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RENÉ CAOVILLA SPA
Sales transacted through the online shop that is part of the Site (hereinafter “E-Store”) and all the activities related to them (for example, handling of orders, sales, product delivery, payments handling, administering returns and warranties, post-sales activity) are carried out by FiloBlu S.p.a. on its own name, in accord to René Caovilla S.p.A., to assure Users an integrated service and to improve their buying experience.
1. DATA CONTROLLER
The independent controller of personal data of Users who visit and browse the Site (browsing and profiling data), as well as of those Users that register and use available service on the Site, with the exception made for online purchases (personal records, further data aimed to marketing and profiling activity, where authorized by the User), is René Caovilla S.p.A. (referred to hereinafter as “Caovilla"), with registered offices at Via Paradisi 1, 30032 Fiesso d’Artico (Venice), Italy, Tax Code/VAT registration number IT00166690271, telephone: +39-049-9801300, email: email@example.com.
As for the processing of personal data connected and correlating to the purchases made through the E-Store (including pre- and post-sales assistance), the joint data controller of the processing, together with Caovilla, is FiloBlu S.p.a., with registered office at Via Caltana 116/C., Santa Maria di Sala (Venice), Italy, VAT registration number IT04274870288 (hereinafter, also referred to as “FiloBlu”).
2. TYPE OF DATA
For Users to consult public pages of the Site they are not requested to provide personal data. However, any possible contact with Caovilla and/or FiloBlu, any optional, explicit, and spontaneous dispatch of messages, of electronic or traditional mail, to their addresses shall entail the subsequent acquisition of the address, including e-mail ones, of the sender or of the respective telephone number, needed to reply to requests, as well as of any other personal data included in the respective communications. Said data shall be used for the sole purpose of giving effect to the request of the User and can be notified to third parties only in the case where this is necessary for that purpose. The data will be held for the time strictly necessary to provide the User with the requested service and shall not be disclosed.
In addition, the information systems and the computer programs used for operating the Site gather certain personal data the transmission of which is implicit in the use of internet communication protocols (for example, IP addresses or dominion names of the computers used by the Users connecting to the Site, URI -Uniform Resource Identifier- addresses of the resources requested, the time of the request, the method used in submitting the request to the server, the size of the file obtained on replying, the numerical code for the status of the reply given by the server - successful, error etc., and other parameters relating to the User’s operating system and computer environment). Though the information is not gathered to be matched with the identified data subjects it could, by its nature, through processing and matching with data held by third parties, enable Users to be identified.
This information is used solely to obtain statistical information - unmatched with an identifying data item of the User - on the use of the Site and to check on its proper operation and it is immediately cancelled after being processed.
Data provided when registering and when using the services
Registering on the Site and using the respective services are optional. Though registering on the Site, it makes browsing and purchasing simpler for Users, any online purchases may be made even without registering.
When Users register at the Site by creating a Personal Account or they use other services available at the Site, the processing of personal data will be directed at the operations, or the complex of operations (purely by way of example: gathering, registering, consulting, organising, keeping, processing, communicating, modifying, selecting, and using), that mostly regard the data provided by Users when they register and/or when they use the services:
a) USERS’ IDENTIFYING AND CONTACTING DATA, obtained when Users register their account, including:
● certain data essential for registering their account (for example: username, password, name, surname, telephone and/or email contacts);
● certain data entirely optional and useful solely to manage the account (for example: date of birth, gender, address where resident);
b) DATA CONCERNING USER’S PROFILE, provided at the choice of the User for creating and handling their profile, including their nickname and any additional information about their occupation, their preferences, and interests;
c) DATA REGARDING ONLINE PURCHASES, provided generally by the User and essential to close the contract and to finalize the orders (for example: personal records, address where resident, data invoicing, delivery, payment data, information regarding any interaction with FiloBlu regarding pre- and post-sales services, returns, complaints, warranties);
d) if Users opt for login using social applications (for example: Facebook Connect, Google+, Twitter), SOME DATA MADE PUBLIC BY USERS IN THEIR PROFILE ON THE RESPECTIVE SOCIAL NETWORK (for example: name, surname, gender, town and email address, language, photograph). Processing shall be limited to data type requested for traditional way of registering on the Site and to manage Users’ accounts. The use of this type of access shall not entail Caovilla in any way notifying data to any social networks;
e) DATA REGARDING USERS’ HABITS AND PREFERENCES (for example: history purchases, wish lists, type of products purchased, consumer preferences, interests, preferred outfits);
f) any DATA ABOUT THIRD PARTIES (FOR EXAMPLE: RECIPIENTS OF PRODUCTS SENT AS PRESENTS) that, though they do not use Site functions, their data may in any case be obtained by Caovilla or FiloBlu in that said third parties are input, by the Users, as recipients of deliveries.
