JACOB COHËN

Website Privacy and Cookies Policy

 

Introduction

This is the privacy and cookies policy for http://www.jacobcohen.com, being the e-commerce website of Jacob Cohen Company Spa (company registration number “REA” MI - 2109529, VAT number IT08566980960) whose registered office is at Via Vittor Pisani 20, 20124 Milan (Italy) (“Jacob Cohen” we, us and our) for the sale and purchase of our products (Site). It is also the privacy policy for the customers of our physical shops.

For the purposes of European data protection legislation (Data Protection Law), and all other applicable data protection laws, we are the data controller in relation to the personal data processed in accordance with this policy.

We are committed to protecting your privacy on-line when visiting the Site or communicating electronically or by any other means with us. We appreciate that you do not want the personal information you provide to us distributed indiscriminately and here we explain how and why we collect and process personal data, what we do with it and what controls you have.  

By using the Site, you acknowledge that you have read the terms of this privacy and cookies policy.

We will treat all your personal information as confidential (although we may disclose this information in the circumstances set out below).  We will keep it on secure servers (as further detailed below) and we will fully comply with all applicable Data Protection Law and consumer legislation.

 

Whose personal data do we process?

We may process personal data relating to you if:

• You are a user of the Site. 
• You are a customer of us.
• You use our products or services.
• You are someone to whom we want to advertise or market our products.

 

Information we may collect from you

We may collect and process the following information about you: 

• Information (such as but not limited to your name, email address, billing address, delivery address, telephone number, product selections, payment type and card expiry number or log in and password details) that you provide by completing forms on the Site, including if you register as a user of the Site, purchase any goods from the Site, upload or submit any material via the Site, request any information, or enter into any competition or promotion we may sponsor;
• Information relating to transactions with us involving details of goods that we have supplied to you.
• Information provided to us when you communicate with us, for example by email or phone. This includes communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Site or its content or services.
• Information from surveys that we may, from time to time, run on the Site for research purposes, if you choose to respond to, or participate in, them.
• Internet pages you have visited immediately before coming to the Site or pages you visit immediately after leaving the Site.
• Information provided to us at our physical shops.

You are under no obligation to provide any such information. However, if you should choose to withhold requested information (e.g. your address or payment details), we may not be able to provide you with certain services.

We may, from time to time, run referral programmes or similar initiatives, such as a "Tell a Friend" programme, that invite you to provide us with the name and email address of someone who is known to you who may find our products or services to be of interest. We will only use those contact details for the purpose of the relevant initiative (and not for general marketing purposes). By providing us with their details, you confirm that you have their permission to do so and must not provide us with the details of anyone from whom you do not have such permission. We reserve the right to identify you as the person who has made the referral in the message that is sent to them.

 

Cookies

What are Cookies

Most websites you visit will use cookies to improve your user experience by enabling that website to remember you, either for the duration of your visit (using a 'session cookie') or for future visits (using a 'persistent cookie').

A cookie is a simple text file that is issued to your computer when you visit a website and which stores and sometimes tracks information about your use of a website. Each cookie is unique to your browser. It will contain some anonymous information such as a unique identifier, the website name and some digits and numbers. It allows a website to remember things like your preferences or what's in your shopping basket.

Although they do identify a user's computer, cookies do not personally identify users, and passwords and credit card information are not stored in cookies.

Cookies are not programs and therefore cannot contain viruses or other malicious software.

 

How We Use Cookies

You can find a summary of the various types of cookies we use below. Our cookies are used for 5 types of purpose:

We use the following categories of cookies on our Site.

CATEGORY 1: FUNCTIONAL COOKIES (NECESSARY COOKIES)

These cookies are required for optimum operation of the website, and cannot be configured. They allow us to offer you the key functions of the website (language used, display resolution, account access, shopping bag, wish list, etc.), provide you with online advice and secure our website against any attempted fraud.

 

CATEGORY 2: STATISTICAL ANALYSIS COOKIES

These cookies are used to measure and analyse our website audience (visitor volume, pages viewed, average browsing time, etc.) to help us improve its performance.

By accepting these cookies, you are helping us to improve our website. 

Google Analytics is a system used by many websites to record information about who visits a website. Google sets five different cookies with expiry dates ranging from 1 day to 2 years. These cookies are used mainly to differentiate between first time visitors to a website and repeat visitors. They do not contain any personally identifiable information. You can find out more about how Google uses cookies at http://www.google.com/intl/en/analytics/privacyoverview.html

 

CATEGORY 3: ADVERTISING AND SOCIAL MEDIA COOKIES

These cookies are used for Jacob Cohen advertisements displayed on third/party websites, including social media, and are tailored to your preferences and to help us measure the effectiveness of our advertising campaigns. If you deactivate these cookies, advertising, including ours, will continue to be displayed as you browse the internet, although they will not be specific to your personal interest, and will therefore be less relevant.

 

CATEGORY 4: COOKIES TO PERSONALIZE YOUR EXPERIENCE

These cookies allow us to provide you with online or in/store recommendations of products, services and content that match your expectations and preferences. By accepting these cookies, you are opting for an enriched and personalised experience. 

