1. What is this document? Why does it matter? What happens to my personal data on this Site?
2. Who controls the processing of my personal data? Who is accountable for it?
The Controller of the personal data processing is: VF INTERNATIONAL S.A.G.L. – Wrangler DIVISION, Via Laveggio 5, 6855 – Stabio, Switzerland, Contact Us
VF NORTHERN Europe Limited, with registered office is at 15, Atholl Crescent, Edinburgh, EH3 8HA, United Kingdom, is acting as the representative of VF International for purposes of personal data protection compliance in the European Union, as well as Data Processor on behalf and under the instructions of VF for the activities of managing the customer support and the VF call centre.
3. What personal data are processed? For what purposes?
In general, the visit and consultation of the Site does not imply collection and processing of your personal data. The processing of your personal data when you merely visit and consult the Site is limited to the so-named surfing data, namely the data whose transmission to the Site is implicit in the functioning of the systems in charge of the managing of the Site and in the communications protocols peculiar to the Internet. Surfing data are, for example, the IP addresses of the devices you use to connect to the Site and other parameters relating to your device and operating system. Surfing data, such as these above specified, and for example the number of visits and the time spent on the Site, are collected and processed by Wrangler exclusively for statistical purposes and in anonymous form for purposes of measuring and enhancing the functioning of the Site. 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, Wrangler does not collect surfing data in order to associate them with identified users. Surfing data are deleted after being processed in anonymous form; said data may be used for purposes of assessing possible responsibilities in case of information crimes realized against the Site or through the Site. With the exception of the aforementioned circumstance, Wrangler keeps surfing data only for the maximum period of time allowed under applicable laws and in anonymous form.
Furthermore, Wrangler collects and processes personal data voluntarily provided by you when you interact with the Site functionalities and request the services offered by the Site, for example upon opening of an account, or upload of user-generated content on the Site; subscription to Wrangler newsletter or mailing list; purchase of products through the Site, which includes all activities relating to the purchase of goods, such as for example delivery of goods, billing issues, returning and exchanging of goods, receiving refunds, purchase and use of gift cards and e-gift cards, as applicable, payment related activities, including fraud prevention, and customer support and interaction with our call centre; participation to promotions and other initiatives realized or communicated through the Site such as for example loyalty programs, contests and sweepstakes, request of information to Wrangler or sending to Wrangler a question, communication or feedback through traditional mail or through the Site. We will process personal data also to comply with the Privacy Law and to assess and defend a legal right. We may process personal data also when you contact our customer support and call centre, which may communicate with you and thus process your personal data through e-mail, chat and telephone. The call centre will also register your phone number for purpose of call-back and back-office services in order to provide you with the requested support and information. In some cases, for purposes of internal training, quality control and verification, the call may be recorded and the e-mails may be saved to the extent not prohibited by the Privacy Law. You will always be informed in advance of the recording of the communication, and you will have the opportunity to object to such recording, save when this is necessary for verification purposes in relation to your purchase or other reasons, as allowed under applicable laws.
With your consent, that is optional, Wrangler may further process your personal data for survey purposes; for marketing purposes, that is for sending, also through e-mail or other electronic communications means such as SMS, MMS, fax, etc., promotional information and material on products and services of Wrangler, on special initiatives on prices and promotions and on initiatives such as loyalty programs, events, exhibitions and fairs organized by the VF group (to which Wrangler belongs) or to which the VF group takes part; and for profiling purposes. For the marketing and profiling activities above defined, personal data may also be shared with other companies of the VF group. You will always have the opportunity to object, at any time and for free, to the processing of your 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 Wrangler 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 you. When requested under the Privacy Law, Wrangler requires your consent before proceeding to processing your personal data.
4. Where will my personal data be stored?
Personal data collected through the Site will be processed and stored by Wrangler; 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 Wrangler hosting services for the web site and related database, so certain personal data processed through electronic means might be stored by such third-party company. In any event, 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 Site.
Cookies are small text files sent to your device by the Site. Cookies are uploaded onto your device, thus allowing the Site to recognize you and store certain information concerning you, in order to permit or improve the service offered.
We may use different types of cookies. We may use what we call "required" cookies to enable core site functionalities, such as logging-in and completing an Order for Products. These cookies do not collect personal information for marketing purposes and can not be disabled.
