Privacy Policy

This page describes how the site is managed with respect to the processing of users' personal data. The website users may simply be visitors or else sign up for the newsletter service, register and create an account or go shopping with e-commerce and/or benefit from customer service.

This is the Privacy Policy that is addressed, pursuant to European Regulation 2016/679 (the ” GDPR”) and Legislative Decree 196/2003 – the Personal Data Protection Code (the "Privacy Code”) to those who interact with the web services of Coccinelle S.p.A., which is accessible online on the website: www.coccinelle.com.

This Privacy Policy is provided exclusively for the present website, not for any other websites that may be visited by the user by following links available on the present website.

The Privacy Policy describes certain requirements for online personal data collection, particularly, the methods, time frames, and nature of the information that data controllers must provide to users when they connect to web pages, regardless of the purpose of connecting.

THE DATA CONTROLLERS

The identity of the Data Controller may vary according to the nature of the personal data and the purposes of the processing.

The only Data Controller in charge of processing transactional and logistical data pertaining to sales activities performed on the Website is:

• The Level S.r.l., a company registered in Italy with Chamber of Commerce registration number MI1945372 and a registered office at Piazza Arcole 4, 20143 Milan (MI), Italy ("TLG"); contact: privacy@thelevelgroup.com

The only Data Controller for the personal data that is used for marketing via e-mail and performance marketing and processed in connection with the activities of the Website is:

• Coccinelle S.p.A., Via Lega dei Carrettieri 6, 43038 – Sala Baganza (Parma), e-mail privacy.reserved@coccinelle.com (“Coccinelle”).

In this second case, TLG acts as the data processor.

TLG and Coccinelle act jointly in the capacity of Data Controllers with respect to the personal accounts of Coccinelle and activities of responding to user requests. Pursuant to the GDPR, Coccinelle and TLG have established the respective responsibilities for the obligations under the GDPR, particularly with respect to the exercise of the data subject’s rights as well as the mutual obligation to provide one another with information under articles 13 and 14, by mutual agreement.

PROCESSED DATA

Browsing data

The computer systems and software procedures used to operate this website will acquire, in the course of their normal operation, certain personal data whose transmission is inherent in using Internet communication protocols.

The information in question is not collected in order to be matched with identified data subjects but, by its nature, such information may enable identifying users through processing and matching.

This category of data includes the IP addresses or domain names of the computers used by users connecting to the website, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used in submitting 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 (successful, error, etc.) and other parameters related to the user's operating system and computer environment (the "Browsing Data").

Such data is used for the sole purpose of collecting anonymous statistical information about website use and to make sure it is functioning properly, and such data is deleted immediately after processing. The data could be used to determine responsibility in case of hypothetical computer crimes against the website: except in such cases, data concerning web contacts is not retained for more than seven days.

Cookies and similar technological tools (referred to jointly as "Cookies") are used on the Website to collect and store data related to use, access and interaction via the Website. For further information regarding the use of Cookies, please refer to the additional relevant EXTENDED INFORMATION that is posted on this website and prepared pursuant to the basis of the Provisions of 10 June 2021 issued by the Italian Data Protection Authority, which supplements and completes the present document.

DATA PROVIDED VOLUNTARILY BY THE USER

The optional, explicit and voluntary sending of messages and requests to the addresses indicated on this website entails the subsequent acquisition of such of the sender's contact data as is necessary to respond, as well as all personal data included in the communications.

Data may also be collected when the user subscribes to the newsletter service, or creates his/her own account, or else makes a purchase with e-commerce. The data necessary for the performance of the requested activity is marked with an asterisk (*) and particularly consists of the user's first and last name, home address, telephone number, e-mail address, country of residence, nationality and date of birth (the "User Data"). The Browsing Data and User Data will be jointly referred to as the “Data”.

COOKIES

Regarding the methods of use of cookies, please refer to the additional relevant EXTENDED INFORMATION that is posted on this website and prepared pursuant to the basis of the Order of 10 June 2021 issued by the Italian Data Protection Authority, which supplements and completes the present document.

PURPOSES OF THE PROCESSING AND RELATED LEGAL BASIS

ACCOUNT

The Data communicated by users during registration on the website (including shipping and payment data) is processed in order allow the user to sign up for an account on the website, add products to their wish list, complete the purchase of the desired products, and manage their own reserved areas.

The controllers may receive the user’s identification and contact data from Facebook or Google if the user logs in through Facebook or Google+. Controllers may receive the user's identification and contact information from Facebook or Google, in the case of user login through Facebook and Google+. The personal account involves the use of authentication credentials that are known solely to the user and must be stored carefully by the user under his entire and exclusive responsibility.

