INFORMATION ON PRIVACY
This information (hereinafter “Information”), is destined for all users of the site www.janetandjanet.com (hereinafter “Site”) of the company A&G CALZATURIFICIO spa (hereinafter “Company”) and of the services connected with it.
The validity and effect of this information is limited to the Company’s Site. Should the user consult one or more websites other than the Site, through one or more links contained in the Site itself, the Company will not accept any liability whatsoever regarding any treatment of any user data undertaken by the owners of such sites. In such cases, in order to become acquainted with the conditions of treatment of the user’s data and the necessary procedure for exercising his/her relative rights, he/she must refer exclusively to any information contained within those sites.
The Information also derives from recommendation n° 2/2001 that the European authorities for the protection of personal data, in the Group instituted by art. 29 of Directive n°. 95/46/CE, adopted on 17 May 2001 to identify certain minimum requirements for the online collection of personal data and, in particular, the methods, times and nature of the information that data controllers must provide to users when users connect to web pages, irrespective of the purpose of the connection.
For particular functions or services that can be accessed through the Site (including, but not limited to, requests for information or contacts, registration onto the Site mailing-list, e-commerce, etc.), specific information is provided which can be consulted on the relevant pages of the Site.
Therefore, pursuant to art.13 of D. Lgs. 196/2003 and successive amendments (hereinafter “Code of Personal Data Protection”), the Company hereby notifies the following:
1. DATA CONTROLLER AND PROCESSOR
- After consulting this site, it may be treated data such they identify the user or they makes the user identifiable. For the purpose referred to in the section “Purposes of Treatment”, the controller of the relative data is the Company, namely A&G CALZATURIFICIO SPA, company under Italian law with head office at Via A. Merloni 20, Serra dei Conti (AN), Italy, registered at the Ancona Chamber of Commerce n° 00101050425 (VAT), registered capital €1,512,000.00, REA n° 86314.
- The Company is the data processor. It reserves the right to appoint, at its own discretion and at any time, pursuant to art.29 of the Code of Personal Data Protection, a supervisor with whom to entrust the maintenance of the technical aspects of the site (Processor). In such cases it will publish the corresponding identification data making reference to this subsection.
2. PLACE of DATA TREATMENT
- The treatment of data connected with consultation of the Site and use of relative services takes place at the office of the Company and is handled only by the technical staff who deal with treatment. If necessary, the data may be treated by staff specifically appointed by the Company for treatment at its own head office. In all cases, the data will be treated in physical and virtual settings to which access is kept under constant control.
3. TYPE OF DATA TREATED and PURPOSES OF TREATMENT
- Navigation data: the Company allows simple navigation within the Site without the need to provide personal data. In this case the computer systems and software procedures in this website are limited to acquiring, in the course of their normal functioning, certain data whose transmission is implicit in the use of internet communication protocols. This regards information which is not gathered in order to be associated with identified interested parties, but which, by its very nature, may, by means of processing and association with data held by third parties, enable the identification of users. This category of data includes IP addresses or the dominain names of computers used by users who connect with the Site, addresses in URI (“Uniform Resource Identifier”) notation of requested resources, the time of the request, the method used to send the request to the server, the dimension of the file obtained in response, the numerical code that indicates the state of the response given by the server (correctly received, error, etc.) and other parameters relating to the operating system and the user’s computer setting. Purpose of treatment: This data is used for the sole purpose of obtaining anonymous statistical information about the use of the Site and to monitor its correct functioning and it is erased immediately after processing. The data may be used to ascertain responsibility in cases of hypothetical cybercrime to the detriment of the Site: apart from this eventuality, present web contact data does not persist for more than fifteen days.
- E-shop registration data: when the user registers with the E-shop, he/she is requested freely and voluntarily to transmit personal information. Purpose of treatment: this data is treated for the sole purpose of enabling the user to gain access to services reserved for registered users, including the online purchasing service and the management of his/her credentials; it also enables the Company to fulfill its relative legal requirements.
