Updated information note according to Regulation (EU) 2016/679
(known as “GDPR”)
Giordano Vini spa (hereinafter, also: “Giordano” o “the Controller”) cares for the users’ privacy and their rights and, since Internet may put at risk confidentiality of information, it intends to undertake to respect rules of conduct while collecting and processing data, in compliance with Regulation (EU) 2016/679 of the European parliament and of the Council of 27April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing directive 95/46/EC (so-called “GDPR”), which ensure a safe, controlled and confidential navigation in the network.
This policy may change with passing of the time, also as a result of amendments and integrations at a legislative level or as a consequence of our institutional purposes and decisions. So, we invite you to periodically read this section, from time to time. Thank you for reading the rules which our company undertakes to apply during the collection and the processing of data, so that it can always give its users a satisfactory service, when they access this website or other websites which belong to Giordano.
Personal data are usually provided by the data subject. However, there may be services where personal data have not been obtained from the data subject. For example, when the customer places an order for another person (“beneficiary”). In such case, personal data are not provided by the beneficiary but by an active customer, who is a third party.
Purposes of data processing and means of processing – legal basis for the processing – criteria used to collect data
Purposes of processing
As best explained in the sections in which you can provide – directly or indirectly also filling forms displayed – your personal data, such data are used to reply to the users’ requests. All collection activities – and subsequent processing – of data are aimed at pursuing the institutional and business purposes of Giordano and, in particular:
Means of data processing
Legal basis for the processing
The legal basis for the processing depends on the purposes of data processing. Here are listed the different legal basis applied for the purposes pursued by Giordano.
Criteria used to collect data
Data required in forms to be filled in may be mandatory or optional. Mandatory data are strictly necessary to perform the data subject’s request and if they are not provided, we will not be able to fulfil the request. Therefore, the user is free to provide data requested in the forms or, anyway, data requested to contact Giordano in order to ask for information or for the purposes mentioned above. If data are mandatory and the user does not provide them, this can imply the impossibility of obtaining what requested. The Controller has implemented appropriate organisational and technical measures for ensuring that only personal data which are necessary for each specific purpose are processed, in compliance with art. 25, GDPR (“Data Protection by design and by default”) which provides that before processing, the controller must implement appropriate technical and organisational measures, such as “pseudonymisation” (art. 4, comma 5, GDPR: “the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person”), which are designed to implement data protection principles, such as data minimisation, in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of GDPR and protect the rights of data subjects. Besides, Giordano has implemented organisational and technical adequate and preventative measures so that only data necessary for each purpose of processing are processed (principle of “data protection by default”).
Criteria used to determine the period for which data will be stored
Personal data will be stored in our filing system (art. 4, comma 6, GDPR: “any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis”) with criteria depending on the category of data, the nature of processing and the purposes of data processing. The criteria or the period of storage are described in information to be provided pursuant to art. 13, GDPR, when data are collected.
Generally, these are the criteria determined by Giordano for data storage:
After the periods stated above, identification data are transformed in anonymous data and used only for statistical reports and analysis which do not allow to trace the identity of the person, but which are useful to improve and adjust our services and products to the needs of our target market. Identification data will be, therefore, destroyed, unless otherwise provided by supervisory authorities, law enforcement or judiciary as well as to exercise, enforce or defend rights of Giordano or of third parties in court.
Where data are processed
Processing carried out for the purposes of the performance of services provided by this website takes place at Giordano’s headquarter and are performed by the persons authorised to processing. If need be, personal data can be processed by companies which are in charge of the technological management of the website (data processors designated pursuant to art. 28, GDPR), at their offices.
Transfers of personal data to third Countries or international organisations
Even though data processing is usually carried out using the Controller’s server and/or third companies entrusted and appointed as data processors, within European Union, if need be, Giordano will have the right to transfer personal data to third Countries. In this case, the Controller assures that the transfer will take place in accordance with provisions in force, on the basis of an agreement or contract which ensures an adequate level of protection and/or by adopting the contractual clauses provided by the Decision 5th February 2010 of the European Commission (articles 45, 46, 47 and 49, GDPR).
Personal data will be transferred to third Countries, mainly to perform customer services activities and telemarketing campaign, adopting the contractual clauses set forth in the Decision 5th February 2010 of the European Commission for the transfer of personal data to data processors, pursuant to article 46; GDPR and for the performance of a contract to which the data subject is party, in compliance with art. 49, par. 1, letter b), GDPR.
