This information is provided pursuant to art. 13 of Italian Legislative Decree no. 196/2003, called “Code on the protection of personal data” (hereinafter the "Code") to those who interact with web services accessible by electronic means originating from www.clubielle.com. This information is made only for such Website and cannot apply to other web sites that provide links to the Website.
From the Website, users can directly access the blog, the private area and the virtual store (e-commerce platform), where they will be able to make online purchases.
Specific summary information may be linked to or displayed on web pages dedicated to particular services (e.g. private area, use of the blog, newsletter, contact with customer service, etc.).
Navigation through the Website may involve processing of data belonging to persons identified or identifiable. The subject in charge of such data processing is Clubielle - Italian Fashion Design, with headquarters at via Podgora 14, 20122 Milano - Italy, which may, at its sole discretion, partially or entirely delegate such tasks to external technical agencies, which will be required to treat confidentially personal data of users. Clubielle - Italian Fashion Design undertakes to not use them for purposes other than those accepted by users through this policy. More information about processing of personal data may be found at [•]. Clubielle - Italian Fashion Design reserves the right not to respond to illegitimate requests or those that are not based on lawful grounds.
Some personal data, whose transmission is implicit in certain Internet communication protocols, is automatically captured by the software and ITC systems that enable the operation of the Website in the course of its normal activity and purposes. Such data is not collected to be associated with identified entities but, by their very nature, through processing and connections with other information held by third parties, allow users to be identified as such. For example, such data may include addresses provided by the ISP, domain names of computers used by users connecting to the Website, URI (Uniform Resource Identifier) of requested resources, time of request, methods used to submit requests to the server, file size obtained in response, numerical code indicating the status of response from the server (successful, error, etc.) and other parameters regarding the operating system and computing environments of the user. The use of this data is limited only to obtaining anonymous statistics on Wesbite usage and to checking its correct functioning and they deleted immediately after processing. The data could be used to ascertain responsibilities in case of computer crimes against the Website or other users of the blog or inside the private area. Except for such cases, data are not stored for more than six months.
So-called log files will be tracked for safety reasons, which require registration and maintenance of log files and their accessibility by police forces and the judiciary in the event that the latter requests it. Any control of log-ins will be carried out gradually and in full respect of the law, particularly of the principles of necessity and proportionality.
Users that send e-mails to the addresses indicated on the Website expressly agree that, for the sake of replying to such requests, such e-mail addresses and any other personal data present in the message are acquired by Clubielle - Italian Fashion Design. Except as specified above with reference to navigation data, users are free to provide personal data on return forms or on request information forms. Should such personal data not be provided, this may result in users’requests not being met for lack of essential information.
Data processing are carried out mainly through electronic and telematic systems by Clubielle - Italian Fashion Design and third parties, carefully selected for their reliability and skills, in order to carry out operations that are essential to achieve the purposes of the Website, its services and e-commerce.
In using data that may directly or indirectly identify each user, Clubielle - Italian Fashion Design undertakes to respect the principle of strict necessity. For this reason, Clubielle - Italian Fashion Design has set up the Website so that the use of personal data is kept to a minimum and therefore the processing of personal data is excluded when the purpose of the specific task can be achieved by the use of anonymous data (such as, for example, market research aimed at improving services) or through other means that make it possible to identify the person involved only if necessary or at the request of the authorities and police forces (such as, for example, for data traffic and permanence in the site or IP address).
Personal information will be disclosed to third parties only with the user’s express consent, except in cases where disclosure is required by law, or the law does not require a consent, or is instead required for purposes envisaged by the law, or for performing a specific lawful request by the user.
Personal data will not be transferred abroad to countries other than EU Member States that provide a sufficient level of privacy protection. Should it be necessary to provide users with the services or to execute a products purchase agreement with Clubielle - Italian Fashion Design, personal data shall be transferred to Countries that do not belong to the European Union or that in any case do not ensure an adequate level of protection only subject to specific contracts to protect users.
Clubielle - Italian Fashion Design reserves the right to delete accounts and all related data if illegitimate contents, or contents that are harmful to the image of Clubielle - Italian Fashion Design and / or its products or a third party, or otherwise offensive material that promote illegal activities or other content that is defamatory, pornographic, promoting violence or discrimination based on race, sex, religion and sexual orientation are discovered.
