BRILLI GOLDINI ("we", "us", and "our") is headquartered at Kaprova 42/14, 110 00, Prague, Czech Republic. We manage and operate our digital platforms with the technical support of LUXX CAPITAL s.r.o.. For the purposes of certain data protection laws and regulations, we are considered to be the data controller.

At BRILLI GOLDINI, we value our relationship with you. To provide the most relevant services and craft a personalized experience, we handle your personal information with the highest level of care and diligence.

Our Privacy Policy is built upon the following three key commitments:

• Commitment 1: Transparency & Trust – Privacy is embedded in all our products and services by design and default. We respect the trust you place in us with your personal information and are fully transparent about how we use it. We will only process your personal data for specified purposes when we have a legal basis to do so, including where required, obtaining your explicit consent. Any material changes to our data processing practices will be communicated to you.
• Commitment 2: Protecting Your Personal Information – We adhere to leading data protection, privacy, and security standards to ensure your personal data remains secure. If a data breach occurs that affects your personal information, we will notify you and/or relevant authorities in compliance with applicable regulations. Your personal information will be safeguarded when shared with third parties or transferred internationally, and we will only retain it for as long as necessary or as legally required.
• Commitment 3: Respecting Your Rights – We respect your choices regarding how your personal information is handled. You have the legal right to access, update, or erase your personal data and to object to certain processing activities. We will provide clear channels for you to contact us with any questions or concerns regarding your privacy.

Please take a moment to review this Privacy Policy along with our Cookie Policy, which explains how we collect, use, disclose, and transfer your personal information. This applies across all touchpoints, including our websites, mobile applications, and digital platforms (together referred to as the “Platforms”), as well as when you visit our boutiques, attend events, contact us via email, phone, or online chat, or engage with us through social media and other marketing channels.

Our Cookie Policy details how we collect information through the use of cookies and related technologies when you use our Platforms.

Where we offer products for sale online or by phone through our Client Relations Center, the applicable Conditions of Sale will govern the terms and conditions of such purchases. Additional terms, such as Conditions of Service, may apply to other services we provide.

From time to time, we may update this Privacy Policy. Any updates will be published on this Platform to keep you informed of any changes.

Information that you provide to us or we collect about you

We collect the following personal information about you as detailed below:

General personal & user account information: To benefit from our products, services, events, boutique appointments and/or other client programmes, you may need to provide your contact details or create an account with us. You may provide personal information about yourself, including name and address, date of birth, e-mail address, telephone number, marital status, nationality and gender. Your account will store information about yourself, your purchasing history, unique account identification number, username, password, time zone, claims and repair history, as well as any conversation history.

Client 360 view data: In order to have a full understanding of our clients, we may also collect and store data about your behaviour, interests, preferences (such as products, topics, and channel and frequency of communication), wish lists, hobbies, client interactions and marketing campaign activities, opinions, customer reviews, demographic data, habits, celebration events, purchasing reviews and feedback as well as your general purchasing tendencies.

Transactional and payment information: When you purchase products and/or services, we collect additional information, such as your shipping address, proof of delivery, billing address and relevant payment information.

Identification information: We may collect identification information from you, such as passport data or national ID data, in circumstances where we need this to provide products and/or services to you.

Correspondence, call recordings, online or video chat: We collect personal information from you when you correspond with us (for example, if you contact us with a query about one of our products and/or services), when you provide your details when you visit our boutiques, contact us or our Client Relations Center by e-mail, telephone, contact form or otherwise participate in online or video chat. Please note that phone calls, online or video chat or other correspondence will on occasion be recorded for security, evidence, training, quality control, analysis and development purposes.

Social media platforms data: If you choose to interact with us via a social media platform or other third party service, we will collect the information you have provided to us through that platform, which may include behavioural data such as your browsing records and purchase history on that platform. In addition, you may grant us access to certain data from your social media profiles for social log-in purposes.

Cookie data: We also collect certain information automatically about visitors to our Platforms, described in our Cookie Policy. This may include data relating to advertising IDs, pixel tags or your unique online personal identifier.

Location data: We will collect information about your location to the extent that we provide any location services.

