(Information notice on the processing of personal data in accordance with Art. 13 of Italian Legislative Decree 196/2003, and EU Regulation 679/2016)
is considered applicable to the website www.brunellocucinelli.com, and to the section thereof dedicated to Investors (hereinafter: “Website”);
constitutes an integral part of the Website and of the services we offer;
is issued in accordance with Art. 13 of the Code, as well as Art. 13 of the Regulation, for anyone interacting with the web services of the Website;
is not considered applicable to the section of the Website dedicated to “Human Resources” or to “Online boutique” websites, for which reference is made to the specific information notices contained therein.
The processing of your personal data shall be based on the principles of correctness, lawfulness, transparency, limitation of the aims and storage, minimization and exactness, integrity and confidentiality, and the principle of accountability in accordance with Art. 5 of the Regulation. Your personal data shall therefore be processed in accordance with the legislative provisions of the Regulation and the confidentiality obligations envisaged therein.
Processing of personal data means any operation or set of operations, performed with or without the aid of automated processes and applied to personal data or sets of personal data such as the collection, recording, organization, structuring, storage, adaptation or amendment, extraction, consultation, use, communication through transmission, disclosure or any other form of provision, comparison or interconnection, limitation, deletion or destruction.
- 1. DATA CONTROLLER AND PROCESSOR
- 2. PERSONAL DATA SUBJECT TO PROCESSING
- a. Navigation data
- b. Cookies
- 3. PROCESSING AIMS
- 4. LEGAL BASIS AND COMPULSORY OR VOLUNTARY NATURE OF PROCESSING
- 5. PERSONAL DATA RECIPIENTS
- 6. TRANSFERS OF PERSONAL DATA
- 7. STORAGE OF PERSONAL DATA
- 8. RIGHTS OF THE INTERESTED PARTY
- 9. MODIFICATIONS
- 10. CONTACTS
1. DATA CONTROLLER AND PROCESSOR
The Data Controller is Brunello Cucinelli S.p.A. having its registered office in Corciano (Perugia, Italy), frazione Solomeo, Viale Parco dell’Industria n. 5, tax code and registration number with the Perugia Companies Register 0188612054.
2. PERSONAL DATA SUBJECT TO PROCESSING
We would like to inform you that the personal data subject to processing may comprise an identification label such as the name, identification number, data related to the location, an online ID or one or more characteristic elements of your physical, physiological, psychological, economic, cultural or social identity suitable to make the interested party identified or identifiable, according to the type of services requested (hereinafter “personal data”). The personal data processed through the Website are as follows:
a. Navigation data
During their normal process, the IT systems and software procedures in place for the operation of the Website acquire some personal data whose transmission is implicit in the use of internet communication protocols. This refers to information that is not collected to be associated with identified interested parties, but that by its very nature could, through processing and association with data held by third parties, allow the users to be identified. IP addresses or domain names of the computers used by the users who connect to the Website, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used for making the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters related to the operating system and the IT environment of the user all fit into this category of data. These data used for the sole purpose of gaining anonymous statistical information on the use of the Website to control the correct operation thereof, to identify any anomalies and/or abuse, are deleted straight after being processed. The data could be used for ascertaining responsibility in the event of any IT crimes that may damage the Website or third parties.
The information on the cookies served by the Website is available here.
3. PROCESSING AIMS
Your personal data shall be processed for the following aims:
3.1. To allow navigation of the Website and the provision of the services made available there by the Controller, including the management of the Website security;
3.2. To fulfil any obligations envisaged by laws in force, regulations or EU legislation or to comply with any requests from authorities;
3.3. To process statistics, without it being possible to trace your identity.
Specific security measures are observed in order to prevent the loss of data, illicit use or incorrect use and unauthorized access.
