Purpose and legal basis of processing
We may process personal data to:

• allow you to navigate on the Site and use its functions, on the basis of the need to provide the services you have requested (art. 6, par. 1(b) GDPR);
• ensure the correct functioning of the Site and monitor its use in aggregate, on the basis of the Controller’s legitimate interest to monitor and improve its services (Art. 6, par. 1(f) GDPR);
• comply with legal obligations to which we are subject on the basis of the need to fulfil legal obligations (Art. 6, par. 1(c) GDPR);
• prevent and ascertain cybercrimes, as well as ascertain, exercise or defend a right in judicial or extra-judicial proceedings, on the basis of the legitimate interest of the Data Controller or of third parties in the protection of their rights and interests (Art. 6, para. 1(f) GDPR).

Over time, OVS may make artificial intelligence tools available to facilitate navigation on the Site. These tools will be optional and will only be activated at your initiative by clicking on the relevant icons. Processing may concern content you have entered, and will be carried out for the same purposes and in the same manner as described herein. Further information will be made available directly within the tools themselves.

Categories of processed data
We may process data relating to your connection to and navigation within the Site (IP address, device identifiers, details of the operating systems and features of the device used, preferences concerning cookies and other trackers, dates of access to the Site, language and country of navigation).
In addition, depending on the functions of the Site you choose to use, we may process additional personal data strictly necessary to provide you with the services you have requested.
These data are also collected through cookies and other tracking tools installed on the Site. If you want to find out more about this, please see our Cookie Policy.

Optional / Compulsory treatment
The provision of data is optional, but necessary. Failure to provide data would make it impossible to navigate correctly on the Site or to use certain functions.

Data retention
Data will be deleted within 14 (fourteen) months from the date of collection, unless legal provisions, official rulings, or the existence of litigation require a longer retention period. For more details on individual cookies and tracking tools, please see our Cookie Policy.

♦ Focus box - Geolocation for 'Find a Store’
While you are browsing the Site, you can decide to authorise the Site to know your location so that OVS can find your nearest store. This function will only be available if you decide to consent to the processing of your location data (Art. 6, para. 1 (A) GDPR). You are absolutely free to withhold your consent: in this case, you can only search for stores via the search bar. OVS will not store your location details unless you select the 'favourite store' option.

♦ Focus box - Feedback
You can choose to send feedback to OVS on your level of satisfaction with the Site by clicking on the ‘Feedback’ bar. This processing is carried out to allow OVS to collect your opinion and your level of satisfaction in using the Site. It is based on the legitimate interest of OVS in monitoring Site effectiveness and quality (art. 6, par. 1(f) GDPR). You are absolutely free not to provide your data: processing will only take place where you decide to click on the bar.

Purpose and legal basis of processing
We may process personal data in order to allow you to register on the Site by creating a private area (‘account') and to grant you access to it, as well as to the use of the functions linked to it, on the basis of the need to provide the services you have requested (art. 6, par. 1(b) GDPR).

Categories of processed data
We may process emails, passwords, purchases, registration of marketing and profiling preferences, and other information that you decide to save on your account.
You can also access your account via "social login" using your social media accounts. In this case, your social media accounts will only share the data required for authentication with OVS.

Optional / Compulsory treatment
Data provision is optional, but failure to provide certain data marked as mandatory (*) during registration will mean that the registration cannot be finalised.

Data retention
Your account and the data relating to it will be deleted in the event of non-use of the account for more than 5 (five) years. This is without prejudice, however, to the possibility of retaining certain data for a longer period if legal provisions, official rulings or the existence of litigation should require a longer retention period.

