pursuant to EU Regulation 2016/679 ("Regulation")
Sales made through the online store integrated into the Site (hereinafter the "E-Store") and all activities related to them (eg. order management, sales, product delivery, payment management, returns and guarantees management, post - sale activities) are carried out by Triboo Digitale Srl in its own name, in coordination with René Caovilla S.p.A. and its subsidiaries, identified below, to ensure the User an integrated service and improve the shopping experience.
1. Data Controller
The data controllers of the Users who visit and browse the Site (navigation and profiling data), as well as the Users who register and use the services available on the Site and possibly the services offered in the stores, are the company René Caovilla SpA, with headquarters in Via Nazionale 24, 30032 Fiesso d'Artico (VE) FC / VAT IT00166690271, telephone: + 39-049-9801300, email: email@example.com , (hereinafter also "Caovilla").
With regard to the processing of personal data connected and related to purchases made through the E-Store (including pre- and post-sales assistance activities), the data controller, together with Caovilla, is Triboo Digitale Srl, with registered office in Milan, viale Sarca 336, building sixteen, Tax Code and VAT n. 02912880966, +39.0264741491 firstname.lastname@example.org (hereinafter also "Triboo", together with Caovilla, the "Co-holders").
Users can also contact Triboo’s Data protection Officer (RPD or DPO), whose contact details are listed below: mail email@example.com.
2. Type of data
For the consultation of the public pages of the Site, no provision of personal data by the User is required. However, any contact with Caovilla and / or Triboo, the optional, explicit and spontaneous sending of messages, by electronic or postal mail, to their contact details entail the subsequent acquisition of the sender's address, including e-mail, or the relative telephone number, necessary to respond to requests, as well as any other personal data included in the relevant communications. These data will be used for the sole purpose of following up on the User's request and may be disclosed to third parties only if this is necessary for this purpose. These data are kept for the time strictly necessary to provide the User with the requested service and will not be disclosed.
In addition, the computer systems and computer programs used for the operation of the Site collect some personal data whose transmission is implicit in the use of Internet communication protocols (e.g. IP addresses or domain names of computers used by users who connect to the Site, URI addresses - Uniform Resource Identifier- of the requested resources, time of the request, method used to submit the request to the server, size of the file obtained in response, numerical code about the status of the response made by the server - success, error, etc. - and other parameters relating to the operating system and the User's IT environment). Although this information is not collected to be associated with identified interested parties, by its nature it could allow to identify users through processing and association with data held by third parties.
These data are used for the sole purpose of obtaining statistical information on the use of the Site not associated with any identification data of the User and to check its correct functioning and are deleted immediately after processing.
Data provided during registration and use of the services
Registration on the Site and the use of the related services are optional: although registration on the Site allows the User to enjoy a simpler browsing and purchase experience, any online purchases may also be made without registration.
In the event of registration on the Site by creating a personal Account or of use other services available on the Site, the processing of personal data will concern the operations, or the complex of operations (such as by way of example: collection, registration, consultation, organisation, storage, processing, communication, modification, selection, use), mainly concerning the data provided by the User during the registration and / or during the use of the services:
- a) identification and contact data of the User, acquired during the registration of the User's account, including:
- - some essential data for account registration (e.g. username, password, name, surname, telephone and / or email contacts);
- - some data that are entirely optional and functional for the management of the account (e.g. date of birth, gender, address of residence);
- b) data relating to the User's profile, optionally provided by the User for the creation and management of their profile, including nicknames and any additional information relating to their profession, or preferences and interests;
- c) data relating to online purchases, generally provided by the User and essential for the conclusion of the contract and the execution of orders (e.g. personal data, billing, residence and delivery address, payment data, information relating to any interactions with Triboo for pre-sales and after-sales, returns, complaints, guarantees services);
- d) if the User decides to log in through social applications (for example Facebook Connect and, Amazon), some data are made public by the User on their social network profile (such as, by way of example: name, surname, gender, city and email address, language, photo). The treatment will be limited to the type of data required for traditional registration on the Site and management of the User's account. The use of this method of access will not entail any communication of data to any social networks by Caovilla;
- e) data relating to the User's profile optionally provided by the User for the creation and management of their profile, including nicknames and any additional information relating to their profession, or preferences and interests;
- f) any data of third parties (e.g. recipients of products sent as gifts) which, although not using the features of the Site, can still be acquired by Caovilla or Triboo as entered by the User as recipients of deliveries.
The User is required to ensure that the personal data provided to the Co-holders are correct and, in case of changes, to update such data by writing to Caovilla (and / or to Triboo in case of data provided in the context of online purchases) or by using the options allowed within the personal area, if the User is registered.
Data relating to minors
The co-holders do not accept registrations or orders made by children under (18) years, nor will they knowingly collect or use their personal data. Minors are asked not to register or not to purchase online and to ask an adult to carry out the necessary procedures.
