Effective Date: May 24, 2018
When it comes to your personal information, we believe in transparency, not surprises. That’s why we’ve set out here what personal information we collect, what we do with it and your choices and rights
1. Who controls your personal information?
Under the GDPR, the controller is the subject that, alone or jointly with others, determines the purposes and means of the processing of personal information
The controller for the data processing related to the activities of the Site is:
- Société 23.3 Srl, Via Felice Casati 20, 20124, Milano (Italy)
There is a designated Data Protection Officer to ensure that the Site processes personal information in compliance with the GDPR. The DPO can be contacted for any enquiries at the following email address: email@example.com
2. What kind of personal information we collect?
We collect various personal information regarding you or your device. This includes the following:
- Information you provide to create an Account, specifically email address, first name and last name. The Site clearly indicates which personal information is mandatory (or not) to set up a Site account
- Information you provide when submitting an order, essential for fulfilling the purchase orders and comply with contractual obligations (e.g., name and surname, e-mail address, delivery address, etc.). Such personal information is also essential for the Customer Service to assist customers on enquiries and for any related necessity, before or after the sale (for instance, with respect to the order delivery status or on product returns). Personal information related to orders will be stored as long as required to comply with contractual obligations and with the applicable tax and financial reporting obligations. The Site may also verify the payment instruments used by customers to purchase on the Site (e.g. credit or debit card, etc.) for the main purpose of preventing fraudulent activities or pursuant to the applicable anti-money-laundering laws. As full reliance for payment verification is given to third party payment processors, the Controllers do not process or store any financial information belonging to customers. Failure to provide the personal information required at checkout will prevent users from completing an order on the Site. Based on its legitimate interest to improve its relationship with customers, the Site will send to the latter email communications with product suggestions, discounts, feedback requests or other updates. Customers are always free to unsubscribe from such email communications (for instance, by clicking on the “unsubscribe link” at the bottom of each email)
- Your newsletter and marketing preferences: On the Site, users can opt to receive newsletters and commercial communications. The Site always collects the explicit, free and unambiguous consent of users prior to submitting newsletters and marketing communications to these users or, more in general, before undertaking electronic marketing initiatives dedicated to them. In such cases, users may be invited to submit personal information in addition to their e-mail address (e.g., gender, country of residence, etc.) for the purpose of having newsletter and marketing communications tailored to the user profile
Users can always easily withdraw their consent from receiving newsletters and commercial communications in the following ways:
- Through their account settings
- By clicking on the ‘unsubscribe’ link in any of such email
- By contacting our Customer service
- The emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. Please be aware that information on public parts of our sites is available to others
- Information you share with us in connection with surveys, contests or promotions
- Information from your use of our website: IP addresses, preferences, web pages you visited prior to coming to our site, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact our site (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors)
- Profiling: Under the explicit user’s consent, newsletter and marketing communications may be tailored to the user “profile”, based on the personal information the Site collects or receives about the concerned user. With respect to the customers of the Site, it is in the Site’s legitimate interest to process personal information to offer more interesting products, to improve the Site and to personalize the products offered on the Site. The main purpose of profiling is to propose products, services and initiatives more responsive to the tastes, shopping habits and interests of users and customers. Personal information may be also used for remarketing, retargeting or profiling purposes, including via third parties (e.g., social networks, etc.). Neither the Site nor the Controllers will ever carry out any profiling activities relating to children
