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Privacy Policy
Article 13 of EU Regulation 2016/679 General Data Protection Regulation.
In accordance with Article 13 of EU Regulation 2016/679, known as the General Data Protection Regulation, this privacy policy is intended to provide information to users of the www.bottegadelsarto.com website regarding the management of personal data.
As autonomous data controllers, the company Bottega del Sarto Industry S.r.l., is committed to protecting the privacy of site visitors and ensuring the security of their personal data. Please read our privacy policy carefully, which applies both when simply browsing the site and when registering for related services.
Navigation on the site is free and does not require any registration, except for some sections where the user can freely and knowingly provide some personal data to access specific services. In the latter case, the user who has provided their personal data will be explicitly informed about the purposes and methods of use of these data by Bottega del Sarto Industry S.r.l., in accordance with EU Regulation 2016/679 and Legislative Decree No. 196 of June 30, 2003, Code on the Protection of Personal Data. Information will be provided, for example, on the user’s rights to request the deletion or updating of their personal data at any time.
Please note that personal data is defined as “any information relating to an identified or identifiable fixed person,” and the processing of personal data includes “ any operation or set of operations, whether or not performed by automated means, which is applied to personal data or sets of personal data , such as collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, disclosure by transmission, diffusion or any other form of making available, comparison or interconnection, restriction, erasure or destruction.”.
By browsing the site, you acknowledge that you have read and understand this privacy policy.
Information on the processing of personal data
In compliance with Art. 13 of EU Regulation 2016/679, Bottega del Sarto Industry Srl. provides the following information:
IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLERS
The data controllers of personal data collected through the site, and limited to the processing actually implemented, are:
BOTTEGA DEL SARTO INDUSTRY S.r.l.
registered office in Via Ascanio Rivaldi 16, 00151 Rome (RM)
VAT. N 13303011004
Tel 071/9882404
customercare@bottegadelsarto.com
PEC bottegadelsartoindustrysrl@pec.it
TYPES OF PERSONAL DATA PROCESSED
Access to the site does not require any registration. However, there are areas, in order to access them, a registration or user authentication is required through a Username and password such as the case when proceeding with the registration to the site, or is required to provide some of the user’s own data in order to contact us, subscribe to the newsletter, etc. Bottega del Sarto Industry S.r.l., in order to allow the user to efficiently use the site itself, will collect some user data related to connection and navigation.
Where necessary, the Companies will specifically request the User’s consent for the processing of data.
By way of example, we list below some of the information that may be collected through the site:
- Identification data: First name, Last name, address, etc.
- Contact information: Residential address, e-mail, phone number;
- Connection data: Your IP address, device number/ID, data about your Internet connection and service provider, the equipment you use to access Web sites, your browsing history, and technical usage details.
- Interest and preference data: such as purchase data and products in the shopping cart.
- Transactional data: Credit card number, fiscal code, VAT, etc.
OPTIONALITY OF PROVIDING PERSONAL DATA
Some personal data requested on the Site are mandatory to access the services offered by the Companies, such as first and last name, telephone number and e-mail address, and are marked with an asterisk. If the User does not provide this mandatory data, the Companies will not be able to provide the requested service. Personal data marked as optional are not necessary to access the services of the Site and failure to provide them will have no consequences.
In addition, Users are required to provide only their own personal data and not that of third parties, unless they have obtained, from these third parties, explicit consent for the processing of their personal data by the Companies or other data controllers.
PURPOSE AND LEGAL BASIS FOR PROCESSING
The Bottega del Sarto website collects and processes users’ personal data to manage, update and use the site, the services offered and to present it to users.
The main finities of data processing are:
- Site Registration: Bottega del Sarto Industry S.r.l. will process data for the purpose of allowing the User to register to the site, create a personal account and access to restricted areas, as well as to ensure access to facilities reserved for members. The e-mail address of the Users may be used for the purpose of delivering the mailing of the site features and the mode of use such as confirmation of successful registration and renewal of credentials.
The processing of data for these finalities does not require consent as it is necessary for the execution of the contract between the Users and Bottega del Sarto Industry S.r.l. (art. 6, paragraph 1, let. B) of the Regulations). - E-commerce: By making a purchase on the site, Bottega del Sarto Industry S.r.l. will process the user’s personal data for the following purposes:
- Complete the sales process by complying with the existing contract between the parties by, for example, managing the processing of payment and shipment of the purchased item.
- Fulfill legal obligations related to the existing contract in both accounting and fiscal matters.