Giordano Vini spa, with registered office in via Cane Guido 47 bis/50, 12055 Diano d’Alba (CN - Italy) - P. IVA e C.F. (VAT) IT04642870960, (art. 4, par. 7, GDPR: “the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data”), pursuant to GDPR, because it decides in which way and for what purposes, communicated in information to be provided to data subjects, it collects and processes personal data, as well as what means and security measures it implements to ensure the integrity, the confidentiality and the availability of personal data, taking on liability and complying with the provisions laid down in art. 24, GDPR.
Data Protection Officer
The Data Protection Officer is the natural person whom Giordano involves, properly and in a timely manner, in all issues which relate to the protection of personal data and supports Giordano to control how to process and protect personal data. Data subjects may contact our Data Protection Officer with regard to all issues related to processing of their personal data and to the exercise of their rights, sending an e-mail to firstname.lastname@example.org.
Data processor and persons authorised to process personal data
Your personal data can be processed, with manual, electronic and telematic means, directly by Giordano or by entities which can appropriately ensure, on account of their experience, capabilities and reliability, thorough compliance with the provisions in force applying to processing as also related to security matters. These entities are selected and controlled by Giordano which has appointed them as “data processor” (art. 4, comma 8, GDPR: “a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller”) and they carry out data processing on Giordano’s behalf. Processing by these entities is governed by a contract which is binding on the processor with regard to the Controller and which sets out the subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects and the obligations and rights of the controller. The processor can, if it is authorised in writing by Giordano, engage other processors, which are contractually bound by the processor appointed by Giordano: the processor appointed by Giordano is liable for any violation committed by the other processors and Giordano has no liability in such cases.
The complete and updated list of data processors (and, where appropriate, the other processors appointed by the initial processor, subject to our authorisation) can be asked to email@example.com (or by writing to Giordano Vini SpA – Via G. Cane 47bis/50 - 12055 Diano d’Alba (CN)).
Personal data can be also processed by the staff from our company acting on specific instructions concerning purposes and arrangements of such processing, in compliance with art. 29, GDPR. The categories of persons authorised to data processing are listed in information to be provided pursuant to art. 13, GDPR. They are usually persons in charge of the performance of our services, of customer care, of administration, of direct marketing and distance selling activities and promotional campaigns, and of information technology and security measures.
Communication and dissemination of personal data
Users’ data can be communicated to third parties for different purposes. In the following, a list of cases which imply data communication.
Other parties which cooperate with Giordano
For the purposes of increasing its business and selling activities, advertising its trademarks, products and services, as well as of better providing its services for users and persons who have contacts with Giordano, Giordano can engage other companies to process and combine and interconnect information kept in its filing systems.
These transmissions are anonymous or imply ““pseudonymisation”(art. 4, comma 5, GDPR: “processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person”). in such cases, anonymous data will be processed, by way of example and not exhaustive by:
Data subjects’ rights
You have the right to control your personal data processing. You can exercise the right of access, to rectification, the right “to be forgotten” (erasure), to restriction of processing, to data portability and to object to the processing of your data on legitimate grounds and for marketing purposes and profiling.
Thanks to the exercise of these rights, you will be able to control the use of your personal data also after you have provided them.
You can exercise these rights, at any time, by sending an e-mail to firstname.lastname@example.org (or by writing to Giordano Vini SpA – Via G. Cane 47bis/50 - 12055 Diano d’Alba (CN – Italy)), In the following, the list of your rights:
Right of access (art. 15, GDPR)
The person has the right to obtain from the controller confirmation as to whether or not personal data are being processed and have information on:
Right to rectification (art. 16, GDPR)
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure (“right to be forgotten”) (art. 17, GDPR)
The person shall have the right to obtain from the controller the erasure of personal data without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
Right to restriction of the processing (art. 18, GDPR)
The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
Notification obligation regarding rectification or erasure of personal data or restriction of processing (art. 19, GDPR)
The person has the right that the controller communicates to third parties the rectification or the erasure of data or the restriction of processing if personal data have been communicated to such third parties. Giordano could not fulfil this request if this proves impossible or involves disproportionate effort.
