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PRIVACY INFORMATION NOTE - Art. 13 Leg. Decree 196/2003
If you wish to complete the registration process and/or use the website services offered to those accessing the reserved areas (e.g make a purchase and instrumental activities to the same, including operations relating to administrative and tax obligations, sending of newsletters (where requested), please complete the fields below and accept this Information Note. Conferral of data pursuant to the registration form and/or the purchase of products is not compulsory. However, we must inform you that the aforementioned conferral is required to process your order and complete the contract formalities. Your refusal may make it impossible for us to complete the product purchase procedure and/or provide the requested services. All collected personal data shall be processed mainly using electronic systems and, only very occasionally, paper based systems.
The Data Controllers are:
Roberto Cavalli S.p.A., with registered office in via Mascani 14 - 20122, MIlan, Tax Code and VAT no. 7641940965, and Business Register no. 07641940965 – REA MI-1973431, ("Roberto Cavalli"); and
Triboo Digitale S.r.l. with registered office in Viale Sarca, 336 - 20126, Milan (MI) Italy, tax code, VAT number and Milan Business Register no. 02912880966, Share capital € 42,678.00, which is only responsible for managing the sales and transactions on then website, for instance, management of product orders, sales and deliveries, return and warranty management and all other activities related to the sales of products via the website.
To conduct such activities functional to the sale of products via the website, Triboo Digitale processes, in its capacity as co-Data Controller, and in accordance with the applicable privacy code, user data such as name and surname, residence and information on credit cards used by users (such as first and last name of the card holder, card number, expiration date, security code.
Please also be informed that Legislative Decree 196/2003 has a particular regime for the processing of sensitive data, i.e. all personal data that reveals the racial and ethnical origin, religious, philosophical or other beliefs, political opinions, memberships with political parties, trade unions, religious, philosophical or trade union associations or organizations, health conditions and sexual orientation; This data may only be processed after receiving the written consent of the Data Subject. In this regard, some purchases made in the Wellness & Health section may reveal information on the health conditions of the purchaser. In light of the above, if you make any purchases of such products, you may be requested to grant specific consent to allow us to process the data and complete the contract formalities.
Roberto Cavalli may also use your personal data to send emails advertising its products and services, similar to those purchases, unless you refuse this option by exercising your right of opposition as per the procedures below (art. 130 paragraph 4 Legislative Decree 196/2003.
Moreover, where express consent is granted, your personal data may also be processed for marketing purposes such as the mailing of promotional material on products and services different to those already purchased, news, promotions, and also third-party communications from our commercial partners.
Transfer of your personal data outside the European Union is not contemplated. Should the same become necessary, the Data Controller shall be accountable for requesting your specific consent.
This does not include the data relating to your Credit card, which is excluded for any purposes other than checking the existence of such payment means, the payment received and the management of payments further to claim management and contentious procedures. To this purpose, the data will also be processed by the Bank that provides the online payment service, further to the entity that issued the credit card you use to confirm your order.
At present, one of the Chief Data Processors designated to the processing of your personal data is Arcese Logistic S.r.l., who will process the data required to ship the merchandise and manage any returns you may make.Please contact the Customer Care service for a complete list of those designated to processing your Personal Data or send an e-mail to the following address privacy@triboo.it for Roberto Cavalli and privacy@triboo.it for Triboo Digitale.
The categories of those designated to processing the data for the aforementioned purposes, include staff assigned to website management, administration, customer care services, marketing activities (where consent is granted), IT systems and third parties who process data on our behalf (such as, for instance, IT service maintenance, couriers and carriers, legal advisers, enterprises assigned to the realisation and/or management of promotional campaigns, etc.); they can also be disclosed to the public entities authorised to receive the same.
Pursuant to art. 7 of L.Decree. 196/2003, you are entitled to obtain the updating, rectification or integration, erasure and anonymisation of the data. You can also oppose the processing of your personal data for marketing purposes or for sending commercial communications, by contacting Roberto Cavalli at the above indicated mailing addresses or by sending an email to privacy@triboo.it. The same procedures can be used to request the complete updated list of the Chief Data Processors.
INFORMATION NOTICE FOR THOSE INTERESTED IN THE COUTURE SERVICE
AND REQUEST INFORMATION USING THE CONTACT FORM
PERSONAL DATA PROTECTION CODE
UNDER ART. 13 OF LEGISLATIVE DECREE NO. 196 OF 30.06.2003
In accordance with the requirements and provisions of art. 13 of Legislative Decree no. 196 of 30 June 2003, the company Roberto Cavalli S.p.A., with registered office in (20122) Milan, in Piazza San Babila no. 3, in its capacity of Data Controller, hereby informs all Data Subjects on the scope and purposes of the processing of the collected personal data, the relative communication and dissemination, and the nature of their conferral.
