Informativa sulla Privacy

The New Own S.r.l.s. ("The New Own", "TNO", "we", "us or "our") is committed to protecting the personal data of users of its website, digital platform and related services.

This Privacy Policy explains how The New Own collects, uses, stores and protects personal data when you:

• visit our website;
• create or use an account;
• browse Products;
• place or manage an Order;
• rent or purchase a Product;
• collect or return a Product;
• communicate with us;
• subscribe to marketing communications;
• participate in surveys, events or community initiatives;
• use personalisation or recommendation features;
• interact with our Platform through cookies or similar technologies.

This Privacy Policy is intended to provide the information required under Regulation (EU) 2016/679 ("GDPR") and applicable Italian data protection legislation.

The Privacy Policy should be read together with our Terms & Conditions and Cookie Policy.

1. DATA CONTROLLER

The data controller responsible for the processing described in this Privacy Policy is:

The New Own S.r.l.s.

Via Monte Somma, 8

00141 Rome (RM), Italy

C.F./P.IVA 18326341007

Registered with the Registro delle Imprese di Roma

Email: e-commerce@thenewown.com

PEC: postmaster@pec.thenewown.com

Telephone: +39 329 074 7110

The New Own determines the purposes and means of processing personal data relating to the consumer-facing Platform and the services provided through it.

For the processing activities described in this Privacy Policy, The New Own acts as the data controller.

2. DATA PROTECTION OFFICER

The New Own has not appointed a Data Protection Officer ("DPO") because, based on the nature and scope of its current processing activities, it is not required to appoint one under applicable law.

For any privacy-related question or request, you may contact The New Own directly at:

e-commerce@thenewown.com

3. WHAT PERSONAL DATA WE COLLECT

Depending on how you use the Platform, we may collect the following categories of personal data.

3.1 Identification and contact information

This may include:

• first and last name;
• email address;
• telephone number;
• billing information;
• account credentials;
• other information necessary to identify or communicate with you.

3.2 Account information

When you create an Account, we may process:

• account registration information;
• login information;
• profile information;
• account preferences;
• saved Products;
• wishlist information;
• interactions with the Platform.

3.3 Order and transaction information

When you rent or purchase a Product, we may process:

• Order number;
• Products rented or purchased;
• Brand associated with the Product;
• Rental Period;
• purchase information;
• rental history;
• transaction value;
• Deposit information;
• Coupon or credit information;
• cancellation and refund information;
• return information;
• customer service communications relating to the Order.

3.4 Collection and logistics information

To provide collection and return services, we may process:

• selected Collection Point;
• Order and collection details;
• return information;
• information necessary to coordinate logistics;
• communications relating to delivery, collection and return.

Where necessary, relevant information may be shared with the Brand, Collection Point, logistics provider or other service provider involved in fulfilling the Order.

3.5 Payment information

Payments may be processed by specialised third-party payment service providers.

Depending on the payment method used, The New Own may receive information such as:

• payment status;
• transaction identifier;
• payment method;
• transaction amount;
• limited payment-related information.

The New Own does not generally store complete payment card numbers where these are processed directly by the relevant payment service provider.

3.6 Product preferences and interaction data

We may collect information concerning your interaction with the Platform, including:

• Products viewed;
• Products added to a wishlist;
• Products rented;
• Products purchased;
• rental preferences;
• size and fit preferences;
• fashion preferences;
• search and browsing interactions;
• interactions with recommendations;
• responses to surveys;
• feedback and reviews.

This information may be used to improve your experience and provide more relevant Product recommendations.

3.7 Communications

If you contact The New Own, we may process:

• the content of your communication;
• email address;
• telephone number;
• Order information;
• attachments or documents you choose to provide;
• information necessary to handle your request.

3.8 Marketing information

Where you provide the required consent, we may process:

• email address;
• marketing preferences;
• information concerning your interaction with our communications;
• information concerning your preferences and interests where lawfully collected.

3.9 Technical and usage information

When you use the Platform, we may automatically collect technical information such as:

• IP address;
• browser type and version;
• device type;
• operating system;
• language and regional settings;
• date and time of access;
• pages or screens visited;
• referring pages;
• technical logs;
• security and authentication information;
• information concerning interactions with the Platform.

Certain technical information is collected automatically because it is necessary to provide, secure and operate the Platform.

Information concerning cookies and similar technologies is provided in the Cookie Policy.