CCTV, video surveillance data & Wi-Fi data: In our retail boutiques, corporate premises or other areas, we collect data using CCTV or other video surveillance technology. If you register for our free Wi-Fi service at our stores, events or other premises, we may collect certain information about your device, including device or IP address, connection date and time and the location(s) at which you connected to our Wi-Fi service.

Photos & video recordings: Some of our technology products, including connected mirrors, augmented reality technologies or photo booths, collect photographs or video recordings from you. This data may also allow us to take measurements from you required for our products and/or services. We may also take photographs or make video or voice recordings of you at one of our events.

Surveys and market research: We carry out surveys and market research and we will collect your response data.

Information you provide about third parties: You may provide personal information about a third party (such as your partner or child), including name and address, date of birth, e-mail address, telephone number, marital status, wish list, hobbies and preferences.

Information we collect from third parties about you: We also may collect any of the above information about you from third parties, including our authorised dealers, social media platforms, advertising and marketing partners, analytics providers, and third parties that provide technical or strategic data services to us and we may collate such information with other information that we have. We may also collect personal information about you from publicly-available sources.

Sensitive or special categories of data: We may ask you to provide sensitive or special categories of data (for example, allergens or accessibility requirements for events), in which case we will provide you with enhanced privacy information and ask for your explicit consent at the time of our request. Otherwise, if you provide such data to us without us asking you for it, we will take the fact you have provided such data as your explicit consent for us to process it.

Purposes of processing and our legal justification for processing

We may process your personal information for the purposes listed below on the basis of the following justifications:

Consent: this is the legal basis when you have given clear consent for us to process your personal information (for example, where you consent to receiving marketing information).

Performance of a contract: the processing is necessary for a contract we are entering into with you (including compliance with our Terms of Use), or because we have asked you to take specific steps before entering into a contract (for example, processing your contact information relating to the purchase and delivery of a product).

Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party (for example, for the running of our business, protecting against fraud, or Platform security), unless there is a good reason to protect your personal information which overrides those legitimate interests.

Legal obligation: the processing is necessary for us to comply with the law (for example, a court order).

Other grounds: the processing may on occasion be necessary for other legal reasons such as to prevent and detect crime, to protect life or the processing is otherwise in the public interest.

The purposes of processing and justifications are as follows:

Service-related processing: We process your personal information for service-related purposes, including product reservations and sales, service communications, programme updates, announcements and administrative messages, such as acknowledgment and confirmation of, or changes to, orders and shipment, confirmation of, or changes to, event or appointment bookings, repair notifications as well as to notify you about changes to our terms or privacy policy. In addition, we may send you service-related messages when you abandon your shopping cart or browsing session unexpectedly – our primary justification is for the performance of a contract but we may also rely on legitimate interests (for example, to ensure you are content with your purchase and that we are providing our products and services to you in a secure, effective and efficient manner), legal obligation or consent.

Marketing-related communications and digital advertising: We process your personal information for marketing-related purposes, including sending you marketing communications (including by telephone,
e-mail, post and electronic or text messages, including WhatsApp or other one-to-one communications, and delivering personalised messages or advertising on social media or other digital platforms) relating to us and other third party partners that we think may be of interest to you. We may also share your personal information (such as your e-mail address, usually in an encrypted or ‘hashed’ form, or specific cookie data) with social media and other platforms or other service providers for the purposes of custom audience or lookalike matching, or intra-group client/prospect matching for marketing purposes – our primary justification for marketing-related communications and digital advertising processing is either consent or legitimate interests (for example, to recommend certain products to you). Where we rely on consent, you may withdraw your consent at any time by e-mailing the address below in the section headed “Contact us” or clicking on the ‘unsubscribe’ link in any marketing e-mails or text messages. Where we request your consent at multiple touchpoints (for example, in-store or on the Platforms) and at different times, any consent collected will remain valid unless you expressly opt-out.

Accounts & records: We process your personal information for the purposes of managing our accounts and records – our primary justification is for the performance of a contract but we may also rely on consent, legitimate interests (for example, to prevent fraud) or legal obligation.

Logistics, transactional and payment processing: We process your personal information for the purposes of managing and fulfilling purchase, gift and repair orders or returns, communications preferences during repairs, facilitating delivery, and providing after-sales services – our primary justification is for the performance of a contract but we may also rely on legitimate interests (for example, to ensure we are collecting payments effectively), legal obligation or consent.

