Last update: February 2022

Reply S.p.A. ("Reply", "we" or “us”) respects user privacy and is committed to protecting it through our compliance with this Reply Online Services Privacy and Cookie Policy ("Cookie Policy"). This Cookie Policy describes the information we collect and process related to our Reply Shop Website shop.reply.com (il "Reply Website") using automated data collection technologies, and what choices the User has with respect to the information.

This Cookie Policy applies to registered users of the Reply Website as well as those who visit the Reply Website (the “User”).

When visitors access the Reply Website, their personal data may be processed, e.g. during their browsing on the Reply Website; other personal data may be voluntarily provided by Reply Website visitors if they register to the Reply Website, as described below.

The Data Controller (or covered business) is Reply S.p.A. (registered office: Corso Francia 110, Torino - Italy).

Navigation data

IT systems and software procedures adopted for the functioning of the Reply Website, as a part of their normal functioning, collect various items of personal data. This personal data is transferred as a part of the normal course of events when using the Internet (based on TCP/IP protocol).

This personal data is not collected in order to be linked to the specific persons it refers to. However, its nature is such that, through processing and collating of data held by third parties, it may be possible to identify navigating Users.

This class of information includes IP addresses or the domain names of the computers of Users visiting the Reply Website, the addresses of requested resources (in URI, Uniform Resource Identifier format), the time of the request, the method used to forward the request to the web server, the size of the file obtained as response, the numerical code indicating the status of the response provided by the web server (e.g., successful, error, etc.) and other parameters relative to operating system and to User’s IT environment.

This data is only to be used for anonymous aggregated statistical information relative to use of the Reply Website and for control of correct functioning of the Reply Website in order to optimize its functionality in relation to the offered services.

Please note that navigation data may be used for investigations directed at identifying any persons responsible for actions classed as computer crime, which are detrimental to the Reply Website or any linked website. If no such investigations are conducted, the data relative to web contacts is destroyed within a few days.

Data provided voluntarily by User

In the registration form, visitors may provide requested personal data in order to submit their registration. Moreover, in the Reply Website section dedicated to registered Users some further data will be collected by the Reply Website during the browsing session as described below.

When e-mail messages are voluntarily sent to the addresses indicated in the address section of Reply Website/Platform, this implies the acquisition of certain items of the requesting party’s personal data, including the requesting party’s e-mail address (necessary for response to requests).

Cookies

The Reply Website uses "Cookie" technology. For information regarding the Cookies used by the Reply Website, how they are used and how to manage them, consult the "Cookie Policy" section of this document.

Personal data is processed by Reply and/or its group of companies (hereinafter, "Reply Group Companies”), and by third parties providing support on the Reply Website by means of automated and non-automated equipment. This data is processed only for no longer than is required to fulfil tasks for which the said data was collected. Conformity with specific security measures is ensured in order to prevent data losses, illicit or incorrect use, and unauthorized access.

The individuals referred to by personal data collected by the Reply Website have the right, at any time, to request access to their personal data and to obtain the correction or deletion of said data, or to limit the processing of their data, or to oppose its processing. The individuals also have the right to data portability.

The individuals whose data are processed after explicit consent, i.e. registered Users, have the right to withdraw their consent at any time without prejudice to the lawfulness of the processing based on the consent given before withdrawal.

EU residents also have the right to lodge a complaint with the competent Supervisory Authority.

Such requests are to be addressed to e-mail address shop@reply.com.

California residents may have additional rights and choices. Please see CCPA Privacy Notice for CA Residents for more information.

Reply does not knowingly use its Reply Website to request and process data from under age individuals, according to privacy law and further laws and regulations applicable in their country of residence.

The Reply Website uses Cookies (the “Cookies”) to make its services simple and effective for visitors and registered users accessing the contents visible only to them.

Cookies are text files, or parcels of information sent from a Reply Website to the User's browser, which are memorized on the computer and automatically returned to the server every time the Reply Website is accessed.

There are various types of Cookies, some used to make using the Reply Website more efficient, others to enable certain functions. Cookies can:

- memorize entered preferences;

- prevent Users from having to re-enter the same information several times during their visit, for example username and password;

- analyze in an anonymous way the use of the services and contents provided by the Reply Website visited in order to optimize the browsing experience and services offered;

- carry out anonymous or personal statistical analysis.

The types of Cookies used by the Reply Website are listed below and grouped according to the purpose for which they are used

Technical and strictly necessary Cookies

These Cookies allows certain portions of the Reply Website to function correctly and are essential in order to allow the User to browse the Reply Website and use its features (e.g. session cookies). Such Cookies do not require prior consent from the User.

There are two categories of technical cookies:

- Persistent: used to store information, such as the login name and password of the User, in order to prevent the same User from typing them again each time he/she visits the Reply Website. These remain stored on the computer even once closed the browser.

- Session: used to store temporary information, allowing the User to link actions that are executed during a specific session, and are removed from the computer when the browser is turned off.

