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PRIVACY INFORMATION NOTICE

FABIANA FILIPPI S. p. A. ,  with registered office in Via Bruno Buozzi, 90, 06030 Giano dell’Umbria (PG) – Italy, VAT no.  / Tax Code 02676310549 (hereinafter “Fabiana Filippi”) and Triboo Digitale S. r. l.   with registered office in Viale Sarca 336, Edificio 16, 20126 Milan, VAT no.  / Tax Code and Milan Business Register Enrolment No.  IT02387250307 (hereinafter “Triboo” and/or the “Partner”) in their capacity as independent Data Controllers (“The Data Controllers”) of the processing of the personal data of the users (hereafter, the “Users”) who browse and exploit the services available on the www.fabianafilippi.com internet website (hereinafter the “Website” and the “Services”) hereby provide the Information Notice on Privacy under art.  13 of Regulation (EU) 2016/679 of  27 April 2016 (hereinafter, “Regulation”, or also the “Applicable Law”).

More specifically, Fabiana Filippi is the Data Controller for the purposes indicated in sections 2, 3 and 4, while the Partner is the Data Controller for the purposes indicated in section 1.

This Website and its Services are reserved to individuals who are eighteen years of age and over.

The Data Controllers do not collect personal data relating to persons under 18 years of age. At the request of the Users, the Data Controllers shall promptly erase all personal data involuntarily collected and related to persons under 18 years of age.

The Data Controllers are committed to ensuring the right to privacy and protection of personal data of its Users.

 

1. Purpose and legal basis of the processing by the Partner

The personal data of Users shall be processed lawfully by the Partner pursuant to art.  6 of the Regulation for the following processing purpose:

a) contractual obligations and provision of the Services, to allow navigation of the Website or to implement the Terms of Use of the Website, which are accepted by the User during registration on the Website and/or during the use of the Services and fulfil specific User requests. The User data collected by the Partner for the aforementioned purposes include: their name, surname, email address, telephone number, password and any personal information of the User that may be voluntarily published. Unless the User gives the Partner a specific and optional consent to the processing of their data for further purposes, the User's personal data will be used by the Partner for the sole purpose of ascertaining the identity of the User (also by validation of the address e-mail), thus avoiding possible scams or abuses, and contacting the User only for reasons of service (e.g.  send notifications about the Services). Notwithstanding the provisions elsewhere in this privacy notice, under no circumstances shall the Partner allow access to the personal data of the Users by other Users and/or third parties;

b) administrative-accounting purposes, or to carry out activities of an organisational, administrative, financial and accounting nature, such as internal organisational activities and functional activities required to fulfil contractual and pre-contractual obligations;

c) legal obligations, i.e. to comply with obligations imposed by a law, authority, regulation or Community legislation;

The provision of personal data for the purposes of processing indicated above is optional but necessary in order to execute the contract which the User is a party to, as failure to provide them will make it impossible for the User to browse the Website, register and use any of its Services. Once the data has been spontaneously provided by Users, the processing for the aforementioned purposes does not require their consent.

 

2. Further purposes and legal basis of the processing by Fabiana Filippi: marketing (sending of advertising material, direct sales and commercial communication)

With the free and optional consent of the User, some personal data of the User, i.e. name, surname, address, email address, telephone number, may be processed by Fabiana Filippi also for marketing purposes (sending advertising material, direct sales and commercial communication), i.e. so that Fabiana Filippi can contact the User by standard mail, email, telephone (fixed and/or mobile, with automated calls or call communication systems with and/or without the intervention of an operator) and/or SMS and/or MMS to propose to the User the purchase of products and/or services offered by Fabiana Filippi and/or by third parties, to present offers, promotions and sales opportunities.

Failure to grant consent shall not in any way comprise the possibility to register with the Website.

In case of consent, the User may at any time withdraw the same, submitting a request to Fabiana Filippi as indicated in paragraph 7 below.

The User can also object to receiving further promotional communications by email by clicking on the appropriate link, which is provided in each email containing the promotional communications. If the User intends to withdraw his or her consent to the sending of promotional communications by telephone, however continuing to receive promotional communications via email, or vice versa, please send a request to Fabiana Filippi in the manner indicated in paragraph 7 below.

Fabiana Filippi hereby declares that, after exercising the right to object to the sending of promotional communications via email, it is possible that, for technical and operational reasons (e.g.  formation of contact lists already completed shortly before receipt by Fabiana Filippi of the right to object) the User will continue to receive some further promotional messages. Should the User continue to receive promotional messages after 24 hours have elapsed from the exercise of the right to object, please report the problem to Fabiana Filippi, using the contacts indicated in paragraph 7 below.

