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Privacy policy

Privacy Notice to Users

 

Triboo Digitale S.r.l. with registered office in Viale Sarca 336, Building 16, 20126 Milan, VAT / C.F. and registration number in the Milan Register of Companies IT02387250307 (hereinafter also "Triboo") and Calzaturificio Pam SPA, with registered office in Via Al Castello, no. 5, VAT number / CF00127550036 and registration number in the Register of Novara companies No. REA NO 109903 (hereinafter, also the "Partner" and, together with Triboo, the "Owners"), as data controllers of the processing of personal data of users (hereinafter, the "Users") who they browse and use the services available on the website WWW.BAGATT.IT (hereinafter, the "Site" and the "Services") provide below the privacy policy pursuant to art. 13 of EU Regulation 2016/679 of 27 April 2016 (hereinafter, "Regulations", or also the "Applicable Regulations").

This Site and the Services are reserved to individuals who have completed eighteen years of age. The Data Controllers therefore do not collect personal data relating to persons under the age of 18. Upon the Users' request, the Data Controllers will promptly delete all personal data involuntarily collected and related to persons under 18 years of age.

 

The Owners take the utmost account of the right to privacy and protection of personal data of their Users. For any information related to this privacy statement, Users may contact the Data Controllers at any time, using the following methods:

For Triboo:

  • By sending a registered letter with return receipt to the registered office of the owner in Viale Sarca 336, Building 16, 20126 Milan

 

For the Partner:

  • By sending a registered letter with return receipt to the registered office of the Owner Via Al Castello, n. 5,28040 Lesa (NO);
  • By sending an e-mail message bagatt@bagatt.it
  • By sending a fax to the n. 0322/47975

The Users may also contact  

  • · the Data Protection Officer (RPD or DPO) of Triboo, whose contact details are shown below: lapo.curinigalletti@triboo.it
  • The Partner 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 Rules.

1. Purpose of the treatment

Users' personal data will be processed lawfully by Triboo pursuant to art. 6 of the Regulations for the following processing purposes:

a)       contractual obligations and provision of the Services, to allow navigation of the Site or to implement the Terms of Use of the Site, which are accepted by the User during registration on the Site and / or during the use of the Services and fulfill the specific requests of the User. The User data collected by Triboo for the purposes listed above include: the name, the surname, the email address. Unless the User gives Triboo a specific and optional consent to the processing of the data for further purposes, the User's personal data will be used by Triboo 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 service reasons (eg. send notifications about the Services). Notwithstanding the provisions elsewhere in this privacy statement, under no circumstances will Triboo make the personal data of the Users accessible to other Users and / or third parties.

b)      Administrative - accounting purposes, or to perform activities of an organizational, administrative, financial and accounting nature, such as internal organizational activities and activities that allow the fulfillment of contractual and pre-contractual obligations;

c)       legal obligations, to fulfill obligations under the law, an authority, a regulation or European legislation.

d)      The provision of personal data for the purposes of processing indicated above is optional but necessary, the failure to provide the same will not allow the user to browse the site, subscribe to the Site and use its Services.

 

2. Further processing purposes: 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 as the name and email address may be processed by the Partner also for marketing purposes (sending of advertising material, direct sales and commercial communication), in order for the Partner to contact the User by post, e-mail, telephone (fixed and / or mobile, with automated call or call communication systems with and / or without the intervention of an operator) and / or SMS and / or MMS to suggest the User the purchase of products and / or services offered by the same Partner and / or by third parties, to propose offers, promotions and business opportunities.

 

In case of lack of consent, the possibility to register on the Site will not be in any way affected.

 

In case of consent, the User may at any time revoke the same, making a request to the Partner in the manner indicated in the following paragraph 5.

 

The User can also easily reject further sending of promotional communications via email by clicking on the appropriate link for the revocation of consent, which is shown in each promotional email. If the User intends to withdraw his/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 the Owner in the manner indicated in paragraph 5 below.

