PRIVACY NOTICE TO USERS

 

Triboo Digitale S.r.l. with registered office in Viale Sarca 336, Building 16, 20126 Milan, VAT number / C.F. and registration number in the Milan Companies’ Register IT02387250307 (hereinafter, also "Triboo") and Dernamaria srl, with registered office in  Via di Tizzano 169 50012 Bagno a Ripoli (FI ) VAT / Tax Code 05441650487 and registration number in the Florence Companies’ Register 547168 (hereinafter also the "Partner" and, together with Triboo, the "Data Controllers"), as joint controllers of the personal data of users (hereinafter, the "Users ") who surf and use the services available on the website www.ermannoscervino.com (hereinafter, the" Site "and the" Services ") provide below the privacy policy pursuant to art. 13 of EU Regulation 2016/679 of 27 April 2016 (hereinafter, the "Regulation", or also the "Applicable Law").

This Site and the related Services are reserved for individuals who have reached the age of eighteen. Therefore, the Data Controllers do not collect personal data relating to persons under the age of 16. At the request of the Users, the Data Controllers will promptly delete any personal data inadvertently collected and relating to subjects under the age of 16.

The Data Controllers take the utmost account of the right to privacy and protection of the personal data of their Users. For any information in relation to this privacy statement, Users can contact the Data Controllers at any time, using the following methods:

For Triboo:

• Sending a registered letter to the registered office of the Data processing controller (Viale Sarca n. 336, Edificio sedici, 20126 Milano);
• By sending an e-mail message to the address privacy@triboo.it
• By sending a fax to +39.0264741491

For the Partner:

• Sending a registered letter to the registered office of the Data processing controller (Via di Tizzano 169 50012 Bagno a Ripoli (FI)
• By sending an e-mail message to the address customercare@ermannoscervino.it

 

Users can also contact

• the Data protection Officer (RPD or DPO) of Triboo, whose contact details are listed below: mail […].
• the Data protection Officer (RPD or DPO) of the Partner, whose contact details are listed below: Avv. Lorenzo Mannocci, born in Florence on 22 August 1969 (fiscal code MNN LNZ 69M22 D612Y; P. IVA 06094060487, with office in Florence, at Via Claudio Monteverdi n. 37, e-mail l.mannocci@mpiconsulting.it, PEC lorenzo.mannocci@firenze.pecavvocati.it, mobile: 3471972803.1.
• Users' personal data will be lawfully processed by Triboo pursuant to art. 6 of the Regulation for the following processing purposes:

1. contractual obligations and provision of the Services, to allow navigation of the Site or to execute the Conditions of Use of the Site, which are accepted by the User when registering on it and / or when using the Services and fulfil specific User requests. The User data collected by Triboo for the purposes listed above are: name, surname and nickname voluntarily chosen, age, province of residence / domicile, gender, email address, date of birth, telephone number as well as all personal information of the User possibly and voluntarily published. Unless the User gives Triboo a specific and optional consent to the processing of his / her data for further purposes, User's personal data will be used by Triboo for the exclusive purpose of ascertaining the User's identity (also by validating the address e-mail), thus avoiding possible scams or abuses, and contacting the User for service reasons only (eg. sending notifications relating to the Services). Without prejudice to the provisions elsewhere in this privacy statement, in no case will Triboo make the personal data of the Users accessible to other Users and / or third parties.
2. administrative-accounting purposes, or to carry out activities of an organisational, administrative, financial and accounting nature, such as internal organisational activities and activities functional to the fulfilment of contractual and pre-contractual obligations;
3. legal obligations, or to fulfil obligations established by law, by an authority, by a regulation or by European legislation.

The provision of personal data for the processing purposes indicated above is optional but necessary, since failure to provide them will make it impossible for the User to browse the site, register on it and the Services proposed.

The personal data that are necessary for the pursuit of the processing purposes described in this paragraph 1 are indicated with an asterisk in the registration form on the Site.

 

2. Additional processing purposes: marketing (sending advertising material, direct sales and commercial communication)

Upon free and optional consent by the User, some personal data of the User (that is name, surname, email address, telephone number and date of birth) may also be processed by the Partner for marketing purposes (sending advertising material, direct sales and commercial communication), or so that the Partner can contact the User  by mail, e-mail, telephone (landline and / or mobile, with automated call or call communication systems with and / or without the intervention of an operator) and / or SMS and / or MMS  to propose to the User the purchase of products and / or services offered by the same Partners and / or from third-party companies, present offers, promotions and commercial opportunities.

In case of lack of consent, the possibility of registering on the Site will not be affected in any way.

In the event of consent, the User may at any time revoke the same, by making a request to the Partner in the manner indicated in the following  paragraph 7.

The User can also easily oppose further sending of promotional communications via email by clicking on the appropriate link for the withdrawal of consent, which is present in each promotional email.  Once the consent has been revoked, the Partner will send the User an e-mail message to confirm that the consent has been revoked.  If the User intends to withdraw his/her consent to the sending of promotional communications by telephone, while continuing to receive promotional communications via email, or vice versa, please send a request to the Data Controller in the manner indicated in the following  paragraph 7.

The Partner informs that, following the exercise of the right to object to the sending of promotional communications via email, it is possible that, for technical and operational reasons (e.g. formation of the contact lists already completed shortly before receipt of the opposition request by the Partner) the User continues to receive some additional promotional messages. Should the User continue to receive promotional messages after 24 hours have elapsed from exercising the right of opposition, please report the problem to the Partner, using the contacts indicated in the following  paragraph 7.

