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PRIVACY POLICY

1. Introduction

This privacy policy (“Privacy Policy”) applies to the website http://www.reef.eu (the “Website”) and refers to the personal data processing activities performed by VF International Sagl – REEF Division (“REEF”), who owns and operates the Website. For more information regarding structure, functioning and purposes of the Website, please also review the Website's Terms and Conditions of Use. User’s personal data will be processed by REEF when user visits the Website and interacts with the services and functionalities offered by the Website. The Privacy Policy has been drafted in accordance with the Recommendation n. 2/2001, adopted on May 17, 2001 by Article 29 Data Protection Working Party in relation to the minimum requirements for the collection of data on-line within the European Union and also represents information statement to the data subjects according to Swiss law and to the European Union privacy law principles (the “Privacy Law”), with which the processing carried out by REEF complies. The Privacy Policy specifies the identity of the data Controller that controls and manages the personal data collected and processed through the Website, specifies what is the personal information collected, the data processing purposes and conditions, the extent of personal data communication to third parties, the data security measures adopted in order to protect and safeguard data and the ways in which the user may verify the processing of data relating to the user and enforce the user’s rights as acknowledged under the Privacy Law.

2. The Data Controller

The Controller of the personal data processing is: VF INTERNATIONAL S.A.G.L. – REEF DIVISION, Via Laveggio 5, 6855 – Stabio, Switzerland, Contact Us.

The updated list of Processors, if any, and addresses of data communications is at your disposal at REEF. Other affiliated to REEF, for example companies of the VF group, may be involved in the processing relating to the activities that may be performed on the Website (for example for accounting activities in case of purchase of products, for personnel selection activities) as specified in the Privacy Policy; they will act according to applicable privacy laws for the purposes herein specified.

3. What kind of data are processed; what are the purposes of the data processing

In general, the visit and consultation of the Website does not imply collection and processing of user’s personal data. The processing of user’s personal data who visits and consults the Website is limited to the so-named surfing data, namely the data whose transmission to the Website is implicit in the functioning of the information systems in charge of the managing of the Website and in the use of communications protocols peculiar to the Internet. Surfing data are, for example, the IP addresses or the domain names of the computers employed by the user who connects to the Website and other parameters relating to the type and the information operating system employed by the user. Surfing data, such as these above specified and for example the number of visits, the time spent on the Website are collected and processed by REEF exclusively for statistical purposes and in anonymous form in relation to the access and use of the Website for purposes of monitoring the correct functioning of the Website and enhancing the Website functioning and content. Due to the nature itself of surfing data, these data may lead to identification of users if they are associated with data held by third parties; however, REEF does not collect surfing data in order to associate them with identified users. Surfing data are deleted after the processing in anonymous form; said data may be used for purposes of assessing possible responsibilities in case of information crimes realized against the Website or through the Website. With the exception of the aforementioned circumstance, REEF keeps the user’s surfing data only for the maximum period of time allowed under applicable laws and then makes said data anonymous.

Furthermore, REEF collects and processes personal data voluntarily provided by user when user interacts with the Website functionalities and requests the services offered by the Website, for example upon user opening of an account, upload of user-generated content on the Website, or subscription to REEF newsletter, user participation to promotions and other initiatives realized or communicated through the Website such as for example contests and sweepstakes, user request of information to REEF or user sending to REEF a question, communication or feedback through traditional mail or through the Website. We will process user’s personal data also to comply with the Privacy Law and to assess and defend a legal right.

