1. Our Business Policy

   Everyone is entitled to the protection of the personal data concerning them. ST.APE B.V. respect users’ rights to be informed with regard to data collection and to other operations to process their personal data. In using data that may directly or indirectly identify you personally, we will apply a principle of strict necessity. For this reason, we have designed saint-ape.com in such a way that the use of your personal data will be kept to a minimum and we do not process your personal data when we can provide you with services through the use of anonymous data (such as market research aimed at improving our services) or by other means which allow you to be identified only when it is strictly necessary or upon request by competent public authorities or the police (for example, in the case of traffic data or your IP address).
   
   ST.APE B.V. determine the purposes and means for processing your personal data, including security measures, as ST.APE B.V. control saint-ape.com users' personal data pursuant to General Data Protection Regulation (EU/2016/679, the GDPR)(Privacy Code). This Privacy Policy provides you with all information needed to understand how we collect and use data which identify saint-ape.com's users’ personal data pursuant to General Data Protection Regulation (EU/2016/679, the GDPR) (Privacy Code). This Privacy Policy provides you with all information needed to understand how we collect and use data which identify saint-ape.com's users. For further information on our Privacy Policy, please contact our Customer Service, or send a request to ST.APE B.V. at its registered office indicated above.

2. Who collects your personal data and for what purposes

   ST.APE B.V. control the use of saint-ape.com users' personal data; they determine the purposes and means of processing personal data and the instruments used, including those for security measures. Due to exclusively organisational and operational requirements, we have appointed certain processors that will also process personal data belonging to saint-ape.com's users’ for purposes strictly connected and correlated to the performance of services on saint-ape.com, including the sale of products. These processors have been chosen because of their experience, ability and reliability in processing personal data and they provide sufficient guarantees regarding compliance with current data processing laws (including the data security profile). In processing the personal data of saint-ape.com's users, the processors shall act only on instructions from ST.APE B.V. Co-controllers regularly check that the processors comply with the instructions and that they continue to provide sufficient guarantees regarding their full compliance with the provisions on personal data processing. In order to receive a full list of data processors, you may contact our Customer Service. Your personal data is collected and processed by ST.APE B.V. for purposes which are strictly connected to the use of the web site, its services and to the purchase of products on the web site. However, your personal data may also be used for other processing operations within the limits of such purposes.

   In particular, your personal data may be processed for the following purposes:

   • when you register with our web site we collect your personal data (for example, your personal details, password, e-mail address) through the registration form (My Account) in order to provide you with services in saint-ape.com’s reserved access areas and to e-mail you our newsletter, when specifically requested;
   • when you purchase products on saint-ape.com, we collect your personal data (such as, for example, personal details, e-mail address, mailing address, credit card and bank account information, telephone number) through the order form on saint-ape.com;
   • when you request technical assistance services, we collect your personal data to provide you with information regarding problems with navigation, browser compatibility and visualization or uploading of web pages of saint-ape.com;
   • when you create a Wish List we process your data to save products that you like the most on saint-ape.com;
   • upon your consent, we process your personal data for marketing purposes.

   Your personal data is mainly processed electronically, and in some cases also in paper format, such as when the processing of your data is needed to prevent fraud on saint-ape.com. Your personal data will be kept in the form that allows you to be identified for the time strictly needed for the purposes for which the data was collected and subsequently processed, and, in any event, within the legal limits. In order to guarantee that your personal data is always precise and up-to-date, not to mention pertinent and complete, we ask that you please update it within the My Account section or by contacting our Customer Service.
   
