Privacy Policy

Privacy Policy

This Privacy Policy (the " Policy") is developed by Philipp Plein Rus, Limited Liability Company, registered at: 4th Lesnoy per., bld. 13, premise I, office 10, Moscow, 125196, Russia, Primary National Registration Number (OGRN): 1177746896227, TIN: 9710033712 (the " FP Rus" or " we") with a view to a detailed description of our approaches to processing your personal data obtained while you are using our website at www.plein.com (the " Website").

By processing your personal data in connection with your use of the Website, FP Rus acts as an operator of personal data (as defined below) and is guided by the requirements of laws and other regulatory instruments of the Russian Federation in the field of protecting information and personal data (inter alia, Federal Law No. 152-FZ On Personal Data dated July 27, 2007, Decree of the Russian Government No. 1119 On Approval of the Requirements for Protection of Personal Data When Processing the Same via Personal Data Information Systems dated November 1, 2012 et al.).

This Policy shall be governed by Russian law.

  1. 1. TERMS USED

Please find below explanations of some terms used in the Policy.

Personal Data Operator shall mean a legal entity, which either independently or in cooperation with other persons arranges for processing and/or processes personal data and identifies the purposes of the personal data processing, composition of the personal data subject to processing and actions (operations) performed in respect of personal data. FP Rus is your personal data operator.

Personal Data shall mean any information relating to a directly or indirectly identified or identifiable individual (Personal Data Subject). You as the Website user are the Personal Data Subject.

Personal Data Confidentiality shall mean requirement binding on FP Rus or other persons who have access to personal data to prevent their dissemination without the consent of the Personal Data Subject or without other legal grounds.

Processing of Personal Data shall mean any action (operation) or cumulative action (operation) performed by FP Rus in respect of personal data with or without the use of automation means, including collection, recording, systematization, accumulation, storage, clarification (update, modification), retrieval, use, transfer (dissemination, provision, access to) depersonalization, blocking, deletion, and destruction of personal data.

Manual Processing of Personal Data shall mean any actions in respect of personal data, provided that the use, clarification, dissemination and destruction thereof are performed with the direct human involvement.

Automated Processing of Personal Data shall mean processing of personal data by means of computer facilities.

Destruction of Personal Data shall mean actions resulted in the impossibility to restore the contents of personal data on the Personal Data Information System and/or in the destruction of personal data physical media.

Cross-Border Transfer of Personal Data shall mean transfer of personal data to a foreign jurisdiction to an authority therein, to a foreign individual or to a foreign legal entity.

Personal Data Depersonalization shall mean actions resulting in the impossibility to identify the specific Personal Data Subject without additional information.

Personal Data Blocking shall mean temporary suspension of the personal data processing (except for where processing is required for the personal data clarification).

Personal Data Information System shall mean an aggregation of the personal data contained on the personal data databases and the IT technologies and technical means ensuring the personal data processing.

  1. 2. WHAT CATEGORIES OF YOUR PERSONAL DATA ARE PROCESSED BY FP RUS?

FP Russhall only process your personal data required to ensure your access to all features of the Website and to send to you information notifications as necessary. Personal Data shall be provided by you voluntarily when completing the registration form for creating an account, making orders or signing up to FP Rus marketing mailings.
Therefore, FP Rus will receive directly from you the following categories of your personal data:

  • Your name and surname;
  • Date of birth;
  • Phone number;
  • Email address;
  • Residence address;
  • Delivery address;
  • Bank card number.

Please note that you shall be responsible for the timely update of your personal data you have specified when creating and further using your account, making orders or signing up to marketing mailings.
FP Rus shall not collect your personal data from any third parties.

  1. 3. LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA

FP Rus shall only process your personal data if there are legal grounds for processing the same. FP Rus shall process your personal data in the following cases:

  • If you gave your consent requested when you were creating your account on the Website, when your order was made and delivered and when you were signing up to marketing mailings;
  • In order to perform the functions, powers and duties imposed on FP Rus by the laws of the Russian Federation;
  • In order to perform the agreement to which you are a party, beneficiary or guarantor and to enter into an agreement on your initiative or enter into an agreement to which you will be a party, beneficiary or guarantor;
  • In order to exercise the rights and legitimate interests of FP Rus or third parties, including in cases provided for by federal laws of the Russian Federation;
  • Based on other legal grounds provided for by the laws of the Russian Federation.
  1. 4. YOUR INFORMATION AUTOMATICALLY COLLECTED. USE OF COOKIES

