This Privacy Policy provides users of this website (hereinafter also the "Site") with as comprehensive an overview as possible of the processing of personal data concerning them, as described below, through the Site pursuant to the General Data Protection Regulation (GDPR) (EU) 2016/679 and applicable Italian data protection legislation.

In accordance with applicable law, this Privacy Policy also sets out:

• the purposes of the processing, the legal basis and the means used for the processing;

• the identity and contact details of the data controllers;

• the contact details of the Data Protection Officer (DPO);

• any third parties involved in the processing activities;

• the retention period of personal data;

• a brief description of the security measures adopted to protect personal data;

• the existence of the data subject's right to request from the data controller access to and rectification or erasure of personal data, or restriction of processing concerning them, or to object to such processing, as well as the right to data portability.

This Privacy Policy applies exclusively to the Site and does not concern any website or platform to which the Site may link.

Users under the age of 16 (sixteen) may not consent to the processing of personal data without the authorisation of the holder of parental responsibility.

A. DATA CONTROLLERS AND DATA PROTECTION OFFICERS

Under the GDPR, the data controller is the entity that, alone, determines the purposes and means of the processing of personal data.

With regard to the processing of personal data connected with the Site and online sales, Harmont & Blaine S.p.A. and Global-e act, for the processing activities falling within their respective areas of responsibility, as separate and independent data controllers. The Parties do not act as joint controllers with regard to personal data shared in connection with the Global-e services.

The data controllers are:

• Harmont & Blaine S.p.A., STRADA STATALE 87 KM.16,460 ZONA A.S.I - 80023, Caivano (NA), Italy; contact: privacy@harmontblaine.com

• GLOBAL-E NL B.V., Krijn Taconiskade 430, 1087 HW Amsterdam, The Netherlands, registered number 72541466; privacy contact: dataprotection@global-e.com

Harmont & Blaine S.p.A. processes personal data as an independent data controller, including for the following purposes:

• Management of browsing on the Site;
• Registration on the Site and related features;
• Management of the customer relationship and orders for the activities falling within its responsibility;
• Customer service for the activities falling within its responsibility;
• Newsletters and marketing communications;
• Profiling;
• Soft-spam;
• Cookies;
• Statistical purposes.

GLOBAL-E NL B.V. processes personal data as an independent data controller for the activities necessary to provide the Global-e services and to manage the sales transaction for the activities falling within its responsibility, including, by way of example, order management and fulfilment, payments, fraud prevention, calculation and management of duties and taxes where applicable, customs clearance activities, shipping, returns, refunds and customer support activities connected with those services.

For further information about the processing activities carried out independently by Global-e, users may consult the privacy notice made available by Global-e in connection with its services.

The Data Protection Officer of Harmont & Blaine S.p.A. may be contacted at the following email address: dpo@harmontblaine.com.

For data protection requests relating to processing carried out by Global-e, users may write to dataprotection@global-e.com. Global-e's Data Protection Officer may be contacted at dpo@global-e.com.

B. PERSONAL DATA, PURPOSES OF PROCESSING, LEGAL BASIS, RETENTION PERIOD

The term "personal data" means any information relating to users of the Site, including information that identifies them personally, alone or in combination with other information. Personal data are collected automatically through the Site or received through various sources: forms, chats, emails, apps, devices, social media and other means.

1. MANAGEMENT OF BROWSING ON THE SITE

The Data Controller (Harmont & Blaine) collects browsing data by automated means in order to enable and improve users' browsing experience on the Site (for example IP address, date/time of the visit and its duration, any referring URLs, pages visited on the Site, device used and other information). Processing such personal data enables users to access the Site and make full use of its features and services.

Browsing data may also be used to verify that the Site is functioning correctly. From time to time, browsing data are anonymised and processed for statistical purposes.

It is unlikely that browsing data will enable identification of the data subject. However, by their very nature, browsing data may allow data subjects to be identified where combined with other information. The browsing data described above are stored only temporarily in accordance with applicable laws. In this context, the legal basis for the processing of personal data is the legitimate interest of the Data Controller (Article 6(1)(f) GDPR). Personal data are processed for the time necessary to achieve the purpose of the processing, plus any additional period required by law. Where the relevant conditions are met and a request is received from a Public Authority, personal data may, in compliance with a legal obligation (Article 6(1)(c) GDPR), be disclosed to the Public Authority for investigation purposes.