Fabiana Filippi is entitled to conduct direct marketing activities via emails to the Users who have made purchases on the site, to propose similar products to those already purchased (so-called soft spam). This processing does not require the consent of the User, who can, in any case, deny the same and object to the processing, also by clicking on the relative Unsubscribe link included in the received email.

 

3. Further processing purposes of Fabiana Filippi: newsletter

With the free and optional consent of the User, certain personal data of the User (i.e. name, surname, address, email address) may be processed for the purpose of sending newsletters. Therefore, the User will receive a periodic newsletter from Fabiana Filippi that will contain information in relation to news and promotions on the Website and / or initiatives organised by Fabiana Filippi.

Failure to grant consent shall not in any way comprise the possibility to register with the Website.

In case of consent, the User may at any time withdraw the same, submitting a request to Fabiana Filippi as indicated in paragraph 7 below.

The User can also object to receiving further promotional communications and, in the case of email communications, the same can object by clicking on the appropriate Unsubscribe link provided in the newsletter.

 

4.  Further processing purposes of Fabiana Filippi: profiling

With the free and optional consent of the User, certain personal data of the User (i.e. personal and contact details and information on the services and product the same has shown an interest in, shopping details) may be processed by Fabiana Filippi also to identify the Customer’s tastes and shopping habits, hence analysing relative consumer preferences to create individual and group profiles, so as to send the User ads and commercial information that are consistent with the identified profile and automated emails based on the shopping habits of the same.

Failure to grant consent shall not in any way comprise the possibility to register with the Website.

In case of consent, the User may at any time withdraw the same, submitting a request to Fabiana Filippi as indicated in paragraph 7 below, or object to the mailing of targeted communications and, in the case of emails,  object by clicking on the appropriate Unsubscribe link provided.

 

5. Data processing procedures and retention times

The Data Controllers shall process the personal data of Users using manual and electronic instruments, with logics which are strictly related to the aforementioned purposes, in a way which guarantees the security and confidentiality of such data.

The personal data of the Users shall be retained for the time strictly necessary to carry out the purposes described in paragraph 1 above, or however as necessary for the protection in civil law of the interests of both the Users and the Data Controllers.

In the cases referred to in paragraphs 2, 3 and 4 above, the personal data of Users shall be retained for a period of 7 years from the date of registration, in accordance with the provisions endorsed by the Italian Data Protection Supervisory Authority for the luxury goods and fashion sectors.

In the cases of soft spam referred to above, the data of Users shall be processed until the User objects to the same or withdraws his or her consent.

 

6. Recipients of personal data

The personal data of the Users may be disclosed to the employees and / or collaborators of the Data Controllers in charge of managing the Website and all aspects of the delivery of Services. Such subjects, who have been duly informed by the Data Controllers under art.  29 of the Regulation, will process the User's data exclusively for the purposes indicated in this privacy notice and in compliance with the provisions of the applicable regulations.

The personal data of Users may also be disclosed to third parties who may process personal data on behalf of the Data Controllers as “Data Processors", such as, for example, IT and logistic service providers functional to the operations of the Website and/or the Services, outsourcing or cloud computing service providers, professionals and consultants.

 Users have the right to obtain a list of the Data Processors from the Data Controller, submitting a request to the Data Controller as indicated in paragraph 7 below.

Furthermore, the personal data of the Users may be disclosed by the Partner, to the extent that this is necessary and essential for implementing contractual obligations, to third parties who are independent data controllers, such as payment service providers and logistics services necessary for delivery of goods sold through the Website. These autonomous Data Controllers shall process the User's data exclusively for the purpose of fulfilling the processing of the orders relating to the Services in a correct manner.

The Partner shall send Fabiana Filippi all the details  related to the sales completed on its Website, as the same are needed to execute the contracts of which it is a Party. Fabiana Filippi shall process the same for accounting-financial control purposes, according to the laws in force and for the aforementioned purposes, with the consent of the data subjects.

Users' personal data may be transferred abroad by Fabiana Filippi to its own group companies that have been appointed Data Processors, also in countries outside the European Union, adopting security measures and due precautions to ensure an adequate level of data security and the exercising of data subject rights.

Users have the right to obtain information on the transfer of their personal data abroad at any moment in time, submitting a request to Fabiana Filippi as indicated in paragraph 7 below.

