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The Personal Data of the Site users will be processed in Italy in compliance with applicable European laws and Legislative Decree no. 196, providing the Code on Personal Data Protection (the “CODE”).
This document was compiled as set forth by art. 13 of the CODE, by SHOOZ LTD, with legal office in via 102 Wells road, Bath - Somerset, United Kingdom, Tax code, VAT number and 213956603 Business Register number, (“SHOOZ LTD”), and Triboo Digitale S.r.l., with registered office in Viale Sarca, 336 – 20126, Milan, Italy, Tax code, VAT number and Milan Business Register number 02912880966, (“TRIBOO DIGITALE”), in quality of joint Data Controllers (hereinafter, jointly, the “JOINT DATA CONTROLLERS” ) and, through this policy, they intend to provide information on data processing procedures concerning the personal data of the Site visitors.
1. THE POLICY
2. WHO PROCESSES THE DATA, HOW AND FOR WHAT PURPOSES
Triboo Digitale is the joint Data Controller in charge of processing the personal data of the Site users aimed at managing, completing and executing commercial transactions concerning the purchase of products through the same Site. Triboo Digitale decides the scopes and processing methods to be implemented and the tools to be used for security measures. Therefore, SHOOZ LTD is the exclusive Data Controller with regards to any further activities not related to the sale of products through this website (such as for example and not limitedly to, transmission of advertising material on products and services other than those potentially purchased on our website). For purely organisational and functional needs, external Data Processors were appointed for processing the personal data of Site users, for purposes strictly linked and related to offering services on the Site, including the sale of products. These Data Processors have been chosen based on their skills, experience and reliability, through compliance with applicable laws on personal data processing, as also related to security matters. Data Processors process the personal data of Site users according to the instructions imparted by the relative joint Data Controller.
Please contact the Customer Service for a complete list of Data Processors assigned to processing the personal data of Site users, or send an email at the following address: email@example.com.
In particular, to achieve the abovementioned scopes, as part of the process when purchasing products on the Site, Triboo Digitale collects personal data (e.g. name and surname, email address, mailing address, credit card and bank details, phone number), through the product order form available on the Site.
All personal data is mainly processed in electronic format and in some cases also in paper format, such as for instance, when processing is necessary to prevent frauds on the Site.
Personal data will be stored in the form that allows identifying the user for the time strictly required to attain the scopes for which it was collected and subsequently processed and, in any case, within the limits set forth by law. To ensure accurate, updated, complete and pertinent personal data, users are asked to kindly notify us of any changes to the same, by sending us an email at: firstname.lastname@example.org.
Further to the provisions set out herein, users' personal data will not be disclosed to third parties for unlawful purposes or without their express consent.
Personal data may be provided to third parties for additional scopes related to the provision of services requested by the user (e.g. for purchase related transactions). For further details on this aspect, please refer to paragraph 4 below. An updated list of Data Processors can be requested and obtained at any time, by sending an email at: email@example.com.
Users’ personal data can be disclosed to Police forces or the Judicial Authority, for instance pursuant to Site anti-fraud services, in compliance with laws and upon request. Personal data will not be transferred abroad, to non-EU Countries which do not guarantee suitable levels of privacy protection. Should the above be required to attain Triboo Digitale’s scopes, we ensure that the transfer of Personal Data to non-EU Countries which do not guarantee adequate privacy levels will only occur after said parties and Triboo Digitale have stipulated specific agreements containing suitable privacy clauses, pursuant to applicable laws and regulations.
The scopes for which personal data is requested and processed are specifically illustrated each time in the Informative Note provided on the page where such conferral is requested.
Triboo Digitale may process third-party personal data communicated directly by Triboo Digitale’s users, for instance when the user intends to notify a friend about a service or product for sale on the Site, or when the user purchases a product to be delivered to a friend or when the subject paying for the purchase is different from the subject to whom the product will be delivered.
In the above cases, Triboo Digitale, within the limits set forth by applicable laws, will fulfil its disclosure obligations to the indicated user and, where necessary, request express consent upon registration of the personal data in its archives, or during the first contact.
3. DENYING CONFERRAL OF PERSONAL DATA AND CONSEQUENCES
Conferral of Personal Data to Triboo Digitale and, in particular, name and surname, email address, mailing address, credit/debit card and bank details and phone number, is necessary to achieve the afore-cited purposes.
