you to create an account, access it, and use the functionality of a specific Collection Channel, including the FlyTrendy Influencer App.
6. To enable you to respond to opportunities, briefs, or campaigns created by other users of a Collection Channel.
7. To allow you to post on your social media channels through a Collection Channel.
8. To facilitate payments from and to you through a Collection Channel.
9. To provide information about your transactions (including uploading, accessing, and receiving content on a website, and purchase transactions on a website), content, services, and products.
10. To provide marketing materials, events, special offers, competitions, and promotions in person and through any means of communication, including mail, phone, and electronic commercial messaging (SMS, MMS, IM, email) or any other form of electronic, emerging, digital, or conventional communication channel.
11. To provide you with relevant advertisements when using our websites or third-party websites.
12. To maintain our relationship with you.
13. To provide services related to our company (e.g., post-sales services).
14. To provide newsletters by mail and electronic newsletters (e-newsletters) via electronic commercial messaging.
15. To respond to customer requests and complaints and manage complaints.
16. To improve the website and system administration.
17. To obtain opinions or comments on products and/or services and conduct other research and development activities.
18. To record statistical data for marketing analysis and conduct market research.
19. To share personal information with companies within our group, our promotional partners, trusted brands using a specific Collection Channel, and their respective corporate bodies and agents, and other trusted third parties as described below.
20. If you are a business we are dealing with, to continue our business relationship with you, including your identification and contacting you, sending you invoices correctly, assessing the risks of providing credit to you or your business, and securing and recovering any debt owed to us.
21. Any other purpose that FlyTrendy may reasonably deem necessary depending on the circumstances.

2. For the purposes described above, personal information may be shared with FlyTrendy group companies, FlyTrendy business partners and their respective corporate bodies, and other trusted third parties (and their directors, officers, and agents) in Italy or abroad. Failure to provide personal information may result in FlyTrendy being unable to provide certain content, information, incoming opportunities, promotions, events, or information about products and/or acceptance of content and submissions from you related to promotions (where applicable).

3. To manage a website or provide a service (including, for example, processing credit card payments), personal information may also be shared with FlyTrendy group companies, selected service providers and their respective corporate bodies, and/or other trusted third parties in Italy or abroad. FlyTrendy group companies, selected service providers, and/or other trusted third parties may be involved by FlyTrendy to perform various functions, such as legal and accounting services, data storage, order processing, market research, credit card payment processing, assistance with promotions, and provision of technical services for our websites. These companies may have access to personal information if necessary to perform such functions. Credit card details are used only to facilitate your purchase. They are not used for any other purpose and will never be provided to third parties other than FlyTrendy or its relevant service provider. If you are a business we are dealing with, we may share your information with debt recovery agents or credit reporting bodies, if necessary.

4. We recognize the trust with which you provide your personal information, and except as stated in this Privacy Policy or as otherwise required by law, such information will not be used or disclosed for any other purpose without your consent. However, FlyTrendy reserves the right to use or disclose any information, including personal information, if necessary to comply with laws, regulations, or legal requests, to protect the rights or property of FlyTrendy, any member of the FlyTrendy group, or any member of the public, to protect the integrity of a website, to fulfill your requests, or to cooperate in any investigative or public safety investigation.

Contact from FlyTrendy:

1. FlyTrendy group companies (and their directors, officers, and agents), FlyTrendy promotional partners and their respective corporate bodies, or trusted third parties (including users of a Collection Channel) and other selected service providers and other non-FlyTrendy companies or professionals in Italy or abroad may contact you by phone, SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email, mail, or any other form of electronic communication, emerging, digital, or conventional channel using the information provided to contact you for the primary purposes of collecting personal information as previously stated.
2. FlyTrendy does not send advertising or marketing information without obtaining prior consent, such as the consent contained in this Privacy Policy, or as otherwise permitted by law. If you receive communications from FlyTrendy that you do not wish to receive, you can remove your name from the database as indicated in the communication, including through the use of the Unsubscribe/Revoke function (if the communication is through electronic commercial messaging) or by contacting FlyTrendy through the contact details in this Privacy Policy. Please allow 30 days for the processing of this request.
3. Despite removing your name from the database for receiving future advertising and marketing information, FlyTrendy may send you non-commercial "Administrative Emails." Administrative Emails refer to the FlyTrendy user account and may include confirmations on administration and transactions, requests and questions, or information about a specific FlyTrendy user account. If you do not wish to receive such communication from FlyTrendy, you can remove your name from the database using the unsubscribe function.

