Privacy Policy

KSM Atelier respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, share and retain personal data when you visit our website, purchase our products, contact us or apply for the KSM Signature Tee Selection.

We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable Italian data protection law.

The data controller is KSM Atelier.

Address: Via Stefano Viale 50A, 12010 Roccasparvera (CN), Italy
Email: info@ksmatelier.com

You can contact us using the email address above to ask questions about this Policy or exercise your data protection rights.

The information we collect depends on how you interact with KSM Atelier.

Website, account and order data may include your name, contact details, billing and delivery addresses, account information, order history, purchased products, transaction status and information needed to manage payments, delivery, returns and customer support.

Technical data may include IP address, browser and device information, operating system, pages visited, website interactions and cookie or consent preferences.

If you contact us, we may process the information you provide in your message.

KSM Signature Tee Selection application data consists only of:

• Full name
• Email address
• Instagram username
• Town or city
• Age confirmation (18+)

The Instagram username is collected through a custom question in the Meta/Instagram form. Full name, town or city and email address are collected through the form’s contact-information section. Age confirmation is collected separately through a required checkbox. This checkbox confirms age eligibility and is not, by itself, consent to all processing described in this Policy.

We do not request delivery details at the application stage. If you are selected, we will request only the information needed for shipping, such as your delivery address and, where required by the shipping provider, your telephone number.

We collect personal data directly from you when you place an order, create or use an account, contact us, submit a form, apply for the KSM Signature Tee Selection or provide delivery details after selection. Technical information may also be collected through cookies and similar technologies, subject to your settings and applicable law.

After applications close, we review information that is publicly accessible on the Instagram profile associated with the username you provide. This may include the profile image, biography, public posts, Reels and captions. We use this information only to assess whether the profile’s public style and content align with KSM Atelier’s lifestyle, brand identity and overall aesthetic when selecting recipients. The legal basis is our legitimate interest in administering the KSM Signature Tee Selection and selecting recipients. The source of this information is the publicly accessible Instagram profile, rather than information supplied directly by you in the application form. We do not use follower counts or engagement metrics as selection criteria, and we do not intentionally seek to assess sensitive personal characteristics. This Policy explains how the information is used, who may receive it, how long it is retained and the rights available to you, including the right to object to processing based on legitimate interests.

We use personal data to:

• Operate, maintain and secure the website.
• Process orders, payments, deliveries, returns and customer-service requests.
• Manage customer accounts where available.
• Respond to enquiries.
• Understand website use and improve our services through analytics, where the required consent has been obtained.
• Measure advertising performance through Meta Pixel, where the required marketing consent has been obtained.
• Administer the KSM Signature Tee Selection, review applications, select recipients and arrange delivery.
• Meet legal obligations and establish, exercise or defend legal claims where necessary.

We do not use campaign applications to subscribe applicants to a newsletter or other marketing communications. Any marketing subscription is separate.

We use the following legal bases for the purposes described in this Policy. We process order, account, payment, delivery, return and related customer-service data where necessary to perform a contract with you or take steps you request before entering into a contract. We process campaign application data and review relevant information visible on public Instagram profiles on the basis of our legitimate interests in administering the KSM Signature Tee Selection and selecting recipients whose public profile is aligned with the campaign’s stated brand criteria. We limit this review to information relevant to that purpose and do not use follower count or engagement metrics as selection criteria. We process data where necessary to comply with legal obligations, including applicable accounting and recordkeeping requirements. We use analytics and marketing technologies where required consent has been obtained. We use a photograph for publication only on the basis of separate consent, which may be withdrawn at any time. When you contact us, we use the information to respond to your request and, where relevant, to take steps you request before a contract or to pursue our legitimate interest in handling enquiries.

Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. The age-confirmation checkbox for the campaign confirms that you meet the minimum age requirement; it is not consent to analytics, marketing, publication of photographs or all other processing.

We may share personal data where necessary with:

• Shopify, for e-commerce and website services.
• Shopify Payments and the payment processor used for the selected payment method, which may include Stripe where enabled, for payment processing.
• Google, for Google Analytics 4, subject to the applicable consent settings.
• Meta, including Instagram, which hosts the campaign application form and provides advertising services.
• Shipping providers, to deliver orders or campaign products.
• The marketing service provider that manages the website, the Instagram account and advertising on KSM Atelier’s behalf, and its team.
• Professional advisers and public authorities where required by law or necessary to establish, exercise or defend legal claims.

The marketing service provider processes campaign data on KSM Atelier’s instructions and on its behalf. Access is limited to what is needed to provide the services. The agency is not named in this public Policy.