Purpose and legal basis of processing
We may process personal data to:

• enable you to proceed with the purchase of products, including our OVS Gift Cards, and manage the related contractual relationship, on the basis of the need to execute the contract or to take pre-contractual measures at your request (art. 6, par. 1(b) GDPR),
• comply with legal obligations to which we are subject on the basis of the need to fulfil legal obligations (Art. 6, para. 1(c) GDPR);
• prevent and combat fraud, as well as accepting, exercising or defending a right in judicial or extra-judicial proceedings, on the basis of the legitimate interest of the Controller or of third parties in the protection of their rights and interests (Art. 6, par. 1(f) GDPR).

We may also carry out such processing in-store, in the event that the product you want is not available at the point of sale and you decide to order it in-store, or in the event that you request a digital receipt.

Categories of processed data
We may process personal data (name and surname), contact details (address, email, telephone number), ecommerce order details, and information on the means of payment used to make the purchase. In the case of digital receipts, only your name and e-mail address will be processed.

Optional / Obligatory processing
You are absolutely free to choose whether or not to provide us with your data. However, in order to proceed with the purchase, it is necessary to complete all fields marked as obligatory (*), without which the purchase cannot be completed. However, failure to fill out the data marked as "optional" will not prevent purchase or have any consequences.

Data retention
Depending on the purpose of data collection and/or processing activities, data will be stored on the basis of the following criteria:

• the time necessary to fulfil the contractual obligations and for the duration of the applicable limitation period (up to 10 (ten) years from the execution of the contract);
• in the case of digital receipts, for 1 (one) year from the issue of the digital receipt;
• the time necessary to fulfil legal and regulatory obligations, including those relating to taxation or accounting (invoicing, bookkeeping and accounting entries);
• in the event of disputes, for the duration of same.

♦ Focus box - Save your items
OVS provides you with some optional features that allow you to save the items that interest you and receive updates on them. Each function is only activated by your voluntary action (e.g. a click on the appropriate icon). Specifically:

• the ‘Cart' function allows you to collect the items you wish to purchase. If you have logged on to the Site and do not complete your purchase, OVS may send you service communications to notify you that your shopping cart is about to expire;
• the ‘Save for Later’ function, available only to users who are logged in to the Site, allows you to move the items in your cart to a separate area, to save them and find them again later;
• The 'Wishlist’ function allows you to save your favourite items in a wishlist for easy retrieval later.

This processing will take place to allow you to use the function you have requested and, where appropriate, to send you service communications relating to the items selected (Art. 6, par. 1(b) GDPR), in compliance with the Site's data retention periods.
Where you have consented to the processing of your data for marketing purposes, OVS may also use that data to send you communications of a promotional nature (see below for more details). You may, however, object to receiving such communications by clicking on the unsubscribe link in the footer of the communication.

♦ Focus box - NotifyMe
When an item is out of stock or when a new collection is launched, OVS will ask you if you want to be notified as soon as the item is back in stock ("Back in Stock") or when the new collection is made available ("Coming Soon"). If you use these features, OVS will process your email and list of selected items.
This processing will take place in order to enable you to use these functions and the legal basis of the processing is the need to provide the services you have requested (Art. 6, para. 1(b) GDPR).
If you have given your consent to the processing of your personal data for marketing purposes, OVS may also use these data to send you communications of a promotional nature (see below for further details). The use of these functions is completely optional and you are free not to activate them.

Purpose and legal basis of processing
We may process personal data to:

• manage and respond to your requests for assistance, reports, enquiries, complaints, questions regarding product warranties or the use of our services, based on the need to provide the services you have requested and, where applicable, to perform our contractual obligations (art. 6, para. 1(b) GDPR);
• comply with legal obligations to which we are subject on the basis of the need to fulfil legal obligations (art. 6, par. 1(c) GDPR);
• claim, exercise or defend a right in judicial or extra-judicial proceedings, on the basis of the legitimate interest of the Controller or of third parties in the protection of their rights and interests (art. 6, para. 1(f) GDPR).

Categories of processed data
We may only process the data strictly necessary to provide you with assistance (e.g. personal data, contact details and information about an order), in addition to the information contained in your request.

