In compliance with the Privacy Code, Triboo Digitale S.r.l., with registered office in Italy at Viale Sarca 336, 16 – 20126 – Milano , VAT no. 02912880966 (hereinafter referred to as "TRIBOO DIGITALE"), and SEVEN S.p.A., with registered office in Italy at Via Fornacino, 96 10040 Leini (TO), registered with Torino Companies House under no. n. 00963330014, R.E.A. 470970-TO, tax code and VAT no. IT00963330014 (hereinafter “SEVEN”), are the Data Controllers of the personal data of the Users, each respectively for the different services supplied in connection with use of the Website.
More specifically, TRIBOO DIGITALE is the autonomous Controller of the personal data of the Users in connection with the on-line sales and after-sales services supplied via the Website, whilst SEVEN is the sole, autonomous Controller of the personal data of the Users in connection with the generalised and potentially profiled marketing activities carried out via the Website.
1. The policy
2. Who processes your personal data, how and to what end
TRIBOO DIGITALE - in accordance with the Privacy Code - is the Data Controller of the Personal Data of the Website Users (hereinafter the "Personal Data"), processed in order to allow for the management, stipulation and fulfilment of commercial transactions concerning the purchase of products via said website (hereinafter the "Commercial Purposes"): TRIBOO DIGITALE decides the purpose and method of this data processing and the tools to be used, also in terms of security. For purely organisational and functional purposes, TRIBOO DIGITALE has appointed some external data supervisors of the Personal Data for purposes strictly connected with and related to the provision of the services on the Website, including the sale of products (merely by way of example, customer services and the delivery of products purchased). These supervisors have been chosen because they have proven experience, capacity and reliability in supplying a suitable guarantee of complete compliance with current processing legislation, including in terms of data security. The supervisors process the Personal Data in accordance with the instructions given by TRIBOO DIGITALE. We regularly check to ensure that supervisors have fulfilled their duties promptly and continue to provide suitable guarantees of complete compliance with personal data protection legislation. Names and details of Personal Data Supervisors appointed by TRIBOO DIGITALE can be obtained by sending a written request to this end to the e-mail address: firstname.lastname@example.org
SEVEN - in accordance with the Privacy Code - is the Data Controller of the Personal Data of the Website Users (hereinafter the "Personal Data"), processed in order to allow for direct and profiled marketing according to the consent given by the data subject (hereinafter the "Marketing Purposes") and uses the Personal Data to send out newsletters relating to the world of SEVEN, its products and for generalised and/or customised promotional messages with respect to the User's consumer habits.
Personal Data is mainly processed in electronic format and in some cases also as hard copies, such as, for example, when Personal Data processing is necessary in order to prevent fraud on the Website. Personal Data will be stored in a way that enables the User to be identified only for the length of time strictly necessary to the purpose for which the data has been collected and thereafter processed and, in any case, within the legal limits. In order to guarantee that Personal Data is always exact and up-to-date, in any case pertinent and complete, please notify us of any changes thereto, by e-mailing: email@example.com
The Personal Data will not be disclosed to any third parties for purposes not permitted by the law or without your specific consent. In addition to the companies acting as data supervisors, Personal Data is also made available to third parties, autonomous data controllers, for purposes that are accessory and related to the supply of the services requested by the User(e.g. for purchase transactions). You can obtain an updated list of the data supervisors at any time, by e-mailing: firstname.lastname@example.org
Personal Data will not be transferred abroad to any non-European Union Member States (apart from companies belonging to the SEVEN Group), which do not ensure suitable personal protection levels. If this should be necessary in order to pursue the Commercial Purposes, we can assure you that Personal Data will only be transferred to non-European Union Member States (apart from the companies belonging to the SEVEN Group), which do not assure suitable protection levels, upon stipulation by TRIBOO DIGITALE and said subjects with reference to the Commercial Purposes, or by SEVEN and said subjects in relation to the marketing purposes of the Website or SEVEN, of specific contracts including clauses designed to safeguard the protection of Personal Data, in compliance with the law and applicable regulations.
3. What happens if you refuse to provide TRIBOO DIGITALE and SEVEN with your personal data
The supply of Personal Data for Commercial Purposes (in particular personal information, your e-mail address, postal address, credit/debit card and bank details and telephone numbers) toTRIBOO DIGITALE is necessary in order to pursue the Commercial Purposes. Any refusal to provide TRIBOO DIGITALE with said Personal Data required to this end may make it impossible to fulfil the purchase contract of products on the Website or, further, to correctly fulfil legal and regulatory obligations. Failure to provide Personal Data may therefore constitute, as applicable, legitimate, justified grounds not to fulfil the contract for the purchase of products on the Website. The indication of additional Personal Data, over and above that required as compulsory, is instead optional and shall have no consequence with respect to the purchase of products from the Website.
The supply to SEVEN of Personal Data for Marketing Purposes is always optional and is connected with the Website registration process. Failure to supply such, and failure to consent to processing for Marketing Purposes shall not have any consequence in terms of the purchase process, apart from the fact that it will be impossible to finalise registration and therefore to benefit from services such as newsletters, generalised or customised offers and access to reserved promotional areas.
