Privacy & Cookie Policy

Effective date: October 19th 2020

This privacy policy describes how Molteni & C. S.p.A. (hereinafter “Molteni” or “we” or “our”) collects, uses, shares, and protects personal information. It also tells you about the rights and choices you have with respect to your personal information, and how you can reach us to get answers to your questions. This privacy policy is provided according to General Data Protection Regulation – in particular art. 13 GDPR – (hereinafter “GDPR”), as well as the relevant US privacy provisions (e.g. Federal “Telephone Consumer Protection Act” – TCPA; “California Consumer Privacy Act Notice” – CCPA) and the best practices (e.g. recommendations for businesses and policy makers “Protecting Consumer Privacy in an era of rapid change” released in 2012 by the Federal Trade Commission).


  1. DATA CONTROLLER 

Molteni & C. S.p.A. with registered address at Via Rossini 50 – Giussano (MB), Italy, duly represented by the Legal Representative. You can reach the Data Controller at the following contacts: T +39 0362 3591 – F +39 0362 354448 - email: privacy@molteni.it.


  1. CATEGORIES OF PERSONAL DATA PROCESSED

This privacy policy covers the “personal information” that Molteni obtains about you by browsing the present website and/or placing an order. When we use the term “personal information” we are referring to information that identifies, relates to, describes or can be associated with you. 


An identifiable natural person is one who “can directly or indirectly be identified, in particular by reference to an identifier such as a name, an identification number, a location data, an online identifier or to one or more specific factors to the physical, physiological, genetic, mental, economic, cultural or social identity” (article 4 par. 1.1 GDPR). 


The personal data that we collect for the purposes mentioned here below are specifically: 

  • browsing data;
  • data provided voluntarily by the user (when placing an online order): account name, name, surname, date of birth, shipping address, billing address, email address, telephone number, payment information (e.g. credit/debit card number).

Please note that the abovementioned list refers to personal information that we have collected directly from you within the last 12 months (according to CCPA). 


  1. HOW WE USE YOUR PERSONAL INFORMATION: PURPOSES OF PROCESSING, LEGAL BASIS FOR THE PROCESSING AND DATA RETENTION PERIOD

PURPOSES OF PROCESSING

LEGAL BASIS FOR THE PROCESSING

DATA RETENTION PERIOD

A) Navigation on this website, obtaining anonymous statistical information on the use of the website and services / control of website’s correct functioning.

Controller’s legitimate interest (art. 6, par. 1 letter f GDPR): ensuring the correct browsing and usage of the website

Duration of the browsing session

B) Fulfillment of contractual obligations.

Processing your orders for products and your payments for such products. We also use this information to provide you receipts and order updates.

Contract (art. 6, par. 1 letter b GDPR)

10 years starting from the placement of the order

C) Direct marketing activities: automated means (email – messages via social networks/sponsorship) and paper mails

  • dispatch of informational and promotional communications about our products to the email address provided.
  • dispatch of promotional or direct sale material; market researches; dispatch of commercial communications and newsletter, both by automated (email or messages sent via social networks or sponsorship) and traditional means (paper mails through our partners, appointed as Data Processor as per art. 28 GDPR).

Communications may contain third parties’ promotional activities and/or third parties’ logo (our partners belong to the following sectors: no profit; agriculture, forestry and fishing; manufacturing; suppliers of electricity, gas, steam and airconditioning; construction; wholesale and retail; repair of motor vehicle and warehousing; accomodation and food services; information and communication activities; financial and insurance activities; real estate activities; professional, scientific and technical activities; rental, travel agencies, support services to businesses; public administration; instruction; artistic, sports, entertainement activites; other service activies).

For the complete list of the abovementioned third parties, please contact Molteni at privacy@molteni.it. We will not share any personal data with third parties for this purpose of processing.

The Data Controller, in order to compare and eventually implement the results of communications, uses systems to send newsletters and promotional communications with reports. Through these reports, the Data Controller may eventually know, for instance: number of readers, openings, unique "clickers" and clicks; the devices and operating system used to read the communication; details concerning the activity of single users; details of emails sent, received and forwarded; All these Data are used in order to compare and eventually implement the results of communications.

You will be subject to the aforesaid direct marketing activities only with your prior consent.