- Manage services closely related to sales such as customer service management.
- The protection of rights arising from the sales contract with the user in or out of court.
- Contact Us: The information provided through the completion of the “Contact Us” form or the use of contact services (including e-mail, fax, telephone or paper mail) will be used by Bottega del Sarto Industry S.r.l. to respond to user requests and reports in an appropriate manner.
The processing of data for this purpose is necessary for the execution of the purchase contract concluded with the user or for the implementation of pre-contractual measures requested by the user (pursuant to Article 6, paragraph 1, letter b) of the Regulation). In addition, subject to specific and explicit consent, user data will be processed by Bottega del Sarto Industry Srl for: - Marketing: The service of updating on promotions, sales and initiatives regarding the brand “Bottega del Sarto” can be activated by voluntary registration of the User. The service involves the use of automated and non-automated means, such as newsletters, e-mail, telephone contact, sms, instant messages, posts, communications and posts on social networks, in order to provide commercial information to the User.
In case of subscription to the “Newsletter”, the User will only receive commercial communications to the e-mail address provided during registration.
If the User has consented to the analysis of his/her preferences, communications will be tailored to his/her interests and other information about the User (e.g., active promotions in the region where he/she resides).
The processing of data for this purpose requires the explicit consent of the User (in accordance with Article 6(1)(b) of the Regulations). - Preference Analysis: To perform analysis of user preferences(including, if available, browsing data) in order to understand users’ shopping preferences and tastes and to improve Bottega del Sarto Industry S.r.l.’s commercial offerings accordingly, personalizing communications.
The processing of data for this purpose requires the specific and explicit consent of users (pursuant to Article 6, paragraph 1, letter b) of the Regulations).
Users are reminded that the consent provided can be revoked at any time through various means, including changing the settings in the personal area of the site, clicking on the link in newsletter communications, contacting Bottega del Sarto Industry S.r.l. customer service or sending a communication to customercare@bottegadelsarto.com. If you withdraw your consent regarding Bottega del Sarto Industry S.r.l.’s update service, you will no longer receive any communications. In addition, you can limit the receipt of commercial communications only through paper mail or telephone contact with an operator, revoking consent only for the receipt of communications by electronic means (e.g., e-mail, SMS, phone calls, messages).
MODE OF TREATMENT
Users’ personal information is managed by storing it on digital media, in accordance with applicable laws, ensuring the protection and confidentiality of the data and preventing its disclosure, unauthorized use, alteration or deletion. All collected information is transmitted securely through a protected connection to prevent interception by unauthorized third parties.
If the user consents to processing for analytical purposes, Bottega del Sarto Industry S.r.l. will use the data collected (such as age and origin) to examine the user’s interests and preferences in order to improve its offerings and personalize its communications. The analysis of data and preferences will not take place exclusively in an automated manner, but will always be subject to the intervention and evaluation of authorized individuals.
RECIPIENTS OF PERSONAL DATA
The operators authorized by the Company will be able to access Users’ data in accordance with their responsibilities, as stipulated in Article 29 of the Regulations. With regard to the purposes indicated in the following outline, the following third parties may become aware of Users’ personal data:
| Purpose | Purpose – Recipients |
|---|---|
| (a) (b) | (i) Public authorities, public and administrative bodies, state and EU control bodies; (ii) banks and credit institutions; (iii) legal, tax and accounting consultants; (iv) the company in charge of managing the company’s information systems; (v) companies in charge of managing the services functional to the payment of purchases; (vi) companies in charge of shipping and delivery of products; (vii) the companies that provide services instrumental to the management of the contractual relationship (e.g. suppliers of the e-commerce platform); (viii) the companies Bottega del Sarto Industry S.r.l., which provide accounting, administrative, tax and management control related services. |
| (c) | (i) the company in charge of managing the company’s information systems; (ii) the companies that provide services instrumental to the management of the contractual relationship (e.g., suppliers of the e-commerce platform); and (iii) the companies Bottega del Sarto Industry S.r.l., which provides accounting, administrative, tax and management control-related services. |
| (d) (e) | (i) the company in charge of managing the company’s information systems; (ii) the companies that provide services instrumental to the management of the contractual relationship (e.g., suppliers of the e-commerce platform); (iii) companies that provide services instrumental to marketing (e.g. providers of platforms for sending commercial communications) and analysis (e.g. providers of dedicated software). Email addresses may also be momentarily communicated – in encrypted and protected form – to social networks (e.g. Facebook, Instagram, etc.) to allow Users subscribed to social to view news or advertising related to the brand “Bottega del Sarto“. |
| (f) | (i) The company in charge of managing the company’s information systems (ii) the companies that provide services instrumental to the operation of the “Store Locator” functionality (e.g., providers of geolocation cookies, such as Web Geo Services). |
CONTROLLERS
The Company has appointed the recipients of Users’ personal data as data processors, pursuant to Article 28 of the Regulations. It is possible to request a list of all data processors by sending a communication to the contact details indicated in this Privacy Policy, specifying that Users’ personal data will never be disseminated.
