This information is provided pursuant to Articles. 13 and 14 of the European Regulation 2016/679 (hereinafter, “Regulation”) to those who interact with the web services of the site https://www.mondovicino.it (hereinafter below, “Site”).
This information does not apply to other sites, pages or online services accessible via hyperlinks possibly published on the Site but referring to resources outside the domain https://www.mondovicino.it.
1. DATA CONTROLLER - DATA PROTECTION OFFICER (DPO) AND DATA PROCESSOR
– The Data Controller of personal data is TAVOLERA S.r.l., in the person of its p. t. legal representative, with headquarters in 12084 Mondovì (CN) – Piazza G. Jemina 47 – Tax code/VAT 02809110048, e-mail firstname.lastname@example.org.
– The Data Protection Officer (DPO), pursuant to art. 37 of the Regulation, can be contacted at the following e-mail address: email@example.com.
– The person responsible for the processing of personal data, as responsible for the commercial management and promotion as well as the management of relations with the interested parties of the Outlet, is Promos S.r.l. – Tax code/VAT: 03123920179 – via San Zeno, 173 – 25124 Brescia (BS), Phone: +39 030 2422862 – Fax: +39 030 2422870, E-mail: firstname.lastname@example.org.
2. THE PRINCIPLES OF PROCESSING
In processing users’ personal data, TAVOLERA will apply the principles of lawfulness, fairness, and transparency.
Personal data will be collected for specific, explicit, and legitimate purposes (purpose limitation); they will be adequate, relevant, and limited in relation to the purposes for which they are processed (data minimisation); will always be updated and accurate and kept for a period of time not exceeding what is necessary for the pursuit of the purposes of the owner (limitation of conservation). After that they will be deleted.
Finally, personal data will be processed by adopting all appropriate security measures to guarantee its integrity and non-accessibility by unauthorized third parties (integrity, confidentiality, and unavailability).
3. PROCESSED DATA
a) Data acquired during navigation:
The computer systems and software procedures used to operate the Site acquire, during their normal exercise, certain personal data whose transmission is implicit in the use of Internet communication protocols.
This information is not collected to be associated with identified users, but by its own nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users connecting to the Site, the URI (Uniform Resource Identifier) notation addresses of the resources requests, the time of the request, the method used to submit the request to the server, the size of the file obtained in response given by the server (successful, error, etc.), and other parameters related to the operating system and to the users’ IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning. The data could also be used to ascertain responsibility in case of hypothetical computer crimes to the detriment of the Site.
b) Data provided voluntarily by users
TAVOLERA also collects personal data provided voluntarily by users on the occasion of their interaction with the services of the Site or filling in data collection forms. Or, again, in case of request of the newsletter, of the participation in initiatives carried out on the Site, of information and sending communications.
In the event that users, during the use of services of the Site, provide personal data of third parties, they guarantee to have provided them with this information and to have acquired their consent to the communication of their personal data, if necessary.
d) Specific information
In the case of further collection of personal data, specific information will be provided to the interested parties (e.g., Loyalty Cards and Gift Cards).
4. PURPOSE AND LEGAL BASIS OF THE PROCESSING
The data collected will be processed for the following purposes:
a) Navigation on the website.
PURPOSE: to allow users to browse the Site.
LEGAL BASIS: need to execute specific requests from interested parties and to execute contracts of which the aforementioned are a party.
NATURE OF THE PROVISION: necessary if you want to browse the Site and use the related services.
b) Newsletters and other marketing activities
PURPOSE: to allow users to subscribe to the newsletter and other communications of the owner on promotions, offers, initiatives, etc. by e-mail, SMS, MMS or other messages, as well as through traditional methods (telephone calls via operator, paper mail).
LEGAL BASIS: the consent of users. Once their consent has been given, in order not to receive promotional communications, users may at any time revoke it or communicate their opposition. In order to oppose it is sufficient to use the “Unsubscribe” mode present in each e-mail that is sent or contact the owner.
NATURE OF THE PROVISION: consent to the processing of data for subscription to the newsletter and to receive other promotional communications of the Data Controller, although optional, is necessary in order to receive the same. In case of lack of consent, it will not be possible to receive newsletters and promotional offers and marketing, but it will still be possible to navigate all sections of the site.
c) LOYALTY CARD:
PURPOSE: to allow users to take advantage of the advantages and special initiatives reserved for holders of the Outlet Loyalty Cards, as well as to offer any further services requested by interested parties, including participation in prize competitions and, more generally, for all related contractual and administrative obligations. For the complete information on this treatment, please refer to the link https://www.mondovicino.it/wp-content/uploads/2020/07/Regolamento-Loyalty-Card-_Mondovicino-Outlet-Village-2.pdf.
