Under the terms and for the purposes of decree Leg. D. no. 196/2003 - Data Protection Act, this Privacy Information describes the methods and aims of processing of data provided by users of the website corporate.moleskine.com (hereinafter, referred to as the "website").
Such Information is published under the terms of art. 13 of the Data Protection Act, and in consideration of Recommendation no. 2/2001 (relating to the minimum requirements for on-line data collection in the European Union, adopted on 17th May by the EC-Group for personal protection relating to personal data processing) and applies to all those who access the website.
Everything set out in this Privacy Information, unless otherwise stated, refers solely to the website. The Site Managers and the contents' Authors are not liable for the contents of third-party websites directly or indirectly connected through links from the website.
1. DATA CONTROLLER AND DATA PROCESSING MANAGER
The data controller is Moleskine SpA, with registered office at Viale Stelvio, 66, 20159 Milan (Italy).
The data processing responsible is NTT DATA, with registered office at 20143 Milano (Italy), Viale Cassala 14/a. The updated list of processing managers appointed by the company is available at Moleskine Spa's seat.
Data processing will be carried out by employees or staff of the company or the processing manager company, working in the sphere of their companies, as processing officers.
2. DATA PROCESSED AND PURPOSE OF THE PROCESSING
Simply visiting the website does not, in itself, lead to the collection or processing of users' personal data. In any event, please refer to sections 5 and 6 of this privacy information for details regarding the importance, for the purposes of privacy, of the browsing data and cookies.
The data that are collected and then processed are limited to the user's e-mail address.
Unless otherwise stated, providing the data requested from time to time is mandatory for the purpose of access to the reserved areas of the website or to other specific functions.
The personal data will be processed to identify users, allow them to become members of the community and, after express consent, transmitting descriptive, promotional and informative material of the Moleskine world and products.
At the time of registering, the user is prompted to read the Privacy Information made available under the terms of the Data Protection Act and to confirm his/her consent for processing of the data provided on that occasion, for the purposes described. This consent is mandatory in order to complete the user's registration with the website and the use of the services requested and, in contrast, is always optional with reference to sending promotional and/or information material relating to Moleskine activities and products.
4. DATA CIRCULATION
The personal data provided by the users will be processed by Moleskine SpA or by the parties it appoints and under its responsability, in Italy, Europe or countries outside Europe.
5. BROWSING DATA
The computer systems and software procedures used for operation of the websites acquire, during normal operation, some data whose transmission is implicit in the use of Internet communication protocols.
This is information that is not collected to be associated with identified data subjects, but that could, by its very nature, through processing and associations with data held by third parties, permit users to be identified.
This category of data includes IP addresses or domain names of the computers used by the users who connect to the website, Uniform Resource Identifier (URI) address of the resources requested, the time of the request, the method used to submit 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 (success, error, etc.) and other parameters relating to the user's operating system and computer environment.
These data are not circulated, but are used for the sole purposes of obtaining anonymous statistical information on the use of the websites and to control their correct operation, and are kept for the times defined by legal regulations on the subject. The data could, however, be used for checking liability in the event of cases of computer crimes involving website damage.
No personal data of the users are acquired for this purpose from the website.
The use of session cookies (which are not permanently stored on the user's computer and are cleared when the browser is closed) is strictly limited to transmission of session usernames (made up of random numbers generated by the server) necessary to allow secure and efficient searching on the website.
Session cookies used in the sites avoid recourse to use of other potentially harmful computer techniques for user browsing privacy and are aimed solely at helping users browse the website, permitting, in particular, frequent users' data to be stored for site access. Most commonly used browsers however feature an option to disable cookies.
7. PROCESSING METHOD
Data processing will be performed using appropriate tools and procedures to guarantee security and privacy in accordance with the law, and may be carried out both through hard copy supports or with the aid of digital media.
Specific security measures are observed to prevent the loss of data, illegal and incorrect usage and unauthorised access.
8. RIGHTS OF THE DATA SUBJECT
Users are entitled to obtain confirmation of the existence or otherwise of their data at any time and to be informed of their content and source, the processing purposes and methods, and - in the event of processing with electronic tools - the applied processing logic, checking the accuracy of their data or requesting corrections and updates (art. 7 of D.Lgs. n. 196/2003). Under the terms of the same article, users are entitled to request deletion, conversion to anonymous form or blocking of data processed in infringement of the law, as well as to oppose, for legitimate reasons, the processing of their data. Data will be processed in conformity with and be governed by Italian law (art. 7 of Leg. D. no. 196/2003)
Section 7: (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, regardless of their being already recorded, and communication of such data in intelligible form.
2. A 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 means;
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 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 therein, integration of the data;
b) erasure, anonymization or blocking of data that have been processed unlawfully, 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 whit 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.
Users' rights can be exercised by sending a written request to Moleskine SpA, Viale Stelvio 66 , 20159 Milan (Italy), or an e-mail to: firstname.lastname@example.org
Any translation of this document into languages other than Italian is provided for informational purposes only. In case of discrepancies, the only version legally valid and binding that governs your use of the Site is the Italian version of this document.
Milan, 13rd March 2013