Users must ensure that personal data provided to Caovilla and to FiloBlu are correct and, in the event of data changes, they must update the data by emailing Caovilla (and/or to FiloBlu in case of data given during online purchases) or, in case of registered Users, by using allowed options in their personal area.
Data regarding minors
Caovilla and FiloBlu do not accept registrations or orders by minors (persons under the age of 18 years old), nor do they knowingly gather or use their personal data. Minors are instructed not to register or not to make online purchases and to ask an adult to carry out the necessary procedures.
3. THE PURPOSES OF PROCESSING PERSONAL DATA
Personal data is gathered and it is processed for the purposes and in the ways listed below:
(1) FOR PROVIDING SERVICES requested by Users (for example: managing the processes of registering and accessing the Site, operating Users’ accounts, assisting Users, and handling any complaints, handling wish lists, and processing data for the performance of individual services requested by Users). In relation to these purposes Caovilla may process personal data without the Users consent in accordance to article 6, point b) of European regulation 2016/679;
(2) for fulfilling any OBBLIGATIONS IN LAW AND/OR IN REGULATIONS (for example: invoicing, keeping accounts, duties to report safety accidents). In relation to these purposes the data may be processed by the joint data controllers without the consent of Users in accordance with article 6, point a) of European regulation EU 2016/679;
(3) for HANDLING ONLINE ORDERS (for example: performing online operations necessary for managing orders; checking that the information given for the transaction is complete, valid, correct and not fraudulent; processing the order and delivering products; providing pre- and after- sales service, including returns and repairs or giving effect to the legal warranties, contacting Users, including via e-mail, for any problem related to handling the order or to subsequent requests relating to the order). In relation to these purposes the data shall be processed by the joint data controllers without the consent of Users in accordance to article 6, point b) of European regulation EU 2016/679;
(4) for DEFENDING OUR RIGHTS both in court proceedings and out of court. In relation to these purposes Caovilla and FiloBlu can process the personal data without the consent of Users in accordance to article 6, point f) of European regulation EU 2016/679;
(5) to conduct internal STATISTICAL ANALYSES, subject to the data being anonymised, to improve quality services. In relation to these purposes the joint data controllers may use the information freely in that it is anonymous and in aggregated form;
(6) subject to the consent of Users, for MARKETING PURPOSES,through dispatching, by e-mail, traditional (paper) mail, telephone, fax and/or SMS/MMS, and push notifications, newsletters and sales communications regarding the products and services of Caovilla, and also to conduct by telephone or via e-mail STATISTICAL ANALYSES, MARKET POLLS AND MARKET RESEARCH, including online, regarding the products and services offered by Caovilla. If Users have also consented to profiling activity described earlier, Caovilla may use the result of the analysis carried out in this way to send notifications that Caovilla judges to be of interest to the Users, and to inform Users about its products and/or services that may be of interest to them;
(7) subject to the consent of Users, for PROFILING PURPOSES, and specifically about the analysis by Caovilla of Users’ purchasing choices, preferences, interests, and habits as recorded while they were using the services. The data may be used by Caovilla also by creating individual and/or aggregated profiles to conduct market and statistical analyses directed at identifying products and/or services of interest to its customers.
4. USERS’ NATURE OF DATA PROVISION – MANDATORY OR OPTIONAL
Regarding data processing purposes listed in points (1) to (5), the provision of data marked as mandatory during registration phase (or in other circumstances where Users are requested to provide data) is necessary in order to use the services and any refusal makes it materially impossible to use the services. For these data processing purposes, the consent of Users doesn’t need to be obtained.
The provision of data other than mandatory data ̶ for example data about Users’ profiles ̶ is entirely optional and free, and any refusal does not in any way prevent Users from using the services. Where this happens, however, Users may be unable to fully use a number of functions on the Site that require, for technical purposes, provision of certain information (for example: suggestions for outfits that may be of interest to the User).
The provision of data that may assist the data processing purposes in points (6) and (7) is not mandatory and any refusal does not in any way prevent Users from using the services. However, where this happens Caovilla may not be able, for example, to transmit to Users targeted promotional material about products that may be of interest to the User. In any case, it is understood that the processing of data for these purposes may only take place where there is the expressed consent of Users.