 

The Partner informs that, following the right of opposition to the sending of promotional communications via e-mail, it is possible that, for technical and operational reasons (eg formation of contact lists already completed shortly before receipt by the Partner of the opposition request) the User continues to receive some further promotional messages. Should the User continue  receiving promotional messages after 24 hours have elapsed from the exercise of the right of opposition, please report the problem to the Partner, using the contacts indicated in paragraph 5 below.

 

3. Processing methods and data retention times

The Data Controllers will process the personal data of the Users using manual and IT tools, with logic strictly related to the purposes themselves and, in any case, in order to guarantee the security and confidentiality of the data.

 

Users' personal data will be kept for the time strictly necessary to carry out the primary purposes described in paragraph 1 above, or in any case as necessary for the protection in civil law of the interests of both Users and Triboo. 

 

In the cases referred to in paragraph 2 above, the personal data of Users will be kept for the time strictly necessary to carry out the purposes described therein and, in any case, for no more than twenty-four (24) months[1].

 

4. Scope of communication and broadcast 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 Site and all the services related to the provision of the Services. These persons, who have been instructed to do so by the Data Controllers pursuant to Article 29 of the Regulations, will process the Users' data exclusively for the purposes indicated in this statement and in compliance with the provisions of the Applicable Law.

 

Personal data of the Users may also be disclosed to third parties who may process personal data on behalf of the Data Controllers as "External Processors", such as, by way of example, suppliers of IT and logistics services functional to the operation of the Website and/or Services, outsourcing or cloud computing service providers, professionals and consultants.

 

Users have the right to obtain a list of any data controllers appointed by each Data Controller respectively, making a request to the Data Controller in the manner indicated in paragraph 5 below.

 

Furthermore, the personal data of the Users may be disclosed by Triboo, 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. Such autonomous owners will process the User's data exclusively for the purpose of the correct processing of orders relating to the Services.

 

5. Interested persons’ rights

Users may exercise their rights guaranteed by the Applicable Regulations by contacting the Data Controllers in the following manner: 

  • By sending a registered return letter to the registered office of the Owners

to Triboo: Viale Sarca 336, Edificio 16, 20126 - Milano

to the Partner: Calzaturificio Pam Spa Via Al Castello 5 28040 Lesa (NO)

  • By sending an e-mail:

to Triboo: triboospa@legalmail.it

to the Partner: bagatt@bagatt.it

  • By sending a fax to the n.

to Triboo: 02647414 14

to the Partner: +39 0322 47975

 

Triboo will comply with the requests of Users related to the treatments referred to in paragraph 1, while the Partner will comply with the requests of Users relating to the treatments referred to in paragraph 2.

 

Pursuant to Applicable Regulations, the Data Controllers inform Users that they have the right to obtain indication (i) of the origin of personal data; (ii) of the purposes and methods of the process; (iii) the logic applied in the event of processing carried out with the aid of electronic instruments; (iv) of the identification details of the Owners and managers; (v) of the subjects or categories of subjects to whom the personal data may be communicated or who may come to know them as managers or agents.

 

Furthermore, Users have the right to obtain :

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

b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;

c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment proves impossible or involves a use of means manifestly disproportionate to the protected right.

 

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 the portability of data (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 the cancellation ("right to be forgotten");

c) the right to oppose:

i) in whole or in part, for legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of the collection;

ii) in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication;

iii) if personal data are processed for direct marketing purposes, at any time, to the processing of their data for this purpose, including profiling in so far as it is connected to such direct marketing.

d) if they believe that the treatment 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 Guarantor for the protection of personal data, located in Piazza di Monte Citorio n. 121, 00186 – Roma (http://www.garanteprivacy.it/).

 

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



[1] As required by the General Provision of the Guarantor for the protection of personal data called "'Fidelity card' and guarantees for consumers. The rules of the Guarantor for loyalty programs of 24 February 2005.