The specific purposes for which personal data are processed are summarised, from time to time, in art. 13 of the Code on the protection of personal data, which is provided to the user when the latter provides personal information.
In general, such data are processed to provide the following services available through the Website:
1. registration on the Website, in order to use its services;
2. subscription to additional specific services, such as the private area, newsletter, blog, the creation and content sharing of a “dream box”, invitations to the user’s contacts to join Clubielle - Italian Fashion Design, letting users known to other users by posting photos and comments;
3. performance of orders and related activities;
4. management of users’ requests: technical, commercial, orders’tracking and general requests;
5. contacting Clubielle - Italian Fashion Design’s services (Press Office, Business Development, Web Marketing, Purchasing, Customer Service).
In addition, should it be of interest to the user, personal data may be used for:
1) direct marketing initiatives (advertising materials, gifts, promotions, events and prize competitions), including communications sent via social networks, e-mail, messaging systems, VOIP, SMS, MMS or phone;
2) market surveys and analysis of purchasing habits (profiling of customers) in order, among other things, to better satisfy and learn about users’ tastes.
The provision of personal information to Clubielle - Italian Fashion Design is required on several occasions of collection that, from time to time, are necessary to achieve the specific purposes, which can be freely chosen by the user who wants to access the services offered by the Website.
Each time that data are requested, those marked with an asterisk (*) next to the information that required are deemed obligatory.
Refusal to communicate certain information marked as mandatory to Clubielle - Italian Fashion Design makes it impossible for Clubielle - Italian Fashion Design to achieve the main purpose of such specific data collection and, for example, it could make it impossible for Clubielle - Italian Fashion Design to execute products sale and purchase agreements with users, or to provide other services available on the Website.
The provision of additional information to Clubielle - Italian Fashion Design, other than those marked as mandatory, is optional and has no consequences in the achievement of the main purpose of such data collection.
For the execution of services requested by the user at the time of providing personal data to Clubielle - Italian Fashion Design, users expressly agree that Clubielle - Italian Fashion Design may also employ external companies that carry out activities strictly related and instrumental to the accomplishment and execution of agreements and services rendered such as archive management for customers; customer relations; transport companies and shipping agents, with regard to the delivery of goods and customs procedures; banks for the management of receipts and payments; government agencies other institutions for abiding by legal, financial and administrative obligations; companies and law firms for the protection of rights pertaining to contractual relationships; professionals for administrative and accounting requirements; postal services; third-party companies for market analysis, marketing and communication.
Data processing by the above-mentioned entities is therefore intended to implement the orders received by customers and / or digital archiving.
Personal data may also be communicated to all persons to whom the communication is due on account of legal obligations.
Users may ask through the Website or the Customer Service a list of parties who process personal data.
No data from the web service is disclosed.
User data will remain confidential and Clubielle - Italian Fashion Design will not keep it for longer than necessary to ensure the proper provision of services required - save the need for conservation for a longer period in compliance with regulations, including accounting, if applicable.
It is understood that the data will be stored and processed by Clubielle - Italian Fashion Design for the purposes of profiling for the maximum time allowed by law. At the end of that period Clubielle - Italian Fashion Design will ask users to renew their consent to personal data processing, or will render them anonymous and store them only for statistical or historical purposes.
Users will always enjoy the right to revoke their consent to their personal data processing for marketing purposes at any time: in each commercial communication there is a section that allows users to revoke their consent in an easy way.
Data transmitted to any service providers will be processed for the time strictly necessary for the performance of the tasks entrusted to them.
Users whose personal data are collected may at any time make use of their rights under art. 7 of the Code on the protection of personal data, including the right to obtain confirmation of the existence of personal data concerning them, to know the content and origin of the data, the purpose and methods of processing. Users also have the right to verify data accuracy, request the update, correction, integration, elimination of their data, render them anonymous, blocking those data that are against the law, including those which need not be kept for the purposes for which the data were collected or subsequently processed, and to oppose, for legitimate reasons, the processing of their personal data, for collection purposes and the processing of such data for advertising, direct sales, market research, promotions, commercial communications, and information communication purposes. Users can refuse at any the use of their personal data for direct marketing from Clubielle - Italian Fashion Design.
For all the above-mentioned purposes, uers can contact Clubielle - Italian Fashion Design by registered letter at via Podgora, 14 - 20122 Milan - Italy