Right to data portability (art. 20, GDPR)
The data subject shall have the right to receive the personal data have been provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
The data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
Right to object (art. 21, GDPR)
The data subject shall have the right to object, at any time, to processing of personal data which is based on for the purposes of the legitimate interests, including profiling, pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
Automated individual decision-making, including profiling (art. 22, GDPR)
The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects the person. This right cannot be exercised where the decision:
The person has the right to express a point of view and to contest Giordano’s decision.
How to lodge a complaint with a supervisory authority
The person has the right to lodge a complaint with a supervisory authority to exercise and defend rights of protection.
In Italy the supervisory authority is the “Garante per la Protezione dei Dati Personali” – Piazza Venezia 11, 00187 Roma (Rome – RM – Italy) – www.garanteprivacy.it, and you can send your complaint at the e-mail email@example.com, using the format which can be found at https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524&zx=e0yn0riezmmw.
What cookies are and how they are used by Giordano
Cookies are small text files transferred and stored by your browser on your computer or mobile device when you visit or interact with a website. They are sent from your device to a web server and relate to your use of the network. Consequently, they allow to know the services, the browsed sites and the options selected by the user. This information is not provided, therefore, spontaneously and directly, but they trace the data collected. Data collected through cookies will be used for technical needs, in order to ensure a smoother, immediate and quick access to the website and its services and facilitate browsing to the user. Cookies can be used, with the user’s explicit consent, to create user’s profiles according to the sections of the website or to the action carried out by the user on this website or browsing the Internet.
Session cookies (which are not permanently stored on your device and are erased by closing the browser) are only used to transmit session identification information (random numbers generated by the server), which is necessary to ensure a safe and effective browsing of the website. Session cookies used by this website avoid using other techniques which are likely to be detrimental to the confidentiality of users’ browsing and do not allow the collection of personal data identifying the user.
Conversely, profiling cookies allow knowing user’s browsing on the network and detecting interests, preferences, needs expressed and allow creating marketing campaigns or creating profiles to better customise promotional, institutional and commercial advertisements. You can always set your browser so that you are informed when a cookie is being received and decide whether to accept it or not.
The information systems and software procedures relied upon to operate this website acquire personal data as part of their standard functioning; the transmission of such data is an inherent feature of Internet communication protocols.
Such information is not collected in order to relate it to identified data subjects, however it might allow user identification after being processed and matched with data held by third parties.
This data category includes IP addresses and / or the domain names of the computers used by any user connecting with this website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the user's operating system and computer environment.
These data are only used to extract anonymous statistical information on website use as well as to check its functioning; they are erased immediately after being processed. The data might be used to establish liability in case computer crimes are committed against the website.
Security of your personal data
Giordano implements appropriate and preventative security measures to protect confidentiality, integrity, completeness and availability of your personal data.
In compliance with the provisions governing data security, Giordano uses technical, organisational and logistics techniques which are aimed at the minimisation of the risk of damage, loss, whether accidental or not, alteration, unproper or unauthorised use of your personal data.
In particular, Giordano has implemented organisational and technical measures aimed at ensuring a level of security adequate and appropriate to the risk which may affect individuals’ rights and freedom, including confidentiality of personal data. Giordano has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:
Such preventative measures are implemented by processors selected by Giordano to carry out data processing on its behalf.
On the other hand, Giordano is not to be held liable for untruthful information sent directly by the user (e.g.: correctness of e-mail address or postal address or other identification data), as well as for other information on the user sent by third parties, even with fraud.
Credit card and financial information needed for purchases
In case of purchase paid with credit card, Giordano ensures the utmost confidentiality and security. Information on credit card (number, expiration date, data identification’s owner) can be known only by the issuing institution. Giordano has knowledge of a code (“token”) which does not allow to know the credit card holder’s identity and the credit card details. Payment by credit card is secure thanks to a transaction system developed by Easy Nolo S.p.A. (Banca Sella Group), having registered office in Piazza Gaudenzio Sella 1, 13900 Biella – Italy, VAT IT02027040027. Credit card information collection is carried out through SSL protocol (Secure Sockets Layer), the most widespread security protocol, which has the main aim of ensuring confidentiality and reliability of communication between the user’s device and the bank’s server, encrypting data at 128 bits. Using this system, the user communicates data on the credit card only to the secure serve of Easy Nolo S.p.A.
Finally, Giordano cannot be held responsible for unauthorised uses and fraud by third parties carried out on information relating to means used for the payment of the purchase.