Website Privacy Policy

Wooliweiss s.r.l. with registered office in Italy, Milano (Mi) Via dell’Unione n.3 (“Data Controller”) are committed to protecting the online privacy of the users of their website www.casarialto.it/ (“Website”). As such, this Privacy Policy has been written in order to allow you to understand Data Controller’s policy regarding your privacy, as well as how your personal information will be handled when using the Website. This Privacy Policy will also provide you with information so that you are able to consent to the processing of your personal data in an explicit and informed manner, where appropriate.

In general, any information and data which you provide to Data Controllers over the Website, or which is otherwise gathered via the Website in the context of the use of Wooliweiss s.r.l services (“Services”) as better defined in Section 3 below, will be processed by Data Controllers in a lawful, fair and transparent manner. To this end, and as further described below, Data Controllers take into consideration internationally recognised principles governing the processing of personal data, such as purpose limitation, storage limitation, data minimisation, data quality and confidentiality.

INDEX

1. Data controller and Data Protection Officer
   2. Personal Data processed
2. Name, contact details and other Personal Data
   b. Data concerning your location
   c. Special categories of Personal Data
   d. Other persons’ Personal Data
   e. Browsing data
   f. Cookies
3. Purposes of processing
   4. Grounds for processing and mandatory / discretionary nature of processing
   5. Recipients of Personal Data
   6. Retention of Personal Data
   7. Data subjects’ rights
   8. Amendments
4. DATA CONTROLLER AND DATA PROTECTION OFFICER

Wooliweiss s.r.l  as identified at the beginning of this Privacy Policy, are the Data controllers regarding all personal data processing carried out through the Website.

To get in touch with Wooliweiss s.r.l Data Protection Officer, please contact: [email protected].

2. PERSONAL DATA PROCESSED

When you use the Website, Data Controllers will collect and process information regarding you (as an individual) which will identity you – according to your choices on how to use the Services- in particular, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, mental, economic, cultural or social an identified or identifiable natural person (“Personal Data”);

This information may be collected both when you choose to provide it (e.g., when you subscribe to our newsletter or when you create a personal account for receiving Services provided by Data Controllers) or simply by analysing your behaviour on the Website.

1. Name, contact details and other Personal Data

In various sections of the Website – including, in particular, if you decide to create an account on the Website – you will be asked to submit information about yourself, such as your name, phone / mobile numbers, e-mail address, date of birth, country of residence and address. Additionally, when subscribing or signing up to receive Services, you might be asked to provide information as to your preferred mode of payment – PayPal, or credit card.

In addition, whenever you participate in surveys and other promotions which may be available on the Website, as well as whenever you communicate with Data Controllers through the contact details provided in the Website or with Customer Care, Data Controllers may collect additional information which you choose to provide.

1. Data concerning the Location

For providing you with more precise and useful Services, you may be asked to enter manually your address, postcode or simply the Country where you are to find the Wooliweiss s.r.l Store close to you.

Alternatively, and under your previous and explicit consent, your navigation programme on Internet (“Browser”) may share with the Website an approximation of your geographic location through information on wireless access points close to you and on your IP address of your device.

In both cases, it is an optional use of a Personal Data processing but extremely useful to Data Controllers for proving you even more useful Services. If you think that sharing your approximate location through your Browser is invasive, you may revoke at any time your consent changing the settings of your Browser (or settings of you operating system). To have more information we invite you to read specific privacy notice of your Browser.

1. Special categories of Personal Data

Certain areas of the Website (e.g., “Work with us”) may include free text fields, where you can provide Data Controllers some information, which may contain Personal Data.

Where these fields are completely free, you may use them to disclose (inadvertently or not) more sensitive categories of Personal Data, such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The content you upload in these fields may also (inadvertently or not) include other types of sensitive information relating to you, such as your genetic data, biometric data or data concerning your health, sex life or sexual orientation.