4. LEGAL BASIS AND COMPULSORY OR VOLUNTARY NATURE OF PROCESSING
The legal basis for the processing of personal data for the aims according to section 3.1 is Art. 6(1)(b) of the Regulation ([…]processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract), since the processing is necessary for the provision of services. The legal basis for the processing of personal data for the aims according to section 3.2 is instead, Art. 6(1)(c) of the Regulation ([…]processing is necessary for compliance with a legal obligation to which the controller is subject). The provision of personal data for these purposes is optional, but any failure to provide data could imply the impossibility to activate the required services. It is instead specified that the processing according to section 3.3 is not performed on personal data and therefore can be freely performed by the Controller.
5. PERSONAL DATA RECIPIENTS
5.1. Subjects who typically act as processors in accordance with Articles 29 of the Code and 28 of the Regulation, i.e., subjects that cooperate with the Data Controller for pursuing the above aims, including subjects appointed to perform technical maintenance activities (collectively “Recipients”);
5.2. Subjects, bodies or authorities to whom it is compulsory to communicate your personal data on the basis of legal provisions or orders of the authorities;
5.3. Persons authorized by the Data Controller, in accordance with Articles 30 of the Code and 29 of the Regulation, to process the personal data necessary for performing activities strictly connected with the provision of services, who have committed to confidentiality or who have a suitable legal confidentiality obligation. The updated list of subjects who could process your personal data as processors is available by sending a written request to the Data Controller to the addresses indicated in the “Contacts” section of this information notice.
6. TRANSFERS OF PERSONAL DATA
Some of your personal data may be shared with Recipients who are located outside the European Economic Area. The Data Controller guarantees that the processing of your personal data by these Recipients takes place in compliance with Articles 43 and 44 of the Code, and with Articles 44 - 49 of the Regulation. More information is available by sending a written request to the Data Controller to the addresses indicated in the “Contacts” section of this information notice.
7. STORAGE OF PERSONAL DATA
The personal data processed for the aims according to section 3.1 shall be stored for the amount of time strictly necessary to achieve such purposes. However, since the processing is performed in order to provide services, the Data Controller shall store the personal data for the amount of time envisaged and permitted by Italian legislation for the protection of its interests (Art. 2946 of the Civil Code et seq.). The personal data processed for the aims according to section 3.2 shall be stored for the amount of time envisaged by the specific obligation or applicable legal standard. More information related to the data storage period and the criteria used to determine such period can be requested by sending a written request to the Data Controller to the addresses indicated in the “Contacts” section of this information notice. This is notwithstanding the possibility for the Data Controller to store your personal data for the period of time envisaged and permitted by Italian law to protect his interests (Art. 2947(1)(3) of the Civil Code).
8. RIGHTS OF THE INTERESTED PARTY
In accordance with Art. 7 of the Code, you have the right at any time to obtain confirmation of the existence or not of your personal data and to find out the contents and origin thereof, verify the accuracy or request the addition, updating or correction thereof; you have the right to request the deletion, transformation into anonymous format or blocking of data processed against the law, or to oppose in any case, for legitimate reasons, the processing thereof. Starting from 25 May 2018 you also have the right to request access to your data, to oppose processing and to request the limitation of processing in the cases envisaged by Art. 18 of the Regulation, where technically possible, and to obtain in a structured format, of common use and legible by an automatic device, the data regarding you, in the cases envisaged by Art. 20 of the Regulation. Requests are to be sent in writing to the Data Controller to the addresses indicated in the “Contacts” section of this information notice. You always have the right to lodge a complaint with the competent control authority (Data Protection Authority) in accordance with Art. 77 of the Regulation, should you consider that the processing of your data infringes legislation in force.
To exercise the above rights or for any other request, you can write to the Data Controller at the postal address indicated above, or through the dedicated contact (link to relevant form for sending the communication to the address firstname.lastname@example.org pre-compiled with the subject: “Request to exercise privacy rights”), preferably entering in the subject of the communication “request to exercise privacy rights”.
