Privacy Policy

Last updated: 06.09.2026

Version: 1.0

General

This Privacy Policy (“Policy”) describes how Divima SA collects and uses your personal data in connection with HÉRITAGE TIES website and services. The terms “HÉRITAGE”, “we”, “us”, or “our” refer to Divima SA, registered under the laws of Italy.

Scope

This Policy applies to the HÉRITAGE website (theheritageties.com – the “Website”) and service offerings available via the Website (collectively – the “Services”). The Services, together with our website, are referred to as the “Platform”. 

This Privacy Policy does not constitute, create, or form part of any contract or warranty between you and HÉRITAGE. This Policy is provided for informational purposes under the applicable privacy laws and regulations.

Who is responsible for your data

For the purposes of applicable data protection laws (in particular, the General Data Protection Regulation (EU) 2016/679 ("GDPR")), your data will be controlled by the HÉRITAGE, which provides the Platform to you as a Controller of your personal data.

HÉRITAGE TIES provides an online retail platform that allows customers to browse, select, and purchase neckties and related accessories directly from our brand. Customers can view product details, customize selections where applicable, and complete purchases through secure checkout system. 

Controller details

Registered name: Divima, SA

Registered address: Via Castagne Della Corte, 2, 84026 Postiglione, Italy

Privacy support: contact@theheritageties.com  

Failure to provide personal data

Please read this Privacy Policy and our Terms of Use carefully before using the Services. If you do not agree with the Terms of Use, you should not use the Services. For information about how we process your personal data, please refer to the Privacy Policy.

 If we are required by law to collect personal data, or if it is necessary to process your requests or fulfill a contract with you, and you do not provide the requested data, we may be unable to carry out your instructions or meet our contractual obligations. In such cases, we may need to terminate our engagement or the contract, but we will inform you of this decision at that time.

Key terms and definitions

Personal data: any information relating to an identified or identifiable natural person (“Data subject”). For the purposes of GDPR, personal data means any information relating to You such as a name, surname, gender, age, health information, preferences etc.

Processing of personal data: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Data controller: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

You: means any individual accessing the Platform (the “Visitor”) or obtaining the Services (the “Customer”), or otherwise interacting with us directly or indirectly, including as a prospective (the “Prospective Customer”), current, former Customer, individual promoting our product (the “Ambassador”), our social media follower (the “Follower”) or individual providing us with the services (including those working on our contractors) (the “Contractor”).

Services: refers to the sale of HÉRITAGE products to Customers through the HÉRITAGE Platform.

Website: refers to the HÉRITAGE website accessible from theheritageties.com.  

Website visitor: a person who visits HÉRITAGE website.

Cookies: text files that are stored on a website visitor’s computer or mobile device by a website’s server.    

Table of contents 

·       Sources of personal data

·       Why we process your data

·       Types of personal data & legal basis for processing

·       The use of Cookies & other tracking technologies

·       Automated decisions

·       How and when we share your information

·       International data transfers

·       Data retention practices

·       Information security

·       Updating personal data

·       Children`s Privacy

·       Your Rights and Choices

·       Updates to this Privacy Policy

·       Contact information   

Sources of personal data

We obtain personal data from the following sources: 

·       Directly from you: when you buy our products through the Platform and enter your personal information (regarding Customers), conclude contract for the provision of services with us (regarding certain Contractors and Vendors), when you conclude product promotion contract with us (regarding Ambassadors), during Customer support provision (e.g. Data Subject Access Request management or “Contact us” form usage).  

·       Automatically through your use of our Platform: when you interact with the Platform, we may obtain certain personal data through the cookies.

·       Third-party and partner sources: we obtain personal data from third-party sources such as social media platforms where we identify potential influencers (Ambassadors) as well as from advertising platforms like Meta that help us with outreach, engagement, promotion and marketing. 

Why we process your data

 We process personal data for the following purposes:

·     Communication with Customers & other parties: to communicate about orders, service updates, shipment status, feature notifications, and other messages necessary for operating the Platform and fulfilling orders. 

·     Compliance with legal and regulatory requirements: to comply with legal obligations, such as responding to lawful requests from authorities, maintain accurate records for accounting and tax purposes and fulfil regulatory requirements to which the Controller is a subject. 

·     Cookies & other tracking technologies implementation: to enable the use of cookies and similar technologies for Platform operation, analytics, marketing, bug detection, crash reporting, and maintaining session state.

·     Defending or resolving legal claims: to protect our rights, manage and resolve disputes, and handle litigation, investigations, or regulatory inquiries

·     Marketing & HÉRITAGE brand promotion: to support marketing, advertising campaigns, announcements, partnerships, outreach, and promotional activities for the Platform.

·     Platform analytics and improvement: to analyze usage patterns, understand trends, measure feature performance, and guide future development.

·     Platform maintenance & performance: to operate and maintain the Platform, ensure stability and security, manage user sessions, and troubleshoot technical issues.

·     Conclusion and fulfilment of sales: to conclude and fulfil contracts for the sale and perform delivery of the product.

·     Billing and payment processing: to manage issue invoices, process payments and money transfers, to select payment processor, support billing and ensure operational and technical transaction routes through the payment infrastructure. 

·     Social and community features: to enable user (follower) interaction and engagement on social media or community-related features (e.g., Instagram interactions or comments).

·     Ambassador program fulfilment: to conclude and perform promotional agreements with Ambassadors.

·     Contractor management: to implement and manage contractual relationship with our contractors, suppliers and vendors, including product development processes (such as timelines and quality control).