PURPOSE OF THE PROCESSING
The personal, identifying data (name, surname, email and any other personal information provided by the Data Subject on the form) and electronic data collected from the DS and provided spontaneously by the same via the section of the corporate website called "contact us if you are interested in the COUTURE SERVICE", subject of the processing, are used by the Data Controller to correctly process the request forwarded by the DS and reply to the same.
Qualora l’interessato presti idoneo consenso, i suddetti dati potranno essere trattati per attività di marketing e comunicazione commerciale anche attraverso telefono, sms, mms, posta cartacea ed elettronica del titolare.
If the DS grants specific consent, the above-mentioned data may be processed for marketing activities and commercial communications of the Data Controller, also by telephone, sms, mms, printed and electronic mail.
PROCESSING OPERATIONS
Personal data is processed using electronic and telematic systems by specifically designated internal employees. In particular, the interested parties will be contacted by the Data Controller's VIP and Couture service managers. Data is stored in electronic archives whose security levels comply with the minimum measures endorsed by the legislature in force.
COMMUNICATION AND DISSEMINATION
The collected data will not be disseminated, sold or exchanged with third-parties without the express consent of the Data Subject, except for any communications to authorised third parties - committed to such confidentiality or appointed as Chief Data Processors under art. 29 of Legislative Decree no. 196/2003 - (e.g. IT support firms) and only where necessary to fulfil the purpose indicated in this Information Notice. Personal data may be communicated to competent authorities as required by the laws in force.
With the optional consent of the Data Subject, personal data may also be communicated to the companies in the Group that the Data Controller belongs to, both in Italy and abroad, for promotional and advertising purposes of the same.
RETENTION TIMES
Personal data is retained for the time required to interact with the Data Subject and exchange information.
As regards the processing for purposes related to the sending of commercial and promotional communications on the Data Controller's services and the sending of information messages regarding its business activities, the data will be retained as foreseen by the laws in force, and further endorsed by the Guarantor for the protection of personal data on 3 March, and unless the Data Subject opposes the processing of the same. The Data Subject can oppose the processing for one or both of the above communication activities independently.
RIGHTS OF THE DATA SUBJECT
You are entitled to execute your rights as illustrated in Arts. 7, 8, 9 and 10 of Legislative Decree no. 196 of June 30, 2003 by contacting the Data Processer. In particular, according to art. 7 you are entitled to obtain confirmation as to whether or not personal data concerning you exists, regardless of their being already recorded, and communication of such data in an intelligible form. The Data Subject has the right to obtain indications on: a) to receive information on the origin of the personal data; b) on the purpose and processing methods; c) on the logic used in the case where the data is processed using electronic equipment; d) on the personal data of the Controller, the persons in charge and the designated representatives pursuant to Art, 5 paragraph 2; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of such data in their capacity as Designated Representatives for the Country or Persons in Charge of Processing. The Data Subject has the right to obtain: a) 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. The Data Subject is entitled to oppose, totally or partially: a) processing of personal data, for legitimate reasons, despite them being relevant to the purpose of the collection; b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
DATA CONTROLLER, CHIEF DATA PROCESSOR AND PRIVACY COMMUNICATIONS
CONFERRAL OF DATA
The conferral of data is optional; however lack of consent to provide the same information will make it impossible for the Data Controller to process the requests submitted.
Conferral of personal data for marketing purposes and communications to third-parties for the above indicated marketing purposes, is optional and will not compromise the processing of the main request.
CONSENT
Pursuant to art. 23 of Legislative Decree no. 196/2003 and the correct processing of the request submitted via the "Contact Us" section of the corporate website, consent to the processing of the above data is necessary as the same are collected outside of any previous contractual agreements
Pursuant to art. 23 of Legislative Decree no. 196/2003, the consent to the processing of personal data is necessary for the marketing purposes illustrated in the "Purpose of the Processing" section. Please note, in accordance with Provision no. 330 of 4 July 2013 issued by the Guarantor for the Protection of Personal Data, that the consent granted for automated procedures also extends to traditional procedures. Without prejudice to the rights already illustrated in the Rights of the Data Subject" paragraph in this Information Notice.
Pursuant to art. 23 of Legislative Decree no. 196/2003 consent is required for the communication of the data to third parties for marketing purposes pursuant to the latter.
Please note that your consent is deemed freely granted when you tick the "I grant my consent" box.