1.1. VIRTUAL FITTING ROOM

When accessing the Site, users may use the Virtual Fitting Room service by entering the requested information, such as height, weight, age and any additional body measurements, in order to receive suggestions regarding the size to purchase.

Harmont & Blaine S.p.A., acting as Data Controller for this purpose, collects such data in order to provide the service requested by the user. The legal basis for the processing of personal data is therefore the performance of pre-contractual measures taken at the request of the data subject (Article 6(1)(b) GDPR).

The Data Controller also processes, by automated means, the user's browsing data connected with the use of the service. The information entered by the user and the browsing data are subsequently anonymised and processed for statistical purposes in order to improve the service. For this processing, the legal basis is the legitimate interest of the Data Controller (Article 6(1)(f) GDPR).

Personal data are processed for the time necessary to achieve the purposes of the processing.

2. ORDER MANAGEMENT

When making a purchase, the Site asks users to provide the personal data necessary to manage the order and perform the sales contract, such as, for example, first and last name, email address, delivery address, telephone number, information relating to the order and transaction necessary to perform the sales contract, and any additional information that may be required for delivery or customs clearance.

For customs clearance activities, the data processed may also include nationality and, where required by local import regulations, a national identification number or a copy of an identity document.

Harmont & Blaine S.p.A. and Global-e process such data, each as an independent data controller and for the activities falling within its respective area of responsibility, in order to manage the order, deliver the products, provide pre- and post-sales assistance, manage returns and refunds and carry out other activities connected with the transaction.

GLOBAL-E NL B.V., acting as an independent data controller, also processes the data necessary to manage payments and may carry out checks on the payment methods used, including for fraud prevention purposes and compliance with applicable obligations. Neither Harmont & Blaine S.p.A. nor Global-e stores complete payment card numbers. Card data are processed by payment service providers contracted by Global-e in a PCI-DSS certified environment. Harmont & Blaine S.p.A. does not directly process or store complete payment card details.

Failure to provide the necessary personal data will prevent the user from completing the order or using the related services.

Where the conditions for a return are met, the return request and refund will be managed in accordance with the conditions applicable to the order and the payment method used.

The legal basis for the processing of personal data necessary to manage the order is the performance of a contract to which the data subject is party (Article 6(1)(b) GDPR), as well as, where applicable, compliance with legal obligations (Article 6(1)(c) GDPR) and the pursuit of legitimate interests, such as fraud prevention and protection of rights (Article 6(1)(f) GDPR).

Personal data relating to orders will be retained for the time necessary to fulfil contractual obligations and any applicable accounting, tax and legal obligations, without prejudice to any additional periods necessary for the establishment, exercise or defence of rights.

The provision of the necessary personal data is mandatory in order to complete the purchase.

2.1. CLICK&COLLECT

When making a purchase on the Site, a registered user may choose whether to have the product delivered to their home or collect it from one of the Harmont & Blaine Points of Sale. If the user chooses to collect the product from a Point of Sale, they will receive all collection instructions by email. The provision of data is necessary in order to use the service. The legal basis for the processing of personal data is the performance of a contract to which the data subject is party (Article 6(1)(b) GDPR). Personal data relating to orders will be retained for as long as necessary to fulfil contractual obligations and any applicable accounting and tax obligations.

2.2. IN-STORE RETURN

It is possible to return a product purchased on the Site directly to the Store. Where the requirements for a return are met, any return request will be managed by authorising the refund to the same payment method. Where cash on delivery has been selected, IBAN details will be requested in order to issue the refund by bank transfer. The provision of data is necessary to achieve the purpose described here.

The legal basis for this processing is the performance of the contract to which the data subject is party (Article 6(1)(b) GDPR). Personal data will be retained for as long as necessary to fulfil contractual obligations and any applicable accounting and tax obligations.

3. REGISTRATION ON THE SITE

When users decide to create and register a personal account on the Site, they are asked to provide personal data (for example date of birth, gender, etc.). The Site clearly indicates which personal data are required (or not required) to set up a Site account.

Users must provide truthful and accurate personal data when registering and are encouraged to keep the personal data provided up to date by accessing their personal account and making any necessary changes.

Users who choose to activate or access their Site account through social media should be aware that when they link their Site account to a social media account, the Site collects certain personal data that the user has already provided to that social media service (for example, email address and public Facebook profile).

The Data Controller (Harmont & Blaine) does not supervise or manage such social media services or users' profiles on those services; nor does it determine the privacy settings or rules governing the use of personal data on those social media platforms (Facebook, Twitter or others).

