Information provided pursuant to Art. 13 of EU Regulation 2016/679 (GDPR)

 

Identity and contact details of the Data Controller 

The Data Controller is Giordano Vini S.p.A. (hereinafter: “Giordano” or “the Data Controller”), with registered office at Viale Abruzzi 94, 20131 Milan - VAT No. and Tax Code 04642870960.

Categories of personal data

The personal data provided are collected when the data subject subscribes to the Giordano Vini commercial Newsletter, for which only the email address is collected.

Providing such personal data is optional. However, if you choose not to provide such personal data, you will not be able to access the Newsletter service.

In addition, where the user provides specific consent as indicated in the section below entitled “Consent to tracking pixels and withdrawal”, the Data Controller processes, through the use of tracking pixels embedded in email communications, the following data: unique, non-sequential pixel identifier, IP address of the device used to open the message, type of device and email client used, date and time the message was opened, and number of subsequent openings.

Purposes of processing, legal basis and retention periods

a) Sending the newsletter. The data are processed to activate and manage the periodic sending of commercial and promotional communications to the email address provided by the data subject. Legal basis: the data subject’s freely given, specific and informed consent, pursuant to Art. 6(1)(a) GDPR and Art. 130(1) of the Italian Privacy Code concerning unsolicited communications. Retention: until consent is withdrawn, which may be done at any time via the “unsubscribe” link at the bottom of each communication, without affecting the lawfulness of processing carried out before consent was withdrawn.

b) Measuring the opening of communications using tracking pixels. Where specific consent has been given, data collected through tracking pixels are processed to determine whether emails have been opened, analyse campaign performance (open rates, frequency), optimise content and sending frequency and, where applicable, infer the recipient’s interest in the communications received. Legal basis: the data subject’s specific and separate consent, pursuant to Art. 122(2-bis) of the Italian Privacy Code and Art. 6(1)(a) GDPR. Retention: until consent to tracking is withdrawn or the subscription is cancelled, as described in the following section.

Consent to tracking pixels and withdrawal

Consent to receive tracking pixels is collected, together with consent to receive the newsletter in a single expression of consent, at the time of subscription, through a specific unticked checkbox presented in a neutral manner, after appropriate information has been provided regarding the purposes of tracking. Combining the consents does not affect the data subject’s right to withdraw consent at any time, including on a granular basis.  

Full withdrawal: the data subject may unsubscribe from the newsletter at any time via the “unsubscribe” link at the bottom of each email, thereby stopping both the sending of communications and the related tracking.

• Partial withdrawal (tracking only): alternatively, the data subject may withdraw consent solely to the use of tracking pixels via the specific link at the bottom of each email or in the “manage your preferences” section, while continuing to receive promotional communications without such tracking pixels.

Withdrawal does not in any way affect access to the newsletter service. The choices expressed by the data subject are recorded by the Data Controller for the purpose of demonstrating consent, pursuant to Art. 7(1) GDPR.

Methods of processing

Personal data are processed by the Data Controller primarily by electronic means and are stored within its company management system. Appropriate security measures are implemented to prevent the loss or alteration of data – including accidental loss or alteration – unlawful or improper use and unauthorised access. 

Disclosure of data

Where appropriate and in accordance with applicable laws and requirements, we may disclose your personal data, in various ways and for various purposes, to the following categories of recipients:

• External service providers acting on our behalf (including external consultants, business partners and professional advisers, IT consultants and technical support staff who carry out checks and development activities on our IT systems);
• External providers of IT and data analysis services 

Place of processing and transfer of data to countries outside the EU

The processing, including storage, of personal data takes place on servers owned by the Data Controller and/or by third-party companies engaged and duly appointed as data processors, located within the European Union. However, personal data may be transferred to third countries, mainly for IT and data analysis services, using the contractual clauses referred to in the European Commission Decision of 5 February 2010 concerning the transfer of personal data to processors established in third countries, in compliance with the requirements of Art. 46 GDPR and, where applicable for the performance of contractual obligations to which the data subject is a party, in accordance with Art. 49(1)(b) GDPR.

Rights of data subjects pursuant to Arts. 15-22 GDPR 

By writing to the Data Controller at the postal address Giordano Vini S.p.A. Viale Abruzzi 94, 20131 Milan or at the email address [email protected], the data subject may exercise the rights of: access (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure and the right to be forgotten (Art. 17 GDPR), restriction of processing (Art. 18 GDPR), notification regarding rectification or erasure (Art. 19 GDPR), data portability (Art. 20 GDPR), withdrawal of consent, objection to processing (Art. 21 GDPR) on legitimate grounds or in relation to marketing and direct sales communications, including with regard to one or more contact methods (e.g. by post and/or email and/or telephone), as well as the right to object to profiling (Art. 22 GDPR) where connected with direct marketing. At any time, the data subject may request the complete and up-to-date list of data processors and third parties to whom personal data may be disclosed.

Complaint to the Supervisory Authority

The data subject has the right to lodge a complaint with the Supervisory Authority, which in Italy is the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali) – Piazza Venezia 11, 00187 Rome (RM) – www.garanteprivacy.it, by sending an email to [email protected], using the form available on the Authority’s website.

Data Protection Officer

The Data Protection Officer may be contacted at [email protected] for information regarding the processing of personal data.