PRIVACY POLICY

Updated information note according to Regulation (EU) 2016/679

(known as “GDPR”)

Preamble

 

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.

 

Principles of Giordano’s privacy policy

 

  1. carry out the processing (art. 4, comma 2, GDPR: “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction”) of personal data (art. 4, comma 1, GDPR: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”) only for the purposes and the means explained in information to be provided to the user when accessing a section of our website where you can, directly or indirectly, provide your personal data;
  2. use data which have been spontaneously provided by the user;
  3. use technical cookies to facilitate the navigation in the website and analytics cookies for statistical purposes; 
  4. use profiling cookies to customise its promotional business and sales activities on services and products;
  5. transmit data to third parties (data processors – 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”) only for connected purposes to what expressly requested by the user and which we have accurately previously select and which we have bound through an agreement or contract;
  6. communicate data to third parties for activities connected to the services asked by the user or whenever required by law, regulation or EU legislation;
  7. only if the data subject has not objected, communicate personal data the third parties for their autonomous processing having the purpose of direct mailing; 
  8. if the data subject has given explicit consent, communicate personal data to third parties for their autonomous processing having the purpose of e-mail marketing, telemarketing, Sms marketing and other means of electronic commercial communication;
  9. reply to the requests of access to data, rectification, right to be forgotten, restriction of processing, data portability or inform about the right to object to data processing. Ensure the data subject the right to object to data processing carried out for marketing purposes, surveys and market research, as well as to object to profiling to the extent that it is related to such direct marketing and inform about the right to lodge a complaint with the supervisory authority;
  10. ensure a correct and lawful processing of your personal data, safeguarding your confidentiality, as well as apply appropriate security measures to protect confidentiality, integrity and availability of such data.

 

 

Data source

 

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:

  1. e-commerce activity, with payment means according to customer’s choices;
  2. registration to our information service on news, products and services, provided, also but not exclusively, through our newsletter;
  3. registration to the website and access to one’s own profile;
  4. requests of information on services, products and activities of Giordano;
  5. direct the user to our social media (e.g.: Facebook);
  6. comply with laws, regulation and EU legislation;
  7. contact you for direct marketing purposes on our services and products, for distance selling, surveys and market research;
  8. profiling activities carried out to analyse your personal preferences, interests, purchasing behaviour, and contact you for marketing purposes. Profiling is carried out analysing data stored in our archives and/or provided to us by third parties. 
  9. communicate data to third parties operating in direct marketing and distance selling for their autonomous processing carried out for direct marketing purposes through direct mailing;
  10. communicate personal data to third parties for their autonomous processing having the purpose of e-mail marketing, telemarketing, Sms marketing and other means of electronic commercial communication.

 

Means of data processing

  1. Personal data are processed by the Controller with manual, electronic and telematic means and stored in its filing system. Appropriate security measures are applied to prevent data from loss or alteration – even if accidental – unlawful or improper uses or unauthorised access. 
  2. All processing will be carried out with criteria which take into account the purposes for which data have been collected and in accordance with the security measures in force, for the purposes explained in information provided pursuant to article 13, GDPR. 
  3. Profiling to the extent which it is related to direct marketing referred to in point 8, “Purposes of data processing”) will be carried out with automatic means by Giordano, analysing preferences and/or customer’s purchasing behaviour (e.g.: product purchased, purchasing frequency, amount spent, campaign related to the offer, type of request of information, frequency of the services used, type of service used, sweepstakes and contests). So, Giordano will carry out processing which implies the selection of data stored on the data subject, so as to contact the person to inform on offers and promotional campaigns, surveys and market research which are of interest and in line with preferences, avoiding nuisance advertising.
  4. For the execution of direct marketing activities – with or without profiling – referred to in points 7. and 8., “Purposes of processing”, the Controller uses the contacts details that have been provided by the data subject and the means of contacts which are usually preferred by the data subject. Therefore, the contacts may be carried out through traditional (e.g.: mailing, vocal calls) and electronic communication means (e.g.: e-mail, Sms).