PRIVACY POLICY
We Roberto Cavalli S.p.A. in our capacity as the Data Controller and owner of the Internet site www.robertocavalli.com, invite you to read the following information in order to inform you of the way in which the web site is managed and, as a consequence, the procedures for the processing of personal data of users navigating the above web site.
This Privacy Policy has been drawn up in full compliance with the law governing the protection of personal data (EU Regulation no. 679/2016), to help you to understand how your personal data will be processed by Roberto Cavalli S.p.A.
The possible introduction of new sector laws and the continuing procedures involving the examination and updating of the services offered could have the effect of changing the processing of personal data. This means that it is possible that our Privacy Policy will change over time and we would thus invite you to check this page on a periodical basis. You will be able to find the dates on which the document has been drawn up as well as of any amendments made further below.
Contents
Below we have specified the purposes for which your personal data have been requested.
The personal data collected will be processed on the basis of the juridical grounds set out below:
Following your specific consent to such end, your personal data may be processed by Roberto Cavalli S.p.A. to analyse your consumption habits, your preferences and in combination with your consent to Marketing, your consent to “targeted” promotional initiatives in line with your preferences.
The processing as described above, will guarantee the security and confidentiality of the information you provide.
Your personal data may be communicated to companies in the Roberto Cavalli Group which, in the capacity of Data Processors based on inter-company agreements between Group companies, will be able to process the data regarding yourself as described in the subsequent point (“Area of Data Transmission”).
Save where indicated otherwise, the inclusion of your personal data requested will be at your discretion. Nonetheless the failure to include them may mean that Roberto Cavalli S.p.A. will be unable to carry out the activities requested.
Here we have provided you with a detailed description of the nature and type of personal data asked of you.
The data processed by Roberto Cavalli S.p.A. come within the following types:
1. Common Personal Data
Roberto Cavalli S.p.A. declines any liability with regard to the possible management of personal data by third party sites and in relation to the management of the authentication credentials provided by third parties.
Our web site uses profiling cookies
Our web site uses profiling cookies which can be checked by clicking on the Cookie Policy
Roberto Cavalli S.p.A. will process the personal data provided by you with respect and the greatest possible care.
Data collected through the web site www.robertocavalli.com will be processed by means of manual, computerised or electronic tools, designed to guarantee the security and confidentiality of the same and will be performed by staff who have been appropriately trained in compliance with the applicable law.
Should you provide your explicit consent in relation to the purposes described above (Marketing and Profiling), your personal data will be made visible and stored in a single computerised archive for Customer Relationship Management (CRM), owned by Roberto Cavalli S.p.A. and accessible to all companies in the Roberto Cavalli S.p.A. Group through specific access privileges. Given that the CRM is a database for the shared and unitary management of the data stored in it, please note that the updating, rectification and/or erasure of any data provided will lead to the updating, rectification and/or erasure of such data for all parties belonging to the Roberto Cavalli S.p.A. Group.
To be able to process the data as required for the creation of a personal account, your consent is not required in that this matches your specific wishes and the data provided by you are necessary for the creation of such an account.
Roberto Cavalli S.p.A. will ensure the following in relation to the data received by it:
Your personal data will be processed:
Your data will be processed by the smallest possible number of people who have been specifically authorised to such end by
Roberto Cavalli S.p.A.
Your personal data may be transmitted within the following areas in the performance of the above-described purposes:
- Area coming within Roberto Cavalli S.p.A.
Your data may be used by staff of the Roberto Cavalli S.p.A. Group who have been assigned the specific duty of processing staff, who have been adequately trained and who are bound by confidentiality obligations.
Your personal data will only be made accessible to those who need to have access to them within Roberto Cavalli S.p.A., as a result of their duties or position in the hierarchy.
The above staff will be appropriately trained in order to avoid losses of, destruction of, unauthorised access to, or processing to which consent has not been given, of the data concerned.
- Area not coming within Roberto Cavalli S.p.A.
The data may be transmitted to Triboo Digitale S.r.l., which, in its capacity as external Data Processor, carries out the management activities applying to the web site on behalf of Roberto Cavalli S.p.A effecting the management of the platform.
Personal data may be used by third party businesses acting in the capacity of Data Processors on behalf of Roberto Cavalli S.p.A.
You can obtain an updated list of the external Data Processors which have been appointed by Roberto Cavalli S.p.A. by sending the related request to the e-mail address dpo@robertocavalli.com.
Your personal data will not be disseminated to third parties
Your personal data will not be published, displayed or made available for viewing by unidentified parties.
Your data may be communicated to the competent authorities according to law.
