Alta Capital AG, with registered office in Landstrasse 37, LI -9490 Vaduz (Leichtenstein), registration number FL-002.490.490-3 (hereinafter “Alta Capital” ) recognizes the importance of protecting your Personal Data of its own customers and for this reason adopts this specific Privacy Policy describing how Alta Capital collects such information, how Alta Capital uses it and to whom and under what circumstances Alta Capital may disclose it including security measures to protect your Personal Data.

Personal data, means any information relating to an identified or identifiable natural person ("data subject"); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

1. Data collection
Alta Capital, as data controller, will collect and use your Personal Data, with your prior express consent, in order to allow your online purchases on the web site jem.style (hereinafter the “Website”) Personal Data may include, your name, postal address, postal code, email address, telephone number, date of birth, payment information, demographic information, details on items purchased, and any other information you choose to provide us.

The Personal Data you provide may be used and processed by Alta Capital for the following main purposes:

a) create your account on Website;
b) manage your online purchase request;
c) process the order and on-line services activity; 
d) comunicate with Alta Capital via social media site;
e) participate in contest and promotion;
f) manage communication, market analysis, research, newsletter, profiling, promotional materials and mailing with Alta Capital
g) apply for a job;
h) compliance with laws;

We use your personal data for the performance of the purchase contract, the management of the customer database, the technical management and the further development of the Website. 
Alta Capital will process your personal data only after receiving your consent, freely expressed, in order to send you advertising material and direct marketing or other commercial communications, including by e-mail, which do not fall within customer requested services.
Each time your consent is required, we will inform you in advance and we will give you the option to either provide or refuse your consent for the use of your personal data, including your email address, for the above purposes, by ticking the appropriate boxes.
We wish to inform you that we may process your personal data also without your consent in certain circumstances provided by law, such as when such processing is necessary for performing a legal obligation to which we are subject or when such processing is necessary for performing obligations undertaken in contracts with the users With your optional consent, your Personal data may be used by Alta Capital for marketing purposes, such as mailing and direct e-mailing, communications and invitation in order to offer you customized services, as described at above mentioned point d), e) and f).

This type of Personal data can be defined as “Optional information”, for this reason you can at any time revoke the use of your Personal Data for marketing purposes by sending a communication to: 
Alta Capital:  e-mail: privacy@jem.style

In some cases, you may provide information to us about third parties (i.e. gift). In such cases, you have to obtain specific authorization from these parties to provide us with their personal information.
This Privacy Policy was drawn up and your Personal Data will be processed in compliance with the Recommendation n. 2/2001 of Data Protection Working Party on certain minimum requirements for collecting personal data on-line in the European Union,  European laws (Directive 95/46/EC).

2. Data processing
The Personal Data will be collected through electronic or paper process under specific secured system. The Personal data will be also processed through CRM system managed by Alta Capital. The customers database is located in the European Union. (hereinafter the “Database”)
Your Personal Data will be processed by Alta Capital’s employees, as data controller, and business partner specifically appointed as person in charge of the processing, therefore Alta Capital can also share your personal data with following third parties:

a) Public entities and authorities;
b) AEFFE Lab srl - via Capestrano - Chieti - Italy;

Personal data will be disclosed to third parties that provide, on behalf of Alta Capital, specific services as data processors only to enable a correct execution of the contract for purchasing products on the Website and for marketing purpose as above mentioned. Personal data will not be disclosed, disseminated, transferred to third parties without informing and obtaining your express consent.

3. Data storage
Your Personal data will be stored at Alta Capital’s database for the time due to the execution of the purchase contract only. The Database is managed and maintained by Alta Capital and by third parties companies involved in the processing. 
You have the right at any time to contact Alta Capital to: (a) confirm your personal data; (b) verify the content, source and accuracy of your personal data; (c) update, integrate or delete your personal data; (d) obtain any other information about your personal data collected by J.E.M.;

4. Data Transfer
For the correct conclusion and execution of the purchase contract your personal data may be transferred to provider – listed at point 2. b) - located in the European Union, operating as Data Importer.
Personal data may also be transferred abroad, including in or outside the European Union, to Alta Capital. affiliates or Alta Capital business partners.
Your personal data will not be transferred abroad to non-EU countries that do not ensure an adequate level of protection of individuals. Should this be necessary in order to supply services or to execute a contract for the purchase of J.E.M products, - as data exporter - will ensure that such personal data is processed in accordance with this Privacy policy. In the absence of local privacy law that guarantees adequate protection to your Personal Data, Alta Capital will enter into agreements ensuring an adequate level of data protection. 
Data exporter, means the data controller who transfers the personal data.
Data importer, means the data processor who agrees to receive from the data exporter personal data intended for processing on his behalf after the transfer in accordance with his instructions and the terms of this Privacy Policy.