Registering for the website allows the user to take advantage of certain benefits, such as invitations to exclusive promotions, birthday discounts and a simplified check-out process for online purchases. It is not necessary to create an account in order to make online purchases.

The legal basis for such processing is a need to perform a contract to which the user is a party and/or precontractual measures adopted at the user’s request, and to comply with the related legal obligations. Any refusal by users to provide their own personal data will make it impossible to complete the account registration process.

RESPONSES TO USER REQUESTS

The Data will be processed in order to respond to requests sent by users based on the contact data or by completing the forms available on the website (for example: general information; customer support). The legal basis for such processing is the need to perform a contract to which the user is a party and/or precontractual measures adopted at the user’s request, and to comply with the related legal obligations. It is necessary to process the above-described data, failing which it will be impossible to respond to the users’ requests.

ONLINE PURCHASES

The Data will be processed for management purposes (to manage the purchase orders, including sending out information and service e-mails regarding the order status; carrying out the related shipments; pre- and post-sales customer support activities) and to allow Coccinelle to comply with the legal obligations.

The legal basis for such processing is the need to perform a contract to which the user is a party and/or precontractual measures adopted at the user’s request, and to comply with the related legal obligations. Processing of the User Data is obligatory to enable completing the purchase process; users who deny their consent to such processing will not be able to complete the purchase of the products on the website.

CUSTOMER SATISFACTION INQUIRIES

Within 48 days after a purchase and/or 30 days after making a request to our customer service, users will receive customer satisfaction surveys and inquiries via e-mail asking users to evaluate Coccinelle products and/or their own experience with customer service. The response will be anonymous unless the user grants the consent that will be requested and collected at the end of the survey. Improvement of the products and services offered by Coccinelle.

The legal basis for such processing is the legitimate interest of Coccinelle and of TLG to keep their own users satisfied with Coccinelle products and with the customer service provided. That interest is commensurate with the users interest in being able to find and purchase high-quality, non-defective products and to be able to ask for assistance from qualified customer service.

“SOFT MARKETING” MESSAGES

The Data (particularly, the e-mail address assigned to the user at the time of registration on the website and of completion of the purchase) will also be processed in order to send by e-mail commercial, promotional or advertising messages exclusively concerning Coccinelle brand products or the equivalent, and products already purchased and used by the user.

Under art. 130 (4) of the Privacy Code, the legal basis of such processing is the legitimate interest of Coccinelle to keep its own customers constantly informed and up to date about its offers of such new products and services as may be available from time to time on the Coccinelle website, as well as the promotions and/or initiatives promoted by Coccinelle. That legitimate interest is commensurate and compatible with the user’s interest insofar as it may reasonably be assumed that the person who buys a Coccinelle brand product or benefits from a web service may be a data subject and expects to receive updates on the catalogue of Coccinelle products and services.

At any time, the data subject has the opportunity to object to the processing carried out for purposes described above, conveniently and free of charge (by following the procedure indicated in each commercial message or by using the contact details of the data controllers indicated below). Any objection to the processing on the part of the data subject shall be without prejudice to the legitimacy of the processing for so long as it is performed, nor shall it affect future purchase of Coccinelle brand products.

NEWSLETTER

The Data will be processed to allow users to subscribe to and benefit from Coccinelle's newsletter service. In the event of a request to subscribe to the newsletter service, the Data will be processed in order to respond to the request and allow the transmission by e-mail of messages containing informative, promotional, commercial and advertising materials concerning Coccinelle products and invitations to events and notices of any extraordinary store openings/closings, catalogues and invitation cards to Coccinelle events and special promotions.

It will not be possible to process data for the purpose of sending out the newsletter unless the user expressly consents thereto by checking the appropriate box on the Coccinelle website.

Users wishing to revoke their consent may object at any time to the processing described herein by writing to Coccinelle at the contact address indicated in the "Rights of Data Subjects" section. In any case, any objection made will be without prejudice to the lawfulness of any processing activities carried out by Coccinelle up to the time of revocation.

PROFILING

Subject to user granting prior consent collected in the process of completing purchase procedure, the Data pertaining to the products purchased, preferred and/or added to the wish list will also be processed – automatically – for the purpose of profiling, that is to say, in order to analyse consumer choices of the user and to personalize accordingly the commercial and promotional messages sent by the controller and to better assist the user with the user’s own purchases, whether online or Coccinelle shops, by suggesting products that may interest them.

Such profiling does not involve automated decision-making that has legally binding effects on the users. The user’s consent is optional, not necessary, in order to complete purchases online, browse the Coccinelle website, send requests for information, and receive messages not subject to profiling.