With the user’s consent, that is optional, REEF may further process user’s personal data for survey purposes; for marketing purposes, that is for sending to user, also through e-mail or other electronic communications means such as SMS, MMS, fax, etc., promotional information and material on products and services of REEF or other companies of the VF group (to which REEF also belongs), on special initiatives on prices and promotions of the VF group and on initiatives such as events, exhibitions and fairs organized by the VF group or to which the VF group takes part; and for profiling purposes. For the marketing and profiling activities above defined user’s personal data may also be shared with other companies of the VF group. User will always have the opportunity to object, at any time and for free, to the processing of his/her personal data for the sending of promotional information and material; in each communication there will be a specific section in which are specified the conditions (easy to perform and free of charge) of revoking the consent. Personal data that REEF collects and processes include name, and contact details such as street address, telephone number, e-mail address and further possible information of an optional nature provided by user. In the relevant sections of the Website where data are collected it may be published a specific information statement, where opportune or required by Privacy Law. When requested under the Privacy Law, REEF requires the user’s consent before proceeding to processing his/her personal data. Where you have provided us with personal data about another person, (for example when using the function e-mail to a friend, gift card functionalities or other purposes) to the extent permitted by applicable laws you hereby confirm that said communication and further processing by us as set out in this Privacy Policy complies with applicable privacy laws, so for example you should inform said person and as requested obtain his/her consent to the processing of his/her personal data for the purposes set out in this Privacy Policy.

4. Place where the data are stored

Personal data collected through the Website will be processed by REEF; the company Rackspace Limited (registered in England & Wales with No. 03897010, registered offices at 5 Millington Road, Hyde Park Hayes, Middlesex, UB3 4AZ) provides for REEF hosting services for the web site and related database. The updated list of Processors and addresses of data communications is at your disposal at REEF. Personal data are processed only through specifically authorized staff designated to access and process the data, including staff designated for performance of non-routine maintenance operations of the Website. Furthermore, other companies of the VF group may be involved in the processing of personal data in relation to the functioning of the Website and performance of the services and functionalities offered through the Website, for example for marketing and profiling activities as above specified. User is invited to check the section of this Privacy Policy relating to Extent of personal data communication. All processors, if any, shall act on behalf and under the instructions of REEF.

5. Cookies

The Website uses cookies, which are small data files which may be uploaded on the hard disk of the users’ computer for a variety of possible purposes. For further information on cookies and on how to modify your preferences or disable them, please see our Cookie Policy.

6. Conditions and features of the personal data processing

Personal data collected by REEF are mainly processed through electronic and automated means but also without the same (paper processing), under procedures and logics that comply with the data processing purposes as herein specified. Personal data of user are processed according to applicable privacy laws, including security and confidentiality issues, and are kept only for the time strictly functional to achieve the specific data processing purpose from time to time pursued and according to applicable laws.

7. Security and quality of personal data

REEF is committed to protect security of the user’s personal data. Personal data are processed by REEF in compliance with the security provisions as set forth by applicable laws in order to prevent loss and destruction, even accidental, of data, unauthorized access to data, unlawful or unfair use of data. Moreover, information systems and software programs are configured so that personal and identification data are used only when necessary to achieve the specific processing purpose from time to time sought.

REEF deploys a variety of advanced security technologies and procedures to help protection of user’s personal data against the risks above outlined. For example, personal data provided by user are stored on secured servers placed in controlled locations. Moreover, for the transmission of some data through the Internet are deployed encryption techniques such as the Secure Socket Layer (SSL) protocol. Users may help REEF to update and maintain accuracy of the personal data provided by user to REEF by notifying REEF of any amendment relating to user’s address, title, telephone number or electronic mail (e-mail) address. Registered user may perform the foregoing on-line following the instructions reported on relevant user’s profile pages of the Website.

8. Extent of personal data communication

REEF communicates user’s personal data within the limits and under the circumstances specified in this Privacy Policy and in any specific information statement published on the Website in the sections where data are collected, in any case in full compliance with the consent given by the user upon collection of data, when required by the Privacy Law. User personal data will be accessible within REEF organization by the internal and external personnel that need to access them because of their duties in relation to the processing purposes herein specified, and by any appointed Processor. The updated list of Processors and of the subjects to which data may be communicated will remain at user disposal free of charge upon request at REEF.

