Privacy Policy

Last Updated: August 10, 2021

This Privacy Policy (“Privacy Policy”) is aimed at illustrating the means and purposes of the processing of personal data carried out by Launchmetrics through the websites launchmetrics.com/fr/it/es/ (“Website” or “Websites”). 

When we refer to “Launchmetrics”, “we”, “us” or “our”, we mean Fashion GPS Inc. In accordance with the applicable legislation on data protection, Launchmetrics is the Controller pursuant to the EU General Data Protection Regulation 2016/679 (“GDPR”) (or Business under the California Consumer Protection Act – “CCPA”) of the Personal Data referred to in this Privacy Policy.

Our Privacy Policy is applicable to anyone who accesses and visits the Website or otherwise interacts with the web services offered on the Website (“User”, “you” or “your”).

As a general principle, please consider that the Processing of the Personal Data carried out by Launchmetrics for the development and management of the Websites is made in compliance with the applicable laws, and is based on the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and accountability.

Any term indicated in capital letters shall have the meaning attributed to it within the GDPR or in the CCPA, or otherwise provided hereto.

Please read this statement carefully to understand our policies and practices regarding your information and how we will treat it, and in case of doubts or questions please feel free to contact us at dpo@launchmetrics.com.

Data Controller and Data Processors

The Controller (or Business under CCPA) of your Personal Data processed through the Website is:

Fashion GPS Inc., a Delaware corporation having its principal offices at 115 E 23rd Street, Floor 6, New York NY 10010 (“Controller”, “Business” or “Launchmetrics”).  

For the purposes of satisfying Users’ requests made through the Websites, or to provide any of the services available on the Websites, the Controller may share or disclose User’s Personal Data to its affiliates. In such events, and depending on a case by case basis, each affiliate will be considered a Processor for the purposes of GDPR.

A full list of Launchmetrics affiliates can be found here.

What Does This Privacy Policy Cover?

This Privacy Policy covers the processing of Users’ Personal Data gathered when they are using, accessing or otherwise interacting with the Websites (e.g., customer services inquiries, newsletter subscriptions, etc.).

This Privacy Policy also covers the processing of any Personal Data that our business partners share with us or that we share with our business partners, for the purposes of publishing news, reports or blogs on the Websites.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third-party websites, services and applications (“Third-Party Services”) that you elect to access through the Websites or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third-Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third-Party Services. We encourage you to carefully review the privacy policies of any Third-Party Services you access.

Please consider that the Websites incorporate links and QR code (like the WeChat QR code) which allow you to connect to other websites run by third parties. Please consider that we do not assume any responsibility regarding the processing of Personal Data which may take place through and/or in connection with third-parties’ websites.

Therefore, whenever you access such web pages and/or social media platforms through the Website, you must carefully read the relevant privacy policies in order to better understand how your Personal Data will be processed by the third parties which, as autonomous controllers, will provide and manage such websites

Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

Please make reference to the Launchmetrics Cloud Privacy Notice to know how we process your Personal Data as a user of the Launchmetrics services.

What Information Do We Collect and Receive?

The data we gather and process through the Websites enables us to personalize, improve and continue to operate the Websites. In connection with certain aspects of the Websites, we may request, collect and/or display some of your Personal Data. 

In particular, we collect the following types of information from our Users:

Usage Information:

  • IP Address Information and Other Information Collected Automatically. We automatically receive and record information from your web browser when you interact with the Website, including your IP address and cookie information. Generally, the Website automatically collects usage information, such as the number and frequency of visitors to the Website. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally, and in any case these information are not made public. Indeed, this type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Website so that we can analyze and improve them. We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.
  • Aggregate Information. Without prejudice to the above, we also collect statistical information about how, collectively, users use the Website (“Aggregate Information”). Some of this information is derived from Personal Data. This statistical information cannot be tied back to you or your web browser. We share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use the Websites and their services or websites, which facilitates improving both their services and how the Websites interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non-Personal Data about you that they have independently developed or acquired.
  • Device Identifiers. When you access the Websites by or through a mobile device (including but not limited to smart-phones or tablets), we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by us. A device identifier may convey information to us about how you browse and use the Website. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Website. Some features of the Website and Website may not function properly if use or availability of device identifiers is impaired or disabled.
  • Profile Preferences. In order to improve the type of content you receive through our subscription channels, we use in our contact & content forms a feature that is called ‘Progressive Profiling’. It is the tool we use for marketing automation and it records your visit through session cookies. Once your IP is identified, the type of information that we ask you through our forms may vary when you access or download content two or more times on our Website. In this way, your profile in our database platform is progressively enriched and allows us to offer you a unique and personalized experience through our emails according to your profile and interests. To avoid features such as the ‘Progressive Profiling’ of our forms, you can always perform your browsing in incognito mode (more info here) or deactivate your browser cookies (Check our Cookies Policy here).
  • Location Data. When you access the Website by or through a mobile device, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device. Location data may convey to us information about how you browse and use the Website and Website. Some features of the Website, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled. Implementation of Location-based services may vary depending on where you are accessing the Website from.

Personal Data Provided by You

If you submit an inquiry through the Website, or you fill in a contact or subscription form provided in the Websites, we may collect Personal Data such as your first and last name, your current job and employer, your email address and telephone number and the country where you are currently located, as well as your message. Before you submit an inquiry providing for your Personal Data you will be asked to tick a checkbox providing your consent so we are sure that you understand the reason why we may collect such information and you will also be provided with a link to this Privacy Policy.

Moreover, when you submit an inquiry, you will always be asked for permission before we send marketing communication (e.g. newsletters and Discover coverage newsletter, campaign emails, etc). Please consider that if you DO NOT wish anymore to receive marketing communication from us, send us an email: dpo@launchmetrics.com or directly unsubscribe from marketing communications by clicking on the unsubscribe link.

Without prejudice to the above, you are free to explore the Websites without providing directly any Personal Data about yourself but some information may be collected automatically. If some information, such as contacts’ details is not provided, we may not  be unable to satisfy your request made through the Websites.

Cookies

The Websites uses first and third parties cookies and similar tracking technologies (including web beacons to analyze which emails are opened, or links clicked), which may collect information about you via the Websites and across other websites and online services. For more details about how we use these technologies, please see our Cookies Policy.

Why We Collect Personal Data and Lawful Basis to Do So?

Your Personal Data will be processed by Launchmetrics in accordance with your instructions, and as required by any applicable laws.

In particular, we will process your Personal Data:

  • to fulfill any request made by you through the Websites. This processing is needed to provide you with the information you have directly requested, by granting your freely and informed consent, according to Art. 6.1, a) of GDPR; 
  • for marketing purposes (for example via the subscription to our newsletter) provided that you granted your consent to this specific purpose, pursuant to Art. 6.1, a) of GDPR;
  • for our legitimate interest, for example to improve the Websites, to prevent frauds, ensure cyber security of the Websites, or to defend ourselves in case of disputes or claims, pursuant to Art. 6.1, f) of GDPR, and provided that your interests do not overridden ours;
  • to comply with obligations set forth by applicable laws and regulations and to ascertain responsibilities in case of any computer crimes against the Website. As this processing is mandatory by law, User’s consent is not required according to Art. 6.1, c) of GDPR.

Please also remember that if you choose to provide Personal Data using certain network features of the Websites, then that information is governed by the privacy settings of those particular features and may be available to others. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Website.

Is Information About Me Secured?

We work hard to secure your Personal Data from any unauthorized access to or unauthorized processing, alteration, disclosure or destruction of Personal Data we hold by taking appropriate technical and organizational security measures, having regard to the state of the technological development and the cost of implementing any measures. Where appropriate, for example, we might implement pseudonymization and encryption of Personal Data.

Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

Please consider that we store all of our information, including your IP address information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Data or otherwise.

Where it is likely that a breach results in a risk to the rights and freedoms of individuals, we will notify the relevant supervisory authority within 72 hours of becoming aware of it. This information can be provided in phases to facilitate fast and efficient reporting.

Where a breach is likely to result in a high risk to the rights and freedoms of individuals, we will notify those concerned directly. If you have any questions or concerns regarding security using the Website, please send a detailed message to security@launchmetrics.com or to dpo@launchmetrics.com.

How Long Do We Conserve Your Data?

Launchmetrics will retain your Personal Data in accordance with your instructions, and as required by applicable laws and only for the period of time necessary to fulfill the specific purposes for which the Personal Data were collected or further processed, if for compatible purposes.

What Happens When There are International Data Transfers?

We are a global organization, as such, we may share information about you within Launchmetrics offices and with affiliates and transfer it to countries in the world where we do business in connection with the uses identified above and in accordance with this Privacy Policy.

In some cases, we use suppliers located in various countries to collect, use, analyze, and otherwise process information on its behalf. It is our practice to require such suppliers to handle information in a manner consistent with our policies and applicable laws. Overall, we commit to comply with any legal requirements provided under any applicable law to transfer Personal Data to third countries.

In particular, for transfers of Personal Data outside of the EEA falling within the scope of application of GDPR, we are making sure that any of these transfers are supported by the strict legal compliance of our suppliers to the GDPR. In particular, depending on the concrete case, we rely on European Commission Adequacy Decisions, or EU Standard Contractual Clauses (also called Model Clauses) to meet the GDPR requirements.

When necessary, compliance can be achieved if suppliers use an approved certification mechanism. 

If you would like to receive more information on the appropriate safeguards we implemented to transfer your Personal Data, please contact us at dpo@launchmetrics.com

Notice for Users Located in the People’s Republic of China

The content of this section is intended exclusively for the benefit of Users who are accessing the Websites from the People’s Republic of China (“China”), and it must be construed in addition and not in lieu of the full Privacy Policy.

In particular, the purpose of this section is to inform Users accessing the Website in China (“Chinese Users”) that for the purposes indicated in section “Why We Collect Personal Data and Lawful Basis to Do So”, we might transfer Chinese Users’ Personal Data outside China. Provided that, we will consider to have received Chinese Users explicit consent to the data transfer every time that he or she will interact with the Website (for example, when he/she signs up to the newsletter, requests information through the contact form etc.).

For the sake of clarity, Chinese Users’ Personal Data might be transferred among the companies affiliated to Launchmetrics, as well as to its service provider, for the purposes indicated above. We will not sell any Chinese Users Personal Data to third parties. Any Chinese Users wishing to know which entities received their Personal Data, can contact Launchmetrics at privacy@parklu.com.

Who can access my Personal Data?

As a general principle, your Personal Data will be shared and made available or otherwise processed in strict compliance with the principle of the “need to know”. Unless upon your specific consent or as otherwise required by applicable laws, your Personal Data shall not be shared with any other organizations.

Without prejudice to the above, Your Personal Data might be shared with:

  • Entities affiliated to Launchmetrics, which will act as data processor pursuant to GDPR. The complete list of the entities affiliated to Launchmetrics can be found here.
  • Analytical Services. We use certain analytics providers (including but not limited to Google Analytics, Inspectlet, Google Optimize, Hotjar) in order to better understand how the Website is used and how it can be improved. Your IP address information may be accessed by one or more of such analytics providers. In addition, information regarding the usage activity of a certain portion of users of the Website may be shared, but such information is shared on an anonymous basis and does not reveal the identity of any individual User. These providers do not collect any personal information or store IP addresses locally on their websites.
  • Service provider. We might share your Personal Data with our service providers (e.g. cloud providers, Website providers) for the purposes of managing your requests/interactions with the Websites. 
  • Agents. We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Data with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Data or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Data with our Agents. 
  • Potential business partner. In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy.