 

Cookies on the Site

Some of the cookies on the Site are set by us and some are set by third parties who are delivering services on our behalf.

 

Controlling or deleting cookies 

Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. 

If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. 

Information on deleting or controlling cookies is available at www.AboutCookies.org, which includes additional useful information on cookies and how to block cookies using different types of browser or mobile device. 

Please note that by deleting or restricting cookies or by disabling future cookies you may not be able to access certain areas or features of our Site or take full advantage of the Site. 

To opt out of being tracked by Google Analytics across all websites visit Google Analytics Opt-out Browser Add-on. 

If you'd like to opt out of other third party cookies relating to behavioural advertising, please go to www.youronlinechoices.eu. Opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns. 

We (and other third parties acting on our behalf) may automatically track and collect information about the IP address, domain service, country location, time zone, language, the type of computer and web browser you are using and the pages you visit (including by using web beacons and other similar technology). If you access our Site via your mobile device, we may also collect information about your mobile provider and your mobile device. We use this information so that we can administer and improve our system, analyse trends, track users' movements, gather broad demographic information for aggregate use and detect suspicious or fraudulent transactions. If these automated processes reject your transaction on the basis that it is a suspicious or fraudulent, you may contact us and ask us to reconsider the decision within 21 days of receiving such notification. We are likely to use very similar criteria to review your transaction in person so there is no guarantee that the decision will be different. 

 

Uses made of your information

We will use the information you provide only for the following purposes:

Information you give to us

We will use this information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• verify and carry out financial transactions in relation to payments you make online
• to notify you about changes to our service provided by the Site;
• to ensure in our legitimate interests that content from our Site is presented in the most effective manner for you and for your computer;
• if you have ticked the relevant box situated on the form on which we collect your data (the order form or registration form to create an account with the Site) indicating your consent for us to:
  • provide you with information about our (direct marketing) or third parties’ (indirect marketing) goods or services, that we deem you may be interested in;
  • for data profiling targeted at defining your profile, through the analysis of the usage of the products/services you chose and your preferences, to offer you products or services of your interest.

 

Information we collect about you

We will use this information:

• to administer our Site and your account with us under our terms and for internal operations, including identifying visitors to the Site, troubleshooting, and, in our legitimate interests, auditing the downloading of data, data analysis (demographic and sales data), testing, research, statistical and survey purposes;
• to improve our Site to ensure that content is presented in the most effective manner for you and for your computer; 
• to identify visitors to the Site;
• to allow you to participate in interactive features of our Site, when you choose to do so;
• as part of our legitimate efforts to keep our Site safe and secure;
• for our legitimate interest of measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them in our legitimate interests and subject to your stated preferences where relevant.
• send you information we think you may find useful or which you have requested from us, including information about our products and services, provided you have indicated that you do not object to being contacted for these purposes;

You can tell us not to contact you with information regarding our products and services, either at the point such information is collected on the Site (by checking (as directed) the relevant box) or, where you do not wish us to continue to use your information in this way, by following the unsubscribe instructions on any communications sent to you. You can also exercise the right at any time by contacting us using the Contacting us details at the end of this privacy policy. 

 

Legal grounds for our processing of your personal data

The basis on which we process your personal data is as follows:

• Where it is necessary to obtain your prior consent to the processing concerned in order for us to be allowed to do it, we will obtain and rely on your consent in relation to the processing concerned.
• Otherwise, we will process your personal data only where the processing is necessary:
  • for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract;
  • for compliance with a legal obligation to which we are a subject; or
  • for the purposes of the legitimate interests pursued by us or another person, provided that this will only be in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data.

 

Information sharing

We may disclose aggregate statistics about visitors to the Site, customers and sales in order to describe our services to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information.

We may disclose your personal information to any of our affiliates or to our agents or contractors who assist us in providing the services we offer through the Site, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks, from time to time.

We have subcontracted the operation of certain aspects of the Site to Farfetch Platform Solutions, company number 10994099, with registered address at The Bower, 211 Old Street, London EC1V 9NR (Farfetch). Services provided or procured by Farfetch include, but are not limited to, payment processing, customer service, hosting and delivery logistics. Our agents and contractors will only use your information to the extent necessary to perform their functions, and always subject to appropriate security and contractual safeguards.

We may share your information with other companies and organisations for identity verification and fraud protection purposes to the extent permitted by applicable laws.

In the event that we undergo re-organisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.

You should be aware that we may be under a duty to disclose or share your personal information and/or user information in order to comply with any legal obligation. We may also disclose your personal information if we believe that such action is necessary to prevent fraud or cyber crime or to protect the Site or the rights, property or personal safety of any person.

 

Public forums

The Site may, from time to time, make chat rooms, message boards, news groups and/or other public forums available to its users. Any information that is disclosed in these areas becomes public information and you should exercise caution when using these and never disclose your personal information.