User’s consent (art. 6, par 1 letter a GDPR – Recitals 42 and 43 GDPR).



Until consent withdrawal/opt-out (by contacting us as described in par. 7 of this Privacy Policy)

D) Direct marketing activities (traditional means)

we will submit promotional, direct sale material or commercial communicastions and/or conduct market researches: 

  • through phone calls of our operators and/or our partners, appointed as Data Processor as per art. 28 GDPR; 
  • via text messages like SMS.

Communications may contain third parties’ promotional activities and/or third parties’ logo (our partners belong to the following sectors: no profit; agriculture, forestry and fishing; manufacturing; suppliers of electricity, gas, steam and airconditioning; construction; wholesale and retail; repair of motor vehicle and warehousing; accomodation and food services; information and communication activities; financial and insurance activities; real estate activities; professional, scientific and technical activities; rental, travel agencies, support services to businesses; public administration; instruction; artistic, sports, entertainement activites; other service activies).

For the complete list of the abovementioned third parties, please contact Molteni at privacy@molteni.it. We will not share any personal data with third parties for this purpose of processing.



We will contact you by telephone or via SMS only with your prior consent.


User’s consent (art. 6, par 1 letter a GDPR – Recitals 42 and 43 GDPR; Federal “Telephone Consumer Protection Act” - TCPA).



 



Until consent withdrawal/opt-out (by contacting us as described in par. 7 of this Privacy Policy)

E) Profiling: your personal data will be stored in our CRM/platforms for internal analysis. We will also cluster personal data in homogeneous groups according to your consuming  histories and/or tendencies in order to ensure a better organization of Molteni’s services and for sending you tailored promotional communications.

We will proceed with profiling activities if you allow us to do so by giving your express consent.


User’s consent (art. 6, par 1 letter a GDPR – Recitals 42 and 43 GDPR).

Until consent withdrawal/opt-out (by contacting us as described in par. 7 of this Privacy Policy) and, in any case, no later than 12 months.

F) Communication/transfer of personal data to companies within Molteni Group (parent company, controlled companies, linked or affiliated companies), for direct marketing purposes. For more details on such transfers, please contact Molteni at privacy@molteni.it.



Personal data provided will be communicated/transferred only with your prior consent.


User’s consent (art. 6, par 1 letter a GDPR – Recitals 42 and 43 GDPR).

Until consent withdrawal/opt-out (by contacting us as described in par. 7 of this Privacy Policy)


  1. SHARING PERSONAL INFORMATIONS – CATEGORIES OF RECIPIENTS

We share your personal information as specified in par. 2 of this Privacy Policy with employees and/or staff acting under the Data Controller’s authority (duly instructed for the former purposes, also according to article 29 GDPR), as well as third parties contractually linked to Molteni, in order to fulfill contractual obligations and achieve one or more of the aforesaid purposes of processing. In particular, we disclose personal information to the following categories of recipients:

- companies within Molteni Group;

- subjects belonging to the distribution network of Molteni (such as: importers; dealers; shipping agencies etc.);

- subjects providing services concerning information system management and communication networks management (including e-mail, web platforms, cloud and software);

- web agencies and, generally speaking, companies that support the Data Controller in carrying out promotional activities;

- offices or companies in the context of assistance and consultancy relationships;

- relevant authorities in order to comply with legal obligations and/or provisions of public bodies, upon request.

Please 

With specific regard to GDPR, please note that the abovementioned recipients could act as Data Processor (appointed pursuant to art. 28 GDPR) or as separate Data Controller. The complete list of the recipients is regularly updated and available upon request at the contact details indicated paragraph 1. of this Privacy Policy.

In the preceding 12 months we have not sold any personal information.


  1. TRANSFERS OF PERSONAL DATA TO THIRD COUNTRIES 

Our website is hosted in the European Union. Personal data will be also transferred to extra EU countries (e.g. US in order to ensure a direct contact with our local distribution network). In that case, they will be processed according to article 44 et seq. GDPR (in particular, according to article 45 par. 9 GDPR) in order to carry out the purposes of processing, as described in paragraph 3. of this privacy policy. For more details on such transfers, please contact Molteni at privacy@molteni.it.


  1. PROVISION OF PERSONAL DATA

Except for what specified for browsing data – which are necessary in order to allow navigation of the website – and personal data voluntarily provided in order to place the order, users are free to provide their personal data. 

