e1972 has implemented a robust data protection compliance program, which includes the adoption of appropriate security measures pursuant to the data protection principles of the data protection laws. The specific type and scope of personal data we collect about you depends on your activity on, and interaction with, the Websites, as described here below.
Table of Contents
- Who is the Data Controller?
- What type of Personal Data do we collect?
- Purpose(s) of the processing and legal basi
- What happens in the event you do not provide your personal data?
- How do we process your personal data?
- How long will we retain your Personal Data?
- Which subjects may become aware of/receive your Personal Data?
- What are your rights?
- California Consumer Privacy Act Rights
- Nevada Privacy Rights
- How to contact us
- Notification of changes
Who is the Data Controller?
The Data Controller of your personal data processing carried out through the Websites is
156 5th Ave, Suite 800
New York, NY 10010)
What type of personal data do we collect?
a) Personal data collected when you use the e1972 Websites for informative purposes only
Information relating to your Websites use
When you use our Websites for informative purposes only (e.g., you are visiting the Websites pages without registering on, purchasing via or otherwise submitting your personal data through the Websites), your internet browser automatically collects, and transfers to us, certain basic information relating to your website use. Such data may include:
- your browser type and version
- your operating system and interface
- language preferences
- the website from which you are visiting us (referrer URL)
- webpage(s) you are visiting on our Website
- date and time of your visit
- your internet protocol (IP) address
Personal data processed by external social media providers (“Social Media Data”):
Our Websites contain share buttons that enable you to share e1972 content with your friends through third party media platforms and/or social networks (such as Facebook (“External Platforms”). The mere use of our Websites does not generally involve data processing activities (including data transfers) in relation to the External Platforms. However, when you use the share button, these External Platforms may collect and otherwise process personal data about you. For more information about the scope and purposes of the data processed by the External Platform provider, including your rights and setting option to protect your privacy, please see the privacy notice of the respective External Platform providers.
Data processed through cookies:
b) Information collected when you reserve a product If you reserve a product through our Websites, we will collect data through the reserve form to process your reserve order.
c) Information collected when you subscribe to the e1972 newsletter If you subscribe to our newsletter or other marketing communication via the Websites in order to receive information on e1972 promotions, collections, discount campaigns, and special events, we will collect personal data through the Newsletter subscription form.
d) Information collected when you otherwise interact with us via the Websites The Websites enable you to get in touch with us in different ways (for example via e-mail telephone, etc.). The collection of personal data depends on how you interact with us and what information you provide us with. If you contact us via the ‘e1972 concierge contact form’ or if you make any service request as available on the Websites, we may collect the following personal data:
- First and Last Name
- Email Address
- Phone Number
- The content of your query
Important Notice: When we collect personal data through forms, including but not limited to electronic forms, we will indicate the mandatory fields via asterisks. Failure to provide the data marked with an asterisk could prevent you from accessing our products and/or services. While submitting any data, including multimedia content (photographs, videos etc.), please ensure it is accurate and do not transmit any sensitive data such as health information, political opinions, religious or philosophical beliefs, information on your sex life or sexual orientation, racial or ethnic origin, nor any content which is not expressly requested through a questionnaire or any other collection method (such as commercial information, advertising, personal creations, ideas, or concepts), unless this is required in exceptional cases. Our Website does not offer services specifically directed to children and persons under the age of 18, therefore we do not knowingly collect personal data from children.
Our Website does not offer services specifically directed to children and persons under the age of 18, therefore we do not knowingly collect personal data from children.