 

3. Further processing purposes: newsletter

Upon free and optional consent by the User, some personal data of the User (i.e. name, surname, address, e-mail address and date of birth may be processed by the Partner also for the purpose of sending the newsletter. Therefore, the User will receive a periodic newsletter from the Partner which will contain information in relation  to news and promotions on the Site and / or initiatives of the Partner.

In case of lack of consent, the possibility of registering on the Website will not be affected in any way.

In the event of consent, the User may at any time revoke the same, by making a request to the Data Controller in the manner indicated in the following paragraph 7.

The User can also easily oppose further sending of promotional communications by clicking on the appropriate link for the withdrawal of consent, which is present in each email containing the newsletter.  Once the consent has been revoked, the Partner will send the User an e-mail message to confirm that the consent has been revoked.

 

4. Further processing purposes: profiling

Upon free and optional consent by the User, the User's personal data (ie  personal and contact data as well as purchase data, the information relating to the services towards which the same has expressed an interest ) may also be processed by the Partner for profiling purposes, or to reconstruct the User's tastes and consumption habits, identifying their consumer profile, in order to be able to send the User commercial offers consistent with the identified profile.

In case of lack of consent, the possibility of registering on the Site will not be affected in any way.

In the event of consent, the User may at any time revoke the same, by making a request to the Partner in the manner indicated in the following  paragraph 7 .

 

5. Methods of processing and time of data retention

The Controller will process the Users' personal data using manual and IT tools, with logic strictly related to the purposes themselves and, in any case, in such a way as to guarantee the security and confidentiality of the data. 

Users’ personal data will be stored for the time strictly necessary to carry out the primary purposes described in paragraph 1 above, or in any case as necessary to protect the rights and interests of both Users and Triboo. 

In the cases referred to in paragraphs 2, 3 and 4 above, the personal data of Users will be kept for the time strictly necessary to carry out the purposes illustrated therein and, in any case, for no more than twenty-four (24) and twelve, (12) months respectively.

 

6. Scope of communication and dissemination of data

The employees and / or collaborators of the Data Controllers in charge of managing the Site and all the services connected to the provision of the Services may become aware of the Users' personal data. These subjects, who have been instructed to do so by the Controllers pursuant to Article 29 of the Regulation, will process the Users' data exclusively for the purposes indicated in this information and in compliance with the provisions of the Applicable Law. 

Third parties who may process personal data on behalf of the Data Controllers as "External Data Processors", such as, by way of example, suppliers of IT and logistical services functional to the operation of the Website, outsourcing or cloud computing service providers, professionals and consultants may also become aware of the Users' personal data.

Users have the right to get a list of possible data processing managers appointed by each Controller, by making a request to the Data Controller concerned in the manner indicated in the following paragraph 7.

Furthermore, the personal data of the Users may be communicated by Triboo to independent third-party data controllers, such as the managers of the payment services and the logistics services necessary for the delivery of goods sold through the Site, as far as this is necessary and essential to execute contractual obligations. These independent owners will process the User's data exclusively for the purpose of the correct fulfilment of orders relating to the Services.

 

7. Rights of the interested parties

Users may exercise the rights guaranteed to them by the Applicable Law, by contacting the Controllers in the following ways:

Sending a registered letter to the registered office of the Data controllers
- for Triboo: Viale Sarca 336, Edificio 16, 20126 - Milan, Italy
- for the Partner: Via di Tizzano 169 50012 Bagno a Ripoli (FI

By sending an e-mail message to the address
- for Triboo: privacy@triboo.it
- for thePartner: customercare@ermannoscervino.it

Triboo will comply with the Users 'requests relating to the treatments referred to in paragraph 1, while the Partner will comply with the Users' requests relating to the treatments referred to in paragraphs 2, 3 and 4.

Pursuant to the Applicable Law, the Data Controllers inform that Users have the right to be informed about (i) the origin of personal data; (ii) the purposes and methods of processing; (iii) the logic applied in the case of processing carried out with the aid of electronic tools; (iv) the identification data concerning the data controllers and data processors; (v) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as managers or agents.

In addition, users have the right to obtain:

1. a) access, updating, rectification or, where interested, integration of the data;
2. b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
3. c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the event that such compliance proves impossible or involves a manifestly disproportionate use of resources with respect to the protected right.

 

In addition, users have:

1. A) the right to withdraw consent at any time, if the treatment is based on their consent;

(b) (where applicable) the right to data portability (right to receive all personal data concerning them in a structured, commonly used and self-readable format), the right to restrict the processing of personal data and the right to cancellation ("Right to Oblivion");

1. c) the right to oppose:
2. i) in whole or in part, for legitimate reasons to the processing of personal data, even if pertinent for collection purposes;
3. ii) in whole or in part, to the processing of personal data for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication.

iii) if personal data are processed for direct marketing purposes, at any time, to the processing of their data carried out for this purpose, including profiling to the extent that it is connected to such direct marketing.

(d) If they believe that the treatment which concerns them violates the regulation, the right to complain to a supervisory authority (in the Member State where they usually reside, in the one where they work or in the one where the alleged violation occurred). The Italian Supervisory Body is the guarantor for the protection of personal data, based in Piazza di Montecitorio n. 121, 00186 – Rome (http://www.garanteprivacy.it/).

The data controllers are not responsible for the updating of all the links present in this Policy, so whenever a link is not working and/or updated, the users acknowledge and accept that they will always have to refer to the document and/or section of the Web sites recalled by that link.

As required by the General Provision of the Guarantor for the protection of personal data called "'Fidelity card' and guarantees for consumers. The rules of the Guarantor for loyalty programs ”of 24 February 2005.