PRIVACY POLICY BARBERINO OUTLET
This information is provided pursuant to articles 13 and 14 of European Regulation no. 2016/679 (hereinafter, “Regulation”) to those who interact with the web services of the website https://www.barberinooutlet.com (hereinafter, “Website”).
This information does not concern other websites, pages or online services that may be reached via any hypertextual links published on the website but referring to resources external to the domain https://www.barberinooutlet.com.
1. DATA CONTROLLER RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA
The Data Controller is BMG BARBERINO SRL (hereinafter abbreviated as BMG), with V.A.T. No. 05176070489, registered office in Barberino Del Mugello (FI), at Via Meucci Snc, 50031, in the person of its legal representative pro tem, e-mail: privacy@barberinooutlet.com. The Data Controller has appointed a Data Protection Officer, who can be reached by e-mail at dpo@barberinooutlet.com or by writing to the address of the Data Controller.
The company responsible for processing personal data, in its role as business and marketing manager in charge of handling relations with the users of the Outlet, is Promos S.r.l. – fiscal code and V.A.T. no.: 03123920179 – Via San Zeno, 173- 25124 Brescia (BS), Phone: +39 030 2422862- Fax: +39 030 2422870,- e-mail: privacy@promosgroup.it.
The Data Processor has also appointed a Data Protection Officer, who can be reached by e-mail at dpo@promosgroup.it or by writing to the address of the Data Processor.
2. PRINCIPLES OF DATA USAGE
In processing the personal data of the users, BMG will apply the principles of legitimacy, correctness and transparency. Personal data will be collected for specific, explicit and legitimate purposes (limitation of purpose) and will be adequate, pertinent and limited with respect to the purpose for which they are used (minimization of data). Data will always be updated and exact, and will be saved for a period of time no longer than necessary for the pursuit of the Data Controller’s purposes (limitation of conservation), after which they will be deleted. Finally, the data will be processed applying all the most adequate safety measures to ensure integrity and inaccessibility by unauthorized third parties (integrity, confidentiality and unavailability).
3. DATA PROCESSED
a) Data acquired during navigation
The systems and applications dedicated to the operation of this website collect, during their normal operation, data whose transmission is implicit in the use of the communication protocols typical of the Internet.
The data in this case are not collected in order to be associated with identified data subjects, but by their nature they could be processed and associated with data controlled by others so as to identify the users. This category of data would include the IP addresses or domain names of the computers used by users who connect to the website, the addresses in URI (Uniform Resource Identifier) notation of the resources requested, the time of the request, the method used in submitting the request to the server, the dimensions of the file obtained in reply, the numerical code indicating the status of the response given by the server (successful outcome, error, etc.) and other parameters relative to the operating system and information environment of the user. These data are used for the sole purpose of obtaining anonymous and aggregate statistical information about the use of the website and to control its correct function. The data may also be used for ascertaining liability in case of hypothetical information crimes against the website.
b) Data provided voluntarily by the users
BMG also collects personal data provided voluntarily by the users when they interact with the services of its Website or fill out forms specifying their first and last names, email addresses or other information supplied when making requests. This may occur when requesting the newsletter or when participating in other initiatives on the Website involving information and the exchange of messages.
In the sections of the website where user data are collected, there is always a link to this Privacy Policy or other specific information about the uses made of personal data.
c) Cookies
Users are invited to click on the following link: https://www.barberinooutlet.com/cookie-policy/ to read the specific Cookies Policy of the Website and obtain all the information necessary about the type and mode of use of the cookies and similar tracing tools.
d) specific Information
In case of further personal data collection, specific information will be given to the data subjects.
4. PURPOSES AND LEGAL GROUNDS FOR PROCESSING DATA.
The data will be processed for the following purposes:
a) Navigation of the website.
PURPOSE: to enable users to navigate the website.
LEGAL GROUNDS: need to respond to specific requests of data subjects and perform the contracts stipulated with them.
NATURE OF SUPPLY: necessary for anyone who wishes to navigate the website and use the relative services.
b) Newsletter and other marketing activities.
PURPOSES: to enable users to subscribe to the newsletter and other communications of the Data Controller about promotions, offers, initiatives, etc., via e-mail, text and video messages and other types of instantaneous messaging, in addition to the traditional advertising methods (telephone calls, regular mail).
LEGAL GROUNDS: consent of the data subjects. After consenting, data subjects can revoke or withdraw their permission at any time. To do so, it is sufficient to use the “Unsubscribe” option provided in every e-mail sent.
NATURE OF CONSENT TO PROCESS PERSONAL DATA: Providing personal data to subscribe to the newsletter and receive other advertising material from the data controller is optional; failure to provide it, however, will make it impossible for BMG to deliver the relative communications.
c) Legal purposes
PURPOSES: to enable BMG to satisfy any legal obligations and comply with specific regulations.
LEGAL GROUNDS: the applicable provisions of law or regulations.
c) Purposes of Legitimate Interest
PURPOSES: to perform activities functional to the sale of the company or company divisions, or to enact acquisitions, mergers, splits or other transformation and to claim and defend the rights of BMG toward its users and third parties in possible disputes.
LEGAL GROUNDS: the legitimate interest of BMG, adequately harmonized with the interests of the data subjects in light of the limits placed on data processing.