Purposes of the processing and legal basis
We process your personal data only if we have at least one of the following legal basis
- to comply with any applicable legal/regulatory obligations
- to perform our contract with you (e.g. when you reserve a product) or to take steps at your request before entering into a contract
- to pursue our legitimate interests or the ones by a third party
- once we’ve received your consent to our specific use
The purpose for which we use and process your personal data and the legal basis on which we carry out each type of processing is explained below.
|PURPOSES FOR WHICH WE PROCESS PERSONAL DATA||LEGAL BASIS FOR THE PROCESSING|
|Delivering services to users and process transactions.||It is necessary for us to process your personal data in order to deliver the services and process transactions according to the applicable contract between you and us (e.g. when you reserve a product through our Websites)|
|Sending communications to you about our products, services, promotions, offers, news, and events.||We will send electronic communications to you if you have consented to these communications. With respect to other communications it is in our legitimate interest to communicate to you about our products, services, promotions, offers, news, and events. We consider this use to be proportionate and will not be prejudicial or detrimental to you.|
|Serving advertising and offers to you based on your interests and online activities, from us or third parties||We will serve you advertising and offers to you based on your interests and online activities if you have consented to this processing|
|Improving our Websites, customers shopping experience, and quality of service.||It is in our legitimate interest to improve our offerings. We consider this use to be proportionate and will not be prejudicial or detrimental to you.|
|Providing you with information and services that you request from us.||It is necessary for us to process your personal data in order to deliver the services and process transactions according to the applicable contract between us.|
|Managing our Websites including troubleshooting, data analysis, testing, research, to keep our Websites safe and secure and to prevent detect fraud and abuse.||It is in our legitimate interest to continually monitor and improve our services and your experience of the Websites and to ensure network security. We consider this use to be proportionate and will not be prejudicial or detrimental to you.|
To unsubscribe from our “Newsletter” you may simply click on the “unsubscribe” link at the bottom of each Newsletter.
What happens in the event you do not provide your personal data?
Where the data are necessary to provide a response to a query, a service you requested or in precontractual phases (e.g. wishlist), we cannot provide any answer/service unless we have access to your personal data (i.e. email or telephone). Where the data are subject to your consent, failure in providing your personal data will not affect the provisions of services or our provision of answers to your requests in any way.
How do we process your personal data?
The processing of your personal data is carried out with appropriate procedures and measures to protect the security of your data, in terms of integrity, confidentiality and availability. e1972 uses commercially reasonable measures to keep your personal data confidential and safe. We take appropriate physical, electronic and administrative steps to maintain the security of personal data we collect, including limiting the number of people who have access to our servers, as well as employing electronic security systems and password protections that guard against unauthorized access. In addition, it is our policy to never ask you to send your payment card number via email. We use industry standard security technology in transferring information to process your orders. All payment card transactions shall take place in protected areas of our Websites, which are designed to reduce the risk of any loss, misuse or alteration of the information collected. Despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While we use commercially reasonable means to ensure the security of information you transmit to us, we cannot guarantee that such information will not be intercepted by third parties. We may, however, prosecute any unauthorized or fraudulent transactions to the fullest extent permitted by law.
Spoofing, Phishing and other risks
Spoofing and phishing and other kinds of attacks are common Internet scams. These scams may occur when you receive an email from what appears to be a legitimate source requesting personal data from you. Please be aware that e1972 will never send you an email requesting you to verify payment card or bank information. If you ever receive an email that appears to be from us requesting such information from you, do not respond to it, and do not click on any links appearing in the email.
How long will we retain your Personal Data?
e1972 will retain your personal data for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods where necessary for the establishment, exercise or defence of legal claims.
Which subjects may become aware of/receive your Personal Data?
Please note e1972 will not sell your personal data for monetary consideration. We may share your personal data in limited circumstances, such as to conduct our business, and share some data (email addresses) in rare circumstances with the Elite Model World companies in order to communicate to you about our companies new products, services, promotions, offers, news, and events.
We share your personal data with service providers that help with our business activities, including shipping vendors, billing and refund vendors, payment card processors, marketing and advertising vendors, and companies that help us improve our products and services. We require our service providers to keep your personal data secure. We do not allow our service providers to use or share your personal data for any purpose other than providing services on our behalf. Your personal data may be stored and processed by our service providers in the United States or other locations where the service providers or e1972 maintains facilities.
