This Privacy Policy provides information about personal data processing – how Apranga group companies (hereinafter – we) collect, process and store your personal data. We understand the importance of personal data processing, therefore, we respect the privacy of our customers and other data subjects (hereinafter – data subjects) and protect personal data.

The detailed list of Apranga group companies is provided there: https://aprangagroup.lt/en/investors/corporate-governance/structure-of-the-group .

1. Categories of personal data, purposes and legal grounds of processing
1.1. Conclusion and performance of contracts with customers and business partners, compliance with accounting requirements, pre-contractual performance

Legal basis for data processing

Categories of personal data

Performance of contracts, compliance with legislation

Conclusion and performance of contracts with customers and business partners (natural persons and legal entities), pre-contractual performance (all or some of the following personal data categories may be processed): name, surname, position, e-mail and/or telephone number, date of birth and personal ID of the customer or business partner, employee or representative of the customer or business partner. For the purpose of conclusion and performance of contracts with natural persons, the following additional personal data may be processed: address, customer's dimensions necessary to produce a custom-made garment, information about the custom-made garment.

The categories of the customer's personal data processed in a specific case depend on the nature of the contract that is made and performed. In any case, personal data shall be processed to the extent necessary to perform the contract or properly comply with legislation.

Compliance with accounting requirements: The personal data processed for invoicing – name, surname, address and other data, if wished by the customer. For the purpose of administration of incoming invoices, the personal data to be provided under the requirements set out in legislation shall be processed.


1.2. Direct marketing and participation in loyalty programmes

Legal basis for data processing

Categories of personal data

Consent

Name, surname, date of birth, address, city, telephone number, e-mail address, details of the social network account, trademark of interest to the customer. We need to process your name, surname and contact details to identify the person who is contacting us when additional information is needed, if the loyalty card is lost or in other similar situations. Data about the date of birth and address shall be processed only when the person agrees to provide them, also when information is provided by customers who participate in loyalty programs of Prestige or VIP, City and Karen Millen.

Information shall also be processed in relation to the goods purchased by customers when the information of direct marketing content is communicated to the participants of a loyalty programme or when a person gives consent to receive information about offers related to the discounts, promotions, sales, new collections and events for participants of loyalty programmes.


1.3. Transfer of personal data to franchise partners

Where you agree, your personal data shall be transferred to the franchise partners that hold the trademarks Max Mara, Marella, Marina Rinaldi, Pennyblack and Weekend Max Mara (Max Mara s.r.l., Marella S.r.l., MANIFATTURE DEL NORD s.r.l., MARINA RINALDI s.r.l. or other companies of Max Mara Fashion Group) so that they could improve the quality of your servicing. On the basis of your consent, your e-mail address may be transferred to the franchise partner that holds the trademark MANGO (PUNTO FA, S.L.) in order to communicate information about the offers of MANGO stores in relation discounts, promotions, and sales.

1.4. Processing of the personal data of the Company's shareholders, beneficial owners, management bodies and their members for internal administration and legal compliance purposes

Legal basis for data processing

Categories of personal data

Compliance with legislation

Name, surname, personal ID number, date of birth, residence address, information about the securities held and other personal data to be processed under legislation

Compliance with legal obligations shall include in this case:

  • legal obligations related to the registration and processing of the data of the Company's shareholders, accounting of shares, compliance with tax and other obligations applicable to them;
  • legal obligations related to the formation of the Company's management bodies, arrangement of their activities, submission and registration of the data of the Company's management bodies and their members to/in public registers, compliance with other legal requirements.

1.5. Organization of games or competitions, announcement of winners and administration of prizes

Legal basis for data processing

Categories of personal data

Consent, performance of contracts

Name, surname, name of account in social network, phone number, e-mail address, date and number of purchasing receipt, other (photo, etc.).

In case of winning: name, surname, personal code or passport number, or ID card number, prize or other gift value.

Depending on the conditions of the game or contest, all or some of the above personal data may be processed.


1.6. Electronic commerce

Legal basis for data processing

Categories of personal data

Performance of contracts

Name, surname, e-mail address, mobile phone number, method of payment, data of the payment card holder, payment card number, validity date of the payment card, delivery address, goods bought, their price, purchasing date and time, access data provided when registering the account in the electronic store, operations in the account, including technical data of browsing (IP address, technical information of log-in and browsing), shopping cart data, data of the identity document if the goods ordered are collected at the store.


1.7. Video surveillance in order to protect the property

Legal basis for data processing

Categories of personal data

Legitimate interest to protect property

Video recordings when customers are within the scope of video cameras.