Some of the abovementioned data may be essential to fulfil obligations set forth by laws or regulations, or to provide other services requested by the user as available on the Site.
Refusal to disclose certain essential personal data, identified on the Site by an asterisk (*), may prevent completing all purchase contract phases or fulfil all obligations set forth by laws and regulations in force. Failure to disclose certain data can therefore, according to specific cases, constitute a legitimate and justified reason for not executing the purchase contract concerning products offered on the Site or supply of services via the same.
Conferral to Triboo Digitale of additional personal data other than mandatory information, is instead optional and does not bear any impact on the purchase of products on the Site.
4. TO WHOM PERSONAL DATA IS DISCLOSED
Personal data may be disclosed to third parties who render specific services on behalf of Triboo Digitale as Data Processors, or it may be disclosed to other recipients of data collected by Triboo Digitale, who process data independently for the sole purpose of executing the purchase contract concerning the Site products (e.g. Global Collect, to provide payment services via credit/debit card) and only when said purpose is not inconsistent with the scopes for which the personal data was collected and subsequently processed and, in any case, in compliance with laws.
Personal data will not be disclosed, assigned or otherwise transferred to third parties without previously informing the users and gathering their consent, when required by law.
5. HOW WE COLLECT DATA ON THE SITE
Triboo Digitale collects Personal Data and other information during the online registration processes to the Site or when transmitting purchase forms for products available on the Site in order to conclude e-commerce transactions. Said data is 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
Nonetheless, as it is impossible to guarantee that the measures implemented for Site security and transmission of data and information on the Site limit or exclude any risk of unauthorised access or dissemination of data, we invite users to make sure they have an updated anti-virus software installed on their computer to protect incoming and outgoing data transmission on the web, and that their Internet provider uses firewalls and anti-spamming filters where suitable, for the security of data transmission on the web.
7. RIGHT TO ACCESS PERSONAL DATA AND OTHER RIGHTS
Users are always entitled to obtain confirmation about the existence of their personal data, even if not registered yet, and its disclosure in intelligible form.
Users are always entitled to obtain from each joint Data Controller:
- updating, correction or integration of personal data;
- deletion, transformation in anonymous form or blocking of data that has been processed unlawfully, including data whose storage is not required according to the scopes for which it was collected or subsequently processed;
- confirmation that the transactions indicated in letters a) and b) were disclosed, also with regards to their content, to those subjects to whom data was notified or disclosed, except in case notification proves impossible or requires the use of means clearly disproportionate to the right being protected.
Users are also entitled to oppose, totally or partially:
- for legitimate reasons, to the processing of personal data, even if related to the collection scope;
- processing of personal data for the transmission of advertising material or direct sales, or for market researches or business communication.
- Users are entitled to freely exercise their rights at any time, within the limits set forth by law, by sending a request to Triboo Digitale at firstname.lastname@example.org and to SHOOZ LTD at email@example.com; we will respond to your email as soon as possible.
8. LINKS TO OTHER WEBSITES
The Site provides links to other websites exclusively to facilitate users in their search and navigation and to facilitate hyper-textual links to other sites on the Internet. Link activation does not imply that Triboo Digitale recommends or endorses the access to and browsing of these websites, nor it provides any guarantees regarding their contents, services or products supplied and sold by these websites to Internet users.
Regular browsing of the Site pages implies the installation of cookies by the latter or third parties, Triboo Digitale’s business partners. This configuration is motivated by needs to provide Site’s regular operation and allows us to offer an improved browsing experience.
Users wishing to receive further information on how each joint Data Controller processes personal data are invited to send an email at the following addresses: to Triboo Digitale at firstname.lastname@example.org, to SHOOZ LTD at email@example.com. To know your rights and always be updated on laws concerning the protection of persons in relation to the processing of personal data, we suggest visiting the website of the Italian Data Protection Authority at http://www.garanteprivacy.it/
11. APPLICABLE LAW
The Code ensures that personal data is processed by respecting fundamental rights and freedoms, as well as the dignity of concerned parties, particularly with regards to privacy, personal identity and the right to personal data protection.