FP Rus may use special cookie technologies to improve the Website performance and to make it more convenient to use. FP Rus understands that, to some extent, cookies should be treated as personal data, and their use should be regulated by the relevant laws. This section of the Policy explains what cookies are and how they are used by FP Rus.
What are cookies?
Cookies are small data files that the Website stores on your computer and that are used to track certain activities on the Website by storing data that can be updated and restored. These files are stored on your computer and contain data that may not harm your devices. They are used to record your preferences, such as the selected language and access data, as well as to personalize the Website.
Cookies may also be used to store information about how you use the Website, e.g., about the web page or ad banner used to visit the Website.
What types of cookies are used by FP Rus and for what purposes?
Session Cookies: temporary cookies that are stored among your browser's cookies until you leave the web page; they will not be stored on your hard drive. The information obtained with these files helps us analyze the network traffic directions. Ultimately, they enable FP Rus to improve the content of and make the use of the Website simpler.
Persistent Cookies: these files will be stored on your computer's hard drive and the Website will identify them whenever you visit it. Persistent cookies have a certain validity period and they stop functioning upon expiration. Persistent cookies enable the Website to remember information and settings for subsequent visits of users, thus making browsing websites more convenient and faster, e.g., because users need not to re-enter their registration data.
Technical Cookies: technical cookies are necessary for the correct operation of the Website and the appropriate use of different personal features and services it offers. For example, such cookies may be used for the session technical support, monitoring of response time, use or confirmation of personal preferences, use of security elements, data transfer via social media, etc.
Cookies for Personalization: these cookies help select or personalize certain Website properties, e.g., by language, regional configuration, or browser type settings.
Analytical Cookies: FP Rus shall use cookies to obtain browser setting details and analyze your behavior on the Website for the purpose of improving the Website's performance and it shall also help you select relevant products and services. In particular, using analytical cookies we will be able to receive information about the products most suitable for you, etc.
Among others, FP Rus uses the following tools, which means the use of analytical cookies:

Advertising Cookies: These files enable us to effectively manage the Website ad zones. They allow us to update the ad content so that to make it interesting to you and avoid displaying the same ads to you again.

Social Media Cookies: The Website is embedded with special buttons to facilitate the Website content sharing through different social media. These buttons may mean that the social network they are connected with uses cookies that are beyond control of FP Rus, but they are used to start and support your session on the social network or they may indicate the number of specific shares on the social network. FP Rus recommends that you regularly read any social media rules regarding privacy and use of cookies and, if applicable, modify the privacy settings so that to limit the amount of data provided and adjust them according to your preferences.
While on the Website, you can see our products or services advertised and a cookie will be installed on your browser used by FP Rus to measure ads, including ad view number, exact place and time of pop-ups, etc.
It may be that some of the cookies used on this Website are not relevant to FP Rus. This is because some web pages have elements that are received from third party web pages. These elements are obtained from webpages other than the Website pages, that is why FP Rus may not manage these cookies settings. Please contact such third party websites for obtaining relevant information if you wish to change your preferences regarding cookie settings.
Your options to manage cookie settings
We will request your consent to processing cookies additionally. If you fail to give your consent, we will only process technical cookies that are necessary for the proper performance of our Website.
In addition, you may at any time withdraw your consent to processing cookies and delete the cookies stored on your computer by changing your browser settings. Please find below the links to additional information on how to modify the settings of the relevant browser.
Chrome (RU): https://support.google.com/chrome/answer/95647?hl=ru
Explorer (RU): https://support.microsoft.com/ru-ru/help/17442/windows-internet-explorer-delete-manage-cookies
Firefox (RU): https://support.mozilla.org/ru/kb/vklyuchenie-i-otklyuchenie-kukov-ispolzuemyh-veb-s
Safari (RU): https://support.apple.com/ru-ru/guide/safari/manage-cookies-and-website-data-sfri11471/mac
Finally, if you wish to manage cookie installation, you can install in your browser special programs or add-ons known as DNTs (Do Not Track) enabling you to choose which cookies are allowed to be stored on your computer.

  1. 5. WHY DOES FP RUS PROCESS YOUR PERSONAL DATA?

FP Rus processes your personal data in order to make access to every Website feature and service available to you and to improve the Website functionalities. This involves the following processes:

  • Registration and management of your account;
  • Communication with you with regards to your use of the Website features (including via email or SMS messages);
  • Fulfillment of the orders of products you make on the Website;
  • Handling of Goods Return Request Applications;
  • Creation of a wish list and tracking changes in the prices of the products chosen;
  • Notification of any updates related to the Website, its use and features;
  • Handling any of your requests and preparing responses;
  • Providing you with high-quality user support;
  • Ensuring information security of our Website;
  • Sending advertising, marketing, news and other information materials to participants (provided that you gave your express consent);
  • Conduct of statistical and other studies based on anonymized data.
  1. 6. HOW DOES FP RUS PROCESS YOUR PERSONAL DATA?

