INFORMATION ON THE PROCESSING OF PERSONAL DATA IN ACCORDANCE WITH EUROPEAN REGULATION (EU) 2016/679 AND THE PRIVACY CODE (Legislative Decree 196/2003) AS NEWLY REVISED BY D. LGS. 101/2018
As required by the European Union Regulation No. 679/2016 (hereinafter “GDPR“) and in particular Article 13, below we provide the information required by law regarding the processing of personal data.
We do not intentionally process personal data belonging to minors under the age of 16. Should we find the existence of data belonging to minors under the age of 16, we will immediately delete them without any prior communication.
The website www.carillomoda.it (hereinafter ” Site“) is owned by. I CARILLO S.r.l., with registered office in Terzigno (NA), Italia, Corso Leonardo da Vinci, 291, VAT NO. 08719491212 and CF , pec: [email protected] (hereinafter referred to as “Carillo Moda“).
This information is provided to users who interact with the web services of the Site (hereinafter “Interested Parties“) not only to comply with legal obligations, but also because transparency and fairness towards the interested parties is a founding part of our activity.
Navigation within the Site is free and does not require any registration.
To make purchases on the Site, you must create a personal account in order to facilitate shopping and access additional services.
1. Data controller
The data controller in accordance with Article 4, Paragraph 7 of the GDPR is I CARILLO S.r.l. with registered office in Terzigno (NA), Italia, Corso Leonardo da Vinci, 291, VAT number 08719491212 and CF , pec: [email protected] (hereinafter “DataController“).
2. What is personal data?
According to Art.4 of the GDPR, personal data is defined as any information relating to an identified or identifiable natural person (data subject) directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more characteristic elements of his or her physical, physiological, genetic, mental, economic, cultural, or social identity.
3. Provision of data
Personal data will be acquired directly from the data subject by:
3.1) Direct assignment of the same
(Section 4.2 “Data voluntarily provided by the user”);
3.2) Automatic acquisition
(Sections 4.2 and 4.3 “Browsing Data” and “Cookies” or similar technologies).
4. Data types.
The following categories of data (collectively, the ” Data“) may be processed:
4.1) Navigation data:
the computer systems and software procedures used to operate the Site acquire, in the course of their normal operation, certain personal data (such as the IP addresses or domain names of the computers used by users, the pages visited and the date/time of the visit) the transmission of which is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties but which by its very nature could, through processing and association with data held by third parties, allow users to be identified.
These data, recorded anonymously, are used for the sole purpose of obtaining statistical information on the use of the Site and to check its correct operation.
The data could be used to ascertain liability in case of hypothetical computer crimes to the detriment of the Site.
4.2) Cookies:
to make navigation on this Website more efficient and immediate, while users are accessing this Website, we make use of cookies: small text strings that allow them to maintain a connection to the Website.
Please refer to the cookie policy on the web page of Carillo Moda.
4.3) Data voluntarily provided by the user:
these are personal data freely released by the user to access certain freely chosen services. Failure to provide them may result in the impossibility of obtaining the requested service. Appropriate information and requests for consent can be found on the pages of the Site dedicated to on-demand services.
5. Purpose of processing
Data are processed for the following purposes:
– Manage enrollment on the website Carillo Moda and manage activities directly related to enrollment;
– Handle orders, provide products and services, process and handle payments, communicate with the data subject about orders, shipments;
– prevent or expose fraud or abuse against our Site to enable third parties to perform technical, logistical and other activities on our behalf;
– to send administration information, marketing communications, advertising and promotional initiatives (in hard copy, text message, e-mail, etc.), promotional offers, periodic customer satisfaction surveys, market research or quality surveys, from the same, related, affiliated, subsidiary, affiliated companies, or third parties commissioned by Carillo Moda;
– Analyze habits or consumption choices in order to propose a personalized service and in line with the interests of the data subject.
Unless otherwise specified in the following provisions, the processing of personal data for the purpose of “online sales” finds the prerequisite of lawfulness in the necessity of the execution of a contract to which the data subject is a party or to the execution of pre-contractual measures taken at the request of the same, pursuant to Article 6, paragraph 1, letter b of the GDPR.
The processing of personal data for “marketing” purposes, on the other hand, finds the prerequisite for lawfulness in the expression of consent under Article 6(1)(a) of the GDPR.
6. Communication and Dissemination of Data
Data collected as part of service delivery may be disclosed to:
– companies that perform functions closely related and instrumental to the operation – including technical – of the services of Carillo Moda, such as suppliers that provide services aimed at the review and verification of ads, providers of direct marketing and customer care services, companies that provide archiving, administrative, payment and billing services, companies that provide technical components for the provision of certain features of the service;
– freight transportation companies, couriers, shipping companies and similar in the freight transportation industry;
– credit institutions, to arrange payments or credits;
– entities and administrative and judicial authorities under legal obligations;
The Data may be communicated to other companies that are part of the Carillo Moda group or otherwise connected to them, as well as to other third parties that Carillo Moda uses to optimize the services offered through the Site.
