PRIVACY POLICY

Officina Profumo-Farmaceutica di Santa Maria Novella S.p.A. (hereinafter referred to as "Officina Profumo-Farmaceutica di Santa Maria Novella", "we", "us" or "our") respects the privacy of our users and is committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

By accessing or using our website at www.smnovella.com (the "Website"), you agree to the collection and use of information in accordance with this policy.

1. LEGAL DISCLOSURES, DATA PROCESSING AND AUTOMATED DECISION

We are Officina Profumo-Farmaceutica di Santa Maria Novella S.p.A., a company registered in Italy with registration number 123456789 and registered office at Via della Scala, 16, 50123 Florence, Italy.

You can contact us by:

• Email: privacy@smnovella.com
• Post: Officina Profumo-Farmaceutica di Santa Maria Novella S.p.A., Via della Scala, 16, 50123 Florence, Italy

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

We process your personal data according to the General Data Protection Regulation (GDPR) and other applicable data protection laws. We will only collect and process your personal data where we have lawful grounds to do so. Where we rely on legitimate interest as the legal basis for processing your personal data, we have carefully considered those interests and will not use your personal data for activities where our interests are overridden by the impact on you.

2. DATA PROTECTION OFFICER

Our Data Protection Officer (DPO) can be contacted at dpo@smnovella.com or by writing to:

Data Protection Officer
Officina Profumo-Farmaceutica di Santa Maria Novella S.p.A.
Via della Scala, 16
50123 Florence, Italy

3. THE DATA WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

4. THIRD PARTY MARKETING AND ANALYTICS TOOLS

We may use third-party Service Providers to monitor and analyze the use of our Service.

• Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
• For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy

5. COOKIES, AUTOMATIC DATA COLLECTION AND RELATED TECHNOLOGIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

6. THE PURPOSE OF DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

7. TRANSFER OF YOUR DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

We ensure that any of our partners or service providers who handle your personal data outside the EEA provide an adequate level of protection. This means that they must ensure that their processing of your personal data is in accordance with EU data protection laws. We achieve this by using specific contracts approved by the European Commission which give personal data the same protection it has in Europe or by ensuring they are part of international frameworks that uphold data protection standards.

8. YOUR RIGHTS AS DATA SUBJECT

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact our DPO at dpo@smnovella.com.

9. RIGHT TO OBJECT

You have the right to object to us processing your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.

10. AMENDMENTS

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "effective date" at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes.

This Privacy Policy was last updated on May 25, 2023.