Users are strongly encouraged to read each privacy policy relating to the social media services published by the operators of those services in order to obtain further information on how personal data are processed through those channels.

Failure to transmit/provide the requested personal data will prevent users from completing the creation of the account on the Site.

In this context, the legal basis for the processing of personal data is the performance of a contract to which the data subject is party (Article 6(1)(b) GDPR).

By registering on the Site, users may also use the features listed below. Personal data processed for the management of a Site account will be retained until the user closes their account, without prejudice to any additional retention required for compliance with legal obligations.

3.1. NOTIFY ME WHEN THE PRODUCT IS BACK IN STOCK (BACK IN STOCK)

To use the Back in Stock service, the user must provide their email address in order to receive a communication when the desired product becomes available again on the e-commerce Site. The provision of data is necessary in order to use the service. The legal basis for the processing of personal data is the performance of pre-contractual measures taken at the request of the data subject (Article 6(1)(b) GDPR).

Personal data for this purpose will be processed until the product becomes available again.

3.2. ABANDONED CART

A registered user may place products they intend to purchase in the cart. The legal basis for placing products intended for purchase in the cart is the performance of pre-contractual measures and the contract (Article 6(1)(b) GDPR). The provision of personal data is necessary in order to save the information in the cart. Products placed in the cart remain visible and available for 30 days.

Until the user completes the purchase, they may receive email notifications reminding them that they can complete an interrupted purchase. The legal basis for sending such notifications is the legitimate interest of the Data Controller in increasing sales (Article 6(1)(f) GDPR). The user may always object to such processing by exercising the rights under Article 21 GDPR. The provision of personal data is optional.

3.3. WISHLIST

A registered user may add products of interest to the wishlist. The legal basis for adding products of interest to the wishlist is the performance of pre-contractual measures and the contract (Article 6(1)(b) GDPR). The provision of personal data is necessary in order to save data in the wishlist. Products will remain in the wishlist until they are removed by the user.

3.4. BOOKING AN APPOINTMENT IN STORE

Through the Site it is possible to book an appointment in store. For the booking, users may be asked to provide in advance the content of their request. The provision of data is necessary for the performance of the requested service. The legal basis for the processing of personal data is the performance of pre-contractual measures at the request of the data subject (Article 6(1)(b) GDPR).

Personal data will be processed until the appointment takes place, without prejudice to any additional retention required for compliance with legal obligations.

4. CUSTOMER SERVICE / REQUEST FOR INFORMATION

To obtain assistance or request information, users may send an email to customerservice@harmontblaine.com, as indicated on the Site, or use the "Contact Us" section, providing the personal data necessary to manage the request, such as name and email address.

Harmont & Blaine S.p.A. processes such data as an independent data controller in order to provide customer support. Where a request concerns activities managed as part of the Global-e services, such as payment, shipping, return or refund, the personal data strictly necessary may be shared with Global-e, which processes them as an independent data controller for the purposes falling within its responsibility.

Failure to provide the necessary data may prevent the request from being properly managed. Data will be processed for the time necessary to provide the requested assistance and for any additional periods required by law or necessary to protect rights.

The legal basis for the processing is, depending on the request, the performance of a contract or pre-contractual measures (Article 6(1)(b) GDPR), compliance with legal obligations (Article 6(1)(c) GDPR) or the legitimate interest in managing and protecting the customer relationship (Article 6(1)(f) GDPR).

5. NEWSLETTERS AND MARKETING COMMUNICATIONS

On the Site, users may choose to receive newsletters and commercial communications.

For these activities, Harmont & Blaine S.p.A. acts as an independent Data Controller.

Harmont & Blaine S.p.A. may use traditional contact methods (ordinary mail and telephone calls made by an operator) and/or digital and automated methods (email, SMS, WhatsApp and, where applicable, automated calls).

Users may always easily withdraw their consent to receive newsletters and commercial communications in the following ways:

• through the account settings, where available;
• by clicking the "unsubscribe" link included in email communications;
• by contacting Customer Service or writing to privacy@harmontblaine.com.

The use of data for this purpose is optional and free of charge and may take place only with the data subject's consent. Failure to provide consent does not prevent users from using the services of the Site or making purchases.

The legal basis for the processing is the data subject's consent (Article 6(1)(a) GDPR). Personal data will be processed for a maximum period of seven years from the date on which consent is given, unless it is withdrawn earlier. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

In order to send commercial communications in the data subject's language, Harmont & Blaine S.p.A. may also process nationality information, where provided.

