I. GENERAL PROVISIONS
1. DATA TITLE RESPONSIBLE FOR DATA PROTECTION
At OFFICIEL SRL, each website (including online shops and mini-sites for special offers), every presence on social media, multimedia portals, chatbots and every application of the OFFICIEL has a data holder responsible for all aspects of the collection of personal data in accordance with the General Regulation for the Data protection (RGPD) (or equivalent provisions depending on applicable privacy legislation). Unless otherwise provided on the WEB SITE (in legal notes, conditions of use, etc.) or sections II and III OnlineOFFICIAL SRL VIA OF JUSTICE N 624 00189 ROME Italyis the owner of the data for the website of OFFICIEL SRL.
OFFICIAL SRL has not appointed any other data protection officer in accordance with Article 37 of the EDPS
HOW TO CONTACT OFFICE SRL
If you wish to exercise your rights regarding subscription to the newsletter, access to data or deletion of data, please do not hesitate to contact our team customer servicewho will be happy to answer any questions you may have.
Any clarifications, complaints or doubts regarding data protection should be addressed to the Group Privacy Team by writing to firstname.lastname@example.org
Alternatively, if you reside in Germany or Liechtenstein, you can contact:
- The Data Protection Officer for Italy, writing to OFFICIEL SRL Via della Giustiniana in 624 00189 Rome
2. TREATMENT OF PERSONAL DATA
OFFICIAL SRL shall collect and process the personal data of the following persons:
- users of WEB-SITIS registered by OFFICIEL SRL;
- users registered at a WEB SITE of OFFICIEL SRL (who have, for example, created a user account);
- individuals who are buyers or recipients/recipients of the products and services of OFFICIEL SRL
- the persons concerned or potentially interested in the products and services of OFFICIEL SRL
- the recipients of the newsletters of OFFICIEL SRL
- the participants in the research campaigns and opinion polls indetti from L' OFFICIEL SRL
- the participants in the courses, seminars and other training initiatives organised by L' OFFICIEL SRL
Personal data of CUSTOMERS is generally acquired directly from L' OFFICIEL SRL during the use of the WEBSITE, or at events organized by L' OFFICIEL SRL and by direct means of communication such as emails, telephone and other means. Personal data may also be acquired indirectly, for example through third parties in charge of data processing (e.g. PARTNERS of L' OFFICIEL SRL, in the meaning attributed to the term later, including wholesale resellers, commercial operators, retailers, suppliers and other business partners such as customer service providers). The OFFICIEL SRL acquires data even when the CUSTOMER making the purchase is not the person who benefits from the purchase or when the item is sent to a different recipient (e.g., in the case of a gift), when it becomes aware that a third party has advised the purchase (e.g., a friend of the CUSTOMER or a member of its family member) or with the acquisition of additional information from third party data sources (e.g. social media).
Specifically, THE OFFICIEL SRL treats the following categories of personal data :
- Personal data and contact details, including, on an indicative and non-exhaustive basis, name and surname, surname, maiden name, address, residence, telephone number, e-mail address, age, date of birth, sex, marital status, close relatives, referent in case of emergency, photographs ;
- Data on orders and purchases, including, as indicative and non-exhaustive, information for payment, credit card data and other details for payment (in accordance with applicable laws and regulations), the address for invoicing and shipping, products and services ordered and purchased, requests for information and advanced complaints in relation to products and services or to the respective signed contracts, such as advanced complaints during the warranty period, after-sales services, servicing services to the clientele, the withdrawal from the contract and any litigation ;
- Data acquired as part of marketing initiatives, including, as indicative and non-exhaustive, information relating to the newsletter and other information channels, preferences indicated with opt-in and opt-outs, invitations to participate in special events and activities (provided that they are not part of a customer loyalty program), preferences and personal interests and information for customer segmentation ;
- Data concerning the use of the WEBSITE, including, on an indicative and non-exhaustive basis, IP addresses and other identifying data of the user (e.g., the username on social media, the MAC address of the smartphone or computer, the cookies), the date and time of the visits to the WEBSITE, the sites and content visited and the sites that have addressed the visitor to our site ;
- Data linked to communications, including, by way of indicative and non-exhaustive, the selected media, correspondence and communications with L' OFFICIEL SRL (including the documentation of the communication) ;
- Data acquired under a program aimed at customers, including, by way of an indicative and non-exhaustive title, registration codes, access codes (including passwords), language of preference, gift certificate code, start date and duration of program enrollment, payment information of the CUSTOMER or potential third parties, information concerning the recipient of a gift, the number of visits to the WEBSITE, the purchase historian, the purchased products (the account opening on the WEBSITE and all activities and events to which the CUSTOMER must register with its own data personal and, in doing so, enters into a contractual relationship with L' OFFICIEL SRL, they are considered a program aimed at customers for the purposes of this policy, apart from traditional customer loyalty programs) ; collectively, the CUSTOMER DATA.