   Your personal data will not be disclosed to third parties for purposes not permitted by law or without your express consent. In addition to companies acting as data processors, your data will also be available to independent third party data controllers for purposes that are related and in addition to the granting of the services requested by the user (for example, for transactions relating to purchases). For details regarding this aspect, see the terms of the paragraph below “To whom we disclose your personal data”. Additionally, your data may be disclosed to the police or to judicial authorities, in accordance with the law and upon formal request from those parties, for example within the context of saint-ape.com’s antifraud services. In all of these cases, your consent is not necessary. Your personal data will not be transferred abroad to countries that are not members of the European Union, which do not provide adequate levels of protection for people. In the event it were to become necessary to provide you with the services or to enter into a contract with ST.APE B.V. to acquire the products, we assure you that the transfer of your personal data to countries that do not belong to the European Union and which do not provide adequate levels of protection, will be performed only upon the signing between ST.APE B.V. and said entities of specific contracts, containing clauses to safeguard the protection of your personal data, in accordance with the law and applicable regulations.
   
   We inform you that ST.APE B.V. process the personal data of their users only for purposes that are strictly connected to the provision of services on saint-ape.com, to the signing of contracts for sale of products. ST.APE B.V., upon consent, process your personal data also for marketing purposes, to send you advertising, promotional and informational material on products and services, as well as for statistical analysis intended to understand the level of satisfaction of the services offered. These activities are carried through traditional channels, as for example paper mail and calls with operator, as well as through digital channels as for example e-mail, SMS, browser and social network. ST.APE B.V. may perform profiling activities regarding your purchasing habits, in order to send offers that are in line with your interests, upon your consent.
   
   The purposes for which your personal data is processed will nevertheless be specifically noted each time in the text of the information that ST.APE B.V. submits to the user on the page requesting the submission of personal data.
   
   ST.APE B.V. may end up processing personal data from third parties that has been directly communicated by their own users to ST.APE B.V., for example if the user has purchased a product to give to a friend, or when the individual paying the price to purchase the product is different from the person for whom the product is intended, or even when the user intends to inform a friend of a service or product for sale on saint-ape.com.
   
   In all of the above cases, please make sure you receive the consent of such individuals before disclosing their personal data to ST.APE B.V. and make sure you inform them about the processing of their data, because you will be the sole person liable in connection with the disclosure of information and data regarding such third parties if they have not provided you with their express consent thereto, as well as solely liable for any improper or unlawful use of that information. In any event, shall fulfil any obligation to inform third parties required by law and, when necessary, shall request their express consent upon registering in its archives the personal information of the user indicated.

3. How we collect your data

   ST.APE B.V. directly collect personal data and other information from their users as part of the online registration processes on saint-ape.com, through pages dedicated to new commercial initiatives of ST.APE B.V. or by product purchase order from users through the web site when they make e-commerce transactions. This data is processed by ST.APE B.V. within the limits and purposes illustrated in the information presented to the user in the specific section on data collection, including therein the potential communication to third party entities for purposes which are essential to the granting of the service requested by the user, as specified in the paragraph “To whom we disclose your personal data”. ST.APE B.V. and Flirt Creativity BV reserve the right to eliminate the accounts of registered users and all of the relative data in the event that content is revealed unlawful, damaging to the image of ST.APE B.V. and/or the products of the latter or third parties’, or which contain content which is offensive or which promotes illegal or defamatory activities, pornographic content, or content which incites violence, promotes racial, sexual or religious discrimination, or discrimination with regard to sexual orientation.

4. What happens if you do not disclose your personal data

   Granting your personal data to ST.APE B.V. and Flirt Creativity BV (in particular, your personal details, your e-mail address, your mailing address and telephone number) is necessary for processing your order for the purchase of products on saint-ape.com. Some of this data might vice versa be essential for the provision of other services rendered on the web site or to perform obligations required by law and other regulations. Therefore, failing to provide some of your data that is required for such purposes to ST.APE B.V. could result in it being impossible to execute the purchase of products on saint-ape.com, or to provide other services that are available on saint-ape.com - such as, for example, providing assistance services (Customer Service), using the Wish List, showing an item to a friend -, or even correctly performing the legal and regulatory obligations. Failure to provide data may thus constitute, depending on the case, a legitimate and justified reason for not executing a purchase of products on saint-ape.com or for not providing services via saint-ape.com.
   
