Privacy Policy

**I – INFORMATION REGARDING THE WEBSITE’S PRIVACY POLICY**

 

1. This section contains information regarding the management methods of Vemlifestyle ltd. with reference to the processing of user data by Vemlifestyle ltd.
2. This notice also applies for the purposes of Article 13 of Legislative Decree no. 196/2003, the Code on the protection of personal data, and for the purposes of Article 13 of EU Regulation no. 2016/679, relating to the protection of natural persons with regard to the processing of personal data and the free movement of such data, for those who interact with Vemlifestyle ltd and is accessible at the address corresponding to the homepage www.vemlifestyle.com
3. This information is provided only for Vemlifestyle ltd and not for other websites that may be consulted by the user through links contained within.
4. The purpose of this document is to provide guidance regarding the methods, timing, and nature of the information that data controllers must provide users when they connect to the web pages of Vemlifestyle ltd, regardless of the purposes of the connection itself, in accordance with Italian and European legislation.
5. This policy may be subject to changes due to the introduction of new regulations; users are therefore encouraged to periodically check this page.
6. If the user is under 16 years of age, according to Article 8, Paragraph 1 of EU Regulation 2016/679, they must legitimize their consent through the authorization of their parents or legal guardians.

 

**II – DATA PROCESSING**

 

**1 – Data Controller**

1. The data controller is the natural or legal person, public authority, service, or other body that, individually or together with others, determines the purposes and means of the processing of personal data. The data controller also deals with security profiles.
2. Regarding this website, the data controller is: George Lion and for any clarification or to exercise user rights, they can be contacted at the following email address: vemlifestyle@vemlifestyle.com

**2 – Data Processor**

1. The data processor is the natural or legal person, public authority, service, or other body that processes personal data on behalf of the data controller.
2. In accordance with Article 28 of EU Regulation no. 2016/679, upon appointment of the data controller, the data processor for the Vemlifestyle ltd website is: George Lion

 

**3 – Data Processing Location**

1. The data processing generated by the use of Vemlifestyle ltd takes place at 2ND Floor College House
   17 King Edwards Road
   Ruislip, London, HA4 7AE.
2. If necessary, data related to the newsletter service can be processed by the data processor or persons appointed by them for this purpose at their respective offices.

 

**III – COOKIES**

 

**1 – Types of Cookies**

1. The Vemlifestyle ltd website uses cookies to make the user’s browsing experience easier and more intuitive: cookies are small text strings used to store some information that may relate to the user, their preferences, or the device used to access the Internet (computer, tablet, or mobile phone) and are

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The Vemlifestyle ltd website uses cookies to make the user’s browsing experience easier and more intuitive. Cookies are small text strings used to store certain information that may relate to the user, their preferences, or their Internet access device (computer, tablet, or mobile) and are mainly used to adapt the site’s operation to the user’s expectations, offering a more personalized browsing experience and remembering previous choices.

 

A cookie consists of a small set of data transferred to the user’s browser by a web server, which can only be read by the server that made the transfer. It is not executable code and does not transmit viruses.

 

Cookies do not record any personal information, and any identifiable data will not be stored. If desired, it is possible to prevent the storage of some or all cookies. However, in this case, the use of the site and the services offered may be compromised. To proceed without changing the cookie settings, simply continue browsing.

 

Below are the types of cookies used by the site:

 

### 2 – Technical Cookies

1. There are numerous technologies used to store information on the user’s computer, which are then collected by websites. Among these, the most well-known and used is HTML cookies. These are used for navigation and to facilitate the user’s access to and use of the site. They are necessary for the transmission of communications over an electronic network or for the provider to deliver the service requested by the customer.

   

2. Settings for managing or disabling cookies may vary depending on the Internet browser used. In any case, the user can manage or request the general deactivation or deletion of cookies by changing the settings of their Internet browser. This deactivation may slow down or prevent access to certain parts of the site.

 

3. The use of technical cookies allows for safe and efficient site usage.

 

4. Cookies inserted in the browser and retransmitted by Google Analytics or through blogger statistics services or similar are considered technical only if used for site optimization directly by the site owner, who can collect aggregated information on the number of users and how they visit the site. Under these conditions, the same rules apply to analytics cookies, in terms of information and consent, as for technical cookies.

 

5. From a duration perspective, temporary session cookies can be distinguished, which are automatically deleted at the end of the browsing session and are used to identify the user, thus avoiding login on each visited page, and permanent ones, which remain active on the computer until expiration or deletion by the user.

