Privacy policy
Last update: 30/04/2021
VAN DE VELDE NORTH AMERICA INC., operating under the tradename PRIMADONNA ("Company," "we", "us" or "our") values your privacy and is committed to protecting your personal information. This Privacy Policy ("Policy") applies to the information we collect online through our website www.primadonna.com (the "Site"). In this Policy we describe the information that we collect from users of our Site, and how we use, disclose and protect such information.
By visiting, placing an order, or otherwise interacting with our Site, you agree that your personal information will be handled as described in this Policy.
Your use of our Site, and any dispute over privacy, is subject to this Privacy Policy and our Terms of Use, including its applicable limitations on damages and the resolution of disputes. The Terms of Use are incorporated by reference into this policy.
What information do we collect about you and why?
We collect information from you when you use our Site or place an order with us. In general, we collect the following types of information from users:
- Registration and Order Information: When you register with us or place an order with us we may collect your name, shipping and billing address, e-mail, phone number and other contact information. If you place an online order with us, we also collect your credit card number, billing address and other information necessary to process your order.
- Order History: When you make online purchases with us, we collect and store information about your purchases, such as the order date, order amount and items purchased, and the like,
- Site Activities: We use cookies and other tracking technologies to automatically collect information about you when you visit our Site or use our services, including IP address, browser type, operating system, date and time of visit, time spent on and/or logged on to Site, pages visited, links clicked, items viewed, items added to your shopping cart, referring URL and other Site activity. We may combine such Site information with the personal information we have collected from you. For more information, see the "What About Cookies and Other Tracking Mechanisms" section, below,
- Other Information: We also collect and store information about any inquiries or communications you submit to us, and any contest, surveys and promotions in which you participate at our Site, including contests, surveys, and promotions that you may enter through Facebook or Twitter. In addition, we collect your e-mail address and name if you sign up to receive information about the latest deals, promotions and information from us.
- If you enroll to the Insiders program we collect your name, mailing address, email address, purchase history, and phone number.
Additional information about the use of our FitQuiz:
You can complete the FitQuiz on our websites without having to create a profile. To obtain size advice with regard to our products, provide the following information as part of the FitQuiz:
- Gender;
- Reference article of clothing or brand;
- Bra size;
- Body type;
- Desired fit;
- Email address
- Furthermore, once you have provided this data any products you have purchased from Van de Velde in the past may be checked to provide you with optimal size and style advice.
The FitQuiz generates specific size and style advice based on your responses to the questions, statistical methods and anonymised purchase and return data. At the end of the FitQuiz you will be asked for an email address to which we can send your personalised size and style advice. You can also forward your preferred size from FitQuiz to your shopping cart in our online store. The data you provide will be stored on the basis of the email address you provide at the end of the quiz.
We use the data obtained from the FitQuiz exclusively for the following purposes:
- Providing size advice with regard to our products in real time;
- Providing size advice with regard to our products by email (one time only);
- Providing size advice with regard to our products in our online store;
- Analysing purchase and return data linked to the FitQuiz results;
- Optimising the general quality of the mechanisms through which these services are provided.
The collected data is not sold to or shared with third parties, as set down in more detail in the “Do we share or sell your personal data?” section of this Policy. After one month the data collected through the FitQuiz is automatically anonymised.
When and How Does Company Share Information It Receives?
We may share information about you, including personal information, under the following circumstances:
- Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personally identifiable information will be subject to this Policy.
- Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf, including with third parties that will assist us in processing payments, marketing and PR actions, fulfilling your order, and maintaining our Site.
- Business transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
- In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.
- To protect company and others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms of Service or this Policy.
Notwithstanding anything else in this Policy, we may freely share aggregate or anonymized information about users with third parties for marketing, advertising, research or similar purposes.
What About Cookies and Other Tracking Mechanisms?
When you interact with our Site, we strive to make your experience easy and meaningful. We or our third-party service providers may use cookies, web beacons (clear GIFs, web bugs) and other technologies to track user activity and collect Site data. We use this information to analyze trends, to administer the Site, to track users’ movements around the Site and to gather demographic information about our user base as a whole.
- Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while other cookies are used to enable a faster log-in process or to allow us to track your activities at the Site. There are two types of cookies: session-based and persistent-based cookies. We also allow vendors to use cookies on our Site.
- Session cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged in to the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
- Persistent cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information
- Third Party cookies. We may also engage third parties to track and analyze Site data. We use the data collected by such third parties to help us administer and improve the quality of the Site and to analyze Site usage. This Policy does not cover such third parties’ use of the data
- Disabling cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable their web browsers’ ability to accept cookies will be able to browse the Site; however, some Site features may not function if you disable cookies.
- Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
- Site analytics. As noted, we may use automated devices and applications, such as Google Analytics, to evaluate usage of our Site. We also may use other analytic means to evaluate our Site. We use these tools to help us improve our Site, performance and user experiences.
What About Third Party Links?
Our Site may contain links to other third party websites. Any access to and use of such linked websites is not governed by this Policy, but, instead, is governed by the privacy policies of those third party websites, and we are not responsible for the information practices of such third party websites.
How Secure Is Information About Me?
We have implemented commercially reasonable precautions, including, where appropriate, password protection and SSL encryption to protect our Site and the personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee 100% security all of the time.
What Choices Do I Have About Receiving Marketing Communications?
We may send periodic emails to users regarding various promotions or other information that we believe may be of interest. If we send you any news and newsletters, special offers, promotions or other information we think may interest you, you may tell us to stop sending you such promotional e-mail communications by following the opt-out instructions contained in any such e-mail. Further, if you opt-out of receiving such promotional emails, we may still send you non-promotional e-mails, such as emails about any orders you place.
What Rights Do I Have To Review And Rectify My Personal Information
You are entitled to review, limit and where appropriate request the rectification of your personal information. To exercise these rights, free of charge, simply email contact@primadonna.com. This service is free of charge.
What About User Generated Content?
If you post your own content on our Site or Services, such as user comments, your posting may become public and Company cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.
What About Contests, Surveys and Other Promotions?
From time-to-time we may provide you the opportunity to participate in contests, surveys and other promotions on our Site. Participation is completely voluntary. If you participate, we will request certain personal information from you. The requested information typically includes contact information (such as name, e-mail and shipping address), and demographic information (such as zip code). We may use this information to notify contest winners and award prizes, and for other purposes set forth above. We may use a third party service provider to conduct these surveys or contests on our behalf.
Children Under 13
Our Site is not designed for children under 13. We do not knowingly collect information from children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
Special Information for California Consumers
California residents may request a list of certain third parties to which we have disclosed personally identifiable information about you for direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us at contact@primadonna.com.
Changes to this Policy
This Privacy Policy is effective as of the date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to our Policy on our Site, at www.us-en.primadonna.com.
Last updated: 12/01/2023
General
Van de Velde cares about your privacy. That is why we want to provide you with as much information as possible about what happens to your personal data once you provide it to us. Within this Privacy Policy (“Policy”) you will find all information you need to know about what personal data we collect, why we collect it, how long we store it, what your rights are and how you can exercise them.
Who are we?
Your personal data collected in stores, at Van de Velde events and on the Van de Velde websites ("Website") is administered by Van de Velde NV, a company incorporated under Belgian law with registered office at Lageweg 4, 9260 Schellebelle, Belgium and with company registration number 0448.746.744 ("Van de Velde" or "we" or “us”). Any reference in this Policy to Van de Velde also includes the European subsidiaries of Van de Velde NV, a list of which can be consulted here here.
Van de Velde is the controller of your personal data. This means that Van de Velde determines the purpose and means for the processing of your personal data.
When is this policy applicable?