Your data will be only stored for the time strictly necessary.
The following table sets out an indication of the times and criteria for the storage of your personal data:
|
Marketing Purposes |
24 months from collection without prejudice to the possibility of changing/revoking your wishes at any time |
|
Profiling purposes |
12 months from collection without prejudice to the possibility of changing/revoking your wishes at any time |
We would also inform you that pursuant to Articles 5 and 89.1 of the Regulation, your personal data may be stored for longer periods than that stated in the previous paragraph but only for statistical purposes, without prejudice to the implementation of adequate technical and organisational measures required by law for the protection of your rights and freedoms.
You have the right to request access to, rectification of, the portability of, or the erasure of, your personal data in addition to the restriction of, opposition to and the revocation of the processing
You have the right to request Roberto Cavalli S.p.A., in relation to the processing of your personal data:
You may send a request to Roberto Cavalli S.p.A. asking to exercise your above rights at any time by writing to the e-mail address dpo@robertocavalli.com and Roberto Cavalli S.p.A. will manage your requests within the time limits laid down by the GDPR.
We would also inform you that you have the right to make a claim to the Italian Regulatory Authority: “Garante per la Protezione dei Dati Personali” (The Regulatory Authority for the Protection of Personal Data) should you consider that your rights have been breached by Roberto Cavalli S.p.A. and/or by a third party when you do not consider the response of Roberto Cavalli S.p.A. to your requests to be satisfactory.
The Data Controller of your data is Roberto Cavalli S.p.A. The contact data of the DPO are as follows.
INFORMATION NOTICE FOR USER WEBSITE REGISTRATION
Personal Data Protection Code
UNDER ART. 13 of Legislative Decree no. 196 of 30.06.2003
Under the provisions of art. 13 of Legislative Decree no. 196/2003 as amended, the company Roberto Cavalli S.p.A., with registered office in (20122) Milan, in Piazza San Babila no. 3, in its capacity as Data Controller, hereby informs all users requesting registration on the www.robertocavalli.com and www.robertocavalli.it websites, in their capacity as Data Subjects on the scope and purposes of the processing of the collected personal data, the relative communication and dissemination, and the nature of their conferral.
PURPOSE OF THE PROCESSING
1) Registration: the personal data and, more specifically, the data indicated on the registration form (name, surname, email address, telephone number, etc.) related to the Data Subject and provided voluntarily by the same during registration on the Roberto Cavalli S.p.A site, are processed pursuant to the request of the Data Subject to create a personal account and exploit the services provided by the Data Controller via the site and access the online portal. It should be noted that such data may also be used for purposes referred to as “soft spam”.
2) Access to services via the portal: the personal data acquired, including the computer related data (e.g. the IP address), are processed to allow access to the services provided by the Data Controller via the corporate website and reserved to registered users only; i.e. by way of example only, online shopping and payments as illustrated in full in the online platform Terms and Conditions available via the following link.
3) Sending of advertising materials, direct marketing, statistics and market research: when consent is granted, personal data, such as email address and telephone number, are also processed to send information messages and commercial and promotional communications on the activities and services provided by the Data Controller, via automated mechanisms (such as email and text messages) and also traditional methods (such as telephone contact with or without and operator), in full compliance with the principles of fairness and lawfulness and any provisions foreseen by the laws in force.
In any case, processing shall take place in accordance with the principle of fairness and lawfulness and the provisions of the laws in force.
PROCESSING OPERATIONS
The processed personal data is sent to the Data Controller's server or servers managed by third parties (appointed for the purpose as Chief Data Processors under art. 29 of Legislative Decree no. 196/2003 as amended). Personal data is processed using electronic and telematic systems by specifically designated officers and/or chief data processors inside and outside the company. Data is stored in electronic archives whose security levels comply with the minimum measures endorsed by the legislature in force.
In particular, for the purpose of sending advertising materials, direct marketing, statistics and market research, commercial and promotional communications on the activities and services provided by the Data Controller the same shall take place (again according to the provision of art. 130m par. 1 and 2 of Legislative Decree no. 196/2003 as amended) by means of:
- automated contact methods, using automated calling or call communication means without the intervention of an operator, email, facsimile, MMS- or SMS-type messages or other means for the purposes referred to therein;
- traditional methods (such as mailing of hard copies and/or operator controlled calls).