3.10 Images and content voluntarily provided by you

If the Platform allows you to upload photographs, reviews or other content, we may process the personal data contained in that content.

You should avoid uploading personal information concerning other individuals unless you have a lawful basis to do so.

4. PERSONAL DATA WE RECEIVE FROM OTHER SOURCES

In certain circumstances, The New Own may receive personal data from sources other than directly from you.

These may include:

• participating Brands;
• Collection Point partners;
• logistics providers;
• payment service providers;
• technology and platform providers;
• fraud-prevention or security providers;
• publicly available sources;
• other service providers involved in fulfilling an Order.

For example, information concerning the availability, preparation or return of a Product may be communicated to The New Own by a Brand or logistics partner in connection with your Order.

Where personal data are received from another source, The New Own will process them in accordance with applicable data protection law and the purposes described in this Privacy Policy.

5. WHY WE PROCESS YOUR PERSONAL DATA

We process personal data for the following purposes.

5.1 Creating and managing your Account

We use your personal data to:

• create your Account;
• authenticate you;
• manage your profile;
• provide access to Platform functions;
• maintain your account preferences;
• protect your Account.

Legal basis: performance of a contract or taking steps at your request before entering into a contract.

5.2 Providing Rentals and Purchases

We use your personal data to:

• process Orders;
• provide Rentals;
• process Purchases;
• manage Rental Periods;
• manage Deposits;
• coordinate collection and return;
• manage logistics;
• process cancellations;
• issue refunds or Coupons;
• provide customer support;
• manage the contractual relationship with you.

Legal basis: performance of a contract.

5.3 Processing payments

We process information necessary to:

• confirm payment;
• reconcile transactions;
• process refunds;
• manage payment disputes;
• detect failed or fraudulent transactions.

Legal basis: performance of a contract and, where applicable, compliance with legal obligations and legitimate interests in preventing fraud.

5.4 Managing Products and inventory

We process information concerning Orders, Rentals and Product availability to:

• determine Product availability;
• coordinate Product preparation;
• organise collection and return;
• manage inventory;
• prevent double bookings;
• improve operational efficiency.

Legal basis: performance of a contract and legitimate interests in operating and improving the Platform.

5.5 Customer support

We process personal data to:

• respond to questions;
• investigate complaints;
• resolve problems;
• manage refunds and claims;
• provide assistance concerning Orders and Products.

Legal basis: performance of a contract and legitimate interests in providing customer service.

5.6 Platform security and fraud prevention

We may process personal data to:

• prevent fraud;
• detect suspicious activity;
• protect Accounts;
• prevent misuse of the Platform;
• investigate security incidents;
• maintain technical and operational security.

Legal basis: legitimate interests in protecting the Platform, its Users and The New Own against fraud, abuse and security threats, and, where applicable, compliance with legal obligations.

5.7 Compliance with legal obligations

We may process personal data where necessary to comply with legal obligations, including obligations relating to:

• accounting;
• taxation;
• consumer protection;
• legal claims;
• regulatory requests;
• data protection;
• fraud prevention;
• record keeping.

Legal basis: compliance with a legal obligation.

5.8 Improving the Platform

We may analyse aggregated or otherwise appropriately protected information concerning how Users interact with the Platform to:

• improve functionality;
• identify technical problems;
• understand Product demand;
• improve logistics;
• improve Product availability;
• develop new services;
• improve the customer experience.

Where the processing involves non-essential cookies or similar tracking technologies requiring consent, the relevant processing will only take place in accordance with the applicable consent mechanism.

Legal basis: legitimate interests and, where required, consent.

6. PERSONALISATION AND RECOMMENDATIONS

The New Own may use information concerning your interactions with the Platform, Products you have viewed or rented, preferences and other relevant information to provide personalised recommendations.

For example, the Platform may recommend Products based on:

• previous Rentals;
• Products viewed;
• wishlist activity;
• selected sizes;
• stated preferences;
• previous purchases;
• interactions with the Platform.

These recommendations are intended to improve Product discovery and the Customer experience.

Personalisation used for ordinary recommendation purposes does not by itself produce legal effects or similarly significant effects concerning you.

Where consent is required for a specific personalisation or tracking activity, the relevant activity will only take place after obtaining the required consent.

7. ARTIFICIAL INTELLIGENCE AND AUTOMATED PROCESSING

The New Own may use third-party artificial intelligence or automated technologies to support certain Platform features, including:

• Product recommendations;
• personal shopping assistance;
• fit or size recommendations;
• virtual fitting;
• other Product discovery or personalisation functions.