By using a Website, attending a Van de Velde event, subscribing in store to direct marketing or accepting the creation of a profile you are deemed to have read, accepted and be bound by this Policy, the Terms & Conditions and the Cookie Policy (jointly called the “Terms”). When attending a Van de Velde event, subscribing in store to direct marketing or when accepting the creation of a profile in store or on a Website, the Terms are available for consultation at these locations. All personal data Van de Velde collects during your visit to the Van de Velde stores, a Van de Velde event, or a Website will be handled in accordance with this Policy. Van de Velde protects your privacy and acts in accordance with the provisions of the Belgian Data Protection Act (the ‘Act of 30 July 2018 on the protection of physical persons with regard to the processing of personal data') and the European General Data Protection Regulation 2016/679 (“GDPR”). Please read this Policy to learn more about how personal data are collected and processed by us through the Website, at events and in stores.
Who is protected by this Policy?
This Policy only applies to the personal data that Van de Velde processes as controller (see chapter: “Who are we?”). This Policy applies to the processing of personal data of our consumers (private) and customers (business) in relation to our products and services. This Policy also applies when you visit our offices or our stores, websites, use our apps, participate in market research, surveys, contests, actions or events, or otherwise use our products and services. The personal data of former consumers and customers will also be treated and secured as carefully as possible, in accordance with this Policy.
What personal data are we processing?
Data you provide to us at our stores and events:
In the Van de Velde stores and at Van de Velde events, the following personal data may be collected. When filling in a 'keep me posted card', you are free to submit the following information: name, address, e-mail, date of birth, favourite store, telephone and shape ID. When creating a Shape ID, you submit the following additional information: size, date of birth, and shape ID. For attendance at one of our events, you submit the following information; name, address, e-mail, date of birth, favourite store, telephone.
Data you provide to us through the use of our services:
You may also provide personal data through the use of our services. Personal data can be collected such as name, address, sex, age, civil status, email address, financial characteristics, place of residence, landline and mobile phone number, size and purchase history. This is for example the case when you place an order on the website, register as a customer, subscribe to one of the following services: electronic newsletter, MMS marketing (by mobile phone) or press information, when you call our Customer Services or when you send us a letter or an e-mail.
Data you provide to us by using our Website:
As part of its normal functioning, Van de Velde’s web server collects the following information about every visitor to a Website: your IP address, the name of your internet service provider, the software, the type and language of your browser, the search engine and keywords used to find the Website, the date and time you accessed the Website, the pages viewed by you on the Website, the pages of other websites from which you accessed the Website. This information is collected through cookies. More information on cookies can be found within our Cookie Policy.
What do we use your personal data for?
Van de Velde processes your personal data for various purposes, whereby we only process the data that are necessary to achieve the intended purpose.
We use personal data when it is necessary for:
i. processing an order;
ii. providing goods, services and/or information requested by you;
iii. providing you with the information, goods and services offered through our Website for billing and order fulfilment;
iv. verifying and carrying out financial transactions in relation to payments you make online;
v. administering your account with us;
vi. auditing the download of data from our Website;
vii. measuring and monitoring the use and improving the quality and content of this Website;
viii. customizing the content and layout of this Website;
ix. improving Van de Velde’s products and services;
x. organising and inviting you to our events;
xi. profiling (in order to provide you with personalized commercial information);
xii. targeting on online platforms;
xiii. organising contests;
xiv. complying with the legal or regulatory provisions to which we are subject;
xv. providing general or direct marketing towards you;
xvi. maintaining your shape in order to assist you better with your next purchase;
xvii. processing a dropshipment order or a 'Reserve & Fit' reservation with an independent retailer of Van de Velde
The processing of the personal data of categories (i) to (v) is necessary for the performance of the contract you have with Van de Velde. Categories (vi) to (xiii) are processed within the framework of the legitimate interests Van de Velde holds to process these personal data: prevention of fraud or misuse of services, marketing research, website improvement purposes, organisation of events and contests, and profiling. In these cases Van de Velde will always aim for a balance between our legitimate interest and your privacy. The processing within the framework of categories (xv) and (xvi) only takes place in case you have provided your consent thereto. The processing within the framework of category (xvii) is necessary for the performance of the contract you have with an independant retailer of Van de Velde.