In addition, THE OFFICIEL SRL collects :
- The data of users of the WEBSITE not registered with THE OFFICIEL SRL (THE VISITORS), which however may constitute personal data, such as data from social media (the VISITORS DATA) and, with regard to this data, find application the provisions of this information collection of data from a CUSTOMER regarding the use of the WEBSITE, although usually THE OFFICIEL SRL cannot identify a VISITOR ;
- Information involving employees and other entities acting on behalf of wholesale resellers, traders, retailers, suppliers and other business partners of L' OFFICIEL SRL (hereinafter referred to as physical persons are indicated with the term PARTNER and the data of the same with the term DATA OF PARTNERS), including, as an indication and non-exhaustive, their contact details, information relating to the position held by them, information regarding previous contacts with these same persons, data related to marketing activities (e.g. sending newsletters), information relating to business transactions concluded with the same, requests, offers, terms and conditions and contracts, information relating to their interests of a professional nature or other nature.
As part of the trade relationship, CUSTOMERS are required to provide the necessary CUSTOMER DATA to be able to establish and formalize the contractual relationship and to fulfil the resulting contractual and statutory obligations. In the absence of this data, in general the OFFICIEL SRL will not be able to conclude or to fulfil the contract with that CUSTOMER. The same is also true for PARTNER DATA with respect to the intercurrent relationship with wholesale dealers, traders, retailers, suppliers and other business partners of L' OFFICIEL SRL ; in principle it is not possible to conclude a contract, nor to formalize it without obtaining the employee data that acts on behalf of the firm and other contacts. At every access registration to the WEBSITE, the connection data (such as the IP address) is also always recorded ; this happens automatically during use and the function cannot be deactivated for individual VISITORS, CUSTOMERS or PARTNER.
3. PURPOSE OF TREATMENT AND LEGAL BASES
3.1. PURPOSE of treatment
In accordance with the applicable legislation, OFFICIEL SRL may deal with CUSTOMER DATA for any legitimate PURPOSE, including, as an indicative and non-exhaustive, the following purposes :
- in connection with the services offered, the conclusion of contracts (e.g. purchase contracts), the improvement of contracts (e.g. purchase contracts and contracts concerning participation in programmes and events intended for customers), the management and development of relations with the customer, communications, services to customers, customer support, promotions, advertising and marketing (including newsletters and mailing promotional material);
- the management of users of the WEB SITE and other activities in which customers participate, the operation and improvement of the WEB SITE (including the provision of functions requiring customer identification or other personal data) and other computer systems and identity verification functions;
- the protection of customers, employees and other persons and the protection of the data, secrets and goods of OFFICIEL SRL data, as well as the protection and security of the systems and offices of OFFICIEL SRL
- Compliance with the regulatory and legal requirements, including the internal rules of OFFICIEL SRL and the protection, including in court, of the rights conferred by the law, recourse to legal remedies and the defence of legal actions brought against it, disputes, complaints and complaints, the fight against abusive behaviour, participation in investigations and legal proceedings, the response to requests from public authorities;
- the acquisition or sale of business divisions, companies, parts of an undertaking or other corporate transactions and the transfer of customer data related to them; and
- for other legitimate purposes that require such processing for reasons that are obvious or that were indicated at the time of data collection (collectively, the FINITIES OF THE TREATMENT OF CLIENT DATA).
3.2. LEGAL BASIS OF TREATMENT
THE OFFICIAL SHARES CLIENT DATA FOR THE FINAL TREATMENT OF CLIENT DATA by reference to the following legal bases:
- performance of contracts;
- compliance with the legal obligations of;OFFICIEL SRL
- CONSUMER's consent (only to the extent that the basis of the processing is a specific request and the consent can be revoked at any time, for example in the case of newsletters to which the customer is subscribed);
- pursuit of the legitimate interests of OFFICIAL SRL as an indication
- the purchase and dispatch of products and services, including in respect of individuals who are not direct contractual partners (e.g. recipients of a gift);
- advertising and marketing activities;
- efficient and effective customer support services, maintaining contacts and other communications with customers, outside of exchanged communications when there is a contractual relationship;
- analysis of the customer's behaviour, activities, interests and needs, market studies;
- efficient and effective improvement of existing products and services and development of new products and services;
- efficient and effective protection of clients, employees and other persons, as well as the protection of the data, secrets and assets of the official entrusted to them, the protection and security of the systems and offices of the Office;
- the safe, efficient and effective maintenance and organisation of commercial activities, including the safe, efficient and efficient operation, as well as the successful further development of WEB SITIs and other computer systems;
- corporate governance and business development;
- the successful sale of business units, companies or parts of an undertaking and other corporate transactions;
- Compliance with the regulatory and legal requirements and internal rules of OFFICIAL SRL
- the prevention of fraud, other offences and wrongdoings, as well as the conduct of investigations in relation to such offences and other incorrect conduct, the management of pretensions and legal actions against the officiel, cooperation possibly necessary in relation to legal proceedings and against public authorities, as well as the pursuit of legal actions taken by us and the defence of those initiated against us.