3. Purposes of the Processing
Personal data will be collected and processed for the purposes and according to the following methods:
- (1) to provide the services requested by the User (e.g. management of the registration and access to the Site processes, management of the User's account, assistance to the user, and management of any complaints, wish list management, data processing for the provision of the individual services requested by the User, to be notified - in the case of a User request - when a product becomes available in the E-Store). For these purposes Caovilla can process personal data without the User's consent pursuant to art. 6 par. b) of the Regulation;
- (2) for the fulfilment of any legal and / or regulatory obligations (e.g. billing, bookkeeping, security incident reporting obligations). For these purposes, the data may be processed by the Co-holders, without the User's consent pursuant to art. 6 par. c) of the Regulation;
- (3) for the management of online orders (e.g. carry out the online operations necessary for the management of the order; verify that the information provided for the transaction is complete, valid, correct and not fraudulent; process the order and deliver the products; provide pre- and post-sale assistance services, including returns or repairs or the management of legal guarantees; contact the User, also via e-mail, for any problem relating to the management of the order or to subsequent requests relating to the order). For these purposes, the data will be processed by the Co-holders, without the User's consent pursuant to art. 6 par. b), of the Regulation;
- (4) for the protection of our rights, both in court and out of court. For these purposes Caovilla and Triboo can process personal data without the User's consent pursuant to art. 6 par. f), of the Regulation;
- (5) to elaborate internal statistical analyses, after anonymization of the data, in order to improve the quality of the services. For these purposes Caovilla may freely use the information as anonymous and aggregated;
- (6) with the User's consent, for marketing purposes by sending, via mail post, e-mail, fixed and mobile telephone, SMS and other digital channels provided by the User, (such as, for example, the instant messaging services Whatsapp and Wechat) - newsletters and commercial communications relating to Caovilla's products or services, as well as, to make by telephone or via e-mail invitations to events, statistical analysis, surveys and market surveys, including online, related to the products and services offered by Caovilla. If the User has also consented to the profiling activity described below, Caovilla may use the result of the analysis thus conducted to send communications deemed of interest to the User by Caovilla, and to inform the User about Caovilla products and / or services that may be of interest;
- (7) with the User’s consent, for profiling purposes, and specifically for Caovilla's analysis of the choices, preferences, interests and purchasing habits of the User and the ways in which the User interacts with Caovilla acquired during the use of the services and/or on the occasion of purchases made at our points of sale, present in the various countries, including non-European ones, where the Caovilla Group operates. The data may also be used by Caovilla through the creation of individual and / or aggregate profiles to process market analysis and statistics aimed at identifying products and / or services of interest to its customers. The data collected relating to purchases - made online and at our stores - can also be used to provide a personalized service in all our stores and will be combined with any information obtained by Caovilla through interactions with the staff of the Caovilla Group stores to offer a better purchase experience in all the Caovilla Group shops.
4. Nature of data provision
With respect to the purposes referred to in points (1) - (5), the provision of data marked as mandatory during registration (or in further circumstances in which the User is required to provide data) is necessary to use the services and the refusal implies the objective impossibility to use the services. It is not necessary to acquire the User's consent for these processing purposes.
The provision of any data, for example data relating to the User profile, other than the mandatory ones, is completely optional and free and any refusal does not affect the possibility for the User to use the services in any way. In this case, the User may not be able to fully enjoy some features of the Site that technically need the provision of some information (e.g. suggestions for outfits that may be of interest to the User).
The provision of data that may be functional to the pursuit of the purposes referred to in points (6) - (7) is not mandatory and any refusal does not in any way affect the possibility for the User to use the services. In this case, Caovilla may not be able, for example, to send the user promotional material targeted on products that may be of interest to the User. In any case, it is understood that the processing of data for these purposes can only take place in the presence of the express and specific consent by the User.
The Site collects and uses technical and profiling cookies, also coming from third parties. For more information or to disable all or some of the cookies used, click here
6. Communication and dissemination of data
For the correct performance of the activities connected to the E-Store, employees and consultants appointed by Caovilla and Triboo respectively for each respective competence, who need to process the data for the performance of their duties will be able to access the personal data indicated above (ex. administration, customer service). Furthermore, personal data may be made available to third-party companies that perform, on behalf of the Co-holders, specific services as Data Processors (e.g. logistics and shipping service providers, IT services) or be disclosed to third parties (whose list is available on request in the ways indicated in point 10) which process data independently and in compliance with the law only to execute the purchase contract (e.g. intermediary in payments or credit institution for the remote execution of electronic payment services by credit / debit card).