- Other information you submit to us directly or through Third Party Services
3. How do we collect personal information?
We obtain personal information from various sources. We do this in three main ways:
- You provide some of it directly (such as by registering for an Account)
- We record some of it automatically when you use our website (including with technologies like cookies)
- We receive some of it from third parties (like when you register for an account using a Third Party Service or when you make payments to us using our payment processor)
We’ve described this in more detail below:
a. Personal information you provide
When you use our website, we collect information from you in a number of ways. For instance, we ask you to provide your name and email address to register and manage your Account. We also maintain your marketing preferences and the emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. You might also provide us with information in other ways, including by responding to surveys, submitting a form or participating in contests or similar promotions
b. Personal information obtained from your use of our website (browsing data)
c. Personal information obtained from other sources
If you use a Third Party Service (such as Google) to register for an Account, the Third Party Service may provide us with your Third Party Service account information on your behalf, such as your name and email address (we don’t store passwords you use to access Third Party Services). Your privacy settings on the Third Party Service normally control what they share with us. Make sure you are comfortable with what they share by reviewing their privacy policies and, if necessary, modifying your privacy settings directly on the Third Party Service
4. How do we use your personal information?
We may transfer personal information of customers to primary third-party suppliers, acting as “data processors” (the “Processors”), for the purpose of performing business operations in order to fulfil their contractual obligations. we will make our best effort to ensure that all Processors will apply their industry best practice to protect personal information and that they will not use personal information for any other purposes than those agreed with the Controllers. sharing personal information with the Processors is necessary for us to fulfil our contractual obligations and, also, to improve the Site’s products and services. Users can request an updated list of the Processors involved in the processing of personal information relevant to the Site’s activities by writing an email to: firstname.lastname@example.org. The Controllers must always reserve the right to disclose personal information about users as required by law (for instance, in response to law enforcement requests), and where needed to protect the rights of the Controllers or their affiliates or third parties.
Moreover, personal information may be disclosed to other companies within our same corporate group, or to third parties in the event of a corporate restructuring process, in full compliance with the applicable law. In any other cases, the sharing of personal information will be conditional upon the preliminary and explicit consent of the user, unless processing is allowed under an alternative legal basis. we will not transfer any personal information outside the European Economic Area (EEA), unless the user has explicitly authorized such transfer or the transfer of personal information outside the EEA is allowed by the GDPR on another legal basis.
We use the personal information we obtain about you to:
- Provision of the Services: Create and manage your Account, provide and personalize our Services, process payments and respond to your inquiries
- Communicating with you: Communicate with you, including by sending you emails about your transactions and Service-related announcements
- Surveys and contests: Administer surveys, contests and other promotions
- Promotion: Promote our Services and send you tailored marketing communications about products, services, offers, programs and promotions
- Advertising: Analyze your interactions with our website so we can tailor our advertising to what we think will interest you
- Security: Ensure the security and integrity of our Services
- Enforcement: Enforce our Terms of Service and other legal terms and policies
- Protection: Protect our and others’ interests, rights and property (e.g., to protect our Users from abuse)
- Complying with law: Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests
5. How can we share your personal information?
We share personal information in the following ways:
- Affiliates: We share personal information with our affiliates when it is reasonably necessary or desirable, such as to help provide services to you or analyze and improve the services we or they provide
- Users: We share with our Users data regarding usage by End Users of their sites. For example, we provide a User with information about what web page the End User visited before coming to their site and how their End Users interacted with their site. This is so Users can analyze the usage of their sites and improve their services
- Business partners: We may share personal information with business partners. For example, we may share your personal information when our Services are integrated with their Third Party Services, but only when you have been informed or would otherwise expect such sharing
- Service providers: We share personal information with our service providers that perform services on our behalf. For example, we may use third parties to help us provide customer support, manage our advertisements on other sites, send marketing and other communications on our behalf or assist with data storage
- Process payments: We transmit your personal information via an encrypted connection to our payment processor
- following the law or protecting rights and interests: We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests (such as enforcing our Terms of Service) or prevent fraud or abuse of Users. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements
- Advertising: We share personal information with third parties so they and we can provide you with tailored advertising and measure and monitor its effectiveness. For example, we may share your pseudonymized email address with a third party social media platform on which we advertise to avoid serving ads to people who already visit our website
- Business transfers: If we're involved in a reorganization, merger, acquisition or sale of some or all of our assets, your personal information may be transferred as part of that deal