Optional / Obligatory processing
You are absolutely free to choose whether or not to provide us with your data. However, the disclosure of your personal data is necessary to enable us to respond to your request. In the absence of your data, we will not be able to follow up.

Data retention
The data will only be stored for as long as it is necessary to process your request or to provide you with the requested information. This is without prejudice to the possibility of retaining your data for a longer period should it be necessary for legal or judicial protection or in the event of litigation.

Purpose and legal basis of processing
We may process personal data to:

• manage your participation in the ‘OVSfriends/card' loyalty programme, based on the need to deliver the OVS Friends loyalty programme (Spain OVSfriends loyalty programme regulations; Italy OVSfriends loyalty programme regulations; France OVScard loyalty programme regulations; Greece OVScard loyalty programme regulations; Croatia OVScard loyalty programme regulations; Luxembourg OVScard loyalty programme regulations; Germany OVScard loyalty programme regulations;) (art. 6, par. 1(b) GDPR);
• comply with legal obligations to which we are subject on the basis of the need to fulfil legal obligations (art. 6, par. 1(c) GDPR);
• claim, exercise or defend a right in judicial or extrajudicial proceedings on the basis of the legitimate interest of the Controller or of third parties in the protection of their rights and interests (art. 6, para. 1(f) GDPR.

Categories of processed data
We may process personal and contact data (name, surname, postal address, email address, telephone number) as entered in the online registration form, or available in ‘OVS’ stores; data relating to points and discounts provided.
To share the benefits of the OVSfriends/card loyalty programme with friends and family members, we may ask you to enter certain of their personal details, in which case you must ensure that these parties are duly informed of this personal data processing.

Optional / Obligatory processing
You are free to choose whether or not to provide us with your personal data; if you choose to provide us with this information, complete the form by filling out all the mandatory fields (*) which are necessary to register for the loyalty programme.

Data retention
Personal data will be kept for as long as necessary to manage your participation in the loyalty programme, until you decide to unsubscribe from the programme. However, OVS may keep the data for a longer period if necessary to fulfil its legal and/or accounting obligations, and, if longer, for the duration of any litigation in which such personal data are relevant.

Purpose and legal basis of processing
We may process personal data in order to send you short surveys aimed at measuring your satisfaction in relation to a recent interaction with OVS (such as a purchase or an interaction with Customer Service), on the basis of OVS's legitimate interest in monitoring and improving the efficiency and quality of its services (art. 6, par. 1(f) GDPR).

Categories of processed data
We may process contact data (name, email address) and information related to the specific transaction or interaction.

Optional / Obligatory processing
You are absolutely free not to provide your data: processing will only take place where you decide to click on the bar/button included in the email. You can still opt out of receiving such communications by clicking on the unsubscribe link in the footer of the communication.

Data retention
Personal data will be stored unencrypted for a maximum period of 12 months after their collection, in order to handle any follow-up on your specific case. Subsequently, the data will be irreversibly anonymised or aggregated for exclusive statistical and historical analysis purposes.

Purpose and legal basis of processing
We may process personal data for marketing purposes, on the basis of your possible consent (art. 6, par. 1(a) GDPR), by sending you advertising, commercial and market research communications relating to products, services, initiatives and promotions of OVS, including the different OVS brands such as UPIM, GAP and many others (the complete and updated list is available on www.ovscorporate.it).
Communications may take place by traditional means of contact (paper mail, operator calls) and automated means (email, text, push notifications, and other electronic communications), including via social networks and other digital channels (including WhatsApp). You may revoke your consent at any time by writing to hello@ovs.it, by changing your preferences in your account on the Site, by using the contact form available on the Site or by clicking on the unsubscribe link in the footer of your electronic commercial communication.. In the event you withdraw your consent to marketing activities, this withdrawal shall apply to any mode of contact (whether automated or not), unless you indicate otherwise.