With regard to further processing activities, Caovilla may make the data available to its employees and consultants; the data may also be available to third-party companies that perform, on behalf of Caovilla, specific services as Data Processors (eg. suppliers of logistics and IT services, management of marketing and analysis activities and sending of newsletters, eg. Triboo Digitale that also manages the Site and stores transactional data relating to online purchases on its servers; the companies of the Caovilla Group that manage the stores). Users have the right to obtain a list of any appointed Data Processors, making a request to Caovilla in the manner indicated in paragraph 10 below.
The data may be communicated to police forces or to the judicial authority, in accordance with the law and upon formal request by these subjects.
Personal data will not be disclosed or transferred to third parties for use for their own purposes; it is understood that, in the event of any extraordinary corporate transactions (e.g. transfer or lease of a company, merger, etc.), the data could be transferred to third-party buyers / tenants or right holders.
7. Transfer of data abroad
Personal data could be transferred outside the territory of the European Union, even in countries where the level of protection of personal data could be lower than that guaranteed by European legislation. This transfer will take place, in any case, in compliance with adequate guarantees for the protection of your data and, in particular, with the standard contractual clauses approved by the EU Commission with decision no. 2010/87/EC.
Each one for its part, Caovilla and Triboo recognise the importance of protecting the personal data of their customers (e.g. identification data and financial data, including credit card numbers) and of the Users of the Site. For this reason, Caovilla and Triboo adopt technical and organisational security policies and measures to protect the Users' personal data and the IT systems used for the management of the Site, in compliance with the regulations in force. In particular, Caovilla and Triboo have implemented measures to protect personal data against accidental or intentional tampering, loss, destruction, disclosure or unauthorised access to data collected online.
However, even though Caovilla and Triboo continue to implement and improve security measures in line with the development of technology and industry standards, by the very nature of the Internet these measures cannot limit or totally exclude the risk of unauthorised access or dissemination of data. It is therefore recommended to periodically update the software for the protection of data transmission in the network (e.g. antivirus) and to verify that your electronic communications service provider has adopted suitable measures for the security of data transmission in the network (e.g. firewall and spam filters). The User is also reminded that access to the personal account, containing personal data, is possible only by means of username and password: to help us better protect these data, it is therefore recommended not to communicate or make this information available to third parties.
With regard to payments made for online purchases through the E-Store, the site uses systems aimed at ensuring maximum security thanks to the use of the most advanced technological and coding systems (SSL).
9. Data storage
Personal data will be kept for the time necessary to achieve the purposes described above. In particular, the data will be kept for the entire duration of the relationship (e.g. opening of the account), as well as for the time required to fulfil legal obligations (e.g. keeping accounts for 10 years, storage for billing purposes and to fulfil tax obligations, in the case of data relating to online purchases) or until the withdrawal of consent or request for cancellation regarding data collected for marketing purposes (e.g. unsubscribe to newsletters).
In case of consent, the information relating to your purchases may be kept - for profiling purposes - for a period of (....7) years, while the information relating to your interactions with us will not be processed beyond 12 months, starting from the date of collection.
Outside these cases, personal data will be kept only to fulfil the legal and regulatory obligations placed on Caovilla and Triboo, or for evidentiary purposes relating to the exercise of the right of defence.
10. Rights of the interested party
Pursuant to the provisions of articles 15-22 of the Regulation Users have at any time the right to
- - receive by Caovilla and Triboo, each for its competence, confirmation of the existence of their personal data, access their content and obtain a copy (right of access);
- - update, modify and / or correct personal data (right of rectification);
- - request the cancellation or limitation of data processing in the cases provided for by the Regulation, including where the data have been processed in violation of the law or if conservation is not necessary in relation to the purposes for which the data were collected or otherwise processed (right to cancellation and right to limitation);
- - withdraw consent, if given, at any time and without prejudice to the lawfulness of the processing based on the consent given before the revocation (right to withdraw the consent);
- - within the limits of the provisions of the Regulation, receive a copy of the data provided in a structured commonly used format, readable by an automatic device and request that such data are transmitted to another data controller if technically feasible (right to data portability).
The User also has the right to object at any time to the processing of data for direct marketing purposes, including profiling, insofar as it is connected to such direct marketing and in the event that the processing is based on legitimate interest (right of opposition).
User also has the right to contact the Guarantor for the protection of personal data to protect his/her rights ( www.garanteprivacy.it ).
To exercise these rights, the User can direct his request via the contact form at this Link or contact Caovilla (and Triboo, if the request concerns the processing of data for the management of online purchases) at the respective offices (see point 1).
If the User has consented to the use of data by Caovilla to receive advertising and promotional and informative material, and he wishes that his data are no longer used to receive advertising (or are used to receive advertising only through certain channels, e.g. mail or email), it will be sufficient to communicate this request to Caovilla in the ways indicated below or by changing the account in this regard. The User may follow the same procedure in the event that he intends to withdraw his consent, if given, to the use of his data for profiling purposes. For the exercise of these rights, the User may contact the contact details indicated in point 1.
Last updated: 14/9/2020