Data Controllers ask that you do not disclose any sensitive Personal Data on the Website, unless you consider this to be strictly necessary. As it is totally optional to provide this information, if you nonetheless choose to do so, please mind that Data Controllers, complying with the applicable law, require your explicit consent to process this sort of Personal Data (which can be provided, e.g., by the flag in your Application).

1. Other persons’ Personal Data

As mentioned in the previous section, certain areas of the Website (when you insert your e-mail to subscribe to the newsletter, or when you purchase products on the Website) allow you to insert text messages or information, which Data Controllers may have access. These messages and information may include Personal Data related to other persons.

In those situations, you will be considered as an independent data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify Data Controllers against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, brought by the third parties whose information you provide through the Website.

As Data Controllers do not collect this information directly from these third parties (but rather collects them, indirectly, from you), you must make sure that you have these third parties’ consent before providing any information regarding them to Data Controllers; if not, then you must make sure there is some other appropriate grounds on which you can rely to lawfully give Data Controllers this information.

1. Browsing data

The Website’s operation, as it is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While Data Controllers do not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information must also be considered Personal Data.

This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on.

These data are used to compile statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website. Save for this last purpose, these data are not kept for more than 50 business days.

1. Cookies

Definitions, characteristics, and application of standards

Cookies are small text files that may be sent to and registered on your computer by the websites you visit, to then be re-sent to those same sites when you visit them again. It is thanks to these cookies that those websites can “remember” your actions and preferences (e.g., login data, language, font size, other display settings, etc.), so that you do not need to configure them again when you next visit the website, or when you change pages within a website.

Cookies are used for electronic authentication, monitoring of sessions and storage of information regarding your activities when accessing a website. They may also contain a unique ID code which allows tracking of your browsing activities within a website, for statistical or advertising purposes. Some operations within a website may not be able to be performed without the use of cookies which, in certain cases, are technically necessary for operation of the website.

When browsing a website, you may also receive cookies from websites or web servers other than the website being visited (i.e., “third-party cookies”).

There are various types of cookies, depending on their characteristics and functions, which may be stored on your computer for different periods of time: “session cookies”, which are automatically deleted when you close your browser, and “persistent cookies”, which will remain on your device until their pre-set expiration period passes.

According to the law which may be applicable to you, your consent may not always be necessary for cookies to be used on a website. In particular, “technical cookies” – i.e. cookies which are only used to send messages through an electronic communications network, or which are needed to provide services you request – typically do not require this consent. This includes browsing or session cookies (used to allow users to login) and function cookies (used to remember choices made by a user when accessing the website, such as language or products selected for purchase).

On the other hand, “profiling cookies” – i.e., cookies used to create profiles on users and to send advertising messages in line with the preferences revealed by users while browsing websites – typically require specific consent from users, although this may vary according to the applicable law.

Types of cookies used by the Website

The Website uses the following types of cookies:

• Browsing or session cookies, which are strictly necessary for the Website’s operation, and/or to allow you to use the Website’s content and Services
• Analytics cookies, which allow Data Controllers to understand how users make use of the Website, and to track traffic to and from the Website.
• Function cookies,which are used to activate specific Website functions and to configure the Website according to your choices (e.g., language), in order to improve your experience.
• Profiling cookies, which are used to observe the preferences you reveal through your use of the Website and to send you advertising messages in line with those preferences.

Data Controllers also use third-party cookies – i.e. cookies from websites / web servers other than Wooliweiss s.r.l, owned by third parties. These third parties will either act as independent data controllers regarding their own cookies (using the data they collect for their own purposes and under terms defined by them) or as data processors for Data Controllers (processing personal data on Data Controllers’ behalf). For further information on how these third parties may use your information, please refer to their privacy policies:

• Google:https://www.google.com/policies/privacy/partners/https://tools.google.com/dlpage/gaoptout.
• DoubleClick – Google: https://policies.google.com/privacy?hl=en
• Insider: http://useinsider.com/privacy-policy/
• Criteo: https://www.criteo.com/it/privacy/
• Adform: https://site.adform.com/privacy-policy-opt-out/
• Facebook: https://it-it.facebook.com/about/privacy/update
• Lengow: https://www.lengow.com/it/note-legali/
• Tooso:https://tooso.ai/privacy-policy.html
• Fanplayr:https://fanplayr.com/files/en/Fanplayr-GDPR-Compliance.pdf
• Quantcast: https://www.quantcast.com/privacy/