1.8. Dealing with requests to return goods

Legal basis for data processing

Categories of personal data

Compliance with legislation

Name, surname, contact details (telephone number or e-mail address), data about the goods returned, reason for returning the goods, bank account number. Contact details and bank account data shall be processed only when required and necessary. When poor quality goods are returned, it shall be requested to provide data about the customer's name, surname, contact details (telephone number, e-mail or postal address), requests concerning the goods (replace, repair the defect, take back and refund the money). Taking into account the legal requirements applicable in a specific situation, it may be requested to provide only part of the above-referred data rather than all. Other data related to the request (data of the purchasing receipt, other information) may also be provided in the request or together with it.


1.9. Dealing with other requests, inquiries and complaints

Legal basis for data processing

Categories of personal data

Performance of contracts, compliance with legislation

Name, surname, contact details (telephone number or e-mail address), content of the inquiry, request or complaint (event, its circumstances, customer's request, claim or feedback, loyalty card number, other information).

Other data provided together with the inquiry, request or complaint (data of the purchasing receipt, other information).


1.10. Selection to employment and assessment of candidates

Legal basis for data processing

Categories of personal data

Consent

General personal data of candidates to employees: name, surname, date of birth, data about the place of residence, e-mail address, telephone number, information about working experience (place of employment, period of employment, position, responsibilities, achievements), information about education (education institution, period of studies, acquired education, qualification), information about professional development (completed training, certificates obtained), information about the languages the candidate knows and their proficiency level, IT, driving skills, other competencies, other information that the candidate to employees provides in his/her CV, letter of motivation (if any) or other documents of the candidate to employees.

Wishes of candidates to employees: position of interest, desirable working schedule, desirable working time per day or week, other information provided by the candidate in the section “Comments”.

Feedback by employers about the candidate to employees, letters of reference: the person who gives feedback or letter of reference, his/her contact details, content of the feedback or letter of reference.

Information of assessment of the candidate to employees: summary of the interview with the candidate to employees, opinions and observations by the person who carries out the selection, results of the tests undertaken by the candidate (if any).

Personal data of special categories shall be collected only in case and only to the extent necessary for the selection to a specific employment position and only as much as allowed under effective legislation.


1.11. Administration of the data base of candidates to employees and submission of job offers

We get personal data of candidates to employees from the candidate himself/herself or from employment agencies, online job search portals and/or other entities that provide job search, selection and/or intermediation services.

Legal basis for data processing

Categories of personal data

Consent

General personal data of candidates to employees: name, surname, date of birth, data about the place of residence, e-mail address, telephone number, information about working experience (place of employment, period of employment, position, responsibilities, achievements), information about education (education institution, period of studies, acquired education, qualification), information about professional development (completed training, certificates obtained), information about the languages the candidate knows and their proficiency level, IT, driving skills, other competencies, other information that the candidate to employees provides in his/her CV, letter of motivation (if any) or other documents of the candidate to employees.

Wishes of candidates to employees: position of interest, desirable working schedule, desirable working time per day or week, other information provided by the candidate in the section “Comments”.

Feedback by employers about the candidate to employees, letters of reference: the person who gives feedback or letter of reference, his/her contact details, content of the feedback or letter of reference.

Information of assessment of the candidate to employees: summary of the interview with the candidate to employees, opinions and observations by the person who carries out the selection, results of the tests undertaken by the candidate (if any).

Personal data of special categories shall be collected only in case and only to the extent necessary for the selection to a specific employment position and only as much as allowed under effective legislation.


2. Where do we get personal data from and in which cases we transfer your personal data?

In many cases, personal data are provided directly by the data subject himself/herself. In certain cases, we get personal data from third persons – employment agencies, online job search portals and/or other entities that provide job search, selection and/or intermediation services.

Your personal data may be provided to state and municipal authorities and other persons carrying out statutory functions, if such obligation is provided for in legislation. We transfer your personal data at their request or in order to pursue our legitimate interest to establish, exercise or defend legal claims.

The transfer of personal data to franchise partners, for the purpose of direct marketing and participation in loyalty programmes

Based on your consent, when necessary to provide you with information about discounts, promotions, sales and new collections, ensure you the opportunity to participate in our loyalty programmes, your personal data may also be transferred to the following third persons:

  • companies belonging to APRANGA Group when they are responsible for the performance of certain functions necessary to provide offers to you;
  • companies providing advertising, media planning, public relations and event organising services;
  • companies providing SMS sending services;
  • companies providing IT maintenance and support services.

On the basis of your consent, your personal data may also be provided to our partners – Companies of Max Mara Fashion Group and PUNTO FA, S.L. More information about the transfer of personal data to our partners is available in p. 1.3 “Transfer of personal data to franchise partners”.

