Cookie Policy

( version 1.0 dated 1 December 2022 )

Dear Visitor (hereinafter, “ You ” or the “ User ”),

This Internet site ( www.sirmoney.com hereinafter, the " Site ") is owned by the company SIR FASHION Srl, with registered office in Via Costantino Maes 66, 00162 Rome, VAT number no. IT098200811009 (hereinafter, “ We ” or the “ Company ”).

Since so-called cookies are used on our site for various purposes, with this information we want to explain what cookies are and how they are used on the site.

Some cookies (so-called own or first-party cookies) are conveyed and controlled directly by us. Through these cookies, the Company collects and processes some personal data concerning you. In this information, pursuant to art. 13 of EU Regulation 2016/679 of 27 April 2016 concerning the protection of natural persons with regard to the processing of personal data (hereinafter, the " Regulation "), we explain how we collect this data, for what purposes and what your rights are.

Other cookies (so-called third-party cookies), are, on the other hand, conveyed and controlled by third parties. In this information you will find links to the information published by these third parties, which we ask you to read carefully.

If you are not familiar with cookies, please read this information and the general privacy information of the Site carefully, so that you can be aware of your choices.

The Company takes the utmost account of the right to privacy and protection of personal data of its Users. For any information relating to this cookie policy, Users can contact the Company at any time, using the following methods:

  • By sending a registered letter with return receipt to the registered office of the Company : Via Costantino Maes 66, 00162 Rome
  • By sending an e-mail message to the address: privacy@sirmoney.it

 The Company has not identified the figure of the Data Protection Officer (RPD or DPO), as he is not subject to the designation obligation set forth in art. 37 of the Regulation

1. What are cookies and what are they for

Cookies are small text files that the sites visited by the user send directly to his terminal (usually to the browser), where they are stored before being re-transmitted to the same sites on the next visit by the same user (so -called first-party cookies ). During navigation on a site, the user can also receive cookies from different sites or web servers on his terminal (so-called third-party cookies ); this happens because on the website visited there may be elements such as, for example, images, maps, sounds, specific links to web pages of other domains that reside on servers other than the one on which the requested page is located. In other words, they are those cookies that are set by a website other than the one you are currently visiting.

Cookies may have a duration limited to a single browsing session on the browser (so -called session cookies ), and in this case they are automatically deactivated when the user closes the browser; or they may have a predetermined expiry date and, in this case, they will remain memorized and active on your hard disk up to that expiry date, continuing to collect information during different browsing sessions on the browser (so-called permanent cookies ).

Cookies are used for various functions. Some are necessary to allow you to browse the site and take advantage of its features (so-called technical cookies ). Others are used to obtain statistical information, in aggregate or otherwise, on the number of users who access the Site and on how the Site is used (so -called monitoring or analytics cookies). Finally, others are used to trace your consumer profile and show you advertisements on the Site that may be of interest to you, as they are consistent with your tastes and consumption habits (so -called profiling cookies ).

To learn more about these different categories of cookies, continue reading this information. Find out how they work and what they are for, and freely choose whether to consent to their use or to prevent it.

a) Technical cookies

Technical cookies are used on the Site for the sole purpose of making your navigation on the Site possible and allowing you to use its functions. These are always first-party cookies, as they are conveyed directly by us on the Site.

Some technical cookies are essential to offer you an optimal browsing experience or to allow you to authenticate yourself on the site, for example to make a purchase on the site or enter your reserved area (so -called navigation cookies ). Navigation cookies are normally session cookies and, therefore, once the navigation browser is closed, they are automatically deactivated.

Other technical cookies are useful for allowing you to memorize some of your preferences (for example, language or country of origin) without having to reset them during subsequent visits (so -called functionality cookies ). For this reason, functionality cookies are often persistent cookies, as they remain stored on your computer even after you close your browser, until their expiry date or until you decide to delete them.

The following technical cookies are currently used on the Site:

Cookie name

Category of the cookie

Function of the cookie

Shopify

We use Shopify to enable people who visit our website to buy our products.

https://www.shopify.com/legal/cookies

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As required by current legislation on privacy, your prior consent is not required for the installation of these cookies. Naturally, you are free to block the installation of technical cookies by modifying the settings of your browser (read paragraph E, n. 1 to find out how to do it). Consider, however, that by blocking the installation of technical cookies, or subsequently eliminating them, the ability to access the Site, to use all or part of it, to enable or disable certain functions or to receive certain services could be wholly or partially compromised.

b) Monitoring or "analytics" cookies

Analytics cookies are used on the Site to collect statistical information, in aggregate or non-aggregated form, on the number of users who access the Site and on how they visit the Site itself.

The analytics cookies of this site are third-party cookies, since they are not conveyed directly by us but by third parties. Therefore, they are not installed directly by the Company but by third parties.