We will duly inform you each time as to whether the supply of the Personal Data to TRIBOO DIGITALE and SEVEN is compulsory or optional and of any consequences should you fail to supply it. Please remember that failure to provide optional Personal Data shall result in no obligation nor disadvantage for Users.
4. To whom we disclose the Personal Data
Personal Data may be made available to third party companies providing TRIBOO DIGITALE and SEVEN with specific services, as data supervisors; it may also be disclosed to other third parties - whose names will be duly specified - which process data autonomously purely in order to fulfil the contract for the purchase of products from the Website (such as banks, for remote electronic payment services made by credit/debit card) and only when these purposes are not incompatible with the purposes for which the Personal Data was collected and thereafter processed and, in any case, in compliance with the law.
More specifically, TRIBOO DIGITALE uses SEVEN, as external data supervisor, to process Personal Data of Users necessary to carry out, under the scope of the Commercial Purposes, the delivery, return and management of non-conformities connected with products purchased on the Website, as better described in the Website Conditions of Sale, available for consultation at the following link. To this end, in turn SEVEN uses, for the delivery stage, professional carriers (UPS, Federal Express, DHL, etc.), which, as external data supervisors, process the personal data of the Users purely in order to fulfil their appointment.
For the Marketing Purposes, SEVEN also uses the mass newsletter mailing services the “Magnews” utility.
If the collaboration between TRIBOO DIGITALE and SEVEN concerning the management by the former of the sales of products of the latter through the Website, should cease, TRIBOO DIGITALE will send SEVEN the data of Users who have completed the Website registration procedure, in order to enable the storage, for each of said Users:
(a) of the effectiveness of the personal credentials;
(b) of details of transactions completed;
(c) of consent given to personal data processing.
Personal Data will not be otherwise disclosed, sold or transferred to any other third parties, without informing the Users in advance and obtaining due consent to such, where so required by the law.
5. How is Personal Data collected on the Website
TRIBOO DIGITALE and SEVEN collect the Personal Data and other information from the Users directly during processes that each of the two companies manages respective (purchase of products on the Website for the stipulation of electronic trade transactions/completion of User registration forms with the Website for the marketing purposes of SEVEN).
More specifically, in the pursuit of the Commercial Purposes, under the scope of the processes for purchasing products on the Website, TRIBOO DIGITALE collects Personal Data (such as personal information, e-mail address, postal address, credit card and bank details, telephone number, etc.) using the order form for the sale of products on the Website.
6. Security measures
7. Compulsory processing
Please note that TRIBOO DIGITALE and SEVEN may process Personal Data even without consent in certain cases envisaged by the law, such as, for example, when this is necessary in order to fulfil a legal obligation.
For example, Personal Data may be disclosed to the police force or legal authorities in compliance with the law and following a formal request submitted by such subjects, for example as part of anti-fraud services.
8. Rights of the data subjects
More specifically, as concerns the processing of your Personal Data for the Marketing Purposes of SEVEN, you may exercise said rights in accordance with Art. 7 of the Privacy Code at any time and obtain a list of supervisors and third parties to whom the data has been disclosed, by e-mailing email@example.com writing to the postal address of SEVEN, via Fornacino, 96 10040 Leinì (TO) ,, Italy.
Finally, any users wishing to be removed from the promotional database of SEVEN, and who no longer wish to receive marketing communications in the future, may send a specific request to this end, in any of the following ways:
1) following the cancellation instructions given at the foot of each e-mail message.
2) e-mailing firstname.lastname@example.org the specific request.
9. Contact details
If you wish to receive more information on how TRIBOO DIGITALE and SEVEN process Personal Data, please e-mail: email@example.com.
To obtain information on your rights and be kept up-to-date on personal protection legislation with respect to personal data processing, we recommend you visit the website of the Privacy Guarantor at www.garanteprivacy.it.
10. Applicable law
2) The Privacy Code guarantees that personal data is processed in compliance with fundamental freedoms and rights and in respect of the dignity of the data subject, with specific reference to the confidentiality, personal identity and right to protection of personal data.
Privacy disclosure pursuant to Article 13 of Italian Legislative Decree no. 196/2003
Please note that the personal data collected will be processed in compliance with legal requirements and the rights assured you by the law, as data subjects:
A) Processing will include: collection over the telephone or by telematic or written means or from public registers, lists of deeds and documents and/or public and/or private databases (commercial information companies), registration, organisation, storage and processing as hard copies, on magnetic, automated or telematic storage devices, processing of data collected by third parties, amendment, selection, extraction, comparison, use, inter-connection, including with data of other subjects on the basis of qualitative, quantitative and time criteria, recurring or definable each time, temporary processing with a view to enabling a rapid aggregation or transformation of said data, adoption of decision in automated and/or discretionary fashion, creation of profiles and information, communication, erasure and destruction of data or combinations or two or more of the above-described operations;
B) Without prejudice to disclosure to third parties in compliance with legal obligations or obligations deriving from regulations or other European Community legislation, the data will be disclosed by us to our appointed members of the administration, marketing, sales, after-sales and claims departments, as well as, both nationally and abroad, to the following subjects: 1) banks and credit institutes, for payments to be made; 2) insurance firms (for transport insurance cover); 3) debt collection companies, insurance and/or credit transfer companies; 4) commercial information companies; 5) consultants and professionals; 6) professionals and professional firms (lawyers, chartered accountants, auditors, etc.); 7) independent auditors; 8) other companies, entities and/or natural persons providing instrumental, support or essential services to the fulfilment of the contracts or services you may have requested (e.g. packaging companies and postal distribution companies, carriers and couriers, sub-suppliers, companies managing commercial information instruments, web space management companies for data archiving). These subjects will in turn process and disclose the data to third parties as "controllers" in accordance with Art. 28 of Italian Legislative Decree no. 196/2003, entirely independently.