 

7. Rights of Data Subjects

For any further information related to this privacy notice, and to exercise their rights guaranteed by the applicable Law, Users may contact the Data Controllers at any time, using the following methods:

For Fabiana Filippi:

  • By sending a registered letter with advice of receipt to the registered office of the Data Controller Fabiana Filippi S. p. A.  – Via Bruno Buozzi, 90, 06030 Giano dell’Umbria (PG), Italy.
  • By sending an email to the Data Protection Officer (DPO) designated by Fabiana Filippi at the address provided below: mail dpo@fabianafilippi.com.

For the Partner:

  • By sending a registered letter with advice of receipt to the registered office of the Data Controller Triboo Digitale S. r. l.  - a Triboo Group company - in Viale Sarca 336, 20126 Milan, Italy, tax code, VAT No, and Milan Business Registry Enrolment No.  02912880966. By sending an email to the addressprivacy@triboo.it
  • By sending an email to the Data Protection Officer (DPO) designated by Triboo, at the address provided below: mail lapo. curinigalletti@triboo.it and the addresses of the aforementioned companies.

The Partner shall proceed to comply with the requests of Users relating to the processing referred to in paragraph 1, while Fabiana Filippi shall proceed to comply with the requests of Users relating to the processing referred to in paragraphs 2, 3 and 4.

In accordance with the applicable regulations, the Data Controllers hereby declare that Users are entitled to obtain information (i) on the origin of the personal data; (ii) the purpose and processing methods; (iii) the logic used in the case where the data is processed using electronic equipment; (iv) the personal data of the Data Controllers and data processors; (v) the persons in charge and the subjects or categories of subjects to whom the personal data may be disclosed or who may become aware of such data.

Users are always entitled to request:

a) access, updating, rectification or, where interested therein, integration of the data;

b) erasure, anonymisation or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;

c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

 

Furthermore, Users have:

a) the right to withdraw consent at any time, if the processing is based on their consent;

b) the right to data portability (right to receive all personal data concerning them in a structured format, commonly used and readable by automatic device), the right to limit the processing of personal data and the right to cancel ("right to be forgotten");

c) the right to oppose:

i) partially or completely, for legitimate reasons, to the processing of personal data, despite them being relevant to the purpose of the collection;

ii) partially or completely oppose the processing of personal data for the distribution of advertising materials or direct sales or business communications;

iii) where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

d) if they believe that the processing that concerns them violates the Regulation, the right to lodge a complaint with a Supervisory Authority (in the Member State in which they usually reside, in the one in which they work or in the one in which the alleged violation has occurred). The Italian Supervisory Authority is the Data Protection Supervisor, with headquarters in Rome (http: www.garanteprivacy.it/).

 

8. Registration via "Connect with Facebook"

The Data Controllers hereby inform Users registered on Facebook that they can register on the Website through the "Connect with Facebook" service or equivalent, in cases where this option is available on the Website. The data that may be communicated by Facebook to the Data Controllers through the "Connect with Facebook" service are as follows: name, surname, profile picture, e-mail address on which the User can be contacted by Facebook (with 'effective' address or address on the domain proxymail. facebook.com), address and date of birth. The Data Controllers will process such data exclusively for the purposes indicated in this Information Notice, in compliance with the consent granted by the User each time. By subscribing to the "Connect with Facebook" service and clicking the "Allow" button, the User grants his/her consent to the communication of the aforementioned data from the Facebook platform to the Data Controllers. The Data Controllers shall use these data to facilitate the registration procedure, pre-filling the fields on the User's registration form with the data communicated by Facebook. Users who use the Facebook Connect service will be able to access the Website using the credentials normally used to access Facebook.

 

For more information on the "Connect with Facebook" service and to change your privacy settings related to this service, please use the following links:

https: //www.facebook.com/help/405977429438260/

https: //www.facebook.com/privacy/explanation

 

The Data Controllers reserve the right to modify or simply update, in part or in full, the content of this data protection Information Notice. Any future modifications to this Information Notice shall be published on the Website and, if appropriate, notified to users by email. Users are invited to read this data protection Information Notice to check for updates or changes.

The Data Controllers are not responsible for updating all the links that can be viewed in this Information Notice, therefore whenever a link is not functional and/or updated, Users hereby acknowledge and accept that they must always refer to the document and/or section of the websites referred to by this link.

 

 

 

PRACTICAL REMINDER

(Profiling consent text to be used on the forms)

 

 

Profiling purposes

 

I consent/I do not consent to the processing, by Fabiana Filippi SpA, of my personal data for purposes related to the analysis of my shopping behaviour and my consumption habits, also connected to direct marketing activities, on the condition that they refer to products targeted and functional to my specific needs, on the basis of my shopping preferences, as well as personalised communications based on individual and group profiles and I receive automated emails based on my shopping behaviour.

 

I accept                                                                                                         I do not accept