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Privacy Policy

PRIVACY POLICY

BROS USA CORPORATION as Data Controller and the Internal Data Processor, Lanfranco Beleggia, provide details on how to manage your personal data in accordance with the provisions of the United States Privacy Law and the California Consumer Privacy Act.

 It specifies that this information will be updated every time that by law and / or Company procedure, changes will be made to the current method of managing your personal data.

 

  1. Data Controller

Below shows the references of the Data Controller and the Data Processor

Data Controller
BROS USA CORPORATION

169 EAST FLAGER STREET

SUITE 1022MIAMI, FL 33131

E-mail   beatrice.beleggia@brosmanifatture.it

Phone 001 305 381 9558

Data Processor: Lanfranco Beleggia

The updated list of data processors and persons in charge of processing is kept at the headquarters of the Data Controller.

 

  1. Methods of access to this Privacy Policy by Consumers with disabilities

The customers who want to receive a copy of this Privacy Notice in an alternative format can contact us at the e-mail address beatrice.beleggia@brosmanifatture.it

 

  1. Type of data processed

This privacy statement applies to personal information received voluntarily by the customers of BROS USA CORPORATION, including through the website www.brosway.us.

BROS USA CORPORATION will ensure that the management of all data processed by its offices complies with this privacy statement.

The categories of personal information, by way of example and not limited to, that are processed and collected are:

  • Identifiers such as name and surname, alias, Internet protocol address, e-mail address, account name;
  • “Personal information” means all information that identifies, relates to, describes or can be associated with a specific person, including but not limited to, name, signature, social security number, physical characteristics or descriptions , address, phone number, passport number, driver’s license or state ID number, insurance policy number, education, occupation, employment history, bank account number, credit card number, card number debt or any other information of a financial or medical nature as well as relating to health insurance. The term “personal information” does not include publicly available information that is legitimately made available to the general public by federal, state or local government records.
  • Characteristics of categorisations protected under California or federal law, including age (40 years or older), race, skin color, ancestry, country of origin, citizenship, religion or belief, marital status, health status, physical disability or mental, sex (including gender, gender identity, gender expression, pregnancy or birth and related health conditions), sexual orientation, military or veteran status, as well as genetic information (including family genetic information).
  • Commercial information, products or services purchased, obtained or considered as well as other historical or trends of purchase or consumption.
  • Education information, defined as information dissimilar to publicly available personally identifiable information as specified in the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99).
  • Conclusions deduced from any of the above information for the creation of a consumer profile that reflects their preferences, characteristics, psychological tendencies, predispositions, behaviors, attitudes, skills and attitudes.
  1. Legal basis of the processing

The legal bases relating to data processing activities concern the current privacy legislation in the United States and the California Consumer Privacy Act (CCPA).

  1. Purpose of the treatment

The data is processed and stored for the management of commercial and administrative relations relating to the production and sale of jewelry and accessories for men and women by BROS USA CORPORATION.

Furthermore, your personal data can be managed to provide, manage and support our website www.brosway.us and related Services; address and resolve customer service, security and support issues; detect, prevent or otherwise address technical problems; detect, prevent or otherwise address issues involving fraud, security or wrongdoing; comply with the applicable legal provisions; fulfill and execute contractual commitments and obligations; improve and enrich our websites and related Services; return analytical data or valuable information to customers and users; update, manage, use and analyze the data in our possession; identify customers for marketing purposes as well as provide products, services, advertisements and other communications of potential interest to users; understand how users use our websites, which features they value most and which least, as well as any problems they encounter that need to be resolved.

We strive to limit the categories of personal data of our users in order to include only the information necessary to achieve the objectives and we do not use data for purposes incompatible with the above.

  1. Categories of Third Parties with whom personal data is shared

Personal data can be shared with the following subjects:

– affiliates;

– suppliers and service providers for the commercialization of products and for marketing;

– channel partners and resellers;

– third parties as required by law, by an administrative measure or by similar provisions;

– third parties in relation to mergers, sales, transfers of assets.

  1. Transfer of data

BROS USA CORPORATION is headquartered in Miami FL. The information that is collected and stored can be transferred, controlled and processed in the United States and / or in other countries around the world.

  1. Right to request

The interested party has the right to receive clear information on the methods and purposes of processing his data. He is required to give his explicit consent which he can revoke at any time. However, it should be noted that this revocation does not affect the lawfulness of the processing based on the consent issued before the revocation itself. The interested party has the right to access his data together with the right to obtain the correction of any inaccurate information concerning him.

Under the CCPA, users have the right to request the deletion of personal information concerning them collected or stored by BROS USA CORPORATION. Users who wish to request the deletion of personal information or receive information on the autonomous procedures for deleting data (if available) can visit the support portal of BROS USA CORPORATION on the website www.brosway.us or send to the following address e-mail beatrice.beleggia@brosmanifatture.it an e-mail message with the words “Request to Delete” in the subject line, taking care to specify which personal information they wish to be deleted, which may concern their entirety under the CCPA.

Requests are subject to our ability to verify the identity of the applicant in compliance with the aforementioned regulations.

  1. Right to explicitly refuse consent to the transfer of personal information

Users have the right to explicitly refuse their consent to the transfer of their personal information. We do not give away users’ personal information nor have we done so.

  1. Authorized representative

Users, in California only, can designate an authorized representative to make a request on their behalf under the CCPA if:

– the authorized representative is a natural person or a commercial entity registered in the office of the California Secretary of State; is

– sign a written declaration in which they legitimize the authorized representative to act on their behalf.