Personal data of the Website users shall be processed by FP Rus, both without the use of automation tools (manual processing) and using automation tools, including such operations (actions) as personal data collection, recording, systematization, accumulation, storage, clarification (updating, modification); extraction, use, transfer (provision, access to), including cross-border transfer to Switzerland, Germany and Italy, depersonalization, blocking, removal, and destruction.
FP Rus shall not make decisions that give rise to legal consequences with respect to users of the Website or otherwise affect their rights and legitimate interests solely on the basis of personal data automated processing.

  1. 7. WITHIN WHAT PERIOD OF TIME ARE YOUR PERSONAL DATA PROCESSED BY FP RUS?

We will process your personal data no longer than it is required to achieve the processing objectives specified in the Policy.
Once they are achieved, FP Rus will destroy or depersonalize personal data within 30 days. We will also stop processing your personal data (and destroy or depersonalize them) if you delete your account or withdraw your consent to processing your personal data (where consent constitutes the only legal ground for processing your personal data).
Please note that in some cases we may continue to process your data upon your account deletion or your consent withdrawal where it is required to fulfill our obligations arising by virtue of the applicable laws, or where processing is necessary to protect our rights and FP Rus and/or third party legitimate interests.
Please let us know if you wish to delete your account by sending your email to russia@philipp-plein.com.

  1. 8. ARE THERE ANY THIRD PARTIES INVOLVED IN THE PROCESSING OF YOUR PERSONAL DATA?

B2B transfer of personal data
Doing business in modern conditions involves a lot of experts and legal, technical and other consultants, as well as the use of complex information systems and IT infrastructures, including in connection with the processing of your personal data and ensuring their confidentiality and security.
In particular, we deliver our products globally that is why your personal data may be transferred to the delivery services and other persons involved in the product deliveries.
In particular, our delivery and customs clearance partners include:

By involving the above mentioned entities and entrusting them with processing personal data on our behalf where it is required by law, FP Rus as an operator of your personal data shall ensure that the third parties keep your data confidential and take necessary managerial, legal and technical actions to protect the same. The third parties involved process your personal data solely for the purpose of providing us with relevant services and by performing certain operations using your personal data. They shall in no case process your personal data for purposes contrary to those specified in this Policy.
Personal data cross-border transfer within the international group of companies
FP Rus is part of Philipp Plein, an international group of companies, operating around the globe. Please note that some business processes of the group are managed by Philipp Plein International AG, the parent company located at: Via Pietro Capelli 18, Lugano, 6900, Switzerland.
In this regard, we may transfer your personal data cross the border to Philipp Plein International AG, Switzerland.
Compliance with laws, judicial and administrative procedures and disclosure obligations
FP Rus may transfer users’ personal data in the following cases (if transfer is required by and does not contradict to the applicable laws):

  • to comply with the requirements of the applicable laws, court decisions, and requests of competent government authorities;
  • in connection with the ongoing investigation;
  • to investigate or assist in preventing any violation of the applicable laws and this Policy;
  • to protect the rights, property and security of FP Rus, our affiliates, the Website users or other persons and in other cases as and where required by the applicable laws.

If you wish to know more about the third parties involved in the processing of your personal data and/or those who receive your data, please send your request to russia@philipp-plein.com and we will send you the information you want.

  1. 9. THIRD PARTY WEBSITES
  • The Website may contain links to third-party websites, while third-party websites may be also linked to our Website.
  • FP Rus shall not be liable for the processing of your personal data by these third-party websites, the policies and practices used by their owners, administrators or others with regards to the processing of user personal data.
  • That is why we strongly recommend that you read the terms and conditions of use and privacy policy of every third-party website you visit.
  1. 10. MARKETING MAILINGS, UNSUBSCRIBE OPTION, CLARIFICATION OF YOUR ACCOUNT DETAILS, ACCOUNT DELETION

We will send you marketing offers and other newsletters provided that you have given your prior express consent. You may give this consent upon registration of your account on the Website or when managing it in the use of the Website.
You may at any time withdraw your consent to processing your data for the purposes of marketing mailings and we immediately stop the relevant processing. We also guarantee that every email sent to you from FP Rus or from Philipp Plein International AG will give you an additional opportunity to refuse receiving marketing mailings in the future.
If you have already registered your account, you may modify, delete or clarify your personal data, change your settings or refuse any marketing mailings.
Please note that if you delete your account, you will not be able to access certain features of the Website.

  1. 11. WHAT MEASURES ARE TAKEN BY FP RUS IN ORDER TO PROTECT YOUR PERSONAL DATA?