In accordance with the applicable data protection legislation, OFFICIE will deal with DATA OF VISITORS for purposes related to the maintenance and development of the WEBSITE (including the provision of functions that require customer identification data or other personal data), for statistical analyses on the use of the WEBSITE, as well as for the fight against abusive conduct, as part of investigative investigations or legal proceedings and in responding to requests from public authorities. The DATA OF VISITORS are treated in accordance with the principles set out for the CUSTOMER DATA above.
In accordance with the applicable data protection law, THE OFFICIEL may deal with PARTNER DATA for purposes related to the stipulation and fulfillment of contracts and within the scope of other business relationships established with PARTNERS, promotions, advertising and marketing, communications, invitations to events and participation in promotions for PARTNERS, organization of joint activities, compliance with regulatory and law requirements and the internal rules of L' OFFICIEL, exploitation and protection, including in court, of the rights recognized by law, recourse to legal avenues and the defence of legal actions promoted against the same, litigation, claims, the fight against abusive conduct, participation in investigative investigations and legal proceedings, the response to requests from public authorities, the sale or purchase of business units, companies or parts of a business and other corporate operations and the transfer of the PARTNER DATA related to them. The DATA OF PARTNERS are treated in accordance with the principles set out for the CONSUMER DATA above.
All the purposes of the treatment are applicable to the whole of the Group L' OFFICIEL, i.e. not only to the company that initially collected the personal data. The personal data of CUSTOMERS, VISITORS and PARTNER are collected for the purposes of all companies L' OFFICIEL subject to the present Privacy Notice, to all other policies prepared by L' OFFICIEL and the applicable data protection legislation.
4. TRANSFER AND TRANSMISSION OF DATA
In accordance with the applicable data protection legislation, THE OFFICIEL may transfer CUSTOMER DATA, DATA OF VISITORS and DATA OF PARTNERS to third PARTS belonging to the categories under reference to deal with the PERSONAL DATA on behalf of de L' OFFICIEL in accordance with the PURPOSES OF THE PROCESSING OF DATA of the same or for their own purposes :
- service providers (undertakings within the Group THE OFFICIEL including providers of data processing services ;
- wholesale resellers, traders, retailers, suppliers and other business partners ;
- the customers of L' OFFICIEL
- local, national and foreign authorities ;
- the media ;
- the public, including visitors to the WEBSITES and social media of L' OFFICIEL
- organisations, associations, bodies and other consortia of industry ;
- purchasers or entities interested in detecting business units, companies or other parts of the Group THE OFFICIEL
- other parties concerned in ongoing or potential legal proceedings ;
The OFFICIEL can transmit CONSUMER DATA, DATA OF VISITORS and PARTNER DATA within the Group THE OFFICIEL as well as TERZE PARTI and in all countries of the world, including in particular all countries where OFFICIE Lis represented by GROUP companies, affiliates or other offices and representatives and in countries in which the service providers de L' OFFICIEL deal with the data of the same (see the ANNEX 2, and any subsequent updates). Where data is transmitted to countries that do not guarantee adequate protection of the same, L' OFFICIEL will put in place the appropriate contractual guarantees (for example, by including the type contractual clauses approved by the Commission of the European Union) to ensure the adequate protection of the data of CUSTOMERS, VISITORS and PARTNER transmitted to those countries, and will introduce binding standards at the Group level, formulated on the basis of the Privacy Shield Framework (Privacy Framework) between the European Union and the United States and between Switzerland and the United States, for transfers to TERZE PARTI domiciled in the USA, or transfer the data by making use of the consent of the data subject, the stipulation or the fulfillment of a contract, or in the context of legal actions to assert or exercise its rights, or whether legitimated by a preeminent public interest, or to protect the integrity of the subjects to which the data relates. The CUSTOMER, VISITOR or PARTNER may request copies of the contractual guarantee placed in the referees referred to in point 1 above which, if they cannot make it available directly, they will be able to indicate whom to turn to to obtain it (see point 1 above).The OFFICIEL reserves the right to arrange the obscuration of part of the text of the warranty for justified legal and confidentiality reasons.