Users who make use of an authorized representative to submit the request to exercise the right to knowledge or elimination are required to ensure that the representative in question follows the procedure described in Article 8.

 

Bros USA Corporation maintains technical data related to the connections (log) to allow for security checks required by law and in order to improve the quality of our services and customize them according to the needs of users/visitors.

In accordance with current legal dispositions on the matter, Bros USA Corporation manages the registration of log files. These data don’t allow any identification of the users if not following operations of elaboration and interconnection, and necessarily by means of the data from other providers.

Operations that will be carried out exclusively under request of the Judicial Authorities, allowed to do that conforming to legal provisions to prevent and/or prosecute crimes.

On brosway.us sites we use temporary files (cookies) which will allow a faster access to the website. A cookie is a piece of information, active for the duration of the connection, which is transmitted from brosway.us to your computer in order to allow easy identification.

The user can disable cookies modifying the settings of the browser, however this operation could slow or prevent the access to the entire site or art of it.

Sending from the users/visitors of personal data in order to access to specific services, that means to send requests by e mail, involves the acquisition of the sender’s address and/or of the other possible personal data, which will be exclusively handled to answer the request, providing the services and will be transmitted to third parties only as long as it is necessary to comply with the requests of the users/visitors.

Prior to acceptance, expressed freely, explicitly and in different ways other than the various scopes of handling, selecting the box “yes” in the registration form to the services, personal data could be managed for the sending through email of commercial information, advertising and promotions related to the Services provided by Bros USA Corporation and/or to services or products of third party companies selected on the basis of the data provided in the registration form.

Consent to data processing for the purposes set out above, under point 3 is not compulsory; therefore, in case of denial the data will be managed for the sole aims previously described.

Even after the registration, it will be possible to object for the processing of the data and advertising, automatically and free of charge, clicking on the link displayed at the bottom of the page of every advertising sent by Bros USA Corporation.

 

INTELLECTUAL PROPERTY RIGHTS

Bros USA Corporation warns the Users of the site that several elements are protected:

  • by the copyright legislation, as far as the structure of the Site, the schemes, the photos, the articles, the texts, the drawings and the animated sequences are concerned.
  • and/or by the legislation on intellectual property (projects and models)
  • and/or by the legislation on trademarks: particularly the trademarks Brosway which appear in the Site.
  • That such elements are property of Bros USA Corporation or third parties which have authorized Bros USA Corporation for such use.

All reproduction, representation, adaptation, using, alteration, modification, incorporation, translation, trading in whole and/or in part, in whatever form and whatever medium ( paper or digital..) of the contents of the Site or part of them, is expressly forbidden, without the prior written consent of Bros USA Corporation, except for the exceptions provided for in the present provision in matter of intellectual property and is liable to constitute an act of counterfeit of copyright and/or of projects and models and/or of trademarks, punishable under criminal law.

The trademarks and logos of the software displayed on the pages of the Site are property of the companies which manage them and cannot be used without the prior written authorization of such companies.

 

COOCKIES

The user is informed that our website uses a system of cookies. Cookies are files sent to the HD of the user to facilitate the user’s navigation on the site and carry out statistical surveys and to facilitates the demands of commercial information.

Cookies do not contain any personal information.

The files of cookies last 10 years.

Cookies from third parties may be used. The user can disable the sending of cookies modifying the settings of his browser.

 

SECURITY

The user agrees not to carry out any manipulation that can cause computer faults, functional or others, which may affect the proper functioning of the Site or the any other service accessible through the Site.

The User agrees to make available only trustworthy information and data which cannot affect the proper functioning of the Site or the any other service accessible through the Site.

The use of the Site or of any other service accessible through the Site has to respect the national and international applicable regulations and the rights of third parties without causing any prejudice, of any kind and any manner, to Bros USA Corporation.

 

LIMITATION OF LIABILITY

The User is fully responsible for the use of the Site.

Bros USA Corporation cannot be held liable for any direct or indirect damages or material damages, losses of data or programs, economic damages, arising from the use of the Site or of the sites linked to it.

The user is informed that the certain products or services shown on the Website can be subject to specific legislations and/or restrictions and prohibitions according to legislations approved by certain countries.

Bros USA Corporation enables the User to submit requests about information and files which are transferred from servers managed by the same user. Hence, Bros USA Corporation cannot be held liable for the contents of texts and/or files submitted by the user through the Site.

Bros USA Corporation cannot be held liable for the contents of texts and/or files which Bros USA Corporation is not the author of and on which does not exercise control.

 

USER RESPONSIBILITY

The Users use the Site under their own responsibility.

The User of the Site agrees to these Terms and Conditions also only by accessing the Site.

Consulting the Website implies knowledge and acceptance of the legal notice.

Bros USA Corporation cannot be held liable for damages arising from the use of the Site, particularly the user shall protect his technical equipment from any kind of contamination from virus and/or attempts of intrusion.

 

HYPERTEXT LINKS

The inclusion of a hypertext link requires the prior written authorization of Bros USA Corporation.

In any cases Bros USA Corporation will not be responsible for the contents and of the products or services offered on the sites to which the Site is linked by hypertext links and any kind of link.

 

APPLICABLE LAW AND JURISDICTION

The Site and the present general conditions are subject to the Italian Law, except for the rules concerning conflict of laws. In case of a dispute on the interpretation or the execution of the present general conditions will be subject to the exclusive jurisdiction of the competent courts of FERMO, ITALY, unless the law referable to Bros USA Corporation provides otherwise.

Where the Member is considered a Consumer the Courts are those appointed by the law.