Keeping your personal data confidential and secure is a key principle for their processing. To this end, FP Rus shall and will take technical, legal and managerial security measures with respect to your personal data; inter alia, it shall:

  • Designate a person responsible for managing the processing of personal data;
  • Adopt local regulations regarding the processing of personal data;
  • Enter into agreements with those engaged in processing personal data on behalf of FP Rus in compliance with the Federal Law On Personal Data;
  • Assess the harm that may be caused to users of FP Rus Website in the event of violation of the Russian laws on data protection and align this harm with measures taken to ensure the protection of personal data;
  • Inform the employees who are directly engaged in processing personal data about the provisions of the Russian personal data laws and FP Rus local regulations regarding the processing of personal data and/or train the above mentioned employees;
  • Keep up-to-date records regarding everyone who is entitled to access to personal data storage systems indicating the data processing activities that they may perform;
  • Provide unrestricted access to this Policy;
  • Protect against unauthorized break-ins to the facilities for the information system used for processing your personal data;
  • Protect information using special data protection tools (including those validated through the conformity assessment procedure);
  • Introduce appropriate modalities, including user names and secret passwords, to ensure access to personal data for authorized persons, only, and to the extent they need this access to perform their duties;
  • Verify and take measures to ensure that everyone who is entitled to access to personal data storage systems and/or folders is aware of their duties and the procedures for personal data processing, as well as of the liabilities they bear;
  • Apply reporting and troubleshooting procedures and take measures to ensure the security level as required hereby;
  • Install antivirus software to protect personal data;
  • Set mediated access to the personal data processed via FP Rus information system(s);
  • FP Rus shall keep up-to-date incident logs indicating the name of the responsible person(s), the time and consequences, if any, of the incident and the actions taken for personal data security breaches.
  • Introduce due procedures for personal data reservation and restoration;
  • Back up personal data regularly;
  • Store personal data physical media in fireproof metal cabinets and safes as required by the laws of the Russian Federation.
  • In the event of manual processing, personal data shall be segregated from other information by recording to individual physical media or entering into special sections or fields on the forms that may contain personal data.
  • In the event of manual processing, FP Rus shall not allow recording data with obviously noncompatible processing purposes to the same physical media. In this case, different, separately stored physical media shall be used for personal data with obviously noncompatible processing purposes.
  • FP Rus employees engaged in manual processing of personal data shall be informed about the features of and rules for manual processing of personal data.

FP Rus shall take other necessary legal, management and technical measures to protect personal data from unauthorized or accidental access to, destruction, modification, blocking, copying, transfer, distribution and other unlawful actions with respect to personal data, in particular, those provided for by Federal Law No. 152-FZ On Personal Data dated July 27, 2006, Government Decree No. 1119 On Approval of the Requirements for Protection of Personal Data When Processing the Same via Personal Data Information Systems dated November 1, 2012, etc.

  1. 12. YOUR RIGHTS IN CONNECTION WITH PROCESSING YOUR PERSONAL DATA

With respect to processing personal data by FP Rus, you shall have the rights to:

  • Withdraw your consent to the processing of your personal data;
  • Get access to your personal data and read them;
  • Require FP Rus to clarify, exclude or correct personal data that are incomplete, incorrect, outdated, unreliable, illegally obtained or those that are irrelevant for FP Rus;
  • Receive from FP Rus the following:
    • Information on those who have or who may be granted access to personal data (safe for employees of FP Rus);
    • List of your personal data processed and the recipient thereof;
    • Timeframes for personal data processing, including storage times;
    • Information about what legal consequences may entail personal data processing;
    • Other information in accordance with the applicable laws of the Russian Federation.
  • Require FP Rus to notify everyone who has previously been informed of incorrect or incomplete personal data about any and all exclusions, corrections or additions made;
  • Exercise other rights in the field of personal data protection stipulated by the applicable Russian laws.

To revoke your consent to processing your personal data, please send your request to: russia@philipp-plein.com. Once your consent is revoked, we will stop processing, destroy or depersonalize your data (unless further processing is required under applicable laws or allowed on other legal grounds).

  • Please note that once your consent to personal data processing is revoked, you will not be able to use your account and, therefore, you will be deprived of access to most features offered by the Website.
  1. 13. PRIVACY POLICY MODIFICATION

FP Rus reserves the right to modify and update this Privacy Policy.
Should we choose to modify or update our Privacy Policy, these updates will be posted here so that you always know how your personal data are processed.
Please note that if you disagree to the Privacy Policy, you will not be able to use all features the Website offers.

  1. 14. WHOM TO CONTACT ABOUT PERSONAL DATA PROCESSING AND EXERCISING MY RIGHTS?

You may send us your request to be able to exercise your rights and regarding any questions related to processing personal data, as follows:

  • By email to: russia@philipp-plein.com; and/or
  • By mail to: 4th Lesnoy per., bld. 13, premise I, office 10, Moscow, 125196, Russia

FP Rus will not handle anonymous requests. FP Rus may also ask you to verify your identity (by providing your passport details) before sending you a response.