The following third-party analytics cookies are installed on the Site without your prior consent, because they are less invasive as they are anonymous, as third parties cannot access disaggregated analytics data at the IP address level (in other words, using these cookies , third parties cannot trace your identity):

Cookie name

Category of the cookie

Link to information / Opt-out instructions

Google Analytics

We use Google Analytics to measure how users interact with our websites.

https://policies.google.com/privacy

Meta Pixels

We use Facebook Pixel to measure how users interact with our websites.

https://www.facebook.com/privacy/explanation

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Other third-party analytics cookies are, on the other hand, installed on the Site only with your prior prior consent, because they are not anonymous, as third parties can access disaggregated analytics data at the IP address level (in other words, using these cookies , third parties could theoretically trace your identity through the IP address):

Cookie name

Category of the cookie

Link to information / Opt-out instructions

Google

We use Google Ads to deliver targeted advertisements to people who visit our websites.

https://policies.google.com/privacy

Half

We use Meta Ads to deliver targeted advertisements to people who visit our websites.

https://www.facebook.com/policy.php

For this reason, when you access the Site, a special banner is displayed, which informs you that with your consent, third-party analytics cookies are used on the Site and that by pressing the appropriate button provided there, you can consent to the use of cookies. Should you express your consent to the installation of cookies in this way, we will keep track of your consent through a specific technical cookie. In this way, we will avoid displaying the cookie banner during your subsequent visits to the Site. Please bear in mind that, should you delete this technical cookie from your browser in the manner described in paragraph E, n. 1), the trace of your consent would be lost and, therefore, during your next visit to the Site, the cookie banner will be displayed again.

Naturally, you are free to block the installation of analytics cookies at any time, without compromising the possibility of visiting the Site and using its contents in any way. To find out how to do this, carefully read the information on third-party cookies by following the links in the table above.

c) Profiling cookies

Profiling cookies are used to create your user profile, based on the preferences and tastes you manifest while browsing the Internet, and display advertising messages consistent with your profile. In this way the advertising messages that you will see on our site will be more interesting for you.

As required by current legislation on privacy, your prior consent is required for the installation of these cookies. For this reason, when you access the Site, a special banner is displayed, informing you that with your consent, profiling cookies are used on the Site and that by pressing the appropriate button provided therein, you can consent to the use of cookies. Should you express your consent to the installation of cookies in this way, we will keep track of your consent through a specific technical cookie. In this way, we will avoid displaying the cookie banner during your subsequent visits to the Site. Please bear in mind that, should you delete this technical cookie from your browser in the manner described in paragraph E, n. 1, the trace of your consent would be lost and, therefore, during your next visit to the Site, the cookie banner will be displayed again.

Naturally, you are free to block the installation of profiling cookies at any time, without compromising the possibility of visiting the Site and using its contents in any way. If you decide to disable behavioral advertising it does not mean that you will no longer receive advertising on the Site. However, the banners you will see on the Site may not reflect your interests or preferences on the browser you are currently using.

Profiling cookies are installed by third parties, who act as independent data controllers (third-party cookies). Here is a list of third-party profiling cookies currently used on the Site, with an indication of the link to the information pages created by their developers:

Cookie name

Category of the cookie

Link to information

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Some third-party cookies are installed by subjects with whom we do not have a direct contractual relationship. For this reason, we provide you below with links to the websites of subjects who act as intermediaries between us and these third parties, on which you can find (i) the list of third parties who install profiling cookies on the Site and (ii) the links to the privacy policies of these third parties, in which you can have all the necessary information on their profiling cookies and on how to oppose their installation ( opt-out ):

Cookie name

Information links

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Please consider that, by logging into the Site using the credentials of a social network to which you are registered, you will receive third-party cookies from the manager of the social network in question, which typically, in addition to allowing you to authenticate on the Site, have also for profiling purposes. Before logging in via the buttons dedicated to social networks, we therefore ask you to carefully read the information provided by the social network managers on the use of these cookies. If you do not want to receive these cookies, log in to the Site as normal without using the social network buttons. Here is a list of cookies associated with social networks that are used on the Site, with an indication of the link to the information pages created by their owners:

Cookie name

Type of cookies

Link to information

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2. How to manage cookies and oppose their use

There are several options for managing, disabling and deleting cookies.

a) Change your browser settings

 Follow the instructions provided by the manufacturer of the browser you use to find out how to manage, disable or delete all cookies (technical, analytics and profiling):

Make your choices carefully. By indiscriminately blocking the reception of all cookies, including technical ones, without providing for a specific exception for the Site, you may, in fact, no longer be able to browse the Site or use all or part of its features. Furthermore, by deleting all cookies from the browser, technical cookies could also be removed and, therefore, you could remove the preferences you have set using the Site or you could no longer find the products or services added to your shopping cart.

b) Use our interactive tools (CMP)

To disable non-anonymised analytics and profiling cookies, without compromising the possibility of visiting the Site and using its contents in any way, you can use our CMP, by clicking on the icon you find on the homepage. This icon allows you to reopen the initial screen of the cookie banner and oppose the installation of all cookies (by clicking on the refusal button or by granular deselection of the cookies or third parties to which you want to oppose and subsequent confirmation).

