Brunello Cucinelli S.p.A.公司作为个人数据处理的控制人（以下简称 “Brunello Cucinelli” 或 “控制人”）依据法令196/2003（以下简称“法令”）以及欧盟法规679/2016（以下简称“法规”）- 把隐私和保护个人数据视为经营活动的主要目标之一。因此，请您在向控制人披露任何个人数据之前仔细阅读本隐私政策，因为后者内含有关保护您个人数据的重要说明。
适用于网站 www.brunellocucinelli.com， 以及同网站上的投资者专区（以下简称“本网站”）；
- 1. 处理控制人及数据保护专员
- 2. 获处理的个人数据
- a. 浏览数据；
- b. Cookie
- 3. 数据处理目的
- 4. 数据处理的法律依据及其强制或可选性质
- 5. 个人数据的接收者
- 6. 个人数据的转移
- 7. 个人数据的保存
- 8. 当事人的权利
- 9. 变更
- 10. 联系方式
数据控制人是Brunello Cucinelli S.p.A.公司，总部设在Corciano市（意大利佩鲁贾省）frazione Solomeo, Viale Parco dell’Industria n. 5，佩鲁贾地区公司注册号码和税务代码0188612054。Brunello Cucinelli S.p.A公司的个人数据保护负责人，可在上述地址数据控制人总部和通过电子邮件信箱: email@example.com联系到。
获处理的个人数据的组成，可包括识别信息如名字、身份识别号码、相关位置的数据、在线识别信息或同身体、生理、心理、经济、文化或社交等身份相关的一个或数个特征元素，这些信息根据使用的服务类型能使当事人被识别或可识别（以下简称 “个人数据” ）。 通过本网站处理的个人数据包括：
第3.1条的个人数据处理目的的法律依据是法规第6（1）（b）条 ([…] 数据处理是执行当事人所签署的合同，或是执行当事人要求的合同前措施的必要条件) ，因为数据处理是获得服务的必要条件。第3.2条的个人数据处理目的的法律依据，则是法规第6（1）（c）条，（ […] 数据处理是控制人履行所承担的法律义务的必要行为）。以此为目的的个人数据提交属于可选性，但不提交可能会影响所需服务的开展。第3.3条中的处理不涉及个人数据，因此控制人可自由执行。
5.3. 根据法令第30条和法规第29条规定，由控制人授权执行数据处理工作的人员，后者开展的活动同提供服务密切相关，并已承诺保密或受到适当的保密法律义务约束。 作为信息负责人可能会处理您个人和数据的主体的更新名单，可按照本隐私政策的 “联系方式”部分列出的地址，向控制人发送书面申请。
按照第3.1条所述目的处理的个人数据，将保留到达标所需的必要时间。但鉴于这些数据处理是以提供服务为目的，控制人将按照意大利法律规定和允许的时间限制保存个人数据，以维护自身利益（ “民法” 第2946条及相关条款）。 按照第3.2条所述目的处理的个人数据，将保留到具体义务或适用法律规定的时间。 若需有关数据保存期以及保存期确定标准的更多信息，可按照本隐私政策的 “联系方式”部分列出的地址，向控制人发送书面申请。 但在任何情况下，控制人都有权按照意大利法律规定和允许的时间保留您的个人数据，以维护其自身利益（民法第2947（1）（3）条）。
为了行使上述权利或提出任何其他请求，请写信给数据控制人邮寄到上述地址，或通过 专用联系方式发送，建议最好在邮件主题中输入 “申请行使隐私权” 。
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: 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.
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: email@example.com
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: firstname.lastname@example.org