6. What rights and choices do you have?
Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information. You can access, update, change or delete personal information either directly in your Account or by contacting us at email@example.com to request the required changes. You can exercise your other rights (including deleting your Account) by contacting us at the same email address. You can also elect not to receive marketing communications by changing your preferences in your Account or by following the unsubscribe instruction in such communications, for example in the footer of every newsletter you receive from us
Please note that, for technical reasons, there is likely to be a delay in deleting your personal Information from our systems when you ask us to delete it. We also will retain personal Information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law
Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal
7. How do we protect your personal information?
We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities
8. How do we retain your personal information?
The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria. For example, the period we keep your email address is connected to how long your Account is active, while the period for which we keep a support message is based on how long has passed since the last submission in the thread
Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized or de-personalized information which we may retain indefinitely
9. Can we transfer your personal data?
Personal information that you submit may be transferred to countries other than where you live, such as, for example, to where our servers are based. We also store personal information locally on the devices you use to access the website. Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information. We rely upon a number of means to transfer personal information which is subject to the European General Data Protection Regulation (“GDPR”) in accordance with Chapter V of the GDPR. These include:
- Privacy Shield: We transfer, in accordance with Article 45 of the GDPR, personal information to companies that have certified their compliance with the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks (each individually and jointly, the “Privacy Shield”)
- Standard data protection clauses: We may, in accordance with Article 46 of the GDPR, transfer personal information to recipients that have entered into the European Commission approved contract for the transfer of personal data outside the European Economic Area
- Other means: We may, in accordance with Articles 45 and 46 of the GDPR, transfer personal information to recipients that are in a country the European Commission or a European data protection supervisory authority has confirmed, by decision, offers an adequate level of data protection, pursuant to an approved certification mechanism or code of conduct, together with binding enforcement commitments from the recipient to apply the appropriate safeguards, including as regards data subjects’ rights, or to processors which have committed to comply with binding corporate rules
15. How to contact us
Manebí (Société 23.3 Srl)
Via Novi 3, 20122, Miano (Italy)
Effective Date: May 24, 2018
1. What are cookies?
Cookies are small pieces of text sent to your browser when you visit a site. They serve a variety of functions, like enabling us to remember certain information you provide to us as you navigate between pages on the Services
2. What kind of cookies do we use?
Advertising cookies: these cookies allow the Site to create an anonymous profile of users based on their browsing experience on this Site and on others. In such a way, it is possible to provide users with advertisements targeted to their interests rather than generic advertising. This is a list of advertising cookies (it includes a link to more information on such cookies and the instructions to manage user consent):
Retargeting cookies: these cookies allow third-parties to send advertising to users who have previously visited the Site. This is a list of retargeting cookies:
- Facebook Custom Audience
Social media cookies: these cookies are needed to share content on social networks. This is a list of social media cookies:
Analytical cookies: these cookies are collected by third parties, in individual or aggregated form, in order to collect information on the number of users and on how they visit the website, such as information on which pages or sections are most viewed. This is a list of analytical cookies (it includes a link to pages with more information on such cookies and the instructions on how to manage user consent):
- Google Analytics
- GA Audience
- Advertising cookies: these cookies allow the Site to create an anonymous profile of users based on their browsing experience on this Site and on others. In such a way, it is possible to provide users with advertisements targeted to their interests rather than generic advertising. This is a list of advertising cookies (it includes a link to more information on such cookies and the instructions to manage user consent):
3. Opting Out
- Internet Explorer
4. Device Identifiers
We use device identifiers on our website to track, analyze and improve the performance of the Services and our ads
5. Third Party Tags
We use and manage third party tags on the website. Third party tags may take the form of pixels or tracking snippets. We use pixels to learn how you interact with our site pages and emails, and this information helps us and our ad partners provide you with a more tailored experience. We use Google Tag Manager to manage our third party tag usage. This may cause other tags to be activated which may, for their part, collect data and set cookies under certain circumstances. Google Tag Manager does not store this data
7. How to contact us
Manebí (Société 23.3 Srl)
Via Novi 3, 20122, Miano (Italy)
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