Pursuant to Provision no. 229 http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/3118884 issued by the Personal Data Protection Authority on May 8, 2014, www.renecaovilla.com provides the following information on cookies and on their functions, as well as instructions on how to disable them.
What are cookies?
Cookies are small text files that the sites visited by the user send and record on his/her PC or on any other device, even mobile, to be sent back to the original sites on the next visit.
Cookies are used for various purposes, for instance, to remember the user’s actions and preferences (such as, for instance, login data, selected language, font size, other display settings, etc.) so that they must not re-entered when the user returns to the same site or surfs from one of its pages to another; or to perform computer authentications, to monitor sessions and store information on the activities of user who access a site, and it can also contain a unique ID code that allows keeping track of the user’s surfing within the site for statistic or advertising purposes.
Cookies can be sent by www.renecaovilla.com or also by different sites (the so-called “third party” cookies). Some operations cannot be carried out without using cookies that in some cases are technically necessary for the site to work.
Types of cookies found on the site www.renecaovilla.com and relevant functions
There are various types of cookies, according to their characteristics and functions:
- Technical cookies, which are used for the sole purpose of sending a communication on an electronic communication network, or in the measure strictly necessary to provide a service explicitly requested by the user. In other words, these cookies are indispensable to make www.renecaovilla.com work, or necessary to perform activities that you have requested. This type of cookie can be found in our site;
- Navigation or session cookies, used to allow you to login in the reserved area of www.renecaovilla.com or to make a purchase on our site. This type of cookie can be found in our site;
- Analytics cookies, used to collect information, in an aggregate form, on the number of users of www.renecaovilla.com and of the displayed pages (for instance, Google AdWords, Google Analytics and Mailchimp). Please, refer to the relevant policies that can change from time to time and that we recommend consulting every now and then, where you will find more detailed information:
This type of cookie can be found in our site;
- Function cookies, which allow you to surf www.renecaovilla.com at your best, according to already selected criteria and options (such as, for instance, your preferred language) so that you won’t have to select such option or the products you have chosen at every access, and they can be stored in the virtual trolley until your next visit to our site. This type of cookie can be found in our site;
- cookies of third parties, used by partners of www.renecaovilla.com, in order to display advertising banners of www.renecaovilla.com when you are on other sites, showing you the latest products that you have looked at on www.renecaovilla.com. While you browse on www.renecaovilla.com, these cookies are used also to show you products that you might like or similar to those you have previously browsed, based on your previous navigation chronology. The use of these cookies does not imply personal data treatment, but it can enable your computer or other devices to connect and track down saved data: these cookies connect to the browser installed on your computer or on other devices used while browsing on www.renecaovilla.com;
- profiling cookies, used to create user profiles in order to send advertising messages consistent with the preferences shown by the user during his/her navigation. Our site contains third party cookies that access user data only at aggregate level. Please, find here below the links to the privacy policies and relevant consent forms of such third parties, which can change from time to time and that we recommend consulting every now and then, where you will find more detailed information:
All the above-described types of cookies can stay in your computer or mobile device for different times, according to their function.
The cookies stored in your computer or mobile device cannot be used to recall any of the data stored in your hard disk, transmit viruses, identify and use your e-mail address, or for purposes other than those described above.
How to modify cookie settings
You can set and manage your cookie preferences at any time, by selecting which cookies you want to authorize, block or cancel, totally or partially, through the settings of your browser (or the navigation program that you use).
Find here below the path to follow to manage the cookies from the following browsers:
Internet Explorer: http://windows.microsoft.com/it-it/windows7/block-enable-or-allow-cookies
For more information and details on the various types of cookies, their functions and characteristics, visit the free access sites, independent from www.renecaovilla.com - www.AllAboutCookies.org and www.youronlinechoices.com.
To disable analytics cookies and prevent Google Analytics from collecting data on your navigation you can download the browser additional Component for disabling Google Analytics: tools.google.com/dlpage/gaoptout.
We will store your cookie preferences thanks to a dedicated technical cookie with the characteristics specified in the previous table.
We inform you that blocking or cancel, totally or partially:
- technical cookies, could make it impossible to use our site, see its contents and use the relevant services;
- function cookies, could make some services or site functions unavailable or working incorrectly, forcing you to modify or manually enter some information or preferences every time you visit the site.
- of other cookies (analytics and profiling), will not affect the site efficiency.