5. RETENTION OF DATA
In general, the OFFICIEL retains personal data not beyond the time it takes for the purposes for which the personal data is processed. Notwithstanding the general principle, L' OFFICIEL may deal with personal data for longer periods in compliance with the following standards and obligations : The OFFICIEL retains personal data (1) as long as the same is obliged to retain them (under a contract, by law or under other provisions) or (ii) to protect a prevailing interest of the same (e.g., which evidentiary element in litigation, to document its compliance with statutory or regulatory requirements, when it is in the interest of the same to carry out an uncustomized analysis). Different rules are applied to the anonymization or pseudonimization of personal data, subject to the provisions of the applicable legislation.
As a rule, for CUSTOMER DATA and PARTNER DATA (including business documents and communications) relating to a contractual relationship, L' OFFICIEL retains personal data for the entire duration of the contractual relationship and for the ten years following the resolution of the same, except that (i) finds an obligation of law that provides for a shorter or longer retention period, as the case may be, (ii) the retention is necessary for evidentiary purposes or for other valid reason as provided for in the applicable law, or (iii) it makes it necessary to proceed to the cancellation of the data sooner than expected (for example, because the data is no longer needed or because L' OFFICIEL is obliged to delete them).
As a rule, in the case of operational data containing CUSTOMER DATA, VISITOR DATA or PARTNER DATA (e.g. protocols, registers), L ' OFFICIEL retains personal data for a period of between 3 and 12 months.
6. COOKIE, GOOGLE ANALYTICS and SOCIAL PLUG-IN
In accordance with applicable legislation, the OFFICIEL can install in newsletters and other marketing emails a code that allows you to know whether the recipient has opened the email or downloaded the images contained therein. Although the recipient can block the application of this technology to his / her emails, agreeing to receive newsletters and other emails containing advertising, consent to that application.
When L' OFFICIEL places on the WEBSITE advertisements of third parties (e.g. banner) or its advertising advertisement on the third party site, it is possible that cookies of companies specializing in this field may be used. The OFFICIEL does not transmit personal data to such companies, that is to say that the latter are limited to placing a permanent cookie in the user's device of the WEBSITE in order to be able to recognise it and do so only in the interest of L' OFFICIEL. This allows L' OFFICIEL to place on external sites of third targeted advertising aimed at certain individuals (e.g., advertising of products to which such individuals have shown an interest during the navigation in the online store).The OFFICIEL does not transmit personal data to the operators of external sites.
The OFFICIEL can use on your WEBSITE Google Analytics or similar services. These applications are third party services that allow L' OFFICIEL to measure and analyse the use of its WEBSITE. The provider of these services may be domiciled in any country in the world (in the case of Google Analytics. which is a service of Google Inc.. the supplier is domiciled in the United States www.google.com). The service provider uses persistent cookies for these applications .The OFFICIEL does not transmit any personal data to the service provider (which does not even store IP addresses). The service provider may, however, monitor the use of the WEBSITE by the user and aggregate this data to data from other sites monitored by the same vendor that the user has visited and use the information so obtained to their own advantage (e.g. to control advertising). The service provider knows the identity of the user who has registered with the service provider. In such a case, the processing of personal data will be the responsibility of the service provider and the data will be processed in accordance with the data protection and data protection law and data protection policies of the service provider (in the case of Google, please visit policies.google.com/privacy). The service provider provides to L' OFFICIEL data on the use of the WEBSITE of the same.
The OFFICIEL can also use on your WEBSITE plug-ins of social media networks such as Facebook, Twitter, Youtube, Google +, Pinterest or Instagram. In the default setting, the plug-ins of the WEBSITE are deactivated ; the user can choose to activate them. If the user has activated them, social media providers will be able to establish a direct connection with the user, when this visit the WEBSITE, which will allow the supplier to detect the visit by the same and to analyze their information. The subsequent processing of personal data will be performed under the responsibility of the social media provider in accordance with the privacy and data protection legislation and its data protection policies published on its website (such as www.facebook.com/; www.twitter.com/; www.youtube.com/; www.google.com/; www.pinterest.com/; www.instagram.com/).
Further information on the cookies used by L' OFFICIEL and how to manage the settings for cookies are available on our WEBSITE.