Under no circumstances do we give away personal data to third parties for any reason (including sale).
Should the Data Controller entrust processing operations to third parties, the latter will be appointed as data controllers for this purpose in accordance with Article 28 of the GDPR, subject to verification that their activities comply with the provisions on the protection of personal data.
The Controller will only use data controllers with sufficient guarantees to put in place appropriate technical and organizational measures so that the processing meets the requirements of the GDPR and ensures the protection of the data subject’s rights.
7. Compulsory or optional nature of providing Data
The provision of Personal Data is mandatory only for the processing necessary for the provision of services offered by Carillo Moda (any refusal for service delivery purposes makes it impossible to use the service itself); on the other hand, it is optional for promotional and profiling purposes, and any refusal to give consent has no negative consequences on the provision of the service offered within the Site.
8. Mode and Duration of Treatment
Personal data will be processed by authorized persons acting under the authority of the Data Controller, adequately instructed by the Data Controller, in compliance with the provisions of Article 29 of the GDPR through automated means for the time strictly necessary to achieve the purposes for which they were collected, as well as for the additional period that may be necessary to fulfill specific legal obligations.
Unless liability is established in the case of hypothetical computer crimes to the detriment of the Site, data related to navigation on the Site will not be kept for more than 30 (thirty) days.
The Data may be processed either electronically or on paper.
For purposes of analysis directed at the development and improvement of the service, the user’s personal data will be stored for 36 (thirty-six) months.
Data related to telematic traffic, excluding in any case the contents of communications, will be kept for a period not exceeding 6 years from the date of communication, pursuant to Article 24 of Law No. 167/2017, which transposed EU Directive 2017/541 on counterterrorism.
For direct marketing purposes, we keep your data for a maximum period equal to that provided by the applicable legislation , which is 24 (twenty-four) months.
Invoices, accounting records and transaction data are kept for 10 (ten) years under the law (including tax preservation obligations).
Carillo Moda guarantees the lawful and fair processing of Personal Data provided through the Site, in full compliance with current legislation, as well as the utmost confidentiality of the data provided during registration.
All Data are collected in accordance with the indications of the reference legislation, with particular regard to the security measures provided by Article 32 of the GDPR for their processing by means of computer, manual and automated tools and with logics strictly related to the purposes indicated in Article 4 and in any case in such a way as to guarantee the security and confidentiality of the data.
9. Transfer of Data Abroad
This Site may share some of the data collected with services located outside the European Union area. In particular with Google, Facebook and Instagram, via social plugins and the Google Analytics service. The transfer is authorized under specific decisions of the European Union and the Data Protection Authority, in particular Decision 1250/2016 (Privacy Shield), so no further consent is needed. The companies mentioned above guarantee their adherence to the Privacy Shield.
10. Rights of the Interested Parties
At any time you may exercise , by written request sent to the address Terzigno (NA), Italia, Corso Leonardo da Vinci, 291, or to the PEC [email protected], pursuant to Article 7 of Legislative Decree 196/2003 and Articles 15-22 of the GDPR, the right to:
- request confirmation of the existence or non-existence of their personal data
- Obtain information about the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data have been or will be disclosed, and, when possible, the retention period
- Obtain rectification and deletion of data
- obtain restriction of processing
- Obtain portability of data, i.e., receive them from a data controller and transmit them to another data controller without hindrance
- object to the processing at any time
- Object to automated decision-making related to natural persons including profiling
- requests from the data controller access to and rectification or erasure of personal data or restriction of processing concerning him or her or to object to the processing of personal data, as well as the right to data portability
- revoke consent at any time without affecting the lawfulness of processing based on consent given before revocation.
Any requests will be processed no later than one month after receipt, subject to the possibility of extending this period for an additional two months if necessary, taking into account the complexity and number of requests received by the Holder.
In addition, you may bring an appeal before the judicial authority (in accordance with the provisions of Article 80 of the GDPR and Article 13 of Legislative Decree 101/2018) or a complaint to the Data Protection Authority, by:
- registered mail with return receipt addressed to Garante per la Protezione dei Dati Personali, Piazza di Monte Citorio, 121, 00186 Rome
- e-mail at: [email protected] or [email protected]
- fax to: 06696773785
It should be noted that the complaint to the Guarantor cannot be brought if, for the same subject and between the same parties, an appeal has been brought before the Judicial Authority.
Any request regarding the Data processed by the Data Controller may be sent by email to the following address [email protected].
11. Revision clause
This Policy may be subject to change. If any material changes are made to the Owner’s use of User Data, the Owner will notify you by prominently posting such changes on its pages or through alternative or similar means.
