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Contents

  1. 1. Who is responsible for processing your data
  2. 2. What personal data we process
  3. 3. Why we use your data
  4. 4. Shopify and our technology platform
  5. 5. Who we share your data with
  6. 6. Cookies and similar technologies
  7. 7. International transfers
  8. 8. Data retention
  9. 9. Automated decision-making
  10. 10. Security
  11. 11. Your rights
  12. 12. How to exercise your rights
  13. 13. Minors
  14. 14. Changes to this Privacy Policy

PRIVACY POLICY — NOVE25

Last updated: October 2026

Contents
  1. 1. Who is responsible for processing your data
  2. 2. What personal data we process
  3. 3. Why we use your data
  4. 4. Shopify and our technology platform
  5. 5. Who we share your data with
  6. 6. Cookies and similar technologies
  7. 7. International transfers
  8. 8. Data retention
  9. 9. Automated decision-making
  10. 10. Security
  11. 11. Your rights
  12. 12. How to exercise your rights
  13. 13. Minors
  14. 14. Changes to this Privacy Policy

1. Who is responsible for processing your data

This Privacy Policy explains how the personal data of users and customers of www.nove25.net (the “Website”) are processed.

Nove25 S.r.l. (“NOVE25”) and Velara Brands, S.L. (“Velara”) act as joint controllers, pursuant to Article 26 of Regulation (EU) 2016/679 (“GDPR”), in relation to activities connected with the online sale of products through the Website, including customer account management, orders, purchases, payments, delivery and purchase-related support.

Nove25 S.r.l. — VAT No. / Tax Code 04217070962 — REA MI-1733121 — Via Savona 127/B, 20144 Milan (MI), Italy.

Velara Brands, S.L. — Spanish Tax ID (NIF) B22672596 — C/ Roger de Lauria 19, 4th Floor, 46002 Valencia, Spain.

Velara operates the Website and acts as Seller of Record and contractual seller for products purchased online.

NOVE25 and Velara have contractually regulated their respective data protection responsibilities. Essential information regarding this arrangement may be requested using the contact channels indicated in this Policy.

NOVE25 also acts as an independent controller in relation to Club Nove25, loyalty programmes, marketing activities, newsletters, commercial communications and profiling relating to the NOVE25 brand, as well as activities carried out in its physical stores.

Velara also acts as an independent controller in relation to processing required for its administrative, accounting, tax and legal obligations as Seller of Record, as well as fraud prevention, transaction security, after-sales management and the defence of potential claims.

2. What personal data we process

Depending on how you use the Website, we may process identification and contact data; account and Club Nove25 data; data relating to orders, purchases, returns, exchanges and refunds; data required for invoicing and compliance with legal obligations; data relating to personalised products; browsing and device data; and marketing and profiling data derived from your preferences, purchases and interaction with the Website.

Payment data are processed through the payment service providers enabled at checkout and, as a general rule, we do not store complete payment card details.

3. Why we use your data

A. Customer account

We use your data to create and manage your account, allow you to access your orders and use features associated with the Website. The legal basis is performance of the contract or taking pre-contractual steps at your request.

B. Sales and order management

NOVE25 and Velara will process the data required to manage purchases made through the Website, including order confirmation, payment, preparation, delivery and communications relating to the purchase. The legal basis is performance of the sales contract.

C. Payments, invoicing and legal obligations

Velara will process the data required to process payments, issue invoices, manage accounting and comply with its tax, administrative and legal obligations as Seller of Record. The legal basis is performance of the contract and compliance with legal obligations.

D. Customer service, returns, exchanges and refunds

Velara and, where necessary, NOVE25 will process your data to respond to enquiries relating to orders and to manage returns, exchanges, refunds, defective products, warranties and other after-sales requests. For certain return or refund operations we may use specialised platforms such as Reveni.

E. Club Nove25

NOVE25 will process your data to manage your participation in Club Nove25, including benefits and promotions associated with the programme, such as the Welcome Discount, Birthday Discount and other loyalty initiatives. Applying these benefits to an online purchase may require certain information to be communicated to Velara so that the relevant promotion can be verified and applied.

F. Marketing and newsletters

Where you have given your consent, NOVE25 may use your data to send newsletters, news, promotions, launches, events and other commercial communications relating to NOVE25. These communications may be managed using specialised providers such as Klaviyo. You may unsubscribe at any time using the link included in each communication or the channels indicated in this Policy.

