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PRIVACY POLICY

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”) and jointly with Fabiana Filippi (the “Reference Data Controller ” and/or the “Data Controllers”), in their capacity as joint Data Controllers for processing the personal data of users, (hereinafter 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 pursuant to art. 13 of Regulation (EU) 679/2016 of 27 April 2016 (hereinafter, “Regulation”, or also the Data Protection Law”).

This Website and Services are reserved to individuals who are over eighteen years of age. 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.Purposes of the Processing

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 browsing of the Website or to implement the Conditions of Use of the Website, which are duly accepted by the User during the Website registration process and/or during the use of the Services and to fulfil specific User requests. The User data collected by Triboo for the aforementioned purposes include: their name, surname, email address, telephone number, password and any personal information of the User that may be eventually published on a voluntary basis. Unless the User grants Triboo specific and optional consent for processing of his/her data for further purposes, the User's personal data shall be used by Triboo for the sole purpose of ascertaining the identity of the User (also by validation of the email address), hence avoiding possible scams or abusive conduct, and for contacting the User for service reasons only (e.g. sending notifications concerning the Services). Notwithstanding the provisions elsewhere in this privacy notice, under no circumstances shall Triboo 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, as failure to provide such personal data will make it impossible for the User to browse the Website, register with the Website and use its Services.

 

2.Other purposes of processing: 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, 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 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 prevent the possibility to register with the Website.

 

In case of consent, the User may withdraw such consent at any time submitting a request to Fabiana Filippi as indicated in paragraph 6 here below.

 

The User can also easily object to receiving further promotional communications by email by clicking on the appropriate link for the withdrawal of consent, which is provided in each email containing the communications. If the User intends to withdraw his 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 the Data Controller in the manner indicated in paragraph 6 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 6 below.

 

3.Other purposes of processing: 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 by the Partner 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 prevent the possibility to register with the Website.

 

In case of consent, the User may withdraw such consent at any time submitting a request to Fabiana Filippi as indicated in paragraph 6 below.

 

The User can also easily object to receiving further promotional material by clicking on the withdrawal of consent link, which is provided in each email containing the newsletter.

 

4.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 primary purposes described in paragraph 1 above, or however as necessary for the protection in civil law of the interests of both the Users and Triboo. 

 

In the cases referred to in paragraphs 2 and 3 above, the personal data of Users shall be retained for the time strictly necessary to carry out the purposes described therein and, in any case, for no more than twenty-four (24) months.

 

5.Disclosure and dissemination of 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 Data Protection Law. 

 

The personal data of Users may also be disclosed to third parties who may process personal data on behalf of the Data Controllers as "External 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 same from the Data Controllers, submitting a request to each reference Data Controller as indicated in paragraph 6 below.

 

Furthermore, the personal data of the Users may be disclosed by Triboo, to the extent where the same is necessary and essential in order to execute the contractual obligations, to third parties who are independent data controllers, such as providers of payment services and logistics services necessary for delivery of the 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 personal data of Users may be transferred abroad by Fabiana Filippi in compliance with the provisions of the applicable law, also to countries outside the European Union where Fabiana Filippi pursues its business operations, adopting all security measures and due precautions to ensure an adequate level of data security. 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 6 below.

 

6.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 - Via Bruno Buozzi, 90, 06030 Giano dell’Umbria (PG) – Italy

- By sending an email to the address privacy@fabianafilippi.com

Fabiana Filippi has not identified the person in charge of data protection (RPD or DPO), as it is not subject to the obligation of designation provided for by art. 37 of the Regulation

For the Partner:

- By sending a registered letter with advice of receipt to the registered office of the Data Controller to Triboo Digitale Srl – A Company of the Triboo group - with registered office in Viale Sarca 336, 20126 Milan, Italy, tax code, VAT number and registration number in the Milan Register of Companies 02912880966.

- By sending an email to the address privacy@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

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 and 3.

 

In accordance with the Data Protection Law, the Data Controller hereby declares 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 Controller 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) (where applicable) the right to data portability (right to receive all personal data concerning them in a structured format, commonly used and readable by automatic devices), the right to request restriction of processing of personal data and the right to be forgotten);

c) the right to object:

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 your personal data for the distribution of advertising materials or direct sales or for market research or business communication;

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 “Garante per la protezione dei dati personali” , with headquarters in Piazza di Monte Citorio no.121, 00186 - Rome (http: www.garanteprivacy.it/).

 

7.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, email address via which the User can be contacted by Facebook (with the 'actual' address or address on the proxymail.facebook.com domain), 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 frequently 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.