These systems are intended to assist Users and are not intended to make decisions producing legal effects or similarly significant effects concerning Users.

The New Own does not use AI-generated recommendations to determine a Customer's eligibility for a Rental or Purchase.

Where applicable, Users will be informed separately about AI features involving additional or particularly sensitive categories of personal data.

You may contact The New Own if you wish to obtain information concerning an automated processing activity that affects you.

8. BODY SCANNING, FITTING AND BIOMETRIC DATA

Certain future or optional Platform features may allow a User to provide body measurements, photographs or other information to receive fit or sizing recommendations.

Where a feature involves biometric data within the meaning of applicable data protection law, such data will only be processed where a valid legal basis and the additional conditions required for special categories of personal data are satisfied.

In particular, biometric data used for the unique identification of a natural person constitute a special category of personal data under Article 9 GDPR.

The New Own will not introduce a biometric identification feature without implementing the additional safeguards and legal requirements applicable to such processing.

Where an optional feature requires explicit consent, the feature will not be activated unless the required consent has been obtained.

If such a feature is not available on the version of the Platform you are using, this section does not mean that The New Own is currently collecting biometric data from you.

9. MARKETING COMMUNICATIONS

9.1 Direct marketing

Where permitted by applicable law, The New Own may send information concerning:

• Products;
• Rentals;
• new Brands;
• promotions;
• events;
• community activities;
• services;
• Platform updates.

Where your consent is required, marketing communications will only be sent after obtaining that consent.

9.2 Withdrawal of marketing consent

You may withdraw your marketing consent at any time.

You can do so by:

• clicking the unsubscribe link in a marketing email;
• changing your communication preferences in your Account, where available; or
• contacting e-commerce@thenewown.com.

Withdrawal of marketing consent does not affect the lawfulness of processing carried out before the withdrawal.

Transactional communications necessary for the performance of an Order or for account administration may continue to be sent even if you opt out of marketing communications.

10. SHARING PERSONAL DATA

The New Own may disclose personal data to the following categories of recipients where necessary for the purposes described in this Privacy Policy.

10.1 Brands

Relevant information may be shared with the Brand supplying the Product where necessary to:

• fulfil an Order;
• prepare a Product;
• manage Product availability;
• manage collection or return;
• inspect a returned Product;
• resolve Product-related issues.

The Brand receives only the information reasonably necessary for the relevant purpose.

The contractual relationship concerning your Rental or Purchase remains with The New Own.

10.2 Collection Point partners

Information necessary to identify and fulfil a collection or return may be shared with the Collection Point selected for your Order.

10.3 Logistics providers

We may share information such as:

• name;
• contact information;
• Order information;
• Collection Point information;
• delivery or return details;

with logistics providers where necessary to fulfil the relevant service.

10.4 Payment providers

Payment-related information may be shared with the payment service provider selected for the transaction.

10.5 Technology and infrastructure providers

We use technology providers to operate the Platform and related services.

Depending on the service, these providers may support:

• hosting;
• databases;
• authentication;
• email delivery;
• platform functionality;
• analytics;
• customer communications;
• security;
• automation;
• rental management.

These providers process personal data only to the extent necessary for the services they provide and, where applicable, act as processors under Article 28 GDPR.

10.6 Professional advisers

We may disclose personal data to:

• lawyers;
• accountants;
• auditors;
• insurers;
• consultants;

where necessary to provide professional services or protect The New Own's legal rights.

10.7 Public authorities

Personal data may be disclosed to courts, regulators, law enforcement authorities or other public bodies where required by law or necessary to establish, exercise or defend legal claims.

11. PROCESSORS AND THIRD-PARTY SERVICE PROVIDERS

The New Own selects service providers appropriate to the nature of the processing involved.

Where a third-party provider acts as a processor, The New Own enters into the contractual arrangements required by applicable data protection law.

Processors may not use personal data for their own purposes where they act solely on behalf of The New Own, except where they have an independent legal basis and role under applicable law.

The list of processors and relevant service providers may change as the Platform develops.

12. INTERNATIONAL DATA TRANSFERS

Some technology and service providers used by The New Own may process personal data outside the European Economic Area ("EEA").

Where personal data are transferred outside the EEA, The New Own will ensure that the transfer is carried out in accordance with Chapter V GDPR.

