Privacy Policy of www.russelleurope.com

www.russelleurope.com collects some Personal Data from its Users.

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Owner and Data Controller

Owner

Fruit of the Loom International Limited
Unit 6 Lisfannon Business Centre
Lisfannon, Buncrana Co. Donegal, Ireland

Data Controller

FOL International GmbH
Von-Miller-Str. 9
67661 Kaiserslautern
Germany

Data Controller contact email:

privacy@fotlinc.com

Types of Data collected

Among the types of Personal Data that www.russelleurope.com collects, by itself or through third parties, there are: first name; last name; phone number; company name; address; country; email address; ZIP/Postal code; various types of Data; city; field of activity; Cookies; Usage Data; geographic position.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using www.russelleurope.com.
Unless specified otherwise, all Data requested by www.russelleurope.com is mandatory and failure to provide this Data may make it impossible for www.russelleurope.com to provide its services. In cases where www.russelleurope.com specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Data Controller.

Any use of Cookies – or of other tracking tools – by www.russelleurope.com or by the owners of third-party services used by www.russelleurope.com serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through www.russelleurope.com and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to the Owner, specifically by certain types of persons in charge of or involved in the operation of www.russelleurope.com (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Data Controller. The updated list of these parties may be requested from the Data Controller at any time.

Legal basis of processing

The Data Controller may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Data Controller may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Data Controller;
  • processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.

In any case, the Data Controller will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Data Controller to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Data Controller using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Data Controller’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Data Controller within the relevant sections of this document or by contacting the Data Controller.

The Data Controller may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Data Controller to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Contacting the User, Data transfer outside the EU, Interaction with external social networks and platforms, Location-based interactions, SPAM protection and User database management.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Contacting the User

Contact form (www.russelleurope.com)

By filling in the contact form with their Data, the User authorizes www.russelleurope.com to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data collected: address; city; company name; country; email address; field of activity; first name; last name; phone number; various types of Data; ZIP/Postal code.

Mailing list or newsletter (www.russelleurope.com)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning www.russelleurope.com. Your email address might also be added to this list as a result of signing up to www.russelleurope.com or after making a purchase.

Personal Data collected: company name; Cookies; country; email address; first name; last name.

Phone contact (www.russelleurope.com)

Users that provided their phone number might be contacted for commercial or promotional purposes related to www.russelleurope.com, as well as for fulfilling support requests.

Personal Data collected: phone number.

Data transfer outside the EU

The Data Controller is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.

Users can inquire with the Data Controller to learn which legal basis applies to which specific service.

Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield (www.russelleurope.com)

If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU – U.S. and Swiss – U.S. Privacy Shield. A copy of the Privacy Shield Policy is available here

In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List. Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.

Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Data Controller to learn about such legal grounds.

Personal Data collected: various types of Data.

Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of www.russelleurope.com.
The interaction and information obtained through www.russelleurope.com are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

It is recommended to log out from the respective services in order to make sure that the processed data on www.russelleurope.com isn’t being connected back to the User’s profile.

Facebook Like button and social widgets (Facebook, Inc.)

The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

YouTube button and social widgets (Google Ireland Limited)

The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google Ireland Limited.

Personal Data collected: Usage Data.

Place of processing: Ireland – Privacy Policy

LinkedIn button and social widgets (LinkedIn Corporation)

The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Location-based interactions

Non-continuous geolocation (www.russelleurope.com)

www.russelleurope.com may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by www.russelleurope.com.

The geographic location of the User is determined in a manner that isn’t continuous, either at the specific request of the User or when the User doesn’t point out its current location in the appropriate field and allows the application to detect the position automatically.

Personal Data collected: geographic position.

SPAM protection

This type of service analyzes the traffic of www.russelleurope.com, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

Google reCAPTCHA (Google Ireland Limited)

Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use

Personal Data collected: Cookies; Usage Data.

Place of processing: Ireland – Privacy Policy.

User database management

This type of service allows the Data Controller to build user profiles by starting from an email address, a personal name, or other information that the User provides to www.russelleurope.com, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Data Controller can display and use for improving www.russelleurope.com.

Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on www.russelleurope.com.

Salesforce Marketing Cloud (Salesforce.com, inc.)

Salesforce Marketing Cloud is a User database management service provided by salesforce.com, inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Salesforce Sales Cloud (Salesforce.com, inc.)

Salesforce Sales Cloud is a User database management service provided by salesforce.com, inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Data Controller.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Data Controller will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Data Controller or for the purposes of the legitimate interests pursued by the Data Controller, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Data Controller is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Data Controller through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Data Controller as early as possible and always within one month.

Cookie Policy

www.russelleurope.com uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Data Controller or Owner in Court or in the stages leading to possible legal action arising from improper use of www.russelleurope.com or the related Services.

The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, www.russelleurope.com may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, www.russelleurope.com and any third-party services may collect files that record interaction with www.russelleurope.com (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

www.russelleurope.com does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within www.russelleurope.com and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Data Controller. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Data Controller shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through www.russelleurope.com (or third-party services employed in www.russelleurope.com), which can include: the IP addresses or domain names of the computers utilized by the Users who use www.russelleurope.com, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using www.russelleurope.com who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of www.russelleurope.com.

www.russelleurope.com (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by www.russelleurope.com as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies

Small sets of data stored in the User’s device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to www.russelleurope.com, if not stated otherwise within this document.

 

Latest update: April 29, 2020