7. RIGHTS OF CUSTOMERS, VISITORS AND PARTNERS
Interested parties, including CUSTOMERS, VISITORS and PARTNERS, may ask L' OFFICIEL information about the processing of the data concerning them. They also have the right to request the rectification or destruction of their personal data, as well as to impose limitations on their use and to object to the treatment of their own. If the processing of personal data is based on consent, those concerned may revoke it at any time. In the EU and EEA countries, those concerned, in certain cases, are entitled to obtain copies of the data generated during the use of online services in a structured format, of common use, readable by automatic device and that allows for further use and transfer of it. These requests shall be forwarded to the referent referred to in point 1 above .The OFFICIEL reserves the right to restrict the rights of the concerned in accordance with the applicable legislation and therefore, by way of example, may not make any omni-inclusive data available or do not delete the data.
In the event that the OFFICIEL takes an automated decision on a certain subject that may produce legal effects that affect it or that, in a similar manner, may significantly affect its person, the data subject will have, in accordance with applicable legislation, the right to make contact with a data holder of L' OFFICIEL and to request the same a review of the decision or be brought to the knowledge of the grounds on which the decision was made. In such a case, it is possible that some automated services will no longer be made available to the data subject. The data subject will be informed of this later or in advance prior to the interruption of the service.
The data subject may also lodge a complaint with the competent authority of privacy.
8. AMENDMENTS TO THE PRIVACY ADVISORY
The OFFICIEL reserves the right to modify this Privacy Notice at any time and without the need for notice, nor notice. The latest version published on the WEBSITE of L' OFFICIEL will be the applicable version.
If the Privacy Statement is an integral part of an agreement with a CLLIENT or a PARTNER, L ' OFFICIEL may inform those affected of the update or changes made through or by another suitable means. The changes will be considered accepted in a lack of objection to the same within 30 days of communication. In the event of an objection, OFFICIEL will be free to terminate the agreement with immediate effect for exceptional circumstances.
II. SPECIAL provisions
The following provisions go to add to the general provisions set out in Section I and are referred to certain activities of L' OFFICIEL. In the case of conflict, the following provisions shall prevail.
1. ONLINE SHOPS
In online shops the credit credit of the CUSTOMER can be assessed in automatic, so that we may or may not offer the possibility to purchase an item on credit according to that assessment. In such a case, credit credit is assessed on the basis of information from external rating agencies that provide L' OFFICIELI with the degree of solvency (credit score) that they are attributed to the CUSTOMER. The rating agency calculates the degree of solvency according to a secret formula that takes into account the historian of payments of that CUSTOMER, the debt to its payload, the historian in terms of solvency and subsistence or not limitations on its ability to act. If the degree of solvency results in less than a certain threshold, the possibility of paying at the front of the invoice is not offered. In such a case, the CUSTOMER may contact the referent indicated in the legal notes of the online store in the object, in case you do not agree with the decision.
2. PARTNERS, INCLUDING WHOLESALE RESELLERS, RESELLERS, INTERMEDIARIES, CUSTOMER SERVICE PROVIDERS, ETC..
As already indicated, CUSTOMER DATA, PARTNER DATA and VISITOR DATA are generally collected by L' OFFICIEL directly, but it is also possible that this will happen indirectly (for example, when L' OFFICIEL requires TERZE PARTI to act as a controller, as in the case of OFFICIEL OFFICIEL). In these cases, OFFICIEL PARTNERS shall treat the personal data on behalf of L' OFFICIEL and on instruction of the same and are bound by specific contracts for the controllers in which the terms and conditions of their work are specified in such a way as to ensure the protection of the rights of our CUSTOMERS, PARTNERS and VISITORS and that the processing of their personal data takes place safely and in accordance with the applicable data protection law.
3. NEWSLETTER AND BANNER ADVERTISEMENT
The OFFICIEL can send to CUSTOMERS and PARTNER newsletters and other commercial nature communications on its products and services. In accordance with the applicable legislation, OFFICIEL reserves the right to send this material to entities that are already customers and to their business partners without requiring their prior consent. Such customers and business partners may, however, object to the sending of additional newsletters or other communications of a commercial nature at any time using their account on the WEBSITE or the link indicated in all sent submissions. Cancelling enrollment to a newsletter may however not be sufficient to erase the inscription even to other newsletters.
The OFFICIEL reserves the right to place customized advertising advertisements during visits to the WEBSITE. Such advertising banners made visible to CUSTOMERS contain products offered on the WEBSITE for which the CONSUMER has previously shown an interest. For advertising, L' OFFICIEL avails itself of cookies