User personal data may be communicated to institutions, authorities, public entities, banks and financial institutions, professionals, independent consultants, also in associate form, business partners and third party service providers to which REEF may revert to for performance of professional, technical and organizational services functional to the managing of the Website and the activities therein performed, the managing of functionalities offered by the Website and of the initiatives and services that user may subscribe to and require through the Website, and for services strictly functional to achievement of the other processing purposes herein specified. For purposes functional to the managing of the Website and related activities, user’s personal data may be also communicated to other companies of the VF group within the European Economic Area, that will process them according to applicable privacy laws for the purposes above specified, including marketing and profiling activities.

The third parties receiving user’s personal data as above specified will process data as Data Controllers (VF entities) or Processors (other third party services providers), as the case may be, according to applicable data protection laws and for the same purposes above specified. Personal data may also be communicated to third parties in case of mergers, acquisitions, transfer of any of our assets, products, websites or operations. These third parties will be provided only with the information necessary to performance of their respective functions; they agree to use the information received only for the processing purposes above specified, to keep it confidential and secure and to comply with applicable law and the instructions received by REEF. The third parties receiving your personal data are established within the European Economic Area and will process them under applicable privacy laws for the purposes above specified.

Except for the foregoing, user’s personal data will not be shared with third parties, natural persons or legal entities, that are unrelated to, or that do not perform a business, professional or technical function for REEF. User’s personal data may further be communicated to whoever is the legitimate addressee of communications as provided by applicable laws and regulations, thus for example in case of judicial processes, request by competent courts and authorities or other legal obligation, to protect and defend the rights and property of REEF and the Website. User’s personal data will not be communicated to third parties for their own marketing purposes and will under no circumstance be spread.

9. Providing of personal data

Except for the foregoing description in relation to the surfing data (please refer to the above section “The nature and kind of data processed”), providing of personal data by user is necessary for performance of the services and functionalities offered by the Website and required by user, such as the user subscription to the Website, to newsletters or mailing lists, the managing of the user's upload of picture and related activities, the managing of user participation to promotions and other initiatives communicated through the Website such as for example contests and sweepstakes, replying to and managing of user’s request of information, questions, communication or feedback to REEF, or other information sent by the user. Providing of user’s personal data for the activities necessary to comply with applicable legislation is mandatory. In the above referenced circumstances, denial of providing personal data by user would make it impossible for REEF to comply with contractual obligations or to provide user with the requested services, products or information as above specified.

Providing of data by user for the survey purposes, the marketing purposes, and the profiling purposes as above specified is optional; denial of providing personal data by user in said circumstances will have no consequences on compliance by REEF with its contractual obligations and on the providing user with the services, products or information requested as above specified.

10. User’s privacy rights

User is entitled at any moment to enforce the rights as provided by applicable privacy law, including but not limited to the right to obtain at any moment confirmation that user’s personal data exist or do not exist, verify their content, origin and accuracy, ask for their integration, updating, amendment, deletion, , and user may oppose for legitimate reason the data processing (including objecting, at any time and for free, to the processing of his personal data for direct marketing purposes).

For any query or request relating to the personal data processing by REEF and to enforce the rights under the Privacy Law, user may contact VF INTERNATIONAL S.A.G.L. – REEF DIVISION, Via Laveggio 5, 6855 – Stabio, Switzerland,, acting as data Controller, telephone number +41 91 649 1000, or by sending an e-mail through the proper form provided at the following link: contact us.

This Privacy Policy is subject to updating and amendment by REEF. The version published on the Website is the version actually in force. If REEF changes this Privacy Policy, REEF will notify user of such changes by posting a link on the home page of the Website to the amended privacy policy that reads “Newly Revised Privacy Policy”. REEF invites user to periodically review the Privacy Policy in order to be informed of any relevant change.

The Effective Date of this Privacy Policy is: June 01 2016.