Namely, provision of personal data direct marketing activities – both via automated means and traditional means (purpose C and D of this Privacy Policy) – and/or profiling (purpose E) and/or transmission to third parties (purpose F) is optional and totally free. Hence, if you do not give your consent:

  • for direct marketing purpose via email, messages via social networks/sponsorship and paper mails (purpose C of this Privacy Policy), we will not be able to send you updates about the launch of our US e-commerce and contact you thorugh these channels;
  • for direct marketing purpose via phone call or SMS (purpose D of this Privacy Policy): we will not contact you through these channels;
  • for profiling activities (purpose E of this Privacy Policy): we will not send you tailored promotional communications;
  • for communications/transmission to third parties (purpose F of this Privacy Policy): we will not share your personal data.

Your eventual consent withdrawal (for purpose C and/or D and/or E and/or F of this Privacy Policy) will not affect the lawfulness of the processing based on the consent previously given.


  1. YOUR RIGHTS REGARDING PERSONAL DATA

  • GENERAL INFORMATION 
  • Molteni is committed to protecting your rights. In order to exercise them, as described here below, please contact us at privacy@molteni.it.

    You have the right, at any time, to obtain from Molteni the access to your personal data (article 15 GDPR), request their rectification (article 16 GDPR), their erasure (article 17 GDPR) or restriction of their processing (article 18 GDPR). Furthermore, you have the right to object anytime to your personal data processing (article 21 GDPR), as well as the right not to be subject to automated processing, including profiling, without your prior consent (article 22 GDPR) voluntarily provided. Finally, you have the right to data portability, if applicable (article 20 GDPR). Furthermore, you have the right to lodge a complaint with the relevant Supervisory Authority.

    You are also entitled to exercise some of the abovementioned rights (e.g. right of access, deletion, rectification, data portability) in accordance with the existing relevant US national law/provisions (mainly: according to your US country of residence).

    If you need any further information regarding your rights and how to exercise them, please contact us at privacy@molteni.it.


  • INFORMATION FOR CALIFORNIA RESIDENTS UNDER “California Consumer Privacy Act Notice” – CCPA
  • You have the right to request that we disclose to you (i) the categories of personal information we collected about you and the categories of sources from which we collected such information; (ii) the personal information we collected about you; (iii) the business or commercial purpose for collecting personal information about you; and (iv) the categories of personal information about you that we shared or disclosed and the categories of third parties with whom we shared or to whom we disclosed such information in the preceding 12 months. You also have the right to request that we delete personal information we collected from you subject to certain exceptions. You also have the right not to be discriminated in pricing and services because you exercise any of your rights under the CCPA. 


  • HOW TO WITHDRAW THE CONSENT PREVIOUSLY GIVEN
  • To stop receiving direct marketing (both automated and traditional means) you can write an e-mail at any time to the address privacy@molteni.it. with the subject "unsubscribe from direct marketing" or use our automatic unsubscribe systems (only for email) and you will no longer be disturbed.

    To stop receiving only direct marketing via email/ messages, via social networks/sponsorship or paper email (purpose C of the Privacy Policy) or only direct marketing through phone calls or SMS (purpose D of the Privacy Policy) please specify that request in your email.

    In order to oppose against profiling (purpose E of the Privacy Policy) and/or transmission to companies within Molteni Group (purpose F of the Privacy Policy), it will be sufficient to write an e-mail to privacy@molteni.it. at any time with the subject "no profiling" or “no sharing of my personal data”.


    1. COOKIES

    Cookies are small pieces of data (text files) that are placed on your computer or device by websites that you visit or applications you use. Cookies are widely used in order to make websites and applications work, or work more efficiently, and help them remember certain information about you, either for the duration of your visit (using a “session” cookie) or for repeat visits (using a “persistent” cookie). On this website we only use technical cookies, which are strictly necessary for the Service to function. They are only set in response to actions made by you which amount to a request for services, such as filling in forms. You can set your browser to block or alert you about these cookies, but without these cookies, some or all of the services you have asked for may not function properly.


    9.CHANGES TO THIS PRIVACY POLICY

    We may revise this privacy policy from time to time. We will notify you of changes by posting the effective date of the latest version at the top of this privacy policy.

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