   Disclosure of further personal data to ST.APE B.V. other than that required for fulfilling legal or contractual obligations or for providing the services requested, is, on the contrary, optional and does not have any effect on the use of the web site and of its services or on the purchase of products on saint-ape.com.
   In some circumstances and if required, from time to time we will duly inform you if the personal data you are disclosing to ST.APE B.V. is compulsory or optional. We will point out to you whether the disclosure of your data is compulsory or optional by marking with an appropriate symbol (*) the information that is compulsory or data needed for providing the required services on saint-ape.com. We remind you that failing to provide optional personal data will not imply any obligation or disadvantage to our users.

5. To whom your personal data will be disclosed

   Personal data may be disclosed to third party companies that provide, on behalf of ST.APE B.V., specific services as data processors or to other recipients of personal data collected by ST.APE B.V. - whose names shall be specified each time - that autonomously process your personal data only for the performance of a contract for purchasing products on saint-ape.com (for example, a credit institution, to perform remote e-payment services via a credit/debit card, whenever you decide to purchase a product on saint-ape.com) and only when such purpose does not exceed the purposes for which your personal data was collected and subsequently processed and, in any case, according to applicable laws and regulations.
   Personal data will not be disclosed to third parties or disseminated or transferred without informing our users of such disclosure/dissemination/transfer, without their consent and, in any case, in accordance with the law.

6. Security Measures

   We have adopted security measures to reduce the risks of destruction or loss, including accidental loss of the data itself, of unauthorised access, or processing that was not permitted or that does not comply with the collection purposes indicated in our Privacy Policy.
   Nevertheless, ST.APE B.V. cannot guarantee to their users that the security measures adopted for the protection of the web site and for data and information transmission on saint-ape.com will limit or exclude any risk of unauthorised access or of loss of data. It is advisable that your computer be provided with software devices that protect network data transmission/receipt (such as updated antivirus systems) and that your Internet service provider take appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering).
   On saint-ape.com each purchase is made with the maximum security thanks to the use of the most advanced technological and coding systems (SSL).

7. Your right to access data and other rights

   You always have the right to obtain from ST.APE B.V. a confirmation of whether or not personal data concerning you exists, even if it has not yet been recorded, and to have such data communicated to you in an intelligible way. You also have the right to obtain information from ST.APE B.V. regarding the source of your personal data; the purpose and method of processing your personal data; the logic applied for processing completed with the assistance of electronic instruments; the identification information of the owner and supervisors of the processing; the indication of individuals or classes of individuals to whom personal data may be communicated or who could become aware of it, such as, for example, supervisors or staff involved in processing. Part of this information is contained in our Privacy Policy; to find out more, you may contact our Customer Service. You always have the right to obtain from ST.APE B.V.:

   • a. the updating, correction or, when you have an interest in such, the integration of your personal data;
   • b. deletion, transformation into an anonymous form or blocking of your personal data which has been unlawfully processed, including data which does not need to be stored for the purposes for which it was collected or subsequently processed;
   • c. the confirmation that the operations under letters a) and b) have been reported (together with the contents of the same) to whom the data was disclosed or disseminated, except when it becomes impossible or if the means used are clearly disproportionate to the right’s protection.

   You are nevertheless entitled to object, in whole or in part:

   • for legitimate reasons, to the processing of your personal data, even if it is related to the purposes for which it was collected;
   • to the processing of your personal data for advertising or direct marketing purposes or in order to carry out marketing research or commercial communications.
     You may freely exercise your rights at any time, provided that you do so in compliance with applicable laws, by sending your request to ST.APE B.V. by contacting our Customer Service, to which we shall respond in a timely manner.
8. Opt-in/Opt out

   ST.APE B.V. also use your personal data to send advertising or direct marketing material or other commercial communications, including via e-mail: if the advertising concerns products that are analogous to those already purchased, ST.APE B.V. may send it to your e-mail address even without your express consent, provided that you have not denied such use upon giving your e-mail address or on subsequent occasions (Art. 130, Subsection 4, lgs. d. No 196/2003), although your express, voluntary consent will be needed to make a mailing by ST.APE B.V. of advertising e-mails relating to products other than those already purchased lawful. Likewise, ST.APE B.V. may process your data even without your consent to provide you with services you have voluntarily requested (such as, for example, sending the Newsletter). Each time your consent is needed, we will inform you in advance and will give you the possibility of providing or denying your consent to use your personal data for these purposes, including your e-mail address.
   