Some additional information on our direct marketing activities (xv.):
Van de Velde will provide you with (personalized) communications only when you have consented to us processing your personal data for direct marketing. We may contact you
- in writing, at your home address;
- by calling you or texting you on the telephone number(s) you have provided;
- by e-mail or fax, with information regarding events, promotions, actions, products, services and/or contests.
If you prefer not to receive any marketing communication from us, or if you prefer for your personal data not to be processed for direct marketing, you can opt out at any time by sending an email to privacy@vandevelde.eu.
How do we protect your personal data?
We work hard to protect your privacy and personal data at our offices, in our stores and on our Website. Van de Velde uses a combination of technical and organisational measures to keep your data safe. Our employees are trained to correctly handle your personal data. Furthermore in the framework of every project that is aiming to process personal data, an assessment is performed with regard to security and the protection of this data, all while keeping into account your interests. Also our internal information Security Policy, security requirements and management standards are followed up for compliance by our employees. We also employ specialized profiles who are responsible for the security of our network, our infrastructure and our information systems. In addition, we use all sorts of technical measures to protect your personal data against unauthorized access, unauthorized use and loss or theft of our data, such as: password protection, firewalls, antivirus and access controls for our employees. No method of transmitting or storing of data is completely secure however, so should a data breach occur with adverse consequences for you, then you will be personally informed in the circumstances provided by the law. If you have a security-related concern, please contact us at privacy@vandevelde.eu.
Are we sharing or selling your personal data?
We do not sell nor share your personal data to any third parties without your prior consent, unless:
— to companies associated by law with Van de Velde, established in the European Economic Area or the United States of America. Your personal data is shared with these companies for the same purposes as those stated within this Policy. These companies qualify as joint controllers in this context.
You may request a list of these companies by sending an email to privacy@vandevelde.eu. This list is also available at the corporate website of Van de Velde, under 'Investor relations, Group structure' (http://www.vandevelde.eu/en/group-structure);
— to a legal successor acquiring part or the whole of Van de Velde;
— to recognized financial or bank institutions whose intervention is necessary for the smooth course of the payment procedure;
— to credit reference agents. We reserve the right to request information about you from other third parties such as credit reference agencies. We will add this information to the information we have previously processed about you so as to enable us to: (1) provide goods or services to you; (2) improve and enhance your buying experience; and (3) contribute to money laundering and fraud prevention.
Where we make such a request we will first inform you of this intention and of whether any record of the search will be recorded on a credit file;
— when we are required to do so by law or if we believe that such action is necessary to prevent fraud or cybercrime or to protect the Website or the rights, property or personal safety of any person. (We refer to chapter “What do we use your data for”);
— when it is necessary to provide you with our services.
A) Some of our databases are made accessible or transferred to third parties who work in our assignment and who assist us in delivering our products and services. Consider for example our commercial agents, the independent retailers and our service providers of web hosting, cloud services or maintenance services. Furthermore, several postal services are assisting us to provide you with the packages you order from us (e.g. UPS, DHL, De Post, Post NL etc.). The transfer of your data only takes place for the purposes as mentioned within this Policy and is limited to the data that they need for the performance of our assignment. We ensure that they, just like us, manage your data safely, respectfully and with due care and we provide adequate contractual guarantees.
B) If you subscribe to our newsletter, we might tailor our communications and online advertising based on the information you provide to us. Social media enable us in this context to provide you with relevant information, updates and marketing content (such as advertisements based on look-a-like profiles). Furthermore social media enable us to function as customer service (for instance when you use social media to contact us). Please be aware that social media channels have their own privacy and cookie policies in place, so the personal information you give them will be subject to their rules and not ours.
— when we have or the third party has a legitimate interest for transfer. We will only transfer your personal data based on an assessment of your rights and freedoms and you will always be transparently informed about them (except in case of legal exceptions).
— when you provide your consent. In any other case where we would be transferring your data to third parties, we will provide you with a transparent notice through which you are informed of the third party, the purpose of the transfer and their processing. Where it is required by law, we will obtain your explicit consent to do so.
