Welcome to the website of Ambush Italy S.r.l. www.ambushdesign.com (hereinafter, for brevity, the “Site”).
1. Data Controller and contact details
Ambush Italy S.r.l., with registered office in Via Turati 12, 20121 Milan, Italy (hereinafter referred to as “Ambush “ and/or the “Data Controller” for brevity) is the autonomous data controller of the processing of personal data of users who browse the Site, including browsing data, marketing and profiling data, as well as data connected and related to sales made through the Site and to the related pre- and post-sales support activities.
Ambush has entrusted some of the services of the Site - related, in particular, to customer service, hosting and delivery logistics - under management to Farfetch Platform Solutions Limited, which has been appointed as the Data Processor.
You may always contact the Data Controller to receive information on the processing and/or to exercise your rights, by writing to the e-mail address firstname.lastname@example.org or to the address of the head office at Via Filippo Turati, 12, 20121, Milan.
2. Type, purpose and legal basis of processing
Through the Site, different types of personal data are processed and collected for different purposes and in different ways. Specifically:
b) personal data provided voluntarily by the user (such as, for example, personal details, e-mail address, telephone number, password provided by filling in the registration form), or otherwise lawfully acquired during interaction on the Site with the user or through interaction with customer care in order to respond to user requests and offer the services, assistance and information requested regarding Ambush products;
c) personal data provided as part of the process of purchasing products on the Site for the conclusion of e-commerce transactions and for activities functional and instrumental to the sale, as well as for any necessary pre- and post-sales assistance;
d) personal and contact data, processed by Ambush - with your express consent - for marketing purposes, i.e. to send you (through traditional and telematic means such as newsletters, e-mails, sms, mms and smart messages) communications and updates on products, sales, promotional campaigns, events and other initiatives promoted by Ambush;
e) personal data relating to purchases and any preferences expressed by the user, processed by Ambush - subject to express consent - for the purpose of studying consumption habits and choices, in order to make products, initiatives and commercial proposals more responsive to the tastes and needs of its customers;
f) personal and contact data communicated by Ambush - against express consent - to the companies directly and/or indirectly controlled by New Guards Group Holding S.p.A. (“New Guards Group”) and to the company Farfetch UK Ltd., so that they, acting as autonomous data controllers, can directly propose and present to the user the products and services they offer.
i) the legitimate interest of Ambush in providing the services of the Site, of the user itself to properly browse the Site and/or the legitimate interest of Ambush in responding to any requests from users;
ii) the fulfilment of the contract and the obligation to fulfil pre- and post-sale obligations as well as the fulfilment of specific legal obligations arising from the contract, with regard to the purposes set out under c);
iii) any consent provided by the user for the purposes set out in points d) e) and f), (marketing, profiling and sending data to third parties for their own purposes).
3. Source of personal data
The personal data collected are provided directly by the user (through registration on the Site or as part of the sales process), with the exception of the browsing data referred to in point 2 a).
4. Study of users’ consumption habits and choices
As indicated in point 2 e) above, with your express consent, Ambush may process your personal data for the purpose of studying your consumption habits and choices, in order to make its products and initiatives more responsive to your tastes and needs.
With the help of automated tools, Ambush may process data on the date, value and frequency of purchases as well as the type of products purchased over a specified period of time. Data relating to consumption and preferences may be collected not only by tracking purchases made both on the Site and in Ambush’s physical shops, but also through the user’s iteration with Ambush and any information that the user voluntarily provides.
In any case, the sole objective of this study is to propose products, services and initiatives to customers in line with their tastes and needs, and it will be carried out in a non-invasive manner. You may at any time request clarification of the logic applied to this processing and modification of the results obtained by contacting Ambush at the contact details given.
As indicated in point 2 a) above and with the express consent of the user, Ambush may also process the user’s personal data, using automated tools, to study cookies in order to verify browsing on the Site and to propose products and services in line with browsing activity.
