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The processing of Personal Data of Site users will be performed in Italy and conducted in accordance with applicable European legislation and Legislative Decree 30 June 2003, No. 196 providing the Personal Data Protection Code, (the "CODE").
This document drawn up in accordance with the provisions of Art. 13 of the CODE by, ROBERTSON S.r.l., with registered office in via Via Manzoni, 45 – 20121, Milano, tax code, VAT number and Business Register number MI 1855665, and Triboo Digitale S.r.l., with registered office in Milan (Italy), viale Sarca 20126, edificio 16, Post Code 336, tax code, VAT number and Milan Business Register number 02912880966 (“TRIBOO DIGITALE”), who act as joint Data Controllers (hereafter, jointly, the “JOINT DATA CONTROLLERS”), and, via the same, intend to supply all useful information pursuant to the processing of the personal data of those visiting the Site.
1. THE POLICY
2. WHO PROCESSES YOUR PERSONAL DATA, HOW AND FOR WHAT PURPOSES
Triboo Digitale is the joint Data Controller in charge of processing the personal data of Site users, exclusively as regards the managing, completion and executing of the commercial transactions involving the purchase of products via the same Site. TD decides the scope and processing methods to be implemented and the tools to be used as far as security measures are concerned. Therefore, the Data Controller for the processing of personal data in relation to all the other activities, including those which are not functional to the sale of products via this website (such as, by way of example and not limited to, the delivery of products, RMA management, mailing of advertising materials on products and services other than those which may have been purchased on the Site) is exclusively ROBERTSON S.r.l. For purely organisational and functional requirements, we have appointed some Chief Data Processors to manage user Personal Data, for purposes strictly linked and related to the provision of services on the Site, including the sale of products. Such Chief Data Processors have been selected on account of their experience, capabilities and reliability, thorough compliance with the provisions in force applying to the processing of personal data, as also related to security matters.
Please contact the Customer Care service for a complete list of the Chief Data Processors assigned to processing the personal data of Site users, or send an e-mail to: email@example.com for Robertson Sr.l. firstname.lastname@example.org for Triboo Digitale.
In particular, to achieve the aforementioned purposes, and as part of the process when purchasing products on the Site, TD collects Personal Data (e.g. name and surname, e-mail address, mailing address, credit card and bank details, telephone number) via the product order form available on the Site.
Personal Data are mainly processed in electronic format and in certain cases also in paper format, such as for instance, when the processing of personal data is necessary to prevent fraud on the Site.
Personal Data shall be retained in the form that allows users to be identified for the time strictly necessary for the purpose for which the data were collected and subsequently processed and, in any case within the limits foreseen by the laws in force. To ensure that Personal Data is always accurate and updated, pertinent and complete, Users are asked to kindly notify us of any changes to the same sending us an e-mail to: email@example.com.
Further to what already provided for above, the personal data of Users shall not be disclosed to third parties for purposes not permitted by law or without their express consent.
Personal data may be made available to third parties, for ancillary purposes related to the provision of services required by the user (for example, for purchase related transactions). For further details on this aspect, please consult paragraph 4 below.
User personal data can be disclosed to Police forces or Judicial authorities, for instance pursuant to Site anti-fraud services, in accordance with the laws in force and whenever requested. Personal data will not be transferred abroad to Countries other than those belonging to the European Union, which do not guarantee a sufficient level of privacy protection. If the above should be necessary to achieve the purposes posed by Triboo Digitale, we will ensure that the transfer of Personal Data to Countries which do not belong to the European Union and do not guarantee adequate levels of protection, will only be implemented after such parties and Triboo Digitale have all signed specific contracts containing clauses for the protection of Personal Data, in accordance with applicable law and regulations.
The purposes for which Personal Data are requests and processed shall be specifically disclosed each time in the Information Note text provided on the page where the same are requested to confer their Personal Data.
There may be cases where Triboo Digitale processes third-party personal data communicated directly by Triboo Digitale users, e.g. when the user intends to tell a friend about a service or product on sale at the Site, or when the user purchases a product to be sent to a friend or when the subject paying for the purchase is different to the subject to whom it will be delivered.
In the above cases, Triboo Digitale, to the extent required by law, shall fulfil its disclosure obligations to the indicated user and, where necessary, request relative consent, upon registration of the relevant data in its Personal Data archives, or the next useful contact.