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. Automatic data collection tools
The Site uses session cookies and permanent cookies. Session cookies are temporary and are eliminated automatically after every visit to the Site. “Permanent” cookies remain on the user's hard disk until they are removed. Cookies are used to enable full use of the Site and to track visits to the various pages/sections of the Site. Cookies are not and will not be used to obtain personal data or information relating to the user's navigation of other sites. The information collected through cookies will be used purely for statistical purposes. The user can disable cookies at any time by selecting the appropriate setting in the web browser, though this may hamper some functions of, or the possibility to interact with, the Site. The Site uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses such cookies in order to help us analyze anonymously how visitors use the Site. The information generated by the cookies about your use of the Site (including your IP address) will be transmitted to and stored by Google on its servers, becoming accessible to webmasters through Google Analytics services. Webmasters will use the Google Analytics services only for the purpose of monitoring the traffic on the Site, tracking your activities, with the exclusion of your personal information and your identification data; such procedure does not affect any potential advertising and promotional content shown during your browsing activities.
Google guarantees that your IP address will by no means be associated with other data of Google Inc., nor with the identity of the users of the devices which are used to browse the internet. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.
By using this website, you grant your consent to the processing of your data collected by Google in the aforementioned manner and for the aforementioned purpose. For further information, please take a look at Google’s terms of service: http://www.google.com/analytics/terms/us.html and Google’s Data Protection Policy: http://www.google.com/intl/en/policies/privacy/.
6. 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.
7. 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 Viale Parco dell’Industria, Corciano, Solomeo (Perugia), or by email to: email@example.com. 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.
8. Data Controller
The data controller is Brunello Cucinelli S.p.a., with legal seat at Viale Parco dell’Industria, Corciano, Solomeo (Perugia). Any communication may be sent to the following email address: firstname.lastname@example.org
Brunello Cucinelli S.p.A.
VAT Number IT-01886120540
Registered Office at Viale Parco dell’Industria, Corciano - Solomeo (PG)
Capital Stock of Euro 13,600,000 fully paid in
Registered in Perugia Trade and Companies Register No. 01886120540
The contents of www.brunellocucinelli.com site as well as the Network Brunello Cucinelli (collectively, the “site”) are the exclusive property of Brunello Cucinelli S.p.a. and therefore protected and covered by national and international legislation. Consequently, users are not authorized to use these contents for purposes not specifically indicated by the site. In the event of violation, Brunello Cucinelli S.p.a. may reserve the right to take action against the violator. Brunello Cucinelli S.p.a. reserves the right to modify at any time the contents of its site, without prior warning.
There is no charge for browsing the www.brunellocucinelli.com site, access to the site is free and registration is discretionary. Information and data in the www.brunellocucinelli.com site are carefully verified. We apologize in advance for any inaccuracies and we would ask users to contact us at the address below, so we can make rectifications. By registering, the user agrees and concurs, moreover, that Brunello Cucinelli S.p.a. is in no way responsible, directly or indirectly, for any damages of any nature or type suffered by the user or by third parties during browsing and consultation of the Brunello Cucinelli site, and in relation to any ensuing initiatives in which the user may decide to participate. We remind all users that they are liable for the truth and completeness of information they transmit to the www.brunellocucinelli.com site. This information will be given independently by users when they register and are sent strictly personal email account and password. Equally, at the time of issue, the user has explicitly authorized addressees of this information to handle these data, in compliance with current legislation. Moreover, when registering, Brunello Cucinelli S.p.a. informs the user, who is therefore aware of this, that the company cannot be held liable for any other sites the user may access using links included in the site. Consequently, Brunello Cucinelli S.p.a. declines any responsibility for the contents of these sites and is in no way liable for any damages of any nature or type suffered by the user or by third parties deriving from their use or from what they offer. The user may unsubscribe at any time by following the instructions given in the site.
For further information please contact Brunello Cucinelli S.p.a. at: email@example.com