Categories of processed data
We may process personal data (name and surname), contact details (email address, phone no.), marketing and purchase choices, and products saved in your cart, wishlist or ‘save for later’ function.

Optional / Obligatory processing
You are absolutely free to give consent or not: your decision not to consent to marketing activities will have no consequences.

Data retention
Personal data will be stored until consent is revoked. In that case, the data will be promptly deleted.

Purpose and legal basis of processing
We may process personal data for profiling purposes, on the basis of your possible consent (art. 6, par. 1 (a) GDPR), in order to analyse your preferences, habits, interests and purchasing behaviour, including by enriching the data collected by OVS (e.g. data relating to purchases or interaction with the Site and other OVS properties) with information obtained from legitimate sources, such as statistical or demographic data. The purpose of this processing is to personalise the commercial offer, improve the services offered, and send you promotional communications in line with your interests for all OVS brands (see www.ovscorporate.it for more details).
In addition, your data will be used to check the impact of online campaigns on in-store purchases and the creation of control groups (users who do not receive communications) for comparative statistical purposes. You may revoke your consent at any time by writing to hello@ovs.it, changing your preferences in your account on the Site, through the contact form available on the Site. If you revoke your consent to marketing, this will automatically be deemed to extend to profiling processing as well.

Categories of processed data
We may process personal data (name and surname, gender and age, country of origin), contact details (email address, phone number), marketing and profiling choices, purchases, interactions with OVS through the Site, apps and other OVS properties, data relating to participation in the "OVSfriends" loyalty programme.

Optional / Obligatory processing
You are absolutely free to give consent or not: your decision not to consent to profiling activities will have no consequences.

Data retention
Personal data will be stored for up to 24 months after collection, unless you decide to revoke your consent. In that case, the data will be promptly deleted.

Purpose and legal basis of processing
We may process personal data to: collect, evaluate and manage your candidacy via the ‘Careers’ portal, on the basis of the need to carry out pre-contractual measures at your request (art. 6, par. 1(b) GDPR and Art. 111-bis Privacy Code).

Categories of processed data
We may process personal data (name and surname, gender and age), contact data (email address, phone number), photos, data on previous work experience and any other information you enter in your curriculum, registration data in the 'Careers' area. Please do not enter sensitive data, such as information concerning your health or trade union membership.

Optional / Obligatory processing
In the event that you do not wish to provide the personal data requested, or fail to complete the fields marked as obligatory (*) within the ‘Careers’ portal, we will not be able to consider your application.

Data retention
Personal data will be stored for up to 12 months after collection.

Purpose and legal basis of processing
We may process personal data in order to analyse the requests that you decide to send in order to become an OVS franchisee partner and a franchisee candidate by filling in the ‘Franchising’ section, on the basis of the need to carry out pre-contractual measures at your request (art. 6, par. 1(b) GDPR).

Categories of processed data
We may process your personal data (name and surname, age), contact details (email address, phone number), venue information, and other information that you decide to share with OVS.

Optional / Obligatory processing
In the event that you do not wish to provide the requested personal data, or fail to complete the fields marked as obligatory (*) within the 'Franchising' section, we will not be able to consider your request.

Data retention
Personal data will be kept for the time strictly necessary to answer your request.

Purpose and legal basis of processing
We may process personal data in order to allow the performance of any extraordinary corporate transactions (such as mergers, acquisitions, disposals, transfers of assets or business units, reorganisations, restructurings, due diligence) involving OVS, on the basis of the legitimate interest of OVS in the performance of corporate transactions (art. 6. par. 1(f) GDPR).

Categories of processed data
We may process any information already collected by OVS in the context of the other processing operations described and which may be necessary, in accordance with a criterion of proportionality and data minimisation.

Optional / Obligatory processing
Whether or not processing is optional will vary depending on the purpose of the original collection. You may in any event object to processing, subject to the conditions and in the manner set out below.

Data retention
Personal data will be stored for the duration of the corporate transaction.