6. PROFILING

Profiling means the analysis and study of the behaviour of registered users of the Site for the purpose of sending personalised communications and improving their shopping experience. For the personalisation of communications and the shopping experience, in addition to actual purchasing behaviour, use of features available on the Harmont & Blaine S.p.A. Site is also taken into account (e.g. abandoned cart, click&collect, etc.).

Personal data collected, subject to obtaining consent, will be used to analyse the user's behaviour on the Site, interests, preferences and purchasing habits, and to create individual or aggregated profiles based on them, understand how to provide a better service, including in order to offer a better shopping experience ("profiling").

The main purpose of profiling is to personalise the shopping experience and propose products, services and initiatives that are more in line with users' tastes, purchasing habits and interests.

The use of data for this purpose is optional and free of charge (as it is based on consent that the user may choose to give) and may take place only where personal data and the relevant consents are provided. In any case, refusal to provide personal data for this purpose does not prevent the user from using the services of the Site or making purchases.

In this context, the legal basis for the processing of personal data is the data subject's consent to the processing of their personal data - Article 6(1)(a) GDPR. Personal data will be processed for up to seven years from the date consent is given, unless consent is withdrawn earlier. Consent may be withdrawn at any time, without affecting the lawfulness of processing carried out before such withdrawal.

7. SOFT-SPAM

The email address collected when purchasing a product will be used to promote products similar to those that were the subject of the sale.

The use of data for this purpose is optional and free of charge. In any case, refusal to provide personal data for this purpose does not prevent the user from using the services of the Site or making purchases.

The legal basis for this processing is the legitimate interest of the Data Controller pursuant to Article 130(4) of Italian Legislative Decree no. 196 of 30 June 2003, as most recently amended by Italian Legislative Decree no. 108 of 10 August 2018. The data subject may object to this type of processing at any time. Personal data will be processed until the data subject objects to the processing.

8. COOKIES

Information relating to the cookies used on the Site is available at the following link: Cookie Policy

9. STATISTICAL PURPOSES

Users' personal data may be processed to create clusters and for statistical purposes in order to enable the company to identify customers/users with similar characteristics. The legal basis for the processing is the legitimate interest in increasing its customer base (Article 6(1)(f) GDPR). The provision of data is optional and the user may object to the processing at any time pursuant to Article 21 GDPR.

Where profiling cookies are used for such processing, the legal basis is the data subject's consent expressed through the appropriate banner when landing on the Site; for further details, please refer to the Cookie Policy.

10. FURTHER PURPOSES OF PROCESSING

Harmont & Blaine S.p.A. and Global-e may also process personal data, each as an independent data controller and for the processing activities falling within its respective area of responsibility, in order to comply with legal obligations and/or for the establishment, exercise or defence of a right in judicial or out-of-court proceedings.

For compliance with legal obligations, the legal basis for the processing is Article 6(1)(c) GDPR. For the establishment, exercise or defence of rights, the legal basis is legitimate interest pursuant to Article 6(1)(f) GDPR.

The retention period is determined by the applicable legal provisions or by the time necessary to protect the respective rights.

C. SHARING AND TRANSFER OF PERSONAL INFORMATION

In connection with online sales, Harmont & Blaine S.p.A. and Global-e exchange the personal data strictly necessary to provide their respective services. Such sharing takes place between separate and independent data controllers.

The data shared may include, by way of example, first and last name, address, contact details, nationality, information relating to the order and transaction and, where required by local regulations, any additional information necessary for delivery or customs clearance.

Harmont & Blaine S.p.A., for the purposes falling within its responsibility, may disclose personal data to third parties acting, as applicable, as data processors or independent data controllers, including IT and technology service providers, CRM and marketing providers, customer support providers, advisers and other parties necessary to carry out the activities described in this Privacy Policy.

Global-e, for the purposes falling within its responsibility, may disclose personal data to companies within its group, carriers, logistics operators, payment service providers, parties involved in fraud prevention, technical service providers, subcontractors and competent authorities, where necessary to provide the services, complete the transaction, deliver the order, manage returns and refunds or comply with legal obligations.

Users may request information about the categories of recipients relating to processing carried out by Harmont & Blaine S.p.A. by writing to privacy@harmontblaine.com. For processing carried out by Global-e, users may write to dataprotection@global-e.com.

Personal data may be transferred outside the European Economic Area (EEA), Switzerland or the United Kingdom where this is necessary for the purposes indicated in this Privacy Policy.