Cookies present on the Website:

In detail, the cookies present on the Website are as follows:

Cookie settings

You can block or delete cookies used on the Website via your browser options. Your cookie preferences will be reset if different browsers are used to access the Website. For more information on how to set the preferences for cookies via your browser, please refer to the following instructions:

• InternetExplorer
• Firefox
• Chrome
• Safari

You may also provide set your preferences on third-party cookies by using online platforms such as AdChoice.

CAUTION: If you block or delete technical and/or function cookies used by the Website, the Website may become impossible to browse, certain services or functions of the Website may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Website.

3. PURPOSES OF PROCESSING

Data Controllers intends to use your Personal Data, collected through the Website, for the following purposes:

• To verify your identity and assist you, in case you lose or forget your login / password details for any of your personal account; to purchase a name Card; to consult the chronology of your orders; to send you newsletters you have subscribed to as a service, containing only informative and not marketing content; to finalise purchase orders and deliver products bought on the Website; to save your favourite order, to find the Wooliweiss s.r.l Store close to you and to provide any other Services which you may request.
• For future marketing, promotional and publicity purposes, including to carry out direct marketing, market research and surveys, via e-mail, SMS, over the phone, through push notifications, pop-up banners, instant messaging, through an operator, through Data Controllers’ official social media pages, […], regarding Wooliweiss s.r.l products and services, as well as those of selected third parties .
• For future marketing, promotional and publicity purposes, by sending you direct e-mail marketing communication regarding products and services provided by Wooliweiss s.r.l and which are similar to those you have previously purchased or requested via the Website ;
• To create a profile of you through the use of profiling cookies and by collecting and analysing information on the preferences you select and choices you make in the Website as well as your general activities on the Website as a registered user, therefore by collecting information on your previous order, whish-list and navigations. This profile will be used to give you information about other websites / services which Data Controllers believe you may be interested in, and to show you information and advertisements which may be relevant to you and your interests. All algorithms involved in this automated or semi-automated processing are regularly tested, to ensure the processing’s fairness and control for bias ;
• For compliance with laws which impose upon Data Controllers the collection and/or further processing of certain kinds of Personal Data ;
• To prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website

4. GROUNDS FOR PROCESSING AND MANDATORY/ DISCRETIONARY NATURE OF PROCESSING

Data Controller’s legal bases to process your Personal Data, according to the purposes identified in Section 3, are as follows:

• Service Provision: processing for these purposes is necessary to provide the Services and, therefore, is necessary for the performance of a contract with you. It is not mandatory for you to give Data Controllers your Personal Data for these purposes; however, if you do not, Data Controllers will not be able to provide any Services to you. The same applies to the newsletter service that you specifically request when you insert your e-mail address and that you may revoke at any time following the indications on Section 8 of this privacy policy.
• Marketing: processing for these purposes is based on your consent. It is not mandatory for you to give consent to Data Controllers for use of your Personal Data for these purposes, and you will suffer no consequence if you choose not to give it (aside from not being able to receive further marketing communications from Data Controllers). Any consent given may also be withdrawn at a later stage (please see Section 8for more information).
• Soft Spam: processing for these purposes is based on Data Controllers’ interest in sending you direct e-mail marketing communication regarding products and services provided by Data Controllers and which are similar to those you have previously purchased through the Website. You can block these communications, and you will suffer no consequence if you do so (aside from not being able to receive further communications from Data Controllers), by objecting through the link provided at the bottom of all such communications.
• Profiling: processing for this purpose is based on your consent. It is not mandatory for you to give consent to Data Controllers for use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from greater personalisation of your user experience regarding the Website). Any consent given may also be withdrawn at a later stage (please see Section 8for more information).
• Compliance: processing for this purpose is necessary for Data Controllers to comply with its legal obligations. When you provide any Personal Data to Data Controllers, Data Controllers must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
• Misuse/Fraud: Information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potentially criminal purposes) and allow Data Controllers to defend themselves in subsequent legal proceedings that may arise.