NATURE OF CONSENT: not mandatory. The user will have the right to object to use of their data for those purposes, using the methods indicated in this text, without prejudice to a prevalent interest of BMG to continue to use them and without prejudice to the case in which such use is necessary in order to apply or defend a right of BMG in court.
5. MODE AND DURATION OF USE
The personal information of data subjects will be collected and processed with electronic devices and, to a lesser degree, using manual devices, only for the time necessary to fulfill the purposes of the data controller. The logics and procedures of processing are related to the purposes specified in this informative document. Depending on the specific purpose for their use, the personal data are accessible for processing by authorized personnel, and by the management-level personnel in charge of data processing.
Fully automated decisional processes that produce legal effects for the data subjects or affect them in significant ways are not used.
The personal data of users will be processed for the time necessary to manage their interaction with the Website and to secure their use of the relative goods and/or services for the duration of the applicable contract. Once these purposes have been achieved, the data will be conserved for the time required by law for administrative, accounting and fiscal purposes and to validate any contractual rights, in accordance with the applicable provisions of law.
Data processed for purposes of marketing and profiling of data subjects are kept for 7 years, while the user retains the right to revoke the consent given previously and/or object to their use, in accordance with the most recent provisions of the Guarantor for the Protection of Personal Data.
Data collected for purposes of legitimate interest are saved for a period of 10 years from the time of collection, in case of use serving to validate and defend the rights of BMG toward the users and third parties in a possible dispute, while with respect to uses serving to perform activities functional to sale of the company or corporate divisions, acquisition, mergers, splits or other transformations, and for the performance of these operations, the terms of conservation indicated above will be replied with respect to the main use made of the data.
6. RECIPIENTS OF PERSONAL DATA
Personal data may be communicated to third parties who perform activities necessary for the provision of the services offered by the website, who process the data as data processors or independent data controllers. Specifically, the data will be processed by the following parties or categories of parties:
companies affiliated with the data controller or business partners that provide IT services;
suppliers of services that operate on behalf of the data controller, on the basis of contractual agreements, to perform activities connected with the administrative, commercial and advertising management of the Outlet;
companies and consultants, engaged in assistance and consulting services on legal, accounting and fiscal matters;
supplying services for the management of the information system and telecommunications networks, including e-mail;
government authorities ensuring compliance with legal obligations;
participating stores and restaurants at the outlet.
The data processed for the purpose of sending newsletters are not communicated to third parties but may be processed by other companies responsible for processing, pursuant to art. 28 of the Regulation.
Through the icons of the social networks present on the website, some user data may also be conveyed to the social networks. With respect to these uses, which are made externally to this website, you are referred to their specific privacy policies.
All the parties listed above are required to use the information received only for the purposes of processing as indicated above, and to keep the data confidential, intact and inaccessible to unauthorized third parties. The data of our users are not made public.
7. TRANSFERRAL OF PERSONAL DATA
User data are not sent to countries outside the European Economic Community. If it should be necessary to send data outside the European Economic Community to a country or international organization that does not guarantee an adequate level of protection as required by the European Commission, the Data Controller will apply an appropriate mechanism to convey them with the guarantees required for such transfer, pursuant to articles 44 and thereafter of the European Regulation.
8. RIGHTS OF DATA SUBJECTS
The articles from 15 to 22 of the GDPR grant data subjects specific rights that they may exercise. Art. 15 recognizes the right of data subjects to access their personal data and obtain a copy of it. The right to obtain a copy of their data shall not infringe on the rights and freedoms of others.
With the request of access, the data subjects have the right to obtain from the data controller confirmation or denial of the fact that their data is being processed and to know the purposes and categories of data processed, the third parties to which they have been communicated and whether the data have been transferred to a country outside Europe with adequate guarantees. The data subjects also have the right to know for how long their personal data will be used, in respect of the aforementioned purposes.
With respect to their personal data, data subjects may request correction of incorrect data and completion of incomplete data, as well as deletion (right to oblivion) at the conditions indicated by art. 17 of the Regulation, and may request limitation of processing and portability of data.
Data subjects have the right at any time to oppose the use or revoke their consent to use their data with regard to purposes of marketing and profiling if connected to marketing.
To stop receiving marketing communications (e-mails, text messages, etc.) it is sufficient to send an e-mail at any time to privacy@barberinooutlet.com subject “delete me” or use the unsubscribe option in the e-mails.
The data controller will issue a statement to the data subject certifying that the operations mentioned above have been notified to those to whom the data had been notified and disclosed, unless this should be found to be impossible or imply the use of means clearly disproportionate to the right protected.
To exercise the above rights, it will be necessary to contact the data controller at the e-mail privacy@promosgroup.it, or at the address of the registered office.
Before responding, it may be necessary to identify the data subjects by asking them to supply a copy of their identity document. The data controller will provide a written answer without undue delay and, in any case, no later than one month after receipt of the request.
9. CLAIMS WITH THE GUARANTOR FOR THE PROTECTION OF PERSONAL DATA
Data subjects who believe that their personal data may have been used in violation of the provisions of the Regulation or local legislation on the subject of data protection have the right to file a claim with Guarantor for the Protection of Personal with office in Rome, pursuant to art. 77 of the Regulation, as well as with the courts of law.
10. UPDATES
This privacy policy may undergo changes and/or additions following possible subsequent amendments and/additions to the regulations, updates or the provision of new services, as well as in response to technological innovations. Any changes will be published on the website and, if necessary, communicated to the data subjects via e-mail.
Version 0.0 July 2024