6. DISCLOSURE AND DATA RELEASE
So that the activities related to the E-Store function properly, the personal data indicated above may be accessed by employee staff, as well as by non-employee personnel appointed by the joint data controllers, that need to process data to carry out their duties (for example, digital function, administration, and customer service). In addition, the personal data can be made available to third party companies that, on behalf of the joint data controllers, perform specific services in the capacity of Data Processors (for example, suppliers of logistical and forwarding services, data services) or notified to third parties (a list of them is available on request following the procedures under article 10) that process the data independently and in accordance with the law solely in order to give effect to the purchase contract (for example, payment intermediaries or banks that perform remote electronic payment services by means of credit/debit cards).
Regarding the other processing activities Caovilla may make available data to its employees and non-employee workers; data may also be available to third party companies that, on behalf of the joint data controllers, perform specific services in the capacity of Data Processors (for example, suppliers of logistical and data services, handling of marketing and analysis activities – FiloBlu, for example, which operates the Site and holds on its servers the transaction data relating to online purchases).
The data may be notified to police forces or to the judicial authorities in accordance with the law and subject to a formal request from them.
The personal data shall not be released or transferred to third parties so that they can use them for their own purposes. The Parties agree that in the event of extraordinary corporate operations (for example, the assignment or renting of a business, mergers, etc.), the data may be assigned or transferred to the third party buyers/leaseholders or title holders.
7. TRANSFER OF DATA ABROAD
As a rule, personal data shall not be transferred abroad. If, to run the Site in a better and more efficient way, the data were to be transferred abroad, Caovilla (and FiloBlu) undertake to guarantee proper levels of protection and safeguard including a contractual nature in accordance with the applicable rules, including making standard contract clauses.
Caovilla, and FiloBlu in so far as it has competence, acknowledge the importance of protecting personal data of customers (for example, their identifying data and their financial data, including their credit card numbers) and of the Users of the Site. For this reason, Caovilla and FiloBlu adopt policies and security measures of a technical and organisational nature to protect, having regard of the rules in force, the personal data of the Users and the information systems used in managing the site. In particular, Caovilla and FiloBlu have implemented measures to protect personal data against accidental or intentional tampering, loss, destruction, dissemination, or unauthorized access to data gathered online.
However, though Caovilla and FiloBlu continue to implement and improve security measures in line with the development of technology and of industry standards, for the very nature of the Internet these measures cannot restrict or totally exclude the risk of unauthorised access or the dissemination of data. Accordingly, Users are advised to periodically update their software for protecting data transmission over networks (for example, antivirus software) and to check that their provider of electronic communication services has adopted suitable means for the security of data transmission over networks (for example, firewalls and anti spamming filters). Users are also reminded that access to their personal account, containing their personal data, is only possible by means of a username and password. To help us to better protect that data we accordingly recommend that Users do not disclose or make available that information to third parties.
About payments made for online purchases via the E-Store, the Site uses systems to guarantee the utmost security thanks to the use of the most advanced technological and codifying systems (SSL).
9. DATA HOLDING
Personal data shall be held for the time needed to achieve the purposes described above. In particular, the data shall be held for the entire duration of the relationship (for example, creation of the account), as well as for the time necessary for fulfilling legal obligations (for example, keeping accounts for 10 years, holding data for invoicing purposes and for fulfilling tax obligations, where the data regards online purchases) or, in case of data related to marketing purposes, until consent is withdrawn or customer asked for deleting (for example, unsubscribing from newsletters).
Where consent is given for profiling, the data shall be held for the maximum time determined for profiling and customized marketing by the “Garante per la protezione dei dati personali” (Italian Data Protection Authority).
Apart from such cases, personal data shall be held only to fulfil the legal and regulatory obligations on Caovilla and FiloBlu, or for evidential purposes connected to conducting a legal defence.
10. RIGHTS OF THE DATA SUBJECT
Under articles 15-22 of European regulation EU 2016/679 Users have the right at any time to obtain from Caovilla and FiloBlu :
Users likewise have the right to apply to the” Garante per la protezione dei dati personali” (Italian Data Protection Authority) www.garanteprivacy.it to uphold their rights. To exercise those rights Users may send their application by email to: firstname.lastname@example.org or contact Caovilla (and FiloBlu, if the application concerns the processing of data for handling online purchases) at their respective registered offices (see point 1).
If Users have consented to the use of their data by Caovilla so that they receive advertising, promotion material and information and want their data no longer to be used to receive advertising (or be used to receive advertising only through certain channels, for example by post of email) all they need to do is notify this request to Caovilla in the manner indicated below, or by changing their account accordingly. Users can also follow the same procedure if they intend to withdraw their consent, if given, to the use of their data for profiling. To exercise these rights Users can apply to the addresses shown in point 1.