5. RECIPIENTS OF PERSONAL DATA

Your Personal Data may be shared with the following list of persons / entities (“Recipients”):

• Persons, companies or professional firms providing Data Controllers with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services and which act typically as data processors on behalf of Data Controllers;
• Entities engaged in order to provide the Services (e.g., hosting providers or e-mail platform providers);
• Persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
• Persons authorised by Data Controllers to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of Data Controllers);
• Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities.

6. RETENTION OD PERSONAL DATA

Personal Data processed for Service Provision will be kept by Data Controllers for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of the Services, Data Controllers may continue to store this Personal Data for a longer period, as may be necessary to protect Data Controllers’ interests related to potential liability related to the provision of the Services.

Personal Data processed for Recruitment will be kept by Data Controllers for as long as the vacancy for which the CV was submitted is still available or, in case of open positions, for up to 1 year. Data Controllers may contact applicants before the expiration of this period, in order to request an extension of the retention period or an update of the application. In case of no response from the applicants, Data Controllers delete Personal Data collected.

Personal Data processed for Marketing e Profiling will be kept by Data Controllers from the moment you give consent until it is withdrawn. We will remind consent you have given every 24 months. Once consent is withdrawn (or not given, following a renewal), Personal Data will no longer be used for these purposes, although it may still be kept by Data Cotrollers, in particular as may be necessary to protect Data Controllers’ interests related to potential liability related to this processing.

Personal Data processed for Soft Spam will be kept by Data Controllers until you object to this processing through the link you find at the bottom of every Soft Spam e-mail.

Personal Data processed for Compliance will be kept by Data Controllers for the period required by the specific legal obligation or by the applicable law.

Personal Data processed for preventing Misuse/Fraud will be kept by Data Controllers for as long as deemed strictly necessary to fulfil the purposes for which it was collected and until Data Controllers have to keep the data in order to defend themselves in subsequent legal proceedings that may arise, or communicate this data to Supervisory authorities, as may be requested.

7. DATA SUBJECT’ S RIGHTS

As a data subject, are entitled to exercise the following rights before Data Controllers, at any time:

• Access your Personal Data being processed by Data Controllers (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
• Correct or update your Personal Data processed by Data Controllers, where it may be inaccurate or incomplete;
• Request erasure of your Personal Data being processed by Data Controllers;
• Request the restriction of the processing of your Personal Data;,
• Exercise your right to portability: the right to obtain a copy of your Personal Data provided to Data Controllers, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller;
• Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent Data Controllers from processing your Personal Data; or Withdraw your consent to processing for Marketing e Profiling.

Please note that most of the Personal Data you provide to Data Controllers can be changed at any time, including your e-mail preferences, by accessing, where applicable, your user profile created on the Website.

When requesting Services via the Website, you may have selected one or more means of communication via which Personal Data processing for Marketing purposes may be carried out (e.g., phone, SMS, email, mail, push notifications, social media). You may withdraw your consent to this processing for all selected means of communication by means of your personal account.

You can also withdraw consent for Marketing for communications received via e-mail and object to Soft Spam by selecting the appropriate link included at the bottom of every marketing e-mail message received. The same applies to the Wooliweiss s.r.l  newsletter which you may have subscribed to, when you have requested it as a Service.

Consent for Profiling carried out by cookies may be withdrawn as described in Section 2(f).

Aside from the above means, you can always exercise your rights described above by sending a written request to Data Controllers at the following address: [email protected].

In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through the Website is unlawful.

8. AMENDMENTS

This Privacy Policy entered into force on 2018/05/22.

Data Controllers reserve the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. Data Controllers will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website. Data Controllers therefore invite you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how Data Controllers collect and use Personal Data.