For transfers carried out by Harmont & Blaine S.p.A., where applicable, the safeguards required by data protection law will be adopted, including adequacy decisions, Standard Contractual Clauses or other mechanisms provided for under Articles 44 et seq. GDPR.

For transfers carried out by Global-e, where applicable, the safeguards required under data protection law are adopted, including adequacy decisions, Standard Contractual Clauses or other mechanisms provided for under Articles 44 et seq. GDPR. In the absence of an adequacy decision or other recognised mechanism, transfers may be governed by the European Commission Standard Contractual Clauses, including Module 1 relating to controller-to-controller transfers, and any additional safeguards applicable.

Global-e and the relevant payment service providers process the data necessary to perform the transaction according to the applicable privacy roles and for their respective purposes.

D. PROCESSING METHODS AND SECURITY MEASURES

Harmont & Blaine S.p.A. and Global-e, each for the processing activities falling within its respective area of responsibility, process personal data using IT, automated and electronic tools and, in limited cases, paper-based means.

Each data controller adopts appropriate technical and organisational measures to protect personal data against unauthorised or unlawful access and against accidental or unlawful loss, destruction, alteration or disclosure, in accordance with applicable law.

Access to personal data is permitted only to authorised personnel and to persons who need access for the performance of the activities falling within their respective responsibilities, subject to the applicable confidentiality and security obligations.

Although appropriate measures are adopted to protect personal data, the risks connected with the transmission of data through networks and online systems cannot be completely eliminated.

E. LINKS TO THIRD-PARTY WEBSITES OR PLATFORMS

The Site may display banners, advertising messages and links to third-party websites or platforms. Harmont & Blaine S.p.A. does not control and is not responsible for the manner in which such third parties process personal data.

Users are encouraged to read the privacy notices of third-party websites and services before providing personal data.

F. MINORS

The protection of minors online is an important element of Harmont & Blaine S.p.A.'s policy. By purchasing on the Site, subscribing to the newsletter or giving consent to marketing and/or profiling, users declare that they meet the age requirements provided for under applicable law.

G. RIGHTS OF DATA SUBJECTS

Under the GDPR, the user/customer, as data subject, has the right, in the cases and within the limits provided for by applicable law, to:

• be informed about the collection and use of personal data concerning them;
• obtain confirmation as to whether or not personal data concerning them are being processed and, where that is the case, access the personal data and the information required by law;
• obtain the rectification or completion of inaccurate or incomplete personal data;
• obtain the erasure of personal data ("right to be forgotten");
• obtain restriction of processing in the cases provided for;
• receive, where applicable, personal data in a structured, commonly used and machine-readable format and transmit those data to another controller ("right to data portability");
• object to processing in the cases provided for by law;
• object at any time to processing for direct marketing purposes, including any profiling related to such direct marketing;
• withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal;
• lodge a complaint with the competent supervisory authority. In Italy, users may contact the Italian Data Protection Authority (Garante per la protezione dei dati personali).

As Harmont & Blaine S.p.A. and Global-e act as independent data controllers, rights must be exercised against the controller responsible for the specific processing activity to which the request relates.

For processing carried out by Harmont & Blaine S.p.A., users may write to privacy@harmontblaine.com or, for data protection matters, to dpo@harmontblaine.com.

For processing carried out by Global-e, users may write to dataprotection@global-e.com or contact Global-e's Data Protection Officer at dpo@global-e.com.

Where a request concerns data shared between Harmont & Blaine S.p.A. and Global-e, the two controllers may cooperate, to the extent necessary, to ensure that the data subject's request is properly managed.

H. RIGHT TO OBJECT

Pursuant to Article 21(1) and (2) GDPR, for processing based on legitimate interest and for marketing purposes, you have the right to object. This right may be exercised by writing to privacy@harmontblaine.com (privacy@harmontblaine.com); by writing to this address, you may request not to receive further commercial communications from the Data Controller.

In addition, to unsubscribe from the newsletter service or stop receiving marketing communications, you may click at any time on the "unsubscribe" link at the bottom of each communication you receive. For marketing calls, where you have given your consent, you may object by registering with the Italian Public Register of Objections ([https://registrodelleopposizioni.it/cittadino/](https://registrodelleopposizioni.it/cittadino/)).

I. CHANGES TO THIS PRIVACY POLICY

Any future changes to this Privacy Policy will be published on the Site and, where necessary, notified to users by email. Users are encouraged to review this Privacy Policy frequently to check for any updates or changes.

Last updated: 29 September 2026