Users wishing to revoke their consent may object at any time to the processing of personal data by writing to Coccinelle at the contact addresses indicated in the "Rights of Data Subjects" section. In any case, any objection made will be without prejudice to the lawfulness of any processing activities carried out on the basis of consent given prior to revocation. If the preference whether or not to give consent is expressed several times (e.g. because several purchases are made or because an account is created and a purchase is made), the last choice made will prevail.

DATA PROCESSING METHODS

The data will be processed according to adequate operating instructions given by the controller, exclusively by the personnel and employees of the controller or of the companies expressly designated as in charge of the processing. Such companies include:

- The Level S.r.l., with a registered office in Piazza Arcole, 4 - 20143, Milan (MI), a provider of development, distribution and operational management services of the platform deployed;

- the companies affiliated with the sales network of Coccinelle S.p.A. that manage the Coccinelle shops under a franchising arrangement. Such companies will be informed of the data of the persons who have created an account on website and/or who have made a purchase online, so that they may assist the users who frequent Coccinelle shops with respect to their purchases or requests concerning customer support and warranties.

The affiliated companies, where not present in Italy, all have registered offices in States that belong to the European Union and/or that benefit from an adequacy decision by the European Commission or, failing that, have signed the standard contract clauses approved by the European Commission as an adequate measure for the transfer of personal data abroad. Specific and adequate security measures are adopted to prevent the loss, unlawful or improper use of such data, and unauthorized access thereto.

DATA COMMUNICATION

Where necessary for the pursuit of the specific purposes of the processing, the Data may be communicated to third party providers of ancillary services (e.g. communication agencies for the preparation and sending of commercial and promotional communications; shippers and carriers for the management of deliveries of products purchased with e-commerce). Such entities will process the data, as appropriate, as autonomous data controllers, or as data processors under a specific written assignment given to them by the data controller.

TRANSFERS TO THIRD COUNTRIES

The data may be transferred abroad only when the user requests that the products purchased with e-commerce be delivered outside Italy, in which case, the transfer will be made (in the case of countries that do not benefit from an adequacy decision of the European Commission and therefore fail to offer an adequate level of personal data protection) only under the exemption corresponding to the need to perform a contract between the controller and the user.

STORAGE PERIOD

The Data will be stored only for the period necessary to achieve the purposes for which the data is processed. In particular

- in order to carry out such activities as are necessary to perform the contract with the user in connection with the purchase of products, the Data will be stored for the retention period prescribed by law;

- in order to send out commercial and promotional messages (including personalized messages, if the user consented thereto) and to send out the newsletter for a maximum period of 48 months after the sign-up for the services or newsletter; such period may be extended by an equal duration whenever users renew their consent for a specific request transmitted by Coccinelle prior to the expiry of the retention period;

- for soft marketing (or soft spam) activities, the Data will be processed in a form that enables identifying the user only for such time as is strictly necessary to achieve the purposes for which the data was collected, particularly, for a period of 24 months after collection;

- for the customer satisfaction inquiries, the Data will be processed and stored for a maximum period of 48 months after each individual purchase;

- for profiling ’activities, the Data will be processed for a maximum period of 48 months after collection.

Please note that the Data may be stored for a longer period if necessary in order to comply with the statutory or regulatory obligations and/or for protective purposes.

RIGHTS OF THE DATA SUBJECT

The users have the right, at any time, to:

(i) obtain access to the Data;

(ii) obtain rectification, erasure or, where appropriate, limitation of the processing;

(iii) object to the processing;

(iv) revoke consent;

(v) where applicable, receive in a commonly used, machine-readable structured format, the Data provided to Coccinelle, and to transmit such Data to another Data Controller without interference on the part of Coccinelle;

(vi) file a claim with the Italian Data Protection Authority, or file an appeal with the Judicial Authority.

Users may also request, at any time, a full list of the addressees of the Data. Such requests should be sent to the following addresses:

to Coccinelle: - by e-mail, to the address: privacy.reserved@coccinelle.com. - by post, to the address: Via Lega dei Carrettieri 6, 43038 – Sala Baganza (PR)

to TLG: - by e-mail, to the address: privacy@thelevelgroup.com - by post, to the address: Piazza Arcole 4, 20143 – Milan (MI)

The same addresses can be used to send requests for clarifications of characteristics of the data processing.

SUPPLEMENTS

In case of any substantial modifications of the present Privacy Policy, the Data Controllers will send out a notice by e-mail and/or publish a notice on the website in order to point out the changes and collect any requests to exercise to the rights described above.