Brunello Cucinelli S.p.a., as the owner of domain names including those at the address http://www.brunellocucinelli.com or in the Brunello Cucinelli S.p.a. (hereinafter, collectively the “Site”), uses the Site not only as a means to inform users about products belonging to Brunello Cucinelli S.p.a. but also as a tool for the collection of personal data.
Therefore, in accordance with the provisions established in the Personal Data Protection Code, Brunello Cucinelli S.p.a., as Data Controller (hereinafter the “Controller”), provides the following information concerning the processing of personal data both of users who only consult the Site (traffic data) and those who freely send their personal data via email and/or by filling in specific forms in order to access reserved sections within the Site or to receive the Controller's newsletter or of those who send their personal data in relation to specific requests addressed to Brunello Cucinelli S.p.A.
This information is provided solely for the Site and the activities carried out by Brunello Cucinelli S.p.a, also through its data processors, and does not apply to other websites which the user may be able to consult via links and/or activities offered by third parties.
1. Types of data processed
1.1 Traffic data
The computer systems and processing programs required to run the Site, during their normal operation, log certain data whose acquisition is automatic and inevitable (whenever Internet protocols are used) and which may, in combination with other information, enable users to be identified.
Such data will be used with the sole aim of obtaining statistical information regarding the use of the Site and to verify that it is operating correctly.
If expressly requested, such data may be used by the Public Authority to determine responsibility in the case of computer crime against the Site and/or third parties, in compliance with the relevant procedures of the appropriate Authorities.
1.2. Data provided voluntarily by individual users
Personal information provided voluntarily by individual users via email, user interaction with the Site's features, requests for services offered by the Site, completion of specific forms to access reserved sections of the Site.
The processing of these data will be mainly, but not exclusively, electronic within the law referred to the Legislative Decree no. 196/2003 (Privacy Act).
2. Processing methods and purposes
Data will be processed manually or with the aid of electronic tools for the following purposes:
- operations management of Site navigation and relevant access data;
- management of data and Site security;
- statistical processing within the limits and at the conditions set forth in paragraph 5;
- staff recruitment and selection within the CV section of the Site. The data so provided shall be solely used for selection purposes. Brunello Cucinelli S.p.a. does not collect through the Site data such as racial and ethnic origin, religious, philosophical or otherwise beliefs, political opinions, membership of parties, unions, associations or organizations of any nature such as, but not limited to, religious, philosophical, political or trade union membership and personal data relevant to identify health and sex life. According to the Privacy Act provisions, the collection of such data is subject to the user’s prior written consent. Therefore, please do not provide sensitive data, since it is not possible through the internet collect a written consent.
Furthermore, with the user's voluntary consent, the Controller may process information for the purpose of establishing individual or group profiles (user profiling) or for marketing purposes such as: notification, via newsletters, emails or text messages, of the Controller's products or of initiatives and events organized by Brunello Cucinelli S.p.a., or with which said subjects are involved, including invitations to aforementioned initiatives or events. The user has the possibility of opposing this last processing purpose at any time, and request to no longer receive promotional and commercial material or information.
3. Data storage
Personal data collected will be stored and processed via an electronic system managed by Brunello Cucinelli S.p.a.
4. Data communication
Data will be communicated to professionals, independent collaborators, service companies and/or third party companies that co-operate with the Controller for the pursuit of the aforementioned purposes.
With the user's explicit consent, data may be transferred outside of Italian territory to other companies that may be located in non-EU countries. In any event, whenever personal data is transferred to a country outside the EU, the principles set out in the Personal Data Protection Code will be applied together with any other law and regulation provisions applicable in this matter.
Subjects who receive the user's personal data may process it as Data Controller, Data Processor and/or Persons in Charge of Processing according to circumstance.
The complete updated list of the Data Processors is available upon request to Brunello Cucinelli S.p.a.
In no circumstance the data will be subject to diffusion.
5. Data submission
With the exception of traffic data (which is collected automatically by the system) the submission of data by the user is necessary to subscribe to the Site and to access the services and features offered by the Site and the reserved areas. The non-submission of data will prevent the user from accessing and using said services and features.
The submission of data for marketing purposes is always voluntary and optional. Any non-submission of data for such activities will have no consequence on the user's possibility to use the services and features offered by the Site.
6. Rights of the user
The user may exercise the rights laid down in Article 7 of the Personal Data Protection Code including, but not limited to, the right to obtain a copy of the processed data, their updating, modification, integration and, in certain cases, their cancellation or block. Requests for access to data pursuant to Article 7 of the Privacy Code may be sent to Brunello Cucinelli S.p.a., at 5, Via dell'Industria, Corciano, Solomeo (Perugia), or by email to: firstname.lastname@example.org. Specifically, the user may at any time revoke his previously given consent to the distribution of promotional and informational material, including the newsletter.
Art. 7 Legislative Decree No196, 30 June 2003 (Right to access personal data and other rights)
1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regard less of their being already recorded, and communication of such data in intelligible form.
2. 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 devices;
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.
3. A data subject shall have the right to obtain:
a) updating, rectification or, where interested there in, integration of the data;
b) erasure, anonymization or blocking of data that have been processed un law fully, 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.
4. 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.
7. Data Controller
The data controller is Brunello Cucinelli S.p.a., with legal seat at 5, Via dell'Industria, Corciano, Solomeo (Perugia). Any communication may be sent to the following email address: email@example.com