Such Cookies, always sent by the Reply Website, are necessary for the correct visualization of the Reply Website and, in relation to the technical services offered and purchased, will therefore always be used and sent (unless the User modifies the settings in his or her browser). Included in this category are the persistent Cookies used to allow the User to register with the Reply Website and access Reply Website restricted area.

The aforementioned Cookies used by the Reply Website avoid the need to use other data processing techniques which could potentially reduce the confidentiality of the Users' navigation of the Reply Website, and do not permit the acquisition of identifying personal information regarding the User.

This type of Cookies include also third-party analytics cookies used to gather information regarding how the User uses the Reply Website for aggregated statistical analysis and to improve and simplify the use of the Reply Website.

The Reply Website uses Google Analytics (a web service provided by Google, Inc.) in anonymous way in order to measure visits to the Reply Website and to improve use of the Reply Website. This type of Cookie gathers information anonymously regarding how the Users use the Reply Website. For more information, please visit the Google Analytics site.

Reply does not use this information to identify Users or to combine such data with other data.

Remark: The Reply Website uses ShareThis, operated by ShareThis Inc., 4005 Miranda Avenue, Suite 100, Palo Alto, CA 94394, USA ("ShareThis"), which displays a widget that allows User to interact with social networks and external platforms and share contents of the Reply Website on the various social networks like Twitter, Facebook, etc. ("Social Networks"). Such social buttons are only links which, if voluntary clicked by the User, redirect this latter to the shown Social Networks on which the User may select his/her cookies preferences.  ShareThis may place cookies on User device and further information may be collected when the User chooses to interact with ShareThis, such as by clicking on the sharing icons. User browser may furthermore build up a direct connection with the servers of the Social Networks which may place cookies on User device for their own purposes. Reply does not have control over the collection, storage and use of any such information by ShareThis or the respective Social Networks and does not have any access to the information collected by them. The User should read ShareThis' and the respective Social Networks' privacy policies carefully before use any of their features. If the User doesn’t want such cookies it is sufficient not to click on such social buttons. If the User afterwards intends to remove them, he/she may follow the instructions in the privacy policies of the Social Networks and ShareThis.

For EU residents, according to Cookie Law (2009/136/CE Directive), the Reply Website is not obliged to request consent for Technical and strictly necessary Cookies, as they are necessary in order to provide the services requested. They are therefore installed automatically by the Reply Website during the User's first visit to any page of the Reply Website.

When the User accesses the Reply Website a special banner (“Cookie banner”) informs the User that the Reply Website uses only Technical and strictly necessary Cookies.

The User has the opportunity to delete individual Cookies from his or her device by consulting the 'Help' menu in the internet browser.

To delete Cookies from the internet browser of a smartphone/tablet, the User should refer to the device's user manual to find further information.

The User can learn more about cookies and how to block cookies on different types of browsers by visiting https://www.allaboutcookies.org.

Reply provides the User with this Cookie Policy pursuant to Section 13 of EU Regulation No. 679/2016, concerning the protection of individuals with regarding to the processing of personal data.

The Data Controller for the processing of User personal data is Reply S.p.A., with a registered office in Corso Francia n. 110, Turin, Italy, represented by the pro tempore legal representative.

If the User has questions or concerns about our collection or use of his or her personal data, the User can contact our EU Data Protection Officers (DPO) at:

- DPO Italy: dpo.it@reply.it

- DPO Germany: dpo.de@reply.de

- DPO UK: dpo.uk@reply.com

If the User is unsatisfied with the way in which we have handled User personal data or any privacy query or request that the User has raised to us, the User has the right to complain to the appropriate National Data Protection Authority (“DPA”). To find the contact details of the DPA in the User country of residence, the User can visit the EU Commission’s directory of DPAs.

If the User is a resident of the State of California, the User is entitled to request information regarding the disclosure of User personal information to third parties for direct marketing purposes, and opt-out of such disclosures. Please note that we do not share User personal information with non-affiliated third parties for such purposes, and we do not sell User personal information. California residents may have additional rights and choices. Please see CCPA Privacy Notice for CA Residents for more information.

Reply provides the User with this Cookie Policy pursuant to Law No. 13.709/2018 (LGPD), that is concerning the personal data protection of individuals with regarding to the processing of data. If the User has questions or concerns about our collection or use of User personal data, the User can contact us at:

- Brazil: privacy.security.br@reply.com

We will answer data subjects’ requests within 15 (fifteen) days upon receipt.

We may make changes to this Cookie Policy from time to time. The “Last Update” noted at the top of this page shows when this Cookie Policy was last revised. Any changes will become effective when we post the revised Cookie Policy on this site.

If the User has any comments or questions regarding this Cookie Policy or our data handling practices, please contact us at shop@reply.com The User may also send us a letter at the following address:

Reply S.p.A.
Corso Francia n. 110
Torino, Italy