 

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.  

  1. For the purposes referred to in points from 1. to 5., “Purposes of processing”, the legal basis is art. 6, par. 1, letter b), GDPR, since processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. In the present case, to allow the user to adhere to the services listed above and, therefore, to fulfil the data subject’s request or of data subject’s interest.
  2. For the purposes referred to in point 6., “Purposes of processing”, the legal basis is article 6, par. 1, letter c), GDPR, since the processing is necessary for compliance with a legal obligation to which the Controller is subject.
  3. For the purpose referred to in point 7., “Purpose of processing”, the legal basis is the “legitimate interest” (art. 6, par. 1, letter f), GDPR, preamble 47, GDPR and Opinion 6/2014 of Working Party 29, par. III.3.1.) pursued by Giordano in keeping in touch with the user who has voluntarily contacted our company to get information on our services and products or who has placed an order or has registered to the website, and, in doing so, the user has expressed interest in and appreciation to our business activity. This legitimate interest is pursued informing the data subject on our marketing and distance selling campaigns, advertising new products and services, presenting offers and promotions, so that the data subject can get to know these chances and decide, if wished, to place orders or ask for information. 
  4. For the purpose referred to in point 8., “Purpose of processing”, the legal basis is the data subject’s consent (art. 6, par. 1, letter a), GDPR). These promotional contacts imply “profiling” (art. 4, par. 4, GDPR – “any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements”) and are carried out only if the data subject has expressly wished – and, therefore, unequivocally consented – this customised operation. In this case, it is not lawful to base the processing on “legitimate interest”: so, the user is asked to express consent.
  5. For the purpose referred to in point 9. “Purpose of processing”, the legal basis is the “legitimate interest” of a third party (art. 6, par. 1, letter f), GDPR) to propose – through direct mailing – the purchase of products which may be appreciated by its market of reference.
  6. For the purpose referred to in point 10. “Purpose of processing”, the legal basis is the data subject’s consent (art. 6, par. 1, letter a), GDPR).

 

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:

  1. For the purposes referred to from point 1. to point 5., “Purpose of processing”, all data are stored for the period necessary to perform the service required. Therefore, and in particular, for registration to the website, data are stored as long as the user is registered and uses the services of interest. User’s data (and profile) will be cancelled if fraud or unlawful actions are detected. In this case, the Controller has the right to inform the competent authorities and communicate user’s data to them. In case of orders, personal data will be stored as long as administrative and tax activities are performed, and, therefore, data will be stored to fulfil the legal obligations in accounting and administrative matters for 10 (ten) years.
  2. For the purposes referred to in point 6., “Purpose of processing”, the period of data storage is determined by the single national and EU rules and laws governing legal obligations to which the Controller is subject.
  3. For the purposes referred to in point 7. “Purposes of processing”, personal data are stored in our archives for the period necessary to keep in touch with the user  who has expressed interest in our business activity and to inform the user on it, so that Giordano can continue its own marketing and distance selling activities as long as the user is interested in our services and products. Of course, this period of storage lasts when the interest to be in touch with Giordano fails: if the person loses this interest, just communicate the objection as described in the paragraph “Data subjects’ rights” and Giordano will implement organisational and technical measures so as not to contact the person any more.
  4. For the purposes referred to in point 8., “Purpose of processing”, personal data are stored in our archives as long as the user’s profile is in line with the customised contacts created by interconnecting information at our disposal and, therefore, as long as Giordano continues its own distance selling and business activity with products, initiatives, offers, market researches and surveys which are considered interesting for the user because they meet characteristics and behaviour and are appreciated by the user. Data storage will cease, before the period here described, if the user objects to receiving such customised contacts and to being profiled for marketing purposes, exercising this right as explained in the paragraph “Data subjects’ rights” and Giordano will implement organisational and technical measures so as not to contact the person any more.
  5. For the purposes referred to in point 9. and 10., “Purpose of processing”, personal data are stored in our archives according to data processing activities and purposes of processing carried out by Giordano as data controller and which are reported in the paragraph “Purpose of processing”.  