Enquiries: We process your personal information for the purposes of dealing with your enquiries and requests, and offering client services to you – our primary justification is for the performance of a contract but we may also rely on legitimate interests (for example, to respond to your queries in an effective manner) or consent.

Events, appointments and communities: We process your personal information for the purposes of organising and running events, boutique appointments and membership communities, including registering you as a member, attendee or speaker, or reporting or logging a health and safety incident that you may have suffered or assisted with. We may also take photographs or make video or voice recordings of you at one of our events for promotional purposes – our primary justification is for the performance of a contract but we may also rely on consent, legitimate interests (for example, to respond to your queries or to manage and administer events) or legal obligation.

Competitions, prize draws and other promotions: We process your personal information for the purposes of running competitions, prize draws, and other promotions, and we need to collect information from you to administer such promotions – our primary justification is for the performance of a contract but we may also rely on legitimate interests (for example, to track client engagement), legal obligation or consent.

Regulatory compliance, credit checking and prevention of prohibited activities: We process your personal information for the purposes of undertaking anti-money laundering or international sanctions compliance, credit checking, prevention of fraud and other prohibited or illegal activities as part of our efforts to keep our Platforms and services secure or as otherwise required to respond to a legitimate request from a third party (for example, a regulatory or police authority or financial institution) – our primary justification is legitimate interests (for example, to prevent fraud or other crime) but we may also rely on legal obligation or consent. We reserve our rights not to provide products and/or services to you where we have a legitimate reason not to do so in accordance with applicable law.

Automated technologies & profiling: We process your personal information as part of our use of innovative technologies, including profiling technologies, artificial intelligence, machine learning and advanced algorithms, to help us identify and predict any products, diagnostics, services or other information that may be of interest to you based on the information that you provide to us or we collect from third parties (as detailed in the section ”Information we collect from third parties about you”). This may lead to automated decisions about you being taken using technology without human involvement. It may include decisions regarding our products, services, event invitations, personal benefits and other information. The purpose is to improve your experience of our products and/or services by way of offering you tailored products and/or services, and being able to respond effectively and swiftly to your feedback. This may involve, for example, techniques used to predict your behaviour and may include data clustering, data mining, data fusion or other data intelligence methods used to extract value and meaning from your personal information. This may be completely automated (such as to escalate complaints) or involve human intervention where the final decision is taken by an individual. When we use your personal information for any automated decisions and/or profiling, we will take steps to be transparent and fair and to make decisions free from bias. We will implement reasonable safeguards designed to protect any of your personal information. In certain circumstances, we will provide you with an opportunity to opt-out of automated decisions and/or profiling – our primary justification is legitimate interests (for example, to improve our Client Relations Center training) and consent.

Market research, analysis of feedback and client engagement: We process your personal information for the purposes of conducting market research (including surveys) and analysis and improve consumer engagement as a result of client feedback, comments, preferences and general use of our Platforms, products and/or services so that we can continuously improve our offerings and the products and/or services we provide to our clients – our primary justification is legitimate interests (for example, to improve our Platforms) but we may also rely on consent.

Location services: We process your personal information for the purposes of providing you with location-based services when we are able to use information about your location. For these services, which are typically available on mobile devices or applications, you are provided with the opportunity to provide your consent to the use of location services, which, for example, process information deriving from GPS, sensors, beacons or Wi-Fi access points in order to allow you to benefit from a more personalised service. Your device will have settings that allow you to turn off these services should you no longer wish to benefit from them – our primary justification is consent.

CCTV, video surveillance & WiFi processing: We process your personal information using CCTV and video surveillance data for the prevention and detection of crime, assisting law enforcement agencies in the apprehension, investigation and prosecution of offenders, ensuring the safety of our staff, visitors and property and, occasionally, to monitor in-store activity or WiFi browsing – our primary justification is legitimate interests (for example, to secure our premises) and legal obligation but we may also rely on consent.

New retail technologies: We may process your personal information for the purposes of our use of new retail technologies to provide you with enhanced in-store and online experiences, including virtual try-ons, augmented reality and product configurators. For example, we may use images or videos of your hand to generate and send you a photograph or a video clip showing product(s) on your hand – our primary justification is both legitimate interests (for example, to monitor client engagement with new technologies) and consent.