   We would like to inform you that ST.APE B.V. may process your personal data, even without your consent, in certain cases that have been prescribed by law such as, for example, when this is necessary to satisfy a legal obligation or when this is necessary to execute obligations that have been contractually assumed with regard to users (such as, for example, if you have purchased products on saint-ape.com or you have asked to benefit from specific services through our web site). In any case, we wish to inform you that ST.APE B.V. guarantee to their users may exercise, at any time and without needing to set forth reasons, their own right not to receive future communications related to the use of particular services, upon request. In particular, you may exercise your right to oppose this (i) by using the method indicated in each communication received or (ii) by managing your permissions in the dedicated My Account area or even by (iii) writing to Customer Service and selecting "Privacy" or by sending a request to ST.APE B.V. at the address of the aforementioned registered office. Specifically, a request to unsubscribe that is made following the instructions of the communication received will result in you being unsubscribed solely from the aforementioned channel. Unsubscribing from marketing through My Account will result in your being unsubscribed from all channels used (traditional and digital). Additionally, we ask that you consider the technical time frames needed to effectively address your request to unsubscribe (a maximum of 15 days).

9. Links to other websites

   saint-ape.com contains links to other websites which may have no connection to saint-ape.com, ST.APE B.V. or their content. ST.APE B.V. do not control or monitor such websites or their web content. ST.APE B.V. do not control or monitor such websites or their web content. ST.APE B.V. shall not be held liable for the web content of such sites and for the rules adopted by them in terms of your privacy and the processing of your personal data while you are visiting those websites. Please pay attention when you connect to these websites through the links provided on our website and read their terms and conditions of use and their privacy policy carefully. saint-ape.com's Privacy Policy does not apply to third party websites. ST.APE B.V. isn’t in any way liable for the privacy policy applied by said websites.
   
   saint-ape.com provides links to these web sites exclusively to help its users in their searches and net-surfing activities and to allow links to other websites on the Internet. When ST.APE B.V. provide links to other websites, ST.APE B.V. does not recommend the use of these websites and do not provide any guarantees regarding their web content or the services and products supplied and sold by these websites to Internet users.

10. Contacts

    If you wish to receive further information on how ST.APE B.V. process your personal data, please contact our Customer Service.

11. Governing Law

    This Privacy Policy is governed by Dutch law and, in particular, by the Dutch Personal Data Protection Code (lgs. d. No. 196 of 30 June 2003) which governs the processing of personal data - also held overseas - carried out by anyone who is domiciled or has registered offices in Italy. The Dutch Personal Data Protection Code guarantees that processing of personal data will be carried out in compliance with fundamental rights and freedom of individuals, as well as of their dignity, with particular reference to confidentiality, identity and to the right to personal data protection.

12. Amendment and Updating of saint-ape.com Privacy Policy

    ST.APE B.V. may amend or simply update all or part of saint-ape.com's Privacy Policy, including when amendments are made to legal provisions or regulations which govern data protection and protect your rights. The amendments and the updating of saint-ape.com Privacy Policy shall be notified to our users as soon as such amendments or updates have been introduced and shall be binding as soon as they are published on the web site in this section. Therefore, you are asked to regularly access this section in order to check the publication of the most recent and updated Privacy Policy of saint-ape.com.

cookies we collect

The table below lists the cookies we collect and what information they store.

Last update in January 2018.