3. DENYING CONFERRAL OF PERSONAL DATA AND RELATIVE CONSEQUENCES
Conferral of Personal Data to Triboo Digitale and, in particular, personal data, email address, mailing address, credit card/debit card and bank details and phone number, is required in order to fulfil the aforementioned purposes.
Some of the aforementioned data may be indispensable so as to fulfil the obligations imposed by the law or other regulations, or to provide other services you may have requested as provided on the Site.
Refusal to disclose certain essential Personal Data, identified on the Site by an asterisk (*), may make it impossible to complete all purchase contract phases, and/or fulfil all obligations required by the laws and regulations in force. Failure to disclose certain Data can therefore, according to individual circumstances, constitute a legitimate and justified reason preventing the execution of the purchase contract on the Site or the supply of services via the same.
On the other hand, conferral to Triboo Digitale of additional Personal Data, other than those which are compulsory, is optional and has no impact on the purchase of products on the Site.
4. TO WHOM PERSONAL DATA IS DISCLOSED
Personal Data may be disclosed and made available to third party companies that provide specific services on behalf of Robertson Sr.l. and/or Triboo Digitale, as Chief Data Processors or disclosed to other recipients of the data collected by ROBERTSON S.r.l and/or Triboo Digitale, who process data independently for the sole purpose of executing the purchase contract for products on the Site (such as, for instance, Global Collect, for the execution of remote electronic payment services, via credit card/debit card) and only when such a purpose is not inconsistent with the purposes for which the Personal Data was collected and subsequently processed and, in any case, in full compliance with the laws in force.
No Personal Data shall be disclosed, assigned or otherwise transferred to third parties without informing users and obtaining their consent in advance, when required by law.
5. HOW WE COLLECT PERSONAL DATA ON THE SITE
Triboo Digitale collects Personal Data and other information during the online registration process or when sending order forms to purchase products on the Site so as to execute e-commerce transactions. These data are processed by Triboo Digitale within the limits and purposes illustrated in the Information Note presented to users in the relative data collection section.
6. SECURITY MEASURES
However, as it is impossible to guarantee that such measures for the security of the Site and the transmission of data and information on the same Site limit or exclude any risk of unauthorised access or dissemination of data, we recommend users check that they have an updated antivirus protection system installed on their computer, which protect incoming and outgoing data, and that their Internet provider uses firewalls and anti-spamming filters where suitable for the security of data transmission on the web.
7. RIGHTS TO ACCESS PERSONAL DATA AND OTHER RIGHTS
Users are entitled to obtain confirmation as to whether or not personal data concerning them exists, regardless of their being already recorded, and communication of such data in an intelligible form.
Users are always entitled to obtain from each Joint Data Controller:
- updating, rectification or integration of Personal Data;
- erasure, anonymisation or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
- certification to the effect that the operations indicated above have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared to the right that is to be protected.
Users are also entitled to oppose, totally or partially:
- on legitimate grounds, to the processing of personal data concerning them, even though they are relevant to the purpose of the collection;
- to the processing of Personal Data concerning them, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
- Users are entitled to exercise their rights at any moment in time, within the terms and conditions of the law, sending such requests by e-mail to Triboo Digitale at firstname.lastname@example.org, to Robertson Sr.l. at email@example.com.; we will respond to your mail as soon as possible.
8. LINKS TO OTHER WEBSITES
The Site provides links to these websites exclusively to assist users in their search and browsing activities and to facilitate links to other websites on the Internet. Posting of such links does not infer that Triboo Digitale recommends the use or browsing of these websites, nor any guarantee of their content, services or merchandise supplied and sold to Internet users.
Cookies shall be set by the above or by third parties consisting of Triboo Digitale's commercial partners. Such settings are required to as to ensure normal Site functions and to allow us to provide the very best browsing experience.
Users wishing to receive further information on how their Personal Data is processed by the Joint Data Controllers should send an e-mail to the following email address: for Triboo Digitale to firstname.lastname@example.org, for Robertson Sr.l. to email@example.com. To receive further information and be updated on the rights and the regulations concerning the protection of persons in relation to the processing of Personal Data, please visit the website of the Authority for the Protection of Personal Data at http://www.garanteprivacy.it
11. APPLICABLE LAW
The Code ensures that Personal Data are processed by respecting data subjects’ rights, fundamental freedoms and dignity, particularly with regard to confidentiality, personal identity and the right to Personal Data protection.