Platform support, maintenance and security: We process your personal information in connection with administering and protecting our business and the Platforms (including troubleshooting, dealing with error messages, data analysis, testing, system maintenance, support, reporting and hosting of data) – our primary justification is legitimate interests (for example, to ensure our Platforms run effectively and securely) but we may also rely on legal obligation or consent.

Receipt of products and services from suppliers: We process your personal information for the purposes of benefiting from any products or services provided by you or your organisation, where you are, or your organisation is, a supplier – our primary justification is performance of a contract but we may also rely on legitimate interests (for example, to receive services) or consent.

Authorised dealer data sharing: We process your personal information for the purposes of ensuring a seamless client experience across our authorised dealer network. You have the option to enable your account data, including your contact details and transaction history, to be shared across our network, including both to and from our authorised dealers and our boutiques, and benefit from a personalised experience when you visit our points of sale in any country – our primary justification is consent.

Business administration and legal compliance: We process your personal information for the purposes of the administration of our business or to comply with our legal obligations – our primary justification is legal obligation but we may also rely on legitimate interests (for example, to maintain our records) or consent.

Enable a corporate transaction such as a merger or acquisition: We process your personal information for the purposes of any merger or acquisition activity and we will disclose your personal information to any third party that purchases, or to which we transfer, all or substantially all of our assets and business – our primary justification is legitimate interests (for example, to facilitate discussions with third party stakeholders) but we may also rely on legal obligation or consent.

Cookie and other automated technologies: We process your personal information in accordance with our Cookie Policy – our primary justification is consent, performance of a contract and legitimate interests (for example, where cookies are strictly necessary).

Material changes

Where we materially change the way in which we process your personal information, or if we plan to use your personal information for a new purpose not set out in the section above, we will take the appropriate measures required under applicable law, such as to notify you by e-mail or other suitable means.

Our Cookie Policy

This website uses cookies according to our Cookie Policy. This Cookie Policy is available to users on each page of the website linked to this Privacy Policy and on each information banner regarding cookies.

Protecting your personal information

We want you to feel confident about sharing your personal information with us, and we are committed to protecting the personal information we collect by implementing leading data protection, privacy and security standards. We limit access to personal information about you to employees who reasonably need access to it, to provide products or services to you or in order to do their jobs. We have appropriate technical and organisational physical, electronic, and procedural safeguards to protect the personal information that you provide to us against unauthorised or unlawful processing and against accidental loss, damage or destruction. However, where we ask you to choose a password in order to access certain parts of our Platforms, you are responsible for selecting a secure password and keeping that password confidential. You should choose a password which you do not use on any other site, and you should not share it with anyone else.

Sharing your personal information

We only share personal information with others when we are permitted by law to do so. When we share personal information with others, we put contractual arrangements and security mechanisms in place to protect the personal information shared and to comply with our data protection, confidentiality and security standards and obligations. We share your personal information with third parties in the following circumstances:

Our affiliated group companies: We may share your personal information with our affiliated group companies for the purposes specified above, where we are permitted by law to do so (including where we have a lawful basis to do so).

Service providers (including data processors): We will disclose your personal information to our appointed third party service providers (which may process your personal information as data processors on our behalf), including for the purposes of providing online and other payment services, handling credit checks and fraud prevention, product shipment, cloud storage and any other services required in order for us to use your personal information for the purposes specified in this Privacy Policy. In certain circumstances, certain fraud-prevention service providers consider themselves to be independent data controllers.

Regulatory, authority and other third party disclosures: We will disclose your personal information to any law enforcement agency, court, police, regulator, government authority or any other third party, including a relevant financial institution, where we believe this is necessary to comply with a legal or regulatory obligation, to protect our rights or the rights of any third party, or where it is otherwise in the public interest or our legitimate interests or those of a third party (for example to respond to a request from a third party to disclose personal information to investigate an alleged crime, to check that we are complying with applicable law and regulations, or to establish, exercise or defend legal rights). In addition, we may share your data with insurance providers and/or lost or stolen organisations to facilitate the recovery of any lost or stolen items.