Depending on the circumstances, this may include:

• a European Commission adequacy decision;
• Standard Contractual Clauses;
• additional safeguards where required;
• another lawful transfer mechanism recognised under the GDPR.

Where appropriate, information concerning the relevant safeguards can be requested from The New Own.

13. HOW LONG WE KEEP YOUR DATA

The New Own retains personal data only for as long as necessary for the purposes for which they were collected, unless a longer period is required or permitted by law.

The following retention principles apply:

Category / purpose

• Retention period
• Account information
• Until Account deletion, subject to data required for legal or contractual purposes
• Order, Rental and Purchase information
• For the duration of the contractual relationship and thereafter for the period necessary to comply with legal, accounting, tax and dispute-related obligations
• Payment and accounting information
• For the period required by applicable accounting, tax and legal obligations
• Customer support communications
• For as long as necessary to resolve the request and, where relevant, to establish or defend legal claims
• Marketing data
• Until consent is withdrawn or, where applicable, until the relevant marketing relationship ends
• Technical/security logs
• For the period reasonably necessary for security, troubleshooting and incident management
• Consent records
• For the period necessary to demonstrate the validity of the consent and comply with legal obligations
• Data relating to legal claims
• Until the claim and any applicable limitation or enforcement period have expired
• Cookie/tracking information
• According to the periods specified in the Cookie Policy
• Where data are subject to multiple retention periods, the longest legally required period may apply to the relevant portion of the data.

Once the applicable retention period expires, personal data will be deleted, anonymised or otherwise securely disposed of.

14. YOUR RIGHTS

Subject to the conditions and limitations established by applicable law, you have the right to:

14.1 Access

Request confirmation as to whether we process your personal data and, where applicable, obtain a copy of those data.

14.2 Rectification

Request correction of inaccurate or incomplete personal data.

14.3 Erasure

Request deletion of your personal data where the legal conditions for erasure are satisfied.

14.4 Restriction

Request restriction of processing where the legal conditions for restriction are satisfied.

14.5 Data portability

Where applicable, receive personal data you have provided to us in a structured, commonly used and machine-readable format and request transmission to another controller.

14.6 Objection

Object to processing based on legitimate interests where applicable.

You may also object to direct marketing at any time.

14.7 Withdrawal of consent

Where processing is based on consent, you may withdraw your consent at any time.

Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

14.8 Rights relating to automated decision-making

Where Article 22 GDPR applies, you may have the right not to be subject to a decision based solely on automated processing producing legal or similarly significant effects, subject to the exceptions provided by law.

Where applicable, you may also have the right to obtain human intervention, express your point of view and contest the decision.

15. HOW TO EXERCISE YOUR RIGHTS

You may exercise your rights by contacting:

The New Own S.r.l.s.

Via Monte Somma, 8

00141 Rome (RM), Italy

Email: e-commerce@thenewown.com

Please provide sufficient information to allow us to identify you and understand your request.

For security reasons, we may ask for additional information to verify your identity before fulfilling certain requests.

We will respond within the timeframe required by applicable law.

16. RIGHT TO LODGE A COMPLAINT

You have the right to lodge a complaint with the competent data protection supervisory authority if you believe that your personal data have been processed unlawfully.

For The New Own, the relevant supervisory authority is:

Garante per la protezione dei dati personali

Piazza Venezia n. 11

00187 Rome, Italy

Website: www.garanteprivacy.it

You may also contact the data protection authority in the EU Member State of your habitual residence, place of work or place of the alleged infringement, where applicable.

17. DATA SECURITY

The New Own adopts appropriate technical and organisational measures designed to protect personal data against:

• unauthorised access;
• unlawful processing;
• accidental loss;
• destruction;
• alteration;
• disclosure;
• other unauthorised or unlawful forms of processing.

Depending on the circumstances, security measures may include:

• access controls;
• authentication mechanisms;
• encryption or pseudonymisation where appropriate;
• secure communications;
• restricted access to personal data;
• contractual controls over service providers;
• monitoring and security procedures;
• backup and recovery procedures.

No online service can guarantee absolute security. If a personal data breach occurs that requires notification under applicable law, The New Own will take the measures required by GDPR and applicable legislation.

18. CHILDREN

The Platform is not intended for children under 18 unless expressly stated otherwise for a specific service.

The New Own does not knowingly collect personal data from children for the purpose of allowing them to enter into Rental or Purchase contracts.