Our service providers may process personal data outside the European Economic Area (EEA). Their published terms describe different transfer arrangements depending on the service and recipient. Shopify states that certain transfers from the EEA to other Shopify entities outside the EEA and Switzerland use its Binding Corporate Rules, and that Standard Contractual Clauses may be used for certain transfers to countries without an adequate level of protection. Stripe’s published Data Processing Agreement and Data Transfers Addendum describe mechanisms including the EU–U.S. Data Privacy Framework and Standard Contractual Clauses where applicable. Google’s published information for advertising and analytics products describes use of the EU–U.S. Data Privacy Framework for transfers to covered U.S. entities and Standard Contractual Clauses for certain other transfers. Meta Platforms, Inc. is listed as active under the EU–U.S. Data Privacy Framework for covered non-HR data, and Meta also publishes information about safeguards for other transfers. The mechanism that applies to a particular transfer depends on the service, receiving entity and data flow.

Published provider information:

• Shopify Data Processing Addendum
• Shopify Binding Corporate Rules
• Stripe Data Processing Agreement
• Stripe Data Transfers Addendum
• Google international transfer information
• Meta Privacy Policy
• Meta Business Tools terms
• Meta Platforms, Inc. EU–U.S. DPF listing

The KSM Signature Tee Selection is a discretionary campaign for individuals aged 18 or older who are located in Italy. Applying does not guarantee selection or receipt of a T-shirt.

The founder or KSM Atelier team selects recipients based on their alignment with KSM Atelier’s lifestyle, brand identity and overall aesthetic. Selection is not based on a random draw or assessment of skill. Follower count and engagement metrics are not selection criteria. We may review an applicant’s public Instagram profile for this purpose.

Only selected applicants will be contacted by email or Instagram direct message. Applicants who are not selected will not receive an individual notification or feedback. Delivery details are requested separately and only from selected recipients, limited to the information needed to ship the T-shirt.

After receiving the T-shirt, a selected recipient may be invited to share a photo wearing it. Sharing a photo is entirely optional and is never a condition of selection or receipt of the T-shirt.

KSM Atelier will publish or otherwise use the photo on its channels only after obtaining separate written consent. The recipient may withdraw that consent at any time. After withdrawal, KSM Atelier will stop future use and remove the photo from channels it controls within a reasonable time, subject to technical limitations and any legal obligations. The photo and the record of consent are retained for as long as the photo is in use, with the consent record retained for any additional period strictly necessary to demonstrate compliance or handle a claim.

We retain personal data only for as long as needed for the relevant purpose or as required by law.

KSM Signature Tee Selection:

• Applicants not selected: KSM Atelier deletes application data within 30 days after the selection closes. The separate file containing the team’s notes on applicants is deleted at the same time. Meta retains its own copy of form submissions under its own settings and retention terms. Leads submitted through the Meta Instant Form remain available for download for up to 90 days from submission. This is Meta’s lead availability period, not KSM Atelier’s own data retention period. Meta’s retention of submissions on its platform is governed by Meta’s own terms and settings.
• Selected recipients: KSM Atelier deletes campaign application data, including the team’s selection notes, within 14 days after the selected recipient confirms acceptance. Delivery details are collected separately and used only to arrange shipping. Delivery, accounting, transaction or other records may be retained separately where and for as long as required by law or necessary to establish, exercise or defend legal claims.

Delivery details are collected only from selected recipients and are limited to what shipping requires.

Meta controls retention of the submissions held on its own platform. Deleting KSM Atelier’s downloaded copies does not itself delete Meta’s copy.

Order, transaction, invoice and accounting records may be retained for the periods required by applicable law. Certain accounting records may be subject to a ten-year retention period under Italian law. This does not mean that every item of personal data is retained for ten years.

We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. Access is limited to people and service providers who need the information for their duties. No method of transmission or storage is completely secure.

Subject to the conditions and exceptions under applicable law, you may request access to, correction of, deletion of or restriction of processing of your personal data; object to processing based on legitimate interests; request data portability where applicable; and withdraw consent where processing is based on consent.

To exercise your rights, contact info@ksmatelier.com. We may need to verify your identity. You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali): https://www.garanteprivacy.it/

The KSM Signature Tee Selection is reviewed by the founder or KSM Atelier team. We do not make selection decisions solely through automated processing that produce legal or similarly significant effects.

Our website and campaign may link to or use third-party platforms, including Shopify, Stripe, Google and Meta/Instagram. Those providers may process personal data under their own terms and privacy information. Please review their policies where relevant.

We may update this Policy to reflect changes in our services, processing practices or legal requirements. The current version and its revision date will be published on our website.

KSM Atelier
Via Stefano Viale 50A, 12010 Roccasparvera (CN), Italy
Email: info@ksmatelier.com