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.

 

Data Controller

 

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 dpo@giordanovini.it.

 

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 privacy@giordanovini.it (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. 

  1. To carry out activities necessary for the service requested by the user, personal data may be communicated to third parties, autonomous controllers, which performs the appropriate processing operations so that the user’s request is fulfilled (e.g.: banks, credit cards operators for the payment of orders). This communication is lawful, as referred to in “Legal basis for the processing”, without data subject’s consent (art. 6, par. 1, letter b), GDPR).
  2. Data must be communicated to third parties because it is necessary for compliance with legal obligations to which the Controller is subject. Such communication is lawful without data subject’s consent, as referred to in “Legal basis for the processing” (art. 6, par. 1, letter c), GDPR). 
  3. Data may be communicated to supervisory authorities, law enforcement and judiciary to establish, exercise or defend a right of Giordano or of third parties. Such communication is lawful without the data subject’s consent pursuant to art. 6, par. 1, letter f), GDPR, because it is necessary for the purposes of the legitimate interests 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.
  4. Personal data may be communicated to third parties for their direct marketing purposes, according to the user’s choices: such third parties can operate in direct marketing field, especially, in distance selling (you can ask for the complete list by contacting the Controller at the address and e-mail as referred to in the paragraph “Data subjects’ rights”).
  5. Data may be disseminated: it is the case when the data subject uses a service which implies such dissemination. For example, when a person takes part in a contest or sweepstake and wins. In addition, when data are disseminated through our social media, also in image format, if the persons want to share their experience with Giordano. Such dissemination is subject to the data subject’s consent.

 

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:

  1. Facebook (https://www.facebook.com/help/cookies/
  2. Google (http://www.google.it/intl/it/policies/privacy e http://www.google.com/settings/ads)
  3. CommandersAct (https://www.commandersact.com/it/privacy/).

 

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 privacy@giordanovini.it (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:

  1. the purposes of processing (e.g.: about purchases placed, have information on services and products);
  2. categories of personal data (e.g.: identification data, behavioural data)
  3. recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
  4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
  5. existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing
  6. right to lodge a complaint with a supervisory authority
  7. where the personal data are not collected from the data subject, any available information as to their source;
  8. existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject (e.g.: if the person has a profile created on the basis of purchases, interconnecting the amount spent with the frequency of purchase).

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:

  1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed
  2. the data subject withdraws consent on which the processing is based and where there is no other legal ground for the processing
  3. the data subject objects to the processing and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing for marketing purposes or profiling
  4. personal data have been unlawfully processed
  5. the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

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:

  1. the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data
  2. the processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead (e.g.: the person objects to data processing for marketing purposes but only for accounting and administrative purposes) 
  3. the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims
  4. the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.

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:

  1. the processing is based on consent or on a contract stipulated with the data subject or for a third party
  2. the processing is carried out with automatic means.

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:

  1. is necessary for entering into, or performance of, a contract between the data subject and a data controller
  2. is authorised by Union or Member State law to which the controller is subject, and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or
  3. is based on the data subject’s explicit consent.

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 protocollo@pec.gpdp.it, 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.

To find out more on our cookie policy and third parties’ cookie policy, click HERE.

 

Browsing data

 

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:

  1. 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”) and / or encryption of data
  2. measures which ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services 
  3. procedures which ensure to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident
  4. procedures for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

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.

 

P3P

 

This privacy policy can be read in automatic format by the most widespread browsers which implement P3P platform ("Platform for Privacy Preferences Project") standard promoted by World Wide Web Consortium (www.w3c.org). Any effort will be put in please as to make interoperable the functionality of this website with automatic privacy controls installed in the user’s devices.

Whereas the state of perfection of the current automatic control mechanisms does not make them free from errors and dysfunctions, we would like to make it clear that this document constitutes the “Privacy Policy” of this website and which will be subject to updates.