Authorised dealers: Where you interact with our authorised dealer network, we may ask for your consent to share your personal information with an authorised dealer from time to time for the purposes of: (i) providing you with services you have requested; (ii) improving your client journey and experience within boutiques when interacting with our products and services and/or our authorised dealers; (iii) ensuring that the information we hold about you is accurate and up to date, including registering purchases, warranty extensions and other transactions, as well as recording your marketing preferences; and (iv) managing client and vendor relationships to improve co-operation with our authorised dealers and provide you with bespoke client experiences with us. In circumstances where an authorised dealer may require access to the information we hold about you, we will seek your permission to share your personal information with an authorised dealer prior to granting such access. Where you grant permission to share your personal information with an authorised dealer, we will maintain industry leading measures to ensure the continued security of your personal information. Where your personal information is shared with an authorised dealer, both the relevant authorised dealer and us may simultaneously be acting as an independent data controller and/or data processor in respect of your personal information, depending upon how we or our authorised dealer are interacting with you.

Mergers & acquisitions: We will disclose your personal information to any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Privacy Policy.

Social media platforms and other third party digital vendors: We may share your personal information with social media platforms as explained above or in the Cookie Policy.

Transferring your personal information globally

If the country we transfer your personal information to does not provide an adequate level of data protection, we have implemented standard contractual clauses to ensure adequate safeguards are in place to protect your personal information where it is transferred to our affiliated companies, boutiques or third party service providers in territories outside the European Economic Area, the United Kingdom and Switzerland. While other territories may not have the same standards of data protection as those within your home country, we will continue to protect the personal information we transfer in accordance with this Privacy Policy.

Privacy risk assessments

We may periodically conduct risk assessments related to the processing of your personal information, especially when introducing new technologies or functionalities. In certain circumstances, these new technologies or functionalities may require us to provide enhanced privacy notices and/or consent forms to ensure that we continue to meet our privacy commitments towards you.

Retaining your personal information

We keep your personal information only for as long as is necessary for our purposes of processing, and in particular to protect ourselves in the event of a legal claim (for example, information relating to a contract with you will be kept for the lifetime of the contract and up to ten years after) as well as necessary to comply with statutory retention obligations. After this period it will be deleted or in some cases anonymised. Where we have your consent to process your personal information and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent we will delete your personal information.

If you request that we no longer send you direct marketing communications or you exercise your right to be forgotten, we will keep a record of your request and contact details to ensure that your request is respected.

We commit to respecting your rights. If you wish to exercise any of the rights set out below, which are available under applicable law, please contact us at the address listed below.

RIGHT OF ACCESS
You have the right to request access to any personal information that we process about you.

RIGHT TO ERASURE / RESTRICTION OF PROCESSING
In certain circumstances, you have the right to request the erasure of your personal information or to restrict how we process it.

RIGHT TO UPDATE OR CORRECT
You have the right to request corrections to any inaccurate personal information and to update any outdated information.

RIGHT TO OBJECT
You have the right, in certain circumstances, to object at any time to the processing of your personal information when it is carried out based on legitimate interests or public interest.

Additionally, you have the right to object to the processing of your personal information for direct marketing purposes.

RIGHT TO DATA PORTABILITY
In some cases, you have the right to request a structured, commonly used, and machine-readable format of the personal information you have provided to us.

RIGHT TO WITHDRAW CONSENT
If you have given consent to process your personal information, you may withdraw this consent at any time with future effect. The withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

RIGHT TO COMPLAIN
If you have concerns regarding the processing of your personal information, please contact us using the details below. We will respond within a reasonable time with any remedial action.

If you believe that your personal information has been processed unlawfully or your rights have been breached, you have the right to lodge a complaint with a data protection authority in your place of residence or the jurisdiction where processing occurred.

RIGHT TO OBJECT TO ADVERTISING VIA EMAIL
If we have obtained your email address in connection with a product or service purchase and use it for direct advertising of similar products or services, you may object at any time by emailing us (see “Contact Us” section) or clicking ‘unsubscribe’ in any of our marketing emails.

However, please note that we may still send you service-related (non-marketing) emails, such as order status updates.

CHILDREN
Our Platforms are not directed at individuals who are children under the relevant country’s data collection laws (e.g., under 13 in the US, under 16 in certain European countries). We do not knowingly collect personal information from children without parental or guardian consent. Children should not use the Platforms or submit personal data without such consent.

f you have any questions or comments regarding these Terms of Use or any other matter, please reach out to us at the contact information!

Additionally, you can contact us via the chat on the right for immediate assistance.