COMMUNICATION AND DISSEMINATION
No Personal data collected will be disseminated, sold, exchanged or communicated to third-parties other than the Data Controller without the express consent of the Data Subject. Dissemination to third-parties, other than the Data Controller, the Chief Data Processors, inside and also outside the corporate structure, and the Designated Officers assigned to the relative processing and appoint under arts. 29 and 30 of Legislative Decree no. 196/2003 as amended, is foreseen, where necessary to fulfil the above illustrated scope and purposes, to: individuals and third-party enterprises providing technical and IT support, marketing companies, who undertake to pursue the illustrated scopes and purposes in a correct and transparent manner. In any case, processing by third-parties shall only take place in accordance with the principle of fairness and lawfulness and the provisions of the laws in force.
RETENTION TIMES
Data shall be retained for the time required to process the purpose of the account created by the Data Subject to access the services provided by the Data Controller via the corporate website. In any case, the data shall be retained until the Data Subject requests the cancellation of the account, or until the same is closed by the Data Controller under the portal terms and conditions.
As regards the processing for purposes related to the sending of commercial and promotional communications on the Data Controller's services and the sending of information messages regarding its business activities, the data will be retained for a maximum of two years from first contact, unless the Data Subject opposes the processing of the same. The Data Subject may oppose the processing independently for one or the other sending methods (traditional or automatic), in particular, for telephone numbers included in phone books, opposition of such processing can be effected by referring to the Public Register of Oppositions, whilst for email addresses, opposition can be effected by cancellation via a specific link. In any case, the cancellation can be requested by email at the following address privacy@robertocavalli.com.
RIGHTS OF THE DATA SUBJECT
The Data Subject is entitled to execute his rights as illustrated in Arts. 7, 8, 9 and 10 of Legislative Decree no. 196/2003 as amended, by contacting the Data Processor. In particular, according to art. 7 you are entitled to obtain confirmation as to whether or not personal data concerning you exists, regardless of their being already recorded, and communication of such data in an intelligible form. The Data Subject has the right to obtain indications: a) on the origin of the personal data; b) on the purpose and processing methods; c) on the logic used in the case where the data is processed using electronic equipment; d) on the personal data of the Data Controller, the Chief Data Processors and the designated representative pursuant to Art, 5 paragraph 2; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of such data in their capacity as designated representatives for the Country, Chief Data Processors or designated officers. The Data Subject has the right to obtain: a) 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. The Data Subject is entitled to oppose, totally or partially: a) processing of personal data, for legitimate reasons, despite them being relevant to the purpose of the collection; b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
DATA CONTROLLER, CHIEF DATA PROCESSOR AND PRIVACY COMMUNICATIONS
The Data Controller is Roberto Cavalli S.p.A., with registered office in (20122) Milano (MI), in Piazza San Babila no. 3. Pursuant to art. 29 of Legislative Decree 196/2003 the Data Controller has appointed Triboo Digitale S.r.l. with registered office in Viale Sarca, 336 - 20126, Milan (MI) Italy, as the Chief Data Processor in charge of the processing of personal data for purposes related to the managing the sales and transactions on the website www.robertocavalli.com and www.robertocavalli.it, for instance, the management of product orders, sales and deliveries, returns and warranty management and all other activities related to the sales of products via the Sites, in addition to the activities related to the creation, ordinary and extraordinary management, and maintenance of the Sites themselves. An updated list of the Chief Data Processors, appointed by the Data Controller under art. 29 of Legislative Decree no. 196/2003, is available at the registered office of the latter. For all communication under art. 7 et seq. of Legislative Decree no. 196/2003 as amended, please contact the Data Controller at privacy@robertocavalli.com.
CONFERRAL OF DATA
Conferral of data is optional, but essential, as refusal to such conferral will make it impossible for the Data Controller to create the personal account required to provide the services provided by the latter via the corporate website and reserved to registered users.
As regards the conferral of data for marketing purposes, this is optional and refusal to such conferral will not effect or compromise the main processing operations, although it will be impossible for the Data Processor to perform the ancillary operations.
CONSENT
Under art. 23 and 24 of Legislative Decree no. 196/2003 as amended, the consent to the processing of personal data to create a personal account so as to exploit the services provided by the Data Controller via the corporate website reserved to registered users, is not required as the same is collected to process the obligations arising from the contract that the Data Subject has entered into.
Under art. 23 and 24 of Legislative Decree no. 196/2003 as amended, the consent to the processing of personal data for the sending of commercial and promotional communications on the services provided by the Data Controller and the sending of information messages regarding the activities of the same, is however required. Under the Guidelines regarding promotional and anti-spam activities, the Guarantor for the protection of personal data clearly states that no consent is required for what is referred to as “soft spam”.
Please note that your consent is deemed freely granted when you tick the "I grant my consent" boxes.