·     Customer support: to provide user support, respond to enquiries, implement your rights under the GDPR and other applicable laws, including rights of access, rectification, erasure, objection, restriction, and withdrawal of consent. 

No sale of personal data

We do not sell personal data. Personal information is used only for the purposes described in this chapter and in accordance with applicable data protection laws. Personal data is shared with third parties only when necessary to provide our services, to comply with legal obligations, or with your explicit consent.

Types of personal data & legal basis for processing 

Below is a list of the categories of personal data we may collect and process about you:

·       Bookkeeping and accounting information: may include name, surname, order number, date and time of purchase, products purchased (e.g., neckties, quantity), payment method type (e.g., credit card), payment status (e.g. paid, refunded), invoice or receipt number, invoice date, order value (net, tax, gross).

·       Communication content: may include support communication content, content of messages exchanged with us and those related to legal and administrative records. 

·       Compliance information: data subject consent records, Data Subject Access Request records.

·       Contact information: may include first name and last name, email, telephone number, preferred contact method, business email or phone number (for ambassadors or corporate clients).

·       Contract information: may include data, included into the contract with our ambassadors, vendors and suppliers, such as: name, surname, identification number, country of residence, service provided.

·       Professional information: portfolio, audience demographics, engagement metrics, previous collaborations, brand fit.

·       Legal and administrative correspondence: correspondence related to contracts, disputes, claim details, court documentation, internal investigation notes and requests from authorities.

·       Device & technical data: may include session identifiers, device data, browser type and settings, cookies, logs.

·       Marketing data: may include cookie identifiers and information about your activities across websites used to deliver targeted advertising.

·       Analytics data: may include anonymized usage metrics, engagement trends, performance metrics.

·       Billing and payment information: may include payment method type (e.g., credit card), payment status (e.g. paid, failed).  Full payment card numbers and authentication credentials are processed exclusively by our payment service providers and are not stored by us. 

·       Shipment & delivery information: may include recipient name, shipping / delivery address, order number, delivery status (e.g. shipped, delivered, returned), carrier or delivery service name, tracking number.

·       Transaction / order information: may include order number, products purchased (e.g., neckties, quantity), order date and time, order status (e.g., confirmed, fulfilled, cancelled, refunded). 

·       Social media interaction information: may include public social media username or handle, public profile information (as made available by the user on the platform), content of public interactions (e.g., comments, likes, replies, mentions), direct message content (if the user contacts us privately), date and time of the interaction, content published on social media or websites relevant to assessing partnership potential.

 

The use of Cookies & other tracking technologies 

HÉRITAGE uses "cookies" – small text files stored on your computer or mobile device by our website’s server, and other limited tracking technologies to ensure smooth platform functionality and enhance your user experience. 

Certain cookies and similar technologies are essential to enable performance of the Platform and are processed on the legal basis of contract performance (Article 6 (1) (b) of the GDPR) and our legitimate interest (Article 6 (1) (f) of the GDPR).

Other cookies and tracking tools are used based on your consent to improve our website, tailor content, to optimize functionality, performance, security and advertise the Platform (Article 6 (1) (a) of the GDPR). 

You can manage your consent by using our cookie consent tool in the footer of the website or via your browser. 

Automated decisions

According to the Article 22 of the GDPR, the data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

HÉRITAGE does NOT make any decisions which produce legal effect on data subject and does not make decisions based solely on automated processing, including profiling, which produces legal effects concerning data subjects.

How and when we share your information

Below are the circumstances under which personal data may be shared: 

·       Corporate transaction: in the event of a potential or actual corporate transaction (e.g., a merger, acquisition, reorganization, sale of assets, or insolvency proceeding), we may transfer your personal data to relevant parties involved in the transaction. Such transfers will occur only to the extent necessary and subject to appropriate confidentiality and data protection safeguards, in compliance with Article 6 (1) (f) GDPR (legitimate interests) or other applicable lawful bases.

·        Compliance with the laws: we may disclose your personal data to third parties where necessary to comply with legal obligations under Article 6 (1) (c) GDPR, including to: 

o    comply with applicable laws and regulatory requirements (e.g., tax reporting).

o    respond to valid legal requests, such as court orders, subpoenas, or lawful requests from public authorities.

·       Protection and safety: we may disclose your personal data to third parties where necessary to protect vital interests including to:

 o    act in emergency situations to safeguard life or physical integrity under Article 6 (1) (d) GDPR (vital interests).

·       Service providers and professional advisors: we may share your personal data with carefully selected providers and professional advisors, such as:

 o    Financial organizations, such as banks and payment service providers, for payment processing.

o    Google LLC for business operations and advertising, including email, document storage, cloud services, and marketing tools.

o    Hostinger International Ltd. – website hosting and infrastructure services.

o    Meta LLC for marketing and advertising purposes.

o    Public authorities, including tax and regulatory bodies, where required by law.

o    Shipping providers (including UPS and FedEx) for order fulfillment and delivery.

o    Shopify Inc. for operating and managing the online store.

 We do not sell user data to any third parties. All service providers engaged by us operate under standard Data Processing Addendums (DPAs) and are compliant in accordance with Article 28 of the GDPR. We adhere to the principle of data minimization, sharing only the information necessary to deliver each specific service. 

·     With your consent: where you explicitly consent (Article 6 (1) (a) GDPR), we may share your personal data with third parties or entities of your choosing.

International data transfers 

The Company has service providers in the European Union and the United States. Therefore, personal information may be transferred to other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

 Legal mechanism for international data transfers