5. How Ambush processes personal data
However, such measures, due to the nature of the online transmission medium, cannot absolutely limit or exclude any risk of unauthorised access or dispersion of data. To this end, it is advisable to periodically check that the computer is equipped with appropriate software devices for the protection of network data transmission, both incoming and outgoing (such as up-to-date antivirus systems) and that the Internet service provider has taken appropriate measures for the security of network data transmission (such as, for example, firewalls and spam filters).
6. Compulsory or optional nature of providing personal data
The provision of personal data, in particular personal data, e-mail address, postal address, telephone number and bank details (in the case of payment by credit card) requested in the purchase form, is necessary for the signing of the contract for the purchase of products through the Site. Failure to provide such data may therefore make it impossible to conclude the purchase via the Site.
In addition, the provision of certain personal data may be necessary for the provision of other services on the Site and related to the sale or to comply with obligations arising from laws or regulations (e.g. anti-money laundering legislation). Therefore, failure to provide such data may constitute, as the case may be, a legitimate and justified reason for not performing the purchase contract or the provision of related services.
Where necessary, the compulsory or optional nature of the communication of data will be indicated from time to time, by appending an appropriate character (*) to the information required for the provision of services and the purchase of products on the Site. Failure to provide personal data indicated as optional will not result in any restriction or disadvantage to the user.
7. Categories of personal data recipients
Personal data may be known and processed by:
- providers of technical, technological, mailing, logistics and transport services and providers of services instrumental to sales;
- the parent company New Guards Group Holding S.p.A. and the company Farfetch UK Ltd;
- providers of services related to marketing and analysis activities (list management and optimisation services, management, support and hosting services, analysis and communication delivery services),
- employees and consultants, who shall act as data processors appointed by Ambush or as persons authorised to process data by the Data Controller and instructed accordingly;
- third parties such as banks, public authorities, payment service management companies, which will operate as autonomous data controllers.
The data will not be disclosed in any way and may be transferred abroad, including to non-European countries, in view of the transnational nature of the Group to which Ambush belongs. In any case, any data transfer shall always take place with adequate protection and safeguards for the protection of such data, through the use of technically secure tools and channels and through the execution of Standard Contractual Clauses, in accordance with applicable legislation.
Please note that you can always contact Ambush, as data controller, to find out the exact location of your data and to request a copy.
8. Data storage period
Personal data collected for sales purposes are retained for a period not exceeding 10 years after purchase, in accordance with tax and civil law, unless specific legal defence needs require retention for a longer period.
Personal data provided by the user when requesting assistance and information are retained for the time strictly necessary to process the request in full.
Personal data provided for marketing and profiling purposes are retained for the period necessary due to the specific processing and up to a maximum of 7 years, in line with the relevant industry.
9. Rights granted to the user
You always have the right to obtain confirmation from Ambush as to whether or not personal data concerning you exist, even if they have not yet been recorded, and their communication in intelligible form. You also have the right to obtain information on the source of your personal data, the purposes and methods of processing, the logic applied in the event of processing carried out with the aid of electronic tools, the identification details of the data controller and data processors, the names of the persons or categories of persons to whom personal data may be communicated or who may become aware of them in their capacity, for example, as data processors or persons authorised to process personal data. The user also has the right to request the updating, rectification or, when interested, integration of personal data, the erasure, transformation into anonymous form or blocking of personal data processed in violation of the law, including those that do not need to be retained for the purposes for which the data were collected or subsequently processed, as well as certification that the above operations have been brought to the attention of those to whom the data have been communicated, except where this proves impossible or involves a manifestly disproportionate effort compared to the right protected. The user also has the right to data portability. The user has, however, the right to object in whole or in part, on legitimate grounds, to the processing of personal data concerning him or her, even if pertinent to the purpose of collection, to the processing of personal data concerning him or her for the purpose of sending advertising or direct marketing material or for carrying out market research or commercial communication, and he or she also has the right to request the restriction of the processing of data concerning him or her. The right to object may also be exercised specifically with regard to one or more of the methods of sending marketing communications.
The rights listed above may be exercised by contacting the Data Controller, writing to email@example.com.
Finally, please note that it is always possible to lodge a complaint with the competent Supervisory Authority (Data Protection Authority).