EXTRA-EU TRANSFERS
To ensure proper and efficient operation of the Site, it may be necessary to transfer Users’ personal data to countries located outside the European Union, including the United States.
The transfer of data will take place in full compliance with privacy regulations, taking all necessary guarantees and measures to protect the rights of Users. Upon the User’s request, more information will be provided about the transfer of personal data and the protection methods adopted.
DURATION OF DATA RETENTION
Users’ data will be retained only for as long as necessary to achieve the objectives as defined in the chapter on “Purpose and Legal Basis for Processing” of our Privacy Policy, subject to any authorizations provided. Once the retention period is over, the data will be destroyed or anonymized.
To be more precise, data retention will follow the criteria set out in the table below:
| Purpose | Conservation |
|---|---|
| (a) | The data will be retained for the duration of registration to the Site. After a period of 5 years of total inactivity of the account, the data will be deleted. |
| (b) | Data will be kept for as long as necessary to properly handle the User’s report and/or request. In any case, Users’ personal data will not be kept for a period longer than 5 years after the request for information. |
| (c) | Data will be kept for as long as necessary to properly handle the User’s report and/or request. In any case, Users’ personal data will not be kept for a period longer than 5 years after the request for information. |
| (d)(e) | The data will be processed for the entire duration of the subscription to the update and/or newsletter service, in full compliance with the consents provided by the User, without prejudice to the possibility of revoking consent at any time. In particular, data related to Users’ purchase details may be processed for marketing or analysis purposes for a maximum period of 48 and 36 months, respectively, after their registration. |
| (f) | Bottega del Sarto Industry S.r.l. does not transmit to Web Geo Services the User’s personal and contact data, nor does it save the User’s location data, when they are used to show the User the stores near him/her. |
CONNECTIONS TO EXTERNAL SITES
This Privacy Policy covers only the www.bottegadelsarto.com website and does not extend to other websites that the User may visit through links. It is not the responsibility of the Company if Users provide personal data to external parties or other websites linked to this site.
TOOLS USED FOR PROFILING AND PERSONALIZATION
Bottega del Sarto Industry S.r.l. does not make any form of communication for promotional or advertising purposes without the prior explicit consent of the User.
Our website uses “cookies”, both technical (aimed at simplifying navigation and use of the Site) and profiling (aimed at analyzing Users, their behaviors and preferences, and providing personalized advertising).
For more information about the cookies used by our website and how to disable them, we invite Users to consult our Cookie Policy.
USER RIGHTS
The User may exercise, simply by contacting Bottega del Sarto Industry S.r.l., the rights provided for in Articles 15-22 of the Regulations, including: to know what data we are processing, in what manner and for what purposes we use it, as well as to modify the data provided, delete it, ask to limit its use, request to receive or transmit the data. You also have the right to revoke and/or modify any processing consents you may have provided.
In addition, you may object at any time to the processing of your data for marketing or preference analysis purposes.
If the User exercises any of the rights under the Regulations, the Controller may request verification of the User’s identity by requesting a photocopy of an identity document attesting to the legitimacy of the request. Once the identity is confirmed, the photocopy received will be immediately destroyed.
COMPLAINTS TO THE SUPERVISORY AUTHORITY
If a User believes that the processing of his or her data violates the provisions of the Regulations, he or she may file a complaint with the Data Protection Authority (www.garanteprivacy.it), or with the Data Protection Authority of the country in which he or she normally resides, works, or where the alleged violation occurred.
REVISION CLAUSE
The Company reserves the right to revise, modify or update, in whole or in part, in any manner and/or at any time, without prior notice, this Privacy Policy, including in consideration of changes in data protection laws or regulations. Changes and updates to the Privacy Policy will be notified to Users as soon as they are adopted and will be binding as soon as they are posted on the site. Therefore, Users are requested to regularly consult the “Privacy” section of the site to check the publication of the most recent and updated version of the Privacy Policy.