- Online purchase data: in cases where the e-commerce service is used, following registration with the E-shop, the user is requested to send a purchase proposal (known by the system as Purchase Order, please see General Purchase Conditions) to the Company, contain certain personal data, further to the data provided at registration and necessary in order to stipulate the purchase contract (e.g. user’s age and home address, address for Product delivery, purchaser’s telephone number, etc.). In cases of online purchase, data relating to Paypal accounts will in no way be treated by the Company nor by the Processor but by the payment service supplier. Purpose of treatment: this data will be treated in order to enable the Company:
a) to carry out procedures connected with the stipulation of the online purchase contract and subsequently to perform the obligations arising from the contract (including administrative and, more in general, legal obligations);
b) to generate a profile of the user (namely to analyze consumption choices based on the example of the type of product bought, time-scale of purchasing, etc.), only with the express consent of the user;
c) limited only to the email coordinates provided by the user when making an online purchase of a product, to suggest to that user to purchase similar products directly (so-called “soft spamming”), unless the user refuses such treatment.
Likewise, when making an online purchase, certain navigation data (e.g. IP address from where the transaction originated, time of the request, user’s browser, etc.) may be recorded to allow the competent Judicial Authorities, on their own initiative, to ascertain responsibility in cases of cybercrime.
- Newsletter registration data or data provided otherwise by the user: the data which is voluntarily and freely provided by the user by means of registration to the newsletter or by means of spontaneous transmission by email, will be treated only upon the user’s voluntary, free and express consent. Purpose of treatment: this data will be treated to enable the Company to notify the user about promotional offers, discounts, benefits and other services, as well as to send commercial or promotional information and free products, participation at shows or events, market research surveys and notification of other initiatives being undertaken by the Company.
N.B.: all the above data, except that referred to in 3.1, may be treated for statistical or historical purposes.
4. PROVISION OF DATA AND CONSEQUENCES WHEN CONSENT TO TREATMENT IS NOT GIVEN
- The provision of data for the purposes described in subsections nn° 2, 3 and 4 in the above section 3 is voluntary and free. Especially:
regarding the treatment of data referred to in subsection n°2 in the above section 3: this is necessary to enable registration with the E-shop and access to the other services reserved for registered users, including the e-commerce service. Any refusal to supply such data or failure to give consent to treatment of such data for its respective purposes will make it impossible to register with the E-shop and to make online purchases by means of the E-shop;
regarding the treatment of personal data referred to in subsection n°3, letter “a” in the above section 3, further to the data already provided at registration: this is necessary to finalize an online purchase transaction and complete the purchase. Any refusal to supply such data or failure to give consent to treatment of such data for its respective purposes will make it impossible to make the online purchase;
regarding the treatment of personal data referred to in subsection n°3, letters “b” and “c” and n°.4 of the above section 3: given that such data is necessary for marketing activities and for the creation of a user profile, any refusal to supply such data or failure to give consent to treatment of such data for its respective purposes:
will not produce any consequences regarding the possibility to register with the E-shop and/or to purchase E-shop products online;
will preclude the Company from sending and the user from receiving information and advertising material, brochures, notifications relating to the Company’s products and services, or the products and services of third parties, as well as promotions, discounts, benefits and other services, commercial or promotional information and free products, invitations to shows or events;
will make it impossible for the Company to carry out market research and to notify the user about all the special initiatives regarding its products or those of third parties and will also make it impossible to proceed with the creation of a profile of the user.
The consent given by the user to treatment of personal data for one or more purposes referred to in above said subsection n°4 above may be revoked at any time by amending the user registration credentials or by contacting the Company or the Processor at the addresses referred to in section 1 above (Data Controller and Processor) or, limited to treatment relating to use of email of information and advertising material, brochures and information messages by clicking in the specific box provided “I do not want to receive other communications” at the bottom of every communication containing advertising information.
5. METHOD OF TREATMENT
- Subject to the above section 2, treatment will be carried out with the use of electronic, telematic and paper tools. Such treatment will be guided by the principles of correctness, legality and transparency and of the protection of users’ rights in compliance with the Code of Personal Data Protection. The data will be treated in such a way as to minimize the risks of destruction, loss, unauthorized access or treatment without consent or which does not correspond to the purpose for the data was obtained. All information and methods of treatment will correspond with and will not be excessive in relation to the services provided to the user.