 

Child safety

Protecting the privacy of children is important. Jacob Cohën does not and does not intend to collect personal information from children (a child is defined as a minor under applicable law) without the permission of the parent or legal guardian. Children should NOT submit personal information to Jacob Cohën without explicit permission from the parent or legal guardian. Where appropriate, we will inform children not to submit personal data. If your child has submitted personal data and you would like to request the removal of that information, please contact us.

 

External links

The Site may, from time to time, contain links to external sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and processes and that we do not accept any responsibility or liability for these policies and processes. Please check these policies before you submit any personal data to these websites.

 

Payment processing

Payment details you provide will be encrypted using secure sockets layer (SSL) technology before they are submitted to us over the internet. Payments made on the Site are made through payment gateway providers from time to time. You will be providing credit or debit card information directly to such payment provider which operates a secure server to process payment details, encrypting your credit/debit card information and authorising payment. Information which you supply to such payment providers is not within our control and will be subject to their own privacy policy and terms and conditions. For more information please contact us. 

 

Security

We place great importance on the security of all personally identifiable information associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal information. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it. 

You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via the Site whilst it is in transit over the internet and any such submission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal information if you use a shared computer or a computer in a public place.

 

Data Retention

We process personal data only for so long as it is necessary for the purpose(s) for which it was originally collected, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject or for another legitimate and lawful purpose.

 

Storage of your information

Your personal information may be transferred to, and stored at a destination inside or outside of the European Economic Area including the US and other non-EEA countries. Where we transfer your information to a country different from where you are we will take all reasonable steps to ensure that your data is subject to appropriate safeguards, such as relying on EU approved standard contractual clauses, or to the appropriate secure standard, relevant to transfers of personal information and that it is treated securely and in accordance with this privacy policy.

Information submitted by you may be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above (see Information sharing), which may be situated inside or outside the European Economic Area (EEA) and may be processed by staff operating outside the EEA who work for these third parties or for us or one of our suppliers. This includes staff engaged in, among other things, the processing of payment details and the provision of support services. The countries concerned may not have similar data protection laws to the EEA. Where we transfer your information we will take all reasonable steps to ensure that your data is subject to appropriate safeguards, such as relying on EU approved standard contractual clauses, or to the appropriate secure standards, relevant to transfers of personal information and that it is treated securely and in accordance with this privacy policy.

 

Your rights

You have the following rights in relation to personal data relating to you that we process:

• You may request access to the personal data concerned (please see the section on how to access to your personal data, below).
• You may request that any incorrect personal data about you that we are processing be rectified.
• In certain circumstances (normally where the personal data has been provided by you and it is no longer necessary for us to continue to process it), you may be entitled to request that we erase the personal data concerned.
• Where we are processing personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent at any time, after which we shall stop the processing concerned. If you do withdraw your consent here, please note that this may affect our ability to provide you with our goods or services. 
• If you have a complaint about any processing of your personal data being conducted by us, you can contact us or lodge a formal compliant with the Information Commissioner.

 

How to withdraw your consent to processing

You can withdraw your consent to any relevant processing of personal data:

• For any matter related to the Site, e-commerce and website newsletter, by emailing us at: customerservice@jacobcohen.com
• For any matter related to the data you provided through our physical shops (boutiques) and boutiques’ newsletters, and any other matter not related to the Site and e-commerce, by emailing us at: privacy@jacobcohen.com

 

How to exercise your right of access to your personal data

You can exercise your right of access, limitation or deletion, to your personal data:

• For any matter related to the Site, e-commerce and website newsletter, by emailing us at: customerservice@jacobcohen.com
• For any matter related to the data you provided through our physical shops (boutiques) and boutiques’ newsletters, and any other matter not related to the Site and e-commerce, by emailing us at: privacy@jacobcohen.com
• To delete your Account created on the Site log in into your account and go to the section “delete Account”

Please note that we may be required to ask you for further information in order to confirm your identity before we provide the information requested.

 

Contacting us

Please submit any questions, concerns or comments you have about this privacy policy or any requests concerning your personal data by email to privacy@jacobcohen.com or write to us at:

Jacob Cohen Company S.p.A., Via Vittor Pisani 20, 20124 Milan (Italy)

 

The Supervisory Authority

Garante per la Protezione dei Dati Personali (https://www.garanteprivacy.it) is the supervisory authority of Jacob Cohen S.p.A. and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data. If you are outside of EU boundaries, you have the right to apply to any other competent supervisory authority as stated by applicable regulations on Data protection.

 

Changes to this policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy and cookies policy. 

 

LAST UPDATE: 22nd January 2024

 

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Jacob Cohen Company S.p.A. and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

 

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

 

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

 

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
• Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
• Directly and indirectly from activity on our website (www.jacobcohen.com). For example, from submissions through our website portal or website usage details collected automatically.
• From third-parties that interact with us in connection with the services we perform.

 

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

 

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: Category A, B.

We disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

 

In the preceding twelve (12) months, we have not sold any personal information.

 

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

 

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at privacy@jacobcohen.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  We will deliver our written response by mail.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

 

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at privacy@jacobcohen.com