5. Data Security
Alta Capital implemented reasonable and advanced technical and organizational security measures to safeguard the personal data under our custody and control, against unauthorized access, misuse, inadvertent or intentional manipulation, loss or destruction. (hereinafter “Security measures”)
To provide you with increased security, the access to personal data stored in your Account is protected with username and password. (hereinafter “Credentials”) You are responsible for maintaining confidential these Account Credentials. Please notify us immediately of any unauthorized use of your credentials.
Alta Capital cannot guarantee that the Security measures will mitigate or eliminate risk of unauthorized access or dispersion of Personal Data by user devices, for this reason you should always keep updating and equipping your computer (or device) with adequate security software. 
The personal data is transmitted in encrypted form (SSL-Secure Socket Layer). The technical security measures to protect your personal data are checked and updated on regular basis.

6. Cookies
On your computer you can store information that can identify you. Such information is designated by the name of “cookies”. This information helps Alta Capital to provide, improve and personalize the website. 
Cookies. It’ a text file sent to your web browser and placed on your computer when you access a website. The cookies can track your activities on the Sites and across websites. Cookies also allow us and our Providers to: 
(a) track your activities on the websites;
(b) track clicks, purchases and conversion; 
(c) recognize your computer or device;
(d) customized content, messages and advertising;
(e) preserve the contents of your shopping cart;
(f) improve Site security;
(g) personalize your experience on the Sites. 
The website uses service providers a web analysis service of Google Inc. US as well as social plugin "like" / "like" the Facebook Inc. US (hereinafter "Providers"). These services collect information and can cookies. The information generated through your use (including, your address IP) will be transmitted to the servers of these providers, at national or international level, where they are stored and processed and can eventually be matched to your account with these providers.
Providers can use this information to analyze your use of our website, compiling reports on website activity for the operators of that site, to insert display advertising and to provide additional services related to use of the website and the Internet. Providers may also transmit this information to third parties, nationally and internationally. By using this website you agree with the processing of data collected about you in the manner described above and for the purpose mentioned before.
The main browsers accept cookies as a standard setting. It is, however, possible to configure your browser to refuse cookies or requires prior confirmation from you. Rejecting cookies may result as a consequence, the inability on your part to take advantage of the full functionality of our website.
By continuing to use this website, you consent to our use of cookies as described in this Privacy Policy.

7. Links To other Websites
Our website and apps may provide links to non J.E.M sites, apps and services that may be operated by companies not affiliated with Alta Capital. If you choose to access a third party website linked to our website, you do so at your own risk and subject to any terms of service or privacy policy associated with such third party websites. Our products and services also may be made available to you through third party platforms or through other third party channels. We are not responsible for the privacy practices of any non J.E.M sites, apps or services.

8. Data Controller and Processor
Data Controller, means a person who, either alone or jointly or in common with other persons, determines the purposes for which and the manner in which any personal data are, or are to be processed. 
The Data controller is 
Alta Capital AG with registered office in Landstrasse 37, LI -9490 Vaduz (Leichtenstein), e-mail: privacy@jem.style

Data Processor, means any person who processes the data on behalf of the data controller.
The data processor is any Alta Capital’s employees specifically appointed as person in charge of the processing, the Legal representative of Alta Capital and Alta Capital’s providers for purposes related to the maintenance of the Database and Website, as listed at previous point 2.

9. Other Privacy Policies
Please note that if you are a Alta Capital customer, and/or you are already registered in any Alta Capital database on worldwide basis, additional privacy policies and statements may apply to you as a customer of a particular Alta Capital relationship or as a registered contact in the said Database. This Privacy Policy does not replace or revise any other privacy policy or statement that may be applicable to personal information collected or used by Alta Capital through that specific relationship with us.

10. This Privacy Policy
Alta Capital may change and amend this Privacy Policy from time to time. Any amended version will be published on the website. 

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