Possibility for other people to view information:

1. FlyTrendy may provide areas on a website where you can upload user-generated content, post or provide information about yourself, communicate with other users, including commercial users and brands, provide reviews of content, products, and/or services, use features that allow you to post content on your social media channels, or interact with or vote on particular content. This information may be shared with others and may be publicly posted on our websites, including, for example, other social media platforms and other public forums that you may choose to participate in. This information may be made available to the public and may be read, collected, and used by other people on our websites or outside of our websites. FlyTrendy is not responsible for the conduct of other people who may read, collect, and use this information.

Your right to access:

1. You have the right to access and review your personal information recorded on the FlyTrendy database at any time. Information can be reviewed by contacting the FlyTrendy privacy officer with the contact details contained in this Privacy Policy. FlyTrendy allows 30 days for the processing of this request.
2. From time to time, FlyTrendy may determine that it is not necessary to provide individual access to personal information to the extent that FlyTrendy can legally do so. If such a determination is made, FlyTrendy will provide you with written notice.
3. If you seek information contained in an electronic file or seek paper copies of personal information, we reserve the right to charge reasonable handling/postal fees as needed.
4. For some personal information that may have been stored, such as if stored on tape programs, it is not practical to provide you with this information without charging an appropriate fee, which we consider reasonable in these circumstances.

Modify and delete your account and/or information we have about you:

1. Information contained in the database can be changed, or your contact preferences can be changed by contacting the FlyTrendy privacy officer through the contact details contained in this Privacy Policy. FlyTrendy allows 30 days for the processing of this request.
2. Similarly, at any time and without any restrictions, a request can be made to delete your account and/or personal information, and in that case, your account will be deleted and/or all reasonable steps will be taken to delete the information, except where it is legally required. Deleting information may result in our inability to facilitate or provide information on certain transactions (including uploading, accessing, and receiving content on a website and purchase transactions on a website), other content, information about services or products, information about upcoming promotions, competitions or events, and/or provide certain content, goods, or services.
3. We are not responsible for removing your personal information from third-party lists that have previously provided information about you in accordance with this policy.

Retention and security of personal information:

1. FlyTrendy will make every effort to keep all your personal information recorded (including credit card details) safe and to keep this information accurate, up-to-date, complete, and relevant. We ensure that only necessary entities will have access to your personal information. Personal information is stored on secure servers protected by controlled equipment. This service may be managed on our behalf, and data may be stored by our selected service providers. In some cases, this equipment may be located overseas, including, for example, the United States, the Philippines, Europe, and the United Kingdom.

Disclosure of personal information to foreign recipients:

1. In some cases, FlyTrendy may disclose your personal information to foreign recipients, including, for example, France, the United States, the Philippines, Europe, and the United Kingdom. FlyTrendy employees, processors, and other trusted third parties are required to comply with the confidentiality of any personal information stored by FlyTrendy. However, the security of communications over the Internet cannot be guaranteed, so absolute assurance that information will always be safe cannot be given. FlyTrendy cannot be held responsible for events resulting from unauthorized access to personal information.

FlyTrendy and links to other websites:

1. Our websites may occasionally contain links to websites of other organizations that may be of interest to you. Their inclusion cannot be considered as implying any validation or certification by us of the content of the third-party website. Linked websites are responsible for their own privacy practices, and you should check the respective privacy statements of those websites. FlyTrendy is not responsible and accepts no responsibility for the conduct of companies linked to our websites.
2. We may use third-party advertising on our websites. All third-party advertising, if paid, is paid by the relevant third-party advertisers and is not endorsed or sponsored by FlyTrendy or any of its affiliates. FlyTrendy is not responsible for the content (including statements) of any third-party advertising on a website. These advertisements may be associated with cookies that allow the advertiser to track the number of anonymous users responding to the Campaign. We do not have access to or control over cookies placed by third parties.

Websites related to FlyTrendy:

1. All websites operated by FlyTrendy adhere to this Privacy Policy. However, the information on the websites of some members of the FlyTrendy group may vary due to local customs, practices, or laws.

Sale of the Company:

1. If FlyTrendy merges or is acquired by another company, or sells a portion or all of its assets, your personal information may be disclosed to our advisors and the advisors of potential buyers, and may be part of the transferred assets. However, personal information will always be subject to this Privacy Policy.

Issues, Deletion, or Requests:

1. If you have any questions about our Privacy Policy, or any issues or complaints about how we have collected, used, stored, managed, and/or disclosed your personal information, please contact our privacy officer through one of the following channels:

Address:

The Privacy Officer
FlyTrendy
Via Dell’Annunciata 2
20121 Milano
Email: influencers@FlyTrendy.com

To delete your account, please proceed through the appropriate button available in the FlyTrendy Influencer App.