Please also consider that we reserve the right to access, read, preserve, and disclose any information as it reasonably believes is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Notice for California residents

The content of this section is aimed solely at providing California residents with relevant information under the CCPA and only applies to Personal Information for which Launchmetrics is a Business (as defined in the CCPA). It must be construed in addition and not in lieu of the full Privacy Policy.

Information we may collect:

California law requires us to disclose certain information regarding the Personal Information we collect in the 12 months prior to the effective date of this Privacy Policy. We have collected Personal Information from you, your devices, our partners, third parties, and from categories of sources otherwise described above in this Privacy Policy.

Although we do not sell Personal Information in exchange for any monetary consideration, the CCPA defines a sale in a way that may include allowing third parties (website analytics companies, providers of email services, and security vendors and event sponsors/partners) to receive certain combined Personal Information such as, identifiers and commercial information that are collected directly from you and Internet or other electronic network activity (e.g. cookies) collected from your usage of the Website.

We do not sell personal information in exchange for any monetary consideration. We share Personal Information as necessary for certain business purposes, as defined by the CCPA (Cal. Civ. Code 1798.140(d)) and described in the section “Why We Collect Personal Data and Lawful Basis to Do So” of this Privacy Policy. California residents may opt out of the sale of their Personal Information. While Launchmetrics does not sell Personal Information in exchange for any monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA. In order to provide you with control over how your Personal Information is collected and shared, if you would like to opt out of Launchmetrics’ use of your Information for such purposes (when considered as a sale), you may do so by contacting us directly. With respect to cookies, you can customize your settings when you access the Website and change them at any time.

Your rights:

Under the CCPA, you have the following rights:

  • Right to Know and Access: You have the right to request that we disclose to you the (i) categories of Personal Information we collect, use, or share, (ii) purposes for which the Personal Information is collected or used by us, (iii) categories of sources from which we collect the Personal Information, and (iv) information about our data practices;
  • Right to Delete: You have the right to request that we delete the Personal Information we currently hold about you. If you ask us to delete some or all of your information that is needed to provide the Service to you, you may no longer be able to access or use the Services.
  • Right to Equal Service: We will not discriminate against you for exercising any of these rights.

Please note that these requests apply only to information that Launchmetrics holds as a Business. If your request relates to the Personal Information collected through a third party’s website or services, you should direct your request to the owner of that website or service.

If you have additional questions about this section or how to exercise your rights under the CCPA, please contact us at dpo@launchmetrics.com. The CCPA allows California consumers to designate an authorized agent to exercise their rights under CCPA. If we receive a request from an agent, then we have the right to verify that you indeed want to take the action requested by the agent and will do so by contacting you directly.

California’s Shine the Light Law:

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Data that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following email address: dpo@launchmetrics.com. The request should attest to the fact that you are a California resident, and provide a current California address.

Your rights under GDPR

Pursuant to GDPR, you have a number of rights concerning the Personal Data that We hold about you. You can exercise any of these rights, by using the contact details set out below:

  • The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and about your rights. This is why we are providing the information in this Privacy Policy.
  • The right of access. You have the right to obtain access to your Personal Data subject to the data Processing. This will enable you, for example, to check that we are using your Personal Data in accordance with the relevant data protection law. You may access the information we hold about you in this way, using the Contact information section.
  • The right to rectification. You are entitled to have your Personal Data corrected if it is inaccurate or incomplete. You can request us to rectify any errors in information that we hold by contacting us (please see section How to contact us?).
  • The right to erasure. Also known as ‘the right to be forgotten’, it enables you to request the deletion or removal of certain Personal Data that we hold about you by contacting us (please see section How to contact us?). Pursuant to applicable laws we may not have all your Personal Data erased.
  • The right to restrict processing. You have rights to ‘block’ or ‘suppress’ certain further use of your Personal Data. When processing is restricted, we can still store your Personal Data, but will not use it further.
  • The right to data portability. You have the right to obtain your Personal Data in an accessible and transferrable format so that you can re-use it for your own purposes across different service providers. This is not a general right however and there are exceptions. To learn more please get in touch (please see section How to contact us? here below).
  • The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your Personal Data with the relevant national Data Protection Authority (please find here the list of European Data Protection Authorities https://edpb.europa.eu/about-edpb/board/members_en).
  • The right to withdraw consent. If you gave your consent to extensive processing that we do with your Personal Data (i.e. we rely on consent as a legal basis for processing your Personal Data), you have the right to withdraw that consent at any time. You can do this by contacting us (please see section How to contact us? here below). Withdrawing consent will not however make unlawful our use of your information while consent has been apparent.
  • The right to object to processing. You have the right to object to certain types of processing. You can for example object to the publication of pictures taken of you within the context of a conference. To exercise this right, please get in contact (please see section How to contact us? here below).
  • The right to not be subject to automated individual decision-making. You have the right not to be subject to a decision solely based on automated processing, including profiling. To exercise this right, please get in contact (please see section How to contact us? here below).

Where you wish to exercise their rights in the context of one or several specific processing operations, please provide their description in the requests.

Your requests will be handled within a maximum of 30 (thirty) working days.

We will maintain complete and accurate records and information to demonstrate our compliance with our obligations under this Privacy Policy and also for audits conducted by you or on your behalf.

How do you Protect Children’s Privacy?

Launchmetrics does not knowingly collect Personal Data from children under the age of thirteen (13). If you believe we might have any information from or about a child under thirteen (13), please contact us at: support@launchmetrics.com or at dpo@launchmetrics.com.

Do you have a Data Protection Officer?

Yes, if you would like to communicate with our Data Protection Officer, please send a message to dpo@launchmetrics.com.

How to contact us?

If you have any questions or concerns regarding privacy using the Websites, please send us a detailed message to dpo@launchmetrics.com. We will make every effort to resolve your concerns.

Which companies are part of the Launchmetrics Group?

  • Fashion GPS Inc. d/b/a Launchmetrics, a Delaware corporation having its principal offices at 115 E 23rd Street, Floor 4, Suite 420, New York NY 10010.
  • Fashion GPS Europe Ltd. t/a Launchmetrics, a limited company incorporated in England and Wales under
    company number 06575966 whose registered office is at 2 Kingly Court, London W1B 5PW, United Kingdom.
  • Launchmetrics France S.A., a limited liability company [a French société anonyme] having its office at 16-18 rue de Londres, 75009 Paris registered with the Commercial Register of Paris under the number 442 748 455.
  • Visual Box S.r.l., a limited liability company [società a responsabilità limitata] with registered office in Via Andrea Solari 11, Milan, Italy Tax code and VAT number 13078140152.
  • Launchmetrics Spain, S.L., a Spanish private limited liability company having its office in Madrid, Spain, at Calle Orense, 62, and registered with the Commercial Register of Madrid under the number M-380293.
  • Launchmetrics Germany GmbH, registered with Amtsgericht München HRB 245516.
  • PARKLU PTE. LTD., a Company incorporated in Singapore whose registered office is situated at 2nd Floor Beach Center, 15 Beach Rd, Singapore.
  • Park Lu Consulting (Shanghai) Limited, a limited company with registered address Room 408~409, 4F Silver Court, No.85 Taoyuan Road, Huangpu District, Shanghai.
  • Park Lu Limited, a Company incorporated in Hong Kong whose registered office is situated at 18/F, Suite D, High Block, H Code, 45 Pottinger Street, Central, Hong Kong.

Changes

We have the sole discretion to modify this Privacy Policy, where appropriate, we will notify you of any changes to this Privacy Policy, for example by email.

English Version Controls

Non-English translations of this Privacy Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.


Additional information on privacy and data protection concepts and principles can be found in the Data Protection Resource Center Page here.