 

6. Session cookies may be installed to allow access and stay in the reserved area of the portal as an authenticated user.

 

7. These are not stored persistently but only for the duration of the navigation until the browser is closed and disappear when it is closed. Their use is strictly limited to the transmission of session identifiers consisting of random numbers generated by the server necessary to allow safe and efficient site exploration.

 

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**Third-Party Cookies**

1. Based on their origin, cookies can be classified as those sent directly to the browser by the site being visited and third-party cookies sent to the computer by other sites, not the one currently being visited.
2. Persistent cookies are often third-party cookies.
3. Most third-party cookies are tracking cookies used to monitor online behaviour, understand interests, and tailor advertising proposals to users.
4. Third-party analytical cookies may be installed. These are sent from the domains of these third parties external to the site.
5. Third-party analytical cookies are used to gather information about user behaviour on [COMPANY NAME]. This data is collected anonymously to monitor site performance and improve usability. Third-party profiling cookies are used to create user profiles, in order to send advertising messages aligned with the users’ preferences.
6. The use of these cookies is governed by the rules established by these third parties, so users are encouraged to review the privacy policies and instructions for managing or disabling cookies on their respective web pages.

 

**Processed Data**

 

**1 – Data Processing Methods**

1. Like all websites, this site uses log files in which information collected in an automated manner during user visits is stored. The information collected may include the following:

   – Internet protocol (IP) address;

   – Type of browser and parameters of the device used to connect to the site;

   – Name of the Internet Service Provider (ISP);

   – Date and time of visit;

   – Web page of origin (referral) and exit;

   – Possibly the number of clicks.

2. The aforementioned information is processed automatically and collected in an exclusively aggregated form to verify the proper functioning of the site and for security purposes. This information will be processed based on the legitimate interests of the owner.
3. For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may also include personal data such as the IP address, which could be used, in accordance with the laws in force, to block attempts to damage the site itself or to harm other users, or otherwise harmful activities or those constituting a crime. Such data is never used for user identification or profiling, but solely for the protection of the site and its users. This information will be processed based on the legitimate interests of the owner.
4. If the site allows for the submission of comments, or in the case of specific services requested by the user, including the possibility of sending a Curriculum Vitae for potential employment, the site automatically detects and records certain user identification data, including the email address. This data is considered voluntarily provided by the user at the time of the request for service provision. By submitting a comment or other information, the user expressly accepts the privacy policy, and specifically consents that the content provided may be freely disclosed to third parties. The data received will be used solely for the provision of the requested service and only for the time necessary to provide the service.
5. Information that users of the site choose to make public through the services and tools made available to them is provided by the user knowingly and voluntarily, exempting this site from any liability for any violations of the law. It is the user’s responsibility to verify they have permission to provide personal data of third parties or content protected by national and international regulations.

 

**2 – Purpose of Data Processing**

1. The data collected by the site during its operation is used for the purposes mentioned above and for the following purposes:

   – Request data for marketing and/or advertising purposes through the sending of newsletters, request data for direct contact purposes or tracking preferences purely related to the clothing, travel, or local flavours sectors.

2. Data retention will be carried out for the period strictly necessary to achieve the aforementioned purpose and in any case not exceeding 5 years.
3. Data used for security purposes (blocking attempts to damage the site) is retained for the time strictly necessary to achieve the previously indicated purpose.

 

**3 – Data Provided by the User**

1. As mentioned above, the optional, explicit, and voluntary sending of email to the addresses indicated on this site entails the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data included in the message.
2. Specific summary information will be progressively reported or displayed on the pages of the site prepared for particular services on request.

 

**4 – Support in Configuring Your Browser**

1. The user can manage cookies through their browser settings. However, deleting cookies from the browser may remove the preferences that have been set for the site.
2. For more information and support, you can also visit the specific help page of the web browser you are using:

 

   – Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

   – Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies-website-preferences

   – Safari: http://www.apple.com/legal/privacy/it/

   – Chrome: https://support.google.com/accounts/answer/61416?hl=it

   – Opera: http://www.opera.com/help/tutorials/security/cookies/

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### Social Network Plugins

 

1. This website also incorporates plugins and/or buttons for social networks to allow easy sharing of content on your preferred social networks. These plugins are programmed in a way that does not set any cookies upon accessing the page, in order to protect user privacy. Cookies may be set, if required by social networks, only when the user actively and voluntarily uses the plugin. Please note that if the user is logged into the social network while browsing, they have already consented to the use of cookies conveyed through this website at the time of their registration on the social network.
2. The collection and use of information obtained through the plugin are governed by the respective privacy policies of the social networks, which users are encouraged to refer to:

   – Facebook: [https://www.facebook.com/help/cookies](https://www.facebook.com/help/cookies)

   – Twitter: [https://support.twitter.com/articles/20170519-use-of-cookies-and-similar-technologies-by-twitter](https://support.twitter.com/articles/20170519-use-of-cookies-and-similar-technologies-by-twitter)

   – Google+: [http://www.google.com/policies/technologies/cookies](http://www.google.com/policies/technologies/cookies)

   – Pinterest: [https://about.pinterest.com/en/privacy-policy](https://about.pinterest.com/en/privacy-policy)

   – AddThis: [http://www.addthis.com/privacy/privacy-policy](http://www.addthis.com/privacy/privacy-policy)

   – LinkedIn: [https://www.linkedin.com/legal/cookie-policy](https://www.linkedin.com/legal/cookie-policy)

 

### USER RIGHTS

 

1. Article 13, paragraph 2 of the EU Regulation 2016/679 lists the rights of the user.
2. The website Vemlifestyle ltd hereby informs the user of the following rights:

   – The right of the data subject to request access to their personal data (Art. 15 of the EU Regulation), its update (Art. 7, paragraph 3, letter a) of Legislative Decree 196/2003), rectification (Art. 16 of the EU Regulation), integration (Art. 7, paragraph 3, letter a) of Legislative Decree 196/2003), or restriction of processing (Art. 18 of the EU Regulation), or to object to processing for legitimate reasons (Art. 21 of the EU Regulation), as well as the right to data portability (Art. 20 of the EU Regulation);

   – The right to request the erasure (Art. 17 of the EU Regulation), anonymization, or blocking of data processed unlawfully, including data that does not need to be retained for the purposes for which it was collected or subsequently processed (Art. 7, paragraph 3, letter b) of Legislative Decree 196/2003);

   – The right to obtain certification that the data update, rectification, integration, erasure, blocking, or anonymization actions have been brought to the attention of those to whom the data has been communicated or disseminated, except where this requirement proves impossible or involves a manifestly disproportionate effort compared to the right being protected (Art. 7, paragraph 3, letter c) of Legislative Decree 196/2003).

3. Requests may be addressed to the data controller, without formalities or, alternatively, using the template provided by the Data Protection Authority, or by sending an email to: vemlifestyle@vemlifestyle.com
4. **If the processing is based on Art. 6, paragraph 1, letter a) – express consent for use – or on Art. 9, paragraph 2, letter a) – express consent for the use of genetic, biometric, or health data revealing religious or philosophical beliefs, or trade union membership, revealing racial or ethnic origin, political opinions – the user has the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.**

 

**5. Similarly, in the event of a violation of the law, the user has the right to lodge a complaint with the Data Protection Authority, which is the authority responsible for monitoring data processing in the Italian State.**

 

**6. For a more detailed examination of your rights, please refer to Articles 15 and following of EU Regulation 2016/679 and Article 7 of Legislative Decree 196/2003.**

 

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**VI – DATA TRANSFER TO NON-EU COUNTRIES**

 

**1. This website may share some of the data collected with services located outside the European Union area. Specifically, with Google, Facebook, and Microsoft (LinkedIn) through social plugins and the Google Analytics service. The transfer is authorized and strictly regulated by Article 45, paragraph 1 of EU Regulation 2016/679, so no further consent is required. The aforementioned companies guarantee their adherence to the Privacy Shield.**

 

**2. Data will never be transferred to third countries that do not comply with the conditions set out in Article 45 and following of the EU Regulation.**

 

**VII. SECURITY OF PROVIDED DATA**

 

**1. This website processes user data in a lawful and correct manner, adopting appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of data. The processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated.**

 

**2. In addition to the data controller, in some cases, categories of persons involved in the organization of the site (administrative, commercial, marketing, legal staff, system administrators) or external subjects (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the data.**

 

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**VIII. CHANGES TO THIS DOCUMENT**

 

**1. This document, published at the address: [URL PRIVACY POLICY PAGE], constitutes the privacy policy of this site.**

 

**2. It may be subject to changes or updates. Users are invited to consult this page periodically to stay informed of the latest legislative updates.**

 

**3. Previous versions of the document will still be accessible on this page.**

 

**4. The document was updated on 25/05/2018 to comply with regulatory requirements, particularly in accordance with EU Regulation 2016/679.**