6. PERSONS OR CATEGORIES OF PERSONS TO WHOM DATA MAY BE TRANSFERRED AND CONDITIONS UNDER WHICH SUCH DATA MAY BE TRANSFERRED
- User data will not be transferred other than in anonymous form and solely for statistical or research purposes.
- Data provided by the user, following consent, for the purposes referred to in section 3 above will be accessible to the Company or Processor, if any, staff appointed to treat data, solely and exclusively for the respective purposes referred to above and in order to guarantee a constant level of correctness and any necessary updating.
- Access may also be given to persons appointed to perform maintenance or computer system development for the time that is strictly necessary for the work to be completed or to those who legally authorised access or by virtue of provisions made by the competent judicial Authorities.
7. DURATION OF TREATMENT
- The data will be kept by the Company for the period that is strictly necessary to guarantee the correct provision of services requested by the user, with the exception of any necessity to conserve data in compliance with applicable legislation. In all cases the user will be able to revoke his/her consent to treatment of data for the purpose of marketing. All commercial messages will contain a section enabling the user to easily revoke his/her consent.
8. USER’S RIGHTS
- As per the above mentioned italian law specifical for this legal field, The user has the right at any time to obtain confirmation or otherwise of treatment of his/her data, to know what information it contains, the origin and method of treatment, to verify its correctness, to ask for elements to be added, updated, corrected or cancelled, transformed into anonymous form, for data to be blocked where its treatment breaks the law and to oppose, for legitimate reasons, its treatment pursuant to art. 7 (“right of access to personal data and other rights”) of the Code of Personal Data Protection of which the full text reads as follows:
- “A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.
- A data subject shall have the right to be informed
a) of the source of the personal data;
b) of the purposes and methods of the processing;
c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;
d) of the identification data concerning data controller, data processors and the representative designated as per Section 5(2);
e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing..
- A data subject shall have the right to obtain
a) updating, rectification or, where interested therein, integration of the data;
b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
- A data subject shall have the right to object, in whole or in part,
a) on legitimate grounds, to the processing of personal data concerning him/ her, even though they are relevant to the purpose of the collection;
b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.”
2. In order for the data subject to exercise his/her User’s rights as allowed by the above mentioned italian law herein applicable, the User may send any request to the following addresses: via email to firstname.lastname@example.org; via fax to 0731-870927; vvia registered post with confirmation of receipt to A&G Calzaturicio SpA, Ufficio Servizio Clienti E-Shop, Via Merloni 20, 60030 Serra dei Conti (AN), Italy.
- Our website uses the so-called plugins relating to the social networks therein pointed out. Further details about the plug-ins relating to these social networks and about their characteristics can be found on their respective websites.
- To prevent transmission and memorisation of browsing data through social networks, the user must disconnect from such social networks before visiting our website.
- Navigation: in cases of simple browsing without registration and/or use of the e-shop, only so-called session cookies are used (that are not memorized permanently onto the user’s computer and disappear when the browser is closed). This is strictly limited to the transmission of session identification (consisting of random numbers generated by the server) necessary to enable safe and efficient exploration of the site. The session cookies used in this site avoid using other computer techniques that could prejudice the confidentiality of users’ browsing behavior and do not allow the acquisition of the user’s personal identification behavior.
- E-Shop: in cases of registration with and use of the e-shop, including the e-commerce service, certain types of persistent cookie are used, namely files that are memorized persistently in the user’s computer upon access. These help the Company to understand the user’s commercial preferences.
11. SOFT SPAMMING
- For the purposes of direct sales of its products or services the Company may use the email coordinates provided by the user when making an online purchase from the e-shop, even without previous consent, in compliance with art. 130, subsection IV of the Personal Data Protection Code, on the condition that the products are the same as those that were sold (so-called “soft spamming”). The user may in any case refuse this type of treatment at any time following the procedure shown in section 8 above.
12. UPDATING OF INFORMATION