C) Processing and disclosure shall take place with the following aims: 1) to satisfy pre-contractual (e.g. instruction of offers or your orders, solvency checks); 2) fulfilment of contractual obligations (connected with the supply or purchase of goods and/or services) and legal requirements (e.g. the keeping of accounts, tax formalities, administrative, accounting and treasury management); 4) customer and supplier management; 5) management of loans and risk control (fraud, insolvency, etc.); 6) management of disputes and the transfer of credits); 7) financial services instrumental to the management of customers/suppliers and management of electronic payment instruments; 8) insurance services instrumental to customer/supplier management. The internal parties appointed as above by SEVEN may also process said data for the purpose of 9) proliferation, 10) gaining fidelity and 11) sending newsletters and other promotional and commercial materials.
D) The conferral of data by yourself is only compulsory for the purposes specified under point C) above, from items 1 to 8 and, therefore, your prior consent for processing to this end, is not necessary. For processing for the purposes specified under points 9, 10 and 11, consent is not compulsory, but any failure to provide consent will prevent us from fulfilling the activities for which said purpose was required.
More specifically, please note that the processing for purpose 11 shall also entail the minimum amount of profiling and obtaining fidelity as is strictly necessary to ensure the targeted fulfilment of your request to receive newsletters and promotional and advertising materials specific to you and/or in your exclusive interests and which, in accordance with Art. 130, paragraph 4 of the Privacy Code, will not require any consent for the sending of advertising e-mails featuring products and services similar to those you have purchase on the Website, except where you should specifically refuse such consent. Data will be processed for the duration of the contracts stipulated with yourself and thereafter, for the time necessary to fulfil our legal obligations and to keep your business profile, in order to rationalise the selection of customers and/or suppliers. You are free to refuse your consent, however such refusal will make it impossible for us to fulfil the contract with yourself.
F) You may in any case exercise the following rights in relation to your personal data, as established by Articles 7, 8 and 9 of the Privacy Code: Paragraph 1 (...): to obtain confirmation as to whether or not personal data concerning him/her exists, regardless of whether or not it has been recorded, and to communication of such data in intelligible form; Paragraph 2 (...): to be informed: a) of the source of the personal data processed; b) of the purposes and methods of processing; c) of the logic applied to the processing, if this is carried out with the help of electronic means; d) of the identification data concerning the data controller, data supervisors, the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative in the State’s territory, data supervisors or persons in charge of the processing. Paragraph 3 (...): to obtain the: a) updating, rectification or, where interested therein, integration of the data; b) erasure, anonymisation or blocking of any data that has been processed unlawfully, including data whose retention is unnecessary for the purposes for which it has 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 was communication or disclosed, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected; Paragraph 4 (...): to object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning him/her, even though 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 (NB: our company, however, if processing the data for the purposes indicated in paragraph 4 of Art. 7 above, will ask you for specific written consent with an appropriate disclosure). Art. 8 Paragraph 1 (...): The rights referred to in Article 7 may be exercised by making a request to the data controller or processor without formalities, also by the agency of a person in charge of the processing. A suitable response shall be provided to said request without delay. Paragraph 2 (...): The rights pursuant to Art. 7, where not regarding objective data, may be exercised without prejudice to where such concerns the rectification or supplement of personal data of an evaluation nature, in relation to the judgements, opinions or other such subjective considerations and the indication of how to behave or decisions being made by the data controller. Art. 9 Paragraph 1 (...): the request made of the controller or supervisor can also be sent a) by letter sent recorded delivery, fax or e-mail, b) if regarding the exercise of the rights pursuant to Art. 7, paragraphs 1 and 2, also orally, and in this case, it is noted in summary form by the person in charge of processing or the supervisor. Paragraph 2 (...): in exercising the above rights, the data subject may issue a written delegation or power of attorney to a natural person, entity, association or organisation. The data subject may also be assisted by a trusted person. Paragraph 3 (...): the rights pursuant to Art. 7 in connection with personal data concerning deceased persons may be exercised by those with an interest or acting on behalf of the data subject or, for family reasons, deserving of protection. Paragraph 5 (...): the request pursuant to Art. 7, paragraphs 1 and 2, can be renewed by the data subject, without prejudice to the existence of justified grounds, at least ninety days apart.