"Functional" cookies provide more advanced functions, such as remembering log-in details, remembering what is in your shopping cart and remembering your preferences such as language and country, analyzing sit usage to measure and improve performance. Also these cookies do not collect information that can identify users. These cookies can be disabled.
"Advertising" cookies may be finally used to keep record of certain behaviours or preferences expressed by you, so as to present content that is more relevant to your interests, in compliance with the applicable privacy laws and upon collection of your express consent if required by law. These cookies may also enable you to share some Site content through social networks such as Facebook and Twitter. To review the respective privacy policies cookies, you can visit the social networks websites. In the case of Facebook and Twitter please visit https://www.facebook.com/help/cookies and https://twitter.com/privacy. These cookies can be disabled.
6. How are personal data processed by Wrangler?
Personal data collected by Wrangler 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 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 the Privacy Law.
7. Are personal data safe in the hands of Wrangler? Can I update my personal data?
Wrangler is committed to protect security of personal data. Personal data are processed by Wrangler 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.
Wrangler deploys a variety of advanced security technologies and procedures to help protection of personal data against the risks above outlined. For example, personal data provided by users 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.
You may help Wrangler to update and maintain accuracy of the personal data you provided to Wrangler by notifying Wrangler of any amendment relating to your address, title, telephone number or electronic mail (e-mail) address. If you opened a Wrangler account, you can perform such updates on-line, following the instructions reported on your account pages.
8. Does Wrangler communicate the personal data collected? To whom? For what purposes?
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 Wrangler may revert to for performance of professional, technical and organizational services functional to the managing of the Site and the activities therein performed, such as for example the sales of goods and related activities, the managing of functionalities offered by the Site and of the initiatives and services that users may subscribe to and require through the Site, and for services strictly functional to achievement of the other processing purposes herein specified. For purposes functional to the managing of the Site and related activities, for example for the purchase of goods through the Site, 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. For closing purchase transactions and payment processing through our e-commerce platform we revert to third party service providers. These service providers are bound by contract obligations so that they will implement adequate security measures to protect security and confidentiality of personal data and credit card information.
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 Wrangler.
Except for the foregoing, 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 Wrangler. Personal data may further be communicated to whomever 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 Wrangler and the Site. Personal data will not be communicated to third parties for their own marketing purposes.
9. Am I obliged to provide my personal data? What are the consequences if I refuse to provide them?
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 may be necessary for the performance of certain services and functionalities offered by the Site and required, such as subscription to the Site, subscription to Wrangler's newsletter, the purchase of Products through the Site, the management of participation to loyalty programs, promotions and other initiatives communicated through the Site, replying to and managing of request of information, questions, communication or feedback to Wrangler. Providing of personal data for the activities necessary to comply with applicable legislation is mandatory. In the above referenced circumstances, denial of providing personal data would make it impossible for Wrangler to comply with contractual obligations or to provide the requested services, products or information as above specified.
Providing of data for survey, marketing and profiling purposes as above specified is optional; denial of providing personal data in said circumstances will have no consequences on compliance by Wrangler with its contractual obligations and on the provision of the services, products or information requested as above specified.
10. Does the site contain elements controlled by third parties? Is Wrangler liable for them?
The Site may contain links to other sites, as well as objects or elements controlled by third parties.
An example are plug-ins that may connect our Site to social networks like Facebook or Twitter ("social plug-in") and that are usually identified by the relevant social network's logo. If you find and interact with a social plug-in on our Site, your browser may send such social network certain data relating to you, such as you user ID, information on the Site, date and time, and other browser-related info. Such information would be processed by the social networks, owned and operated by third parties, according o their privacy policies.
11. What are my rights as regards my personal data collected and processed by Wrangler?
You are entitled at any moment to enforce the rights as provided by the Privacy Law, including but not limited to the right to obtain at any moment confirmation that your personal data exist or do not exist, verify their content, origin and accuracy, ask for their integration, updating, amendment, deletion, and you may oppose for legitimate reason the data processing (including objecting, at any time and for free, to the processing of your personal data for direct marketing purposes).
For any query or request relating to the personal data processing by VF and to enforce the rights under the Privacy Law, you may contact VF NORTHERN EUROPE Limited, acting as data Processor of VF, as follows: "VF NORTHERN EUROPE Limited - Wrangler E-commerce Customer Service, Park Road East, Claverton, Nottingham, NG14 6GD, United Kingdom". Full contact details are provided at our Contact Us page.
Version updated in: April 2016