G. Profiling and personalisation

Where you have given your consent, NOVE25 may analyse information relating to your purchases, browsing, preferences and campaign interactions in order to create commercial profiles and provide more relevant content, recommendations and communications. This processing may rely on tools such as Shopify, Klaviyo and analytics and advertising platforms.

H. Analytics and advertising

Where you have provided the consent required through the cookie management system, we may use analytics, measurement and advertising technologies provided, among others, by Google, including Google Analytics and Google Ads, and by Meta Platforms, including Facebook, Instagram, Meta Ads and technologies such as Meta Pixel.

These technologies allow us to analyse how the Website is used, measure advertising campaign performance, create audiences and display relevant advertising. Depending on the specific service and its configuration, these providers may act as processors, independent controllers or joint controllers in accordance with their own terms and applicable law.

I. Security and fraud prevention

Velara may process data relating to transactions, devices, purchasing behaviour and other indicators in order to detect and prevent fraud, misuse or threats to the security of the Website and transactions. The legal basis is the legitimate interest in protecting operations, customers and systems.

4. Shopify and our technology platform

The Website uses Shopify as its e-commerce technology platform. Shopify processes personal data required to provide functions such as browsing, checkout, accounts, orders and store operation.

As a general rule, in relation to customer data processed to provide the platform, the merchant acts as controller and Shopify as processor. Shopify may, however, act as controller in relation to certain additional services depending on its own terms and configuration.

The Shopify environment may integrate the applications, providers and technologies required to manage the different functions of the Website.

5. Who we share your data with

To provide our services, we may disclose or provide access to certain personal data to service providers and partners, including Shopify and its subprocessors; payment service providers; logistics operators, warehouses and carriers; Reveni for certain return or refund processes; Klaviyo for CRM and communications; Google for analytics and advertising; Meta Platforms for advertising, measurement and audiences; fraud prevention and security providers; and legal, tax, accounting and technology advisers.

Some providers may act as independent controllers in relation to specific processing activities. In such cases, the processing will also be subject to their own policies and terms.

We do not sell your personal data.

6. Cookies and similar technologies

The Website uses cookies and similar technologies that are necessary for its operation and, with your consent where required, for analytics, personalisation, advertising and profiling.

You may accept, reject or change your preferences using the cookie manager available on the Website. Consent may be withdrawn at any time. For details of the cookies and technologies used, please see our Cookie Policy.

7. International transfers

Some technology providers may process personal data from countries outside the European Economic Area. Where international transfers of data take place, the safeguards required by applicable law will be used, including adequacy decisions, Standard Contractual Clauses or other legally recognised mechanisms.

8. Data retention

We will retain data only for as long as necessary to fulfil the purpose for which they were collected. Data relating to orders, invoicing and legal obligations will be retained for the periods required by applicable law; account data while the account remains active and for any necessary subsequent periods; and data used for marketing and profiling while there is a valid legal basis for such processing and until you withdraw your consent or object where applicable.

Where applicable, certain marketing and profiling data may be retained for a maximum of 24 months from collection or from the last relevant interaction. Certain data may also be retained for the applicable limitation periods in order to establish, exercise or defend legal claims.

9. Automated decision-making

We may use automated tools to analyse browsing patterns, preferences, commercial behaviour or fraud risk. Unless we expressly inform you otherwise, we will not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.

10. Security

NOVE25 and Velara will apply appropriate technical and organisational measures to protect personal data against loss, destruction, alteration, unauthorised access or disclosure. Providers processing data on our behalf must offer appropriate guarantees of security and confidentiality.

11. Your rights

Under the conditions provided for by the GDPR, you may request access to your personal data, rectification or erasure, restriction of processing, object to certain processing activities and request data portability.

Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal. You also have the right to lodge a complaint with the competent data protection authority.

12. How to exercise your rights

To facilitate the handling of requests relating to the Website, you may contact us at info@nove25.net.

NOVE25 and Velara will coordinate any request affecting processing carried out jointly, regardless of which of the two companies initially receives the request. This does not limit your right to contact either Joint Controller directly.

13. Minors

The Website and online sales services are intended for adults. NOVE25 and Velara do not knowingly collect data from minors where this is not permitted by applicable law.

14. Changes to this Privacy Policy

This Policy may be updated to reflect changes in legislation, the operation of the Website, the services offered or the providers used. The current version will be available on the Website at all times together with the date of its latest update.

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