LEGAL BASIS: execution of contracts of which the interested parties are a party and/or execution of pre-contractual measures adopted at their request (loyalty purposes) and the consent of the interested parties (marketing purposes and profiling).
NATURE OF THE PROVISION: the provision of data for the issue of Loyalty Cards is necessary if you want to get one. The user is then free to give or not to give consent for marketing and promotion purposes.
d) GIFT CARD:
PURPOSE: to allow users to obtain a card with prepaid credit, which can be spent at the points of sale of the Outlet. For the complete information on this treatment, please refer to the link https://mondovicino.mygiftcard.it/privacy/.
LEGAL BASIS: need to execute contracts to which the interested parties are parties.
NATURE OF THE PROVISION: the provision of data for the issue of Gift Cards, is necessary if you wish to get one.
e) Data collection through the “Work with us” form.
PURPOSE: The data provided by sending curricula, or by completing the specially prepared form on the Site, will be processed solely for the purposes of research and selection of personnel. The complete information will be made during any interview.
LEGAL BASIS: execution of pre-contractual measures adopted at the request of the interested party and consent in the case of communication of curricula to brands that have stores in the Outlet.
NATURE OF THE PROVISION: the provision of data is necessary if you intend to submit the application to the Companies or brands that have stores in the Outlet.
f) Data collection through the “Commercial Opportunities” form.
PURPOSE: The data that users provide by sending information, or by completing the form specially prepared on the Site, will be processed solely for the purpose of evaluating the promotion of the companies concerned.
LEGAL BASIS: execution of pre-contractual measures adopted at the request of users.
NATURE OF THE PROVISION: the provision of data of your company is necessary if you want TAVOLERA to take into account the request of users.
5. METHODS AND DURATION OF PROCESSING
6. RECIPIENTS OF PERSONAL DATA
Personal data may be disclosed to third parties who carry out activities necessary for the provision of the services offered on the Site, which will process the data as data processors or independent data controllers.
Precisely, the data will be processed by the following subjects or categories of subjects:
- companies related to the owner or business partners that provide IT services;
- service providers acting on behalf of the owner on the basis of contractual agreements, in order to carry out activities related to the administrative, commercial, and advertising management of the Outlet including the company Promos;
- companies and consultants, in the field of legal, accounting, and tax assistance and advice;
- subjects that provide services for the management of the information system and telecommunications networks, including e-mails;
- competent authorities for the fulfilment of legal obligations;
- participating outlet shops and refreshment points.
The data processed for the purpose of loyalty and sending newsletters and other commercial communications are not communicated to third parties, but may be processed by external companies such as data processors, pursuant to art. 28, Regulation.
Through the icons of the Social networks on the Site, some user data may be transmitted also to social networks. With respect to these treatments, which are carried out outside this Site, please refer to their specific Privacy Policies.
All the above subjects are obliged to use the information received only for the purposes of processing indicated above, to keep them confidential, intact, and not available to unauthorized third parties. User data are not widespread.
7. TRANSFER OF PERSONAL DATA
8. RIGHTS OF THE INTERESTED PARTIES
Articles 15 to 22, Regulation, confer on users, as interested parties, the exercise of specific rights. Art. 15 grants users the right to access their personal data and to obtain a copy thereof. The right to obtain a copy of the data must not adversely affect the rights and freedoms of others.
With the access request, users have the right to obtain confirmation from the holder whether or not it is in progress a processing of personal data and to know the purposes and categories of data processed, third parties to whom the data are communicated, and if the data are transferred to a non-European country with adequate guarantees. Users also have the right to know the storage time of their personal data, with respect to the purposes above.
With respect to their personal data, users have the right to request the correction of inaccurate data and the integration of incomplete data, cancellation (right to be forgotten) under the conditions indicated by Art. 17 of the Regulation, the limitation of processing and data portability.
Users then have the right to object at any time or to withdraw their consent to the processing carried out for marketing purposes.
To stop receiving marketing communications (e.g., e-mail, sms) it will be sufficient to write at any time an e-mail to the address email@example.com subject “Unsubscribe”, or to use the “Unsubscribe” cancellation systems present in the e-mails.
The owner will also provide users with certification that the operations that follow the above requests have been brought to the attention of those to whom the data may have been communicated, except in the event that such fulfilment proves impossible or involves a use of means manifestly disproportionate to the protected rights.
To exercise the above rights, it is necessary to contact the owner at the e-mail address firstname.lastname@example.org, or at the address of the registered office.
To provide a response, you may need to identify users by requesting a copy of their identity document. The owner will provide written feedback without undue delay and, in any case, no later than one month after receipt of the request.
9. COMPLAINT TO THE GUARANTOR AUTHORITY FOR THE PROTECTION OF PERSONAL DATA
Version 0.1 of July 2023