Transfer of personal data for the purpose of selection to employment and assessment of candidates, administration of the data base of candidates to employees and submission of job offers

Personal data may be transferred to third persons who help us carry out the selection of candidates or provide us with selection, candidate assessment and internal administration services (e.g., providers of personnel selection and assessment services, suppliers of data base software, providers of data base administration services, providers of data centre, hosting and clouding services, etc.). We may also transfer the personal data of candidates to employees to other companies belonging to Apranga Group, if they are involved in the procedure of assessment of the employees in managerial positions. Where personal data are processed by us for the purpose of administration of the data base of candidates and for the submission of job offers, we may transfer the personal data of any candidate to employees to other companies belonging to Apranga Group, if a particular candidate can be suitable for being employed in a position in these companies. In such a case, personal data shall be provided only to the extent necessary for a particular task or a particular service.


3. What are the rights of the data subject and how to exercise them?

You have the right to access your personal data and know how they are processed, request their rectification, supplementing or destruction, as well as stop their processing operations (revoke your consent). You also have the right to request the personal data processor to restrict the processing of personal data, the right to data portability, file a complaint to the supervisory authority and object to the processing of the personal data provided.

The list of supervisory authorities that are relevant to the scope of this Privacy Policy:
The State Data Protection Inspectorate in Lithuania: https://vdai.lrv.lt
The Data State Inspectorate in Latvia: https://www.dvi.gov.lv
The Estonian Data Protection Inspectorate in Estonia: https://www.aki.ee

Information about the exercise of these rights is provided by e-mail addresses: dataprotection@apranga.lt, dataprotection@apranga.lv and dataprotection@apranga.ee.


4. How long do we store personal data?

We store personal data not longer than required for data processing purposes or by legislation, in case they provide for a longer storage period. Personal data may be stored longer where that is provided for in legislation or where necessary for the defence by the Company against the asserted claims or legal actions, also when personal data are necessary for an investigation or as an item of proof in civil, administrative or criminal proceedings.


5. Amendment to the provisions of the Privacy Policy

We reserve the right to amend the provisions of this Privacy Policy. Notices about any amendments or supplements to this Privacy Policy shall be published on the website www.aprangagroup.lt.


This version of the Privacy Policy was updated on 23 July 2019.

STATISTICAL DATA ABOUT BROWSING ON THE WEBSITE

We are improving our website on a regular basis to make it most convenient to use. To be able to improve the website, we have to know which information interests our website visitors most, from which countries and cities our website is visited, visitors' returning frequency, browsers used, devices on which our website is read, etc. This information is collected by using Google Analytics tools which enable recording and analysing statistical data of the website use. More information about Google Analytics and information which can be collected by using these tool is available here: https://support.google.com/analytics/answer/6004245?hl=lt.
If you do not wish Google Analytics tools to record information about your browsing online, you can select Google Analytics op-out browser add-on.

WHAT ARE COOKIES?

Cookies are small text files that a website places on your device when you visit a website. Cookies do not contain any personal information and are sent from your visited website server to your computer or mobile phone.

WHAT TYPES OF COOKIES ARE USED IN OUR WEBSITE?

We use the essential cookies (ensuring the functioning of the website or facilitating the use of the website, etc.), such as filtering settings or log-in remembrance, functional cookies and analytics cookies (Google Analytics cookies). Google cookies are used to collect statistical information about your browsing on the website, as described above. We also may use third-party cookies, when you contact us by e-mail, as well as when advertisement is used in our website or when you visit our website. Analytical cookies can be used for identifying and counting the number of visitors and to see how visitors move around the website during its usage. This information helps us to improve the functioning of the website. The information received by cookies about your use of this website is stored by Google. Google can hand over the information collected by Google Analytics to third parties as required by the law, or where these third parties process information on behalf of Google.

HOW DO WE USE COOKIES ON OUR WEBSITE?

We use cookies on our website to improve your browsing and experience on our website, to learn about the behaviour of our website users, to analyse flows, to improve the website. Cookies are not kept longer than necessary.

WHAT CAN YOU DO TO MANAGE COOKIES STORED ON YOUR COMPUTER?

If you wish, you can configure your browser's cookie settings. To learn more about cookies, e.g. how to manage them, click www.allaboutcookies.org.

DATA PROTECTION

We confirm that your personal data is managed in accordance with the requirements of the laws of the European Union and the Republic of Lithuania. For further information about your rights, please contact us at dataprotection@apranga.lt by sending an enquiry along with properly completed Data subject’s enquiry form, which you can find here, or you can download, complete and deliver it to our office, which is at Vasario 16-osios str. 2, Vilnius, 8 - 17 (I-IV), 8 - 15.30 (V).

AMENDMENTS OF THE COOKIES POLICY

We reserve the right to amend Cookies policy. Notice about any amendments or supplements to Cookies policy and the latest version of Cookies policy will be published on our website.

Legal basis for data processing

Legitimate interest to protect property

Categories of personal data

Video recordings when customers are within the scope of video cameras.

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