If you believe that a child has provided personal data to The New Own without the necessary legal authorisation, please contact us at:

e-commerce@thenewown.com

19. COOKIES AND SIMILAR TECHNOLOGIES

The New Own uses cookies and similar technologies to operate and improve the Platform.

Different categories of cookies and tracking technologies may be used, including:

• strictly necessary technologies;
• preference or functionality technologies;
• analytics technologies;
• marketing or profiling technologies.

Where consent is legally required, non-essential cookies and tracking technologies will only be activated after obtaining the required consent.

You can manage or withdraw your cookie preferences through the cookie-management mechanism available on the Platform.

For detailed information concerning the specific cookies, technologies, purposes, providers, retention periods and consent mechanism, please consult the Cookie Policy.

20. THIRD-PARTY WEBSITES AND SERVICES

The Platform may contain links to websites, applications or services operated by third parties.

This Privacy Policy does not apply to the processing carried out independently by those third parties.

Users should review the privacy policies of third-party services before providing personal data to them.

Where a third-party service is integrated into the Platform and processes data on behalf of The New Own, the processing will be governed by the applicable contractual and data protection arrangements.

21. CHANGES TO THIS PRIVACY POLICY

The New Own may update this Privacy Policy from time to time to reflect:

• changes to the Platform;
• new services;
• changes to the categories of personal data processed;
• changes to service providers;
• changes in applicable law;
• regulatory guidance;
• changes to our data protection practices.

The updated version will be published on the Platform and will indicate the date on which it becomes effective.

Where required by law, we will provide additional notice of material changes.

22. CONTACT US

For any question concerning this Privacy Policy or the processing of your personal data, please contact:

The New Own S.r.l.s.

Via Monte Somma, 8

00141 Rome (RM), Italy

Email: e-commerce@thenewown.com

PEC: postmaster@pec.thenewown.com

Telephone: +39 329 074 7110

ANNEX I

CATEGORIES OF PROCESSING AND LEGAL BASES

Processing activity

• Main data categories
• Legal basis
• Account creation and management
• Identification, contact, account data
• Contract / pre-contractual measures
• Product browsing and Platform operation
• Technical and usage data
• Legitimate interests; consent where required for tracking
• Rental management
• Identification, contact, Order, Rental and payment-related data
• Contract
• Purchase management
• Identification, contact, Order and payment-related data
• Contract
• Collection and return
• Identification, Order and logistics data
• Contract
• Deposit management
• Identification, Order, transaction and return data
• Contract
• Customer support
• Identification, contact, Order and communication data
• Contract / legitimate interests
• Fraud and security
• Account, transaction and technical data
• Legitimate interests / legal obligation where applicable
• Accounting and taxation
• Identification, transaction and billing data
• Legal obligation
• Marketing
• Contact and preference data
• Consent where required / applicable legal basis
• Personalised recommendations
• Interaction, preference and Product data
• Legitimate interests or consent where required
• Analytics
• Technical and usage data
• Consent where required; otherwise applicable legal basis for exempt analytics
• AI shopping assistance
• Product interaction and preference data
• Contract / legitimate interests / consent depending on feature
• Body/fit technology
• Measurements, images and potentially biometric data
• Explicit consent where required and applicable legal basis
• Legal claims
• Relevant account, transaction and communication data
• Legitimate interests / legal obligation

ANNEX II

CATEGORIES OF RECIPIENTS

Depending on the service used, personal data may be made available to:

1. The New Own personnel and authorised contractors;

2. participating Brands;

3. Collection Point partners;

4. logistics and delivery providers;

5. payment service providers;

6. hosting and cloud infrastructure providers;

7. database and software providers;

8. email and communication providers;

9. customer-support providers;

10. analytics and technology providers;

11. security and fraud-prevention providers;

12. professional advisers;

13. insurers;

14. public authorities and courts where legally required.

Access to personal data is limited to what is necessary for the relevant purpose.

ANNEX III

DATA PROTECTION PRINCIPLES

The New Own processes personal data in accordance with the principles of:

• lawfulness, fairness and transparency;
• purpose limitation;
• data minimisation;
• accuracy;
• storage limitation;
• integrity and confidentiality;
• accountability.

We seek to collect only the information reasonably necessary for the purposes described in this Privacy Policy and to protect that information through appropriate technical and organisational measures.

End of Privacy Policy