Remember that by disabling unnecessary cookies (i) you oppose their use not only on the Site but on all Internet sites on which these cookies are used and (ii) the ability to navigate on the Site and use its functions will not be prejudiced way.

c) Use the website www.youronlinechoices.eu/it/ 

Your Online Choices is a website managed by the non-profit association European Interactive Digital Advertising Alliance (EDAA), whose Italian version can be reached at the address www.youronlinechoices.eu/it/ , which provides information on behavioral advertising based on profiling cookies ( http://www.youronlinechoices.com/it/a-proposito ) and allows Internet users to easily oppose (opt-out) the installation of the main profiling cookies installed by advertisers and used on Internet sites ( http://www.youronlinechoices.com/it/le-tue-scelte ). Before using this tool, we advise you to carefully read the general conditions of service of the Your Online Choices site ( http://www.youronlinechoices.com/it/condizioni-generali-di-servizio ), the frequently asked questions (FAQ) ( http://www.youronlinechoices.com/it/faqs ) and the user guide ( http://www.youronlinechoices.com/it/help ).

Use Your Online Choices consciously. Although, in fact, Your Online Choices brings together many of the most important companies in the advertising world that use cookies, some of the third parties who install cookies through the Site may not have joined Your Online Choices. Therefore, the use of Your Online Choices does not guarantee that you will receive third-party cookies while browsing the Site. Also remember that by deleting all cookies from your browser, even the technical cookies issued by Your Online Choices to remember your choices could be deleted, making third-party cookies active again.

3. Processing methods and data retention times

As highlighted in the introduction to this information, it is possible that the Company collects and processes some of your personal data through the cookies that it conveys directly on the Site ( first-party cookies ). The Company acts as data controller for this data, in compliance with the provisions of the Regulation. We will process your data only with electronic tools, in a totally automated way and without human intermediation. Therefore, our employees and collaborators will never access the content of your personal data obtained through cookies, which means that they will never be able to access and / or have PII (Personally Identifiable Information), i.e. information from which it will be possible to identify you directly.

Some of our employees and collaborators, appointed by us as data processors, could carry out maintenance work on the computer systems that host your data, without ever being able to access their actual content. Personal data could be stored on servers managed by third parties (e.g. IT system suppliers) or could be managed by subjects specialized in online advertising, who act as external data processors on the basis of a specific appointment in writing by part of the Company. We inform you that, in compliance with the assumptions and guarantees established by the Regulation, your data could be transferred to countries not belonging to the European Economic Area, which may not offer a level of protection of privacy and personal data protection comparable to that guaranteed by Italian and European laws on privacy, but where the Company will act as owner we will take the utmost consideration of data security, therefore we will proceed in the management of such transfers with all due caution and guarantees. Your personal data will not be disclosed to third party data controllers nor will they be disclosed.

Your personal data will be kept for the time strictly necessary to carry out the primary purposes illustrated in this information, or in any case according to what is necessary for the protection of the rights of both the Users and the Company.

4. Your rights

To exercise your rights, or obtain any further information or clarification in relation to this cookie policy, please contact the Company in the following ways:

  • By sending a registered letter with return receipt to the registered office of the Company : Via Costantino Maes 66, 00162 Rome;
  • By sending an e-mail message to the address: privacy@sirmoney.it

 The Company has not identified the figure of the Data Protection Officer (RPD or DPO), as he is not subject to the designation obligation set forth in art. 37 of the Regulation

Pursuant to the Regulation, the Company informs that Users have the right to obtain indication (i) of the origin of personal data; (ii) the purposes and methods of processing; (iii) of the logic applied in case of treatment carried out with the aid of electronic instruments; (iv) of the identification details of the owner and managers; (v) of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as managers or agents.

Furthermore, Users have the right to obtain:

a) access, updating, rectification or, when interested, integration of data;

b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;

c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this requirement is proves impossible or involves the use of means manifestly disproportionate to the protected right.

Furthermore, Users have:

a) the right to withdraw consent at any time, if the treatment is based on their consent;

b) (where applicable) the right to data portability (right to receive all personal data concerning them in a structured format, commonly used and readable by an automatic device), the right to limit the processing of personal data and the right to cancellation (“right to be forgotten”);

c) the right to object:

i) in whole or in part, for legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of the collection;

ii) in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising materials or direct sales or for carrying out market research or commercial communication;

d) if they believe that the processing that concerns them violates the Regulation, the right to lodge a complaint with a Supervisory Authority (in the Member State in which they usually reside, in the one in which they work or in the one in which the alleged violation has occurred ). The Italian Supervisory Authority is the Guarantor for the protection of personal data, with headquarters in Piazza Venezia, n. 11, 00186 - Rome (RM) ( http://www.garanteprivacy.it/) .

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The Company is not responsible for updating all the links that can be viewed in this cookie policy, therefore whenever a link is not functional and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the sites internet referred to by this link.