For all data transfers outside of the European Economic Area, we ensure through the appropriate safeguards embedded in the contract or other measures that your data receives an adequate level of protection comparable to the protection it would have within the EU in accordance with the European regulations. We may also disclose anonymous, aggregated statistics for commercial and internal/external reporting. For example: about visitors to our Website in order to describe our services to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes. These statistics will not include information through which you may be identified. If you have any queries about the processing of your data by such third parties, please contact the third party in question. To the extent that this processing goes beyond the scope of purposes determined by Van de Velde, the third party is fully responsible for such processing, and Van de Velde can in no way be responsible or liable for such processing.
What are your privacy-rights and how can you exercise them?
An overview of your rights:
You are entitled to review and to request the rectification or erasure (“right to be forgotten”) of your personal data. Furthermore, you are entitled to object to the use of your personal data for direct marketing purposes. You also have the right to ask for the provision of a copy of all your personal data which are processed by us, where technically feasible. You also have the right to exercise your right to data portability.
Practicalities:
How to exercise your rights?
To exercise these rights, or if you require further information regarding your rights, simply email privacy@vandevelde.eu. In order to exercise your right of access and to prevent any unauthorized disclosure of your personal data, we must verify your identity. In case of doubt or ambiguity, we will first ask you for additional information (for example a copy of your identity card).
Will you have to pay?
You can exercise your privacy rights free of charge, unless your request is manifestly unfounded or excessive, in particular because of repetitive nature. In such a case we have – in accordance with the General Data Protection Regulation – the right and the choice to charge you a reasonable fee (taking into account the administrative costs to provide the requested information or communication) or to refuse to comply with your request.
How will you receive an answer? If you submit your request electronically, the requested information will be provided to you electronically if possible, unless you request otherwise. In any case, we will provide you with a concise, transparent, understandable and easily accessible answer.
When will you receive an answer?
We will respond to your request as soon as possible, and in any case within one month of receipt of your request. Depending on the complexity of the request and the number of requests, this period could be extended for an additional two months if required. If this would be the case, we will notify you within one month of receipt of the request.
Finally, you have the right to lodge a complaint with your local data protection authority or with the Belgian Data Protection Authority (our lead supervisory authority) regarding the processing of your personal data by Van de Velde. The Belgian Data Protection Authority can be reached at: Drukpersstraat 35, 1000 Brussel. +32 (0)2 274 48 00 / contact@apd-gba.be / www.dataprotectionauthority.be
How long are we keeping your personal data?
By law, we are not allowed to store personal data for longer than is necessary to achieve the purpose for which we collected it. The retention period can therefore be different according to the processing activity. Some examples: Generally, we will be storing your personal data for a period of 5 years after your most recent login or transaction with Van de Velde. Personal data that has been collected for contests will only be kept for 1 year after the contest has been closed. For marketing purposes for which you have provided us with consent, your contact information will be kept by us for as long as you don’t withdraw your consent. Finally, in order to meet our accounting and tax obligations, we are subject to a variety of local laws to keep your data for a certain period of time.
After the applicable storage period(s) have expired, your personal data will be deleted or anonymized.
How can you stay informed of adjustments to this Policy?
Van de Velde reserves the right to change, adapt, supplement or remove this Policy wholly or partly at any time as it sees fit. This can happen for example in the light of market evolutions or new processing activities we employ. Therefore you are invited to check this Policy regularly for changes. By using a Website after any such change has been made to this Policy, you are deemed to have accepted this change, regardless of whether you have read this Policy. If you do not accept this Policy, please leave the Website through which you are consulting this Policy immediately. You will not be allowed to create a profile or receive direct marketing if you do not accept this Policy. How can you get into contact with us?
If you have questions, suggestions, or concerns about this Policy, or about our use of your information, please contact us at privacy@vandevelde.eu.
You may also contact us at:
Van de Velde NV
Lageweg 4
9260 Schellebelle
Belgium
Company registration number: 0448.746.744