1. TYPES OF PROCESSED DATA
1.1 Navigation data
Visiting and consulting the Site does not generally involve collection and processing of user’s Personal Data. The Personal Data processing of users who visit and consult the Site is limited to the so-called navigation data which transmission is necessary for the functioning of computer systems and of programs essentials for the operation of the Site but which, by their very nature and in conjunction with other data, may permit the identification of users. This category includes, for example, the IP addresses (Internet Protocol) or the domain names of the computer used to visit the Site, as well as other parameters concerning the operating system used by the user to connect to the Site. The collection of Navigation data occurs automatically and inevitably and can only be used to obtain statistical information on the use of the Site and to verify its proper functioning. If expressly requested, such data may be used by the Public Authority to ascertain liability in the event of computer offenses committed against the Site and/or third parties, in accordance with the procedures in force at the competent Authorities. Except for this possibility, navigation data described above are only temporarily kept in compliance with the applicable regulations.
1.2 Data voluntarily provided by individual users
In addition, MONCLER collects and processes Personal Data voluntarily provided by individual users that consist of those data collected through the sending of e-mail, the interaction with the Site’s features, the request for services offered by the Site, the compilation of other specific format for access to reserved sections of the Site. Personal Data that MONCLER collects and processes include name, gender, place and date of birth, nationality, contact information such as addresses, phone numbers, e-mails.
2. MEANS AND PURPOSES FOR PROCESSING PERSONAL DATA
The Data will be processed both manually and with the help of electronic instruments for the following purposes:
(i) to provide services rendered on the Website, including registration and updates and to manage the initiatives organized through the Site;
(ii) with the specific and express consent of the user, for marketing operations, market research, newsletters and commercial or advertising communications related to products, services, events, offers and promotions of MONCLER through automated tools (such as email, sms, mms, push notifications and social network) and traditional ones (paper mail and phone calls with operator). The user will always be able to indicate the contact details he/she prefers among the above mentioned and will have the opportunity at any time to oppose to the processing of his/her Data for commercial purposes and to no longer receive promotional and/or commercial materials and information through all or just some of the contact ways indicated above;
(iii) furthermore, with the specific and express consent of the user, Personal Data may be disclosed to other Moncler Group companies and/or to Moncler’s trading partners (without prejudice to the adoption of security and Personal Data protection clauses required by law and applicable regulations) for marketing purposes through automated ways (such as email, sms, mms, push notifications and social networks) and traditional ones (such as paper mail and phone calls with operator). Again, the user will always be able to indicate the contact details he/she prefers among those listed above and will be able at any time to oppose to the processing of his/her data for commercial purposes and no longer receive promotional and/or commercial materials and information through all or just some of the above mentioned contact ways;
(iv) with the specific and express consent of the user, information referring to preferences, habits, lifestyles, individual and group profiles definition (profiling purposes) can be collected with the aim of sending personalized communications.
Personal Data will be stored for a period of time not exceeding what is necessary to achieve the purposes for which they have been collected and, in any case, not longer than the one provided for by the applicable regulations.
3. NATURE OF PERSONAL DATA GRANTING
The Personal Data granting for the purposes mentioned in point 2 (i) above, is necessary, for example, to provide the services requested through the Site, including registration; in the event of non-submission of Personal Data for the purposes referred to in point 2 (i), MONCLER will not be able to provide the services requested through the Site.
The Personal Data granting for the purposes set out in point 2 (ii) and (iii) is optional and, in the event of non-submission, the user may access the Site in any case, register, ask for information and use the services offered.
The Personal Data granting for the purposes of point 2 (iv) is optional and, in the event of non-submission, the user may access the Site in any case, register, ask for information and use the services offered.
4. PERSONAL DATA DISCLOSURE
Personal Data are accessible to the Data Processor indicated below, to the other persons who will act as external Controllers appointed by MONCLER and, in their quality as Persons in charge of the Processing, to the staff of MONCLER involved in the provision of services and features from time to time offered by MONCLER according to criteria of need.
Personal Data may be disclosed to agencies, authorities, public institutions and legitimate recipients in compliance with laws and regulations; they may be made accessible to self-employed professionals and collaborators, also organized in associated form, third parties suppliers of professional and technical service for the for processing purposes referred to in paragraph 2 that assist MONCLER in legal, tax, social security, accounting and/or organization’s field, who will act as Data Processors or Persons in charge of the Processing, as the case may be, without prejudice to the adoption of Personal Data security and protection measures pursuant to current legislation.
Personal Data may also be disclosed to third parties in the event of extraordinary transactions (e.g. mergers, acquisitions, transfer of business, etc.) by MONCLER. Only the information necessary to perform their respective functions will be provided to such those persons. Such third parties will commit to use the information received only for purposes for processing specified above, to keep them confidential and secure and to comply with the protection of Personal Data required by law and any instructions given by MONCLER.
As specified in point 2 (iii) above, only with the specific and express consent of the user, Personal Data may be disclosed to other Moncler Group’s companies and/or to Moncler’s trading partners (without prejudice to the adoption of security and Personal Data protection clauses required by law and applicable regulations) for marketing and profiling purposes as described above.
Personal Data may also be transferred abroad to persons established in countries that are not members of the European Union (e.g. other Moncler Group’s companies) that could not guarantee an adequate level of protection pursuant to the Privacy Code. In such cases, MONCLER transfers Personal Data to such third countries after the adoption of the measures laid down in Art. 44 of the Privacy Code in order to legitimate the transfer and ensure adequate protection to transferred Personal Data. Persons who receive user’s Personal Data may process them as Controllers, Processors and/or Persons in charge of the Processing, as the case may be.
The complete and updated list of Data Processors will be provided on request by contacting MONCLER at email@example.com.
Personal Data will in no case be subject to dissemination.
5. AUTOMATIC DATA COLLECTION MECHANISMS – COOKIES
6. USER’S RIGHTS
User may exercise at any time the rights to which he/she is entitled to pursuant to Article 7 of the Privacy Code including, for example, the right to obtain confirmation of the existence or not of Personal Data relating to him/her, verifying its content, source and accuracy, requesting its integration, updating, rectification, deletion, transformation into an anonymous form or blocking of data which have been unlawfully processed. The user may object in whole or in part to the processing of data for legitimate reasons as well as to the processing for marketing purposes.
For any question or request about the processing of Personal Data and for exercise the rights granted by the Privacy Code, the user may contact MONCLER at the following address: [firstname.lastname@example.org].
8. DATA CONTROLLER AND DATA PROCESSOR
The Data Controller is INDUSTRIES S.p.A., a company of the Moncler Group, based in Via Stendhal 47, Milan – 20144 – Tel. 02/422041.
The Data Processor is Vegan Solutions S.r.l., domiciled at the headquarters of the Controller and available at the following e-mail address [email@example.com].
9. GOVERNING LAW