Legal Requirements and Protection of Our Company and Others
Transfer of your personal data
We could share your personal data with entities located in U.S. or in the European Union or everywhere in the World. In case you are a person living in the European Union, this will involve transferring your data outside the European Economic Area (“EEA”). Where personal data is transferred to and stored in a country not determined by the European Commission as providing adequate levels of protection for personal data, we take steps to provide appropriate safeguards to protect your personal data, including entering into standard contractual clauses approved by the European Commission, obliging recipients to protect your personal data.
What are your rights?
e1972 always grant you the rights to know the personal data processes and related purposes, as well as the ability to revoke the consent in case the consent is the legal basis of the personal data processing. In particular, the following rights can be exercised:
- Right of access to your personal data: You have the right to ask us for confirmation on whether we are processing your personal data, and access to the personal data and related information.
- Right to correction: You have the right to have your personal data corrected, as permitted by law.
- Right to erasure: You have the right to ask us to delete your personal data, as permitted by law.
- Right to restriction of processing: You have the right to request the limiting of our processing under limited circumstances. (*)
- Right to data portability: You have the right to receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible. (*)
- Right to object: You have the right to object to our processing of your personal data, as permitted by law, under limited circumstances.
You also have the right to lodge a complaint with the data protection authority in the European Member State of your habitual residence, place of work or place of the alleged infringement. (*) In order to exercise any of these rights, please contact us using the “Contact Us” section. Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.
(*) these rights apply only for natural persons living in the European Union
In the event you request to exercise your rights, we may need to verify your identity and, therefore, need you to provide your identifying data and contact data essential to identify and contact you with reference to your request. Possible limitations to the exercise of your rights, and to the consequent obligations of e1972, can be imposed by the applicable law.
California Consumer Privacy Rights
Effective January 1, 2020, if you are a California resident, you have expanded rights regarding the collection and disclosure of information about yourself as part of the California Consumer Privacy Act of 2018 (CCPA). Only you or your authorized representative may make these requests. You may make requests for data disclosure or portability no more than twice in a 12-month period. In your request, you must provide enough information to allow us to verify you are the person about whom we collected personal information, or their authorized representative. You must also describe your request with enough detail so that we can understand, evaluate and respond to it. We can’t respond to your request if we can’t verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity. Authorized representatives must provide a signed, written permission to make such requests or power of attorney. You may also make a request on behalf of your minor child. If you have questions about any of these rights, see section “Contact Us”. We will not discriminate against you for exercising any of your CCPA rights. This generally means we will not deny you goods or services, charge different prices or rates, provide a different level of service or quality of goods, or suggest that you might receive a different price or level of quality for goods.
What are your California Privacy Rights?
If you are a California resident, you can make certain requests regarding your personal data. We will fulfill each of these requests to the extent required by law.
- You can ask us what personal data we have about you, including a list of categories of your personal data that we have sold and a list of categories of your personal data that we have shared with another company for a business purpose.
- You can ask us to delete your personal data.
- You can ask that we stop selling your personal data.
More information on each of these requests is below:
- What personal data do you collect about me? If you make this request, we will return to you (to the extent required by law): please refer to the above description on “What type of personal data do we collect? You can ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to personal data we collected about you in the previous 12 months.
- I want to delete my personal data. You have the right to ask that we delete your personal data. Once we receive a request, we will delete the personal data (to the extent required by law) we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain website services that require your personal data to operate. Deleting your personal data may not involve also the account registration data.
- I want you to stop selling my personal data. We do not sell your personal information for monetary consideration.
Again, we will not discriminate against you for exercising your rights.
Nevada Privacy Rights
If you are a Nevada resident, in addition to the rights set forth above, you have the right to request that we do not make any sale (as such term is defined in N.R.S. 603A) of your covered information (as such term is defined in N.R.S. 603A.320) that we may have collected from you (or may collect from you in the future). We do not sell your personal information for monetary consideration, as “sale” is defined by such law, and we don’t have plans to sell this information. However, if you would like to be notified if we decide in the future to sell personal information covered by the Act, such requests should be made to our designated email address in the “How to Contact Us” section. Please allow up to 60 days for a response.
Contact Us: firstname.lastname@example.org
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Notification of changes