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Website Policy

This page describes how the site handles users' personal data. Site users may be simply visitors, or may subscribe to a newsletter or may register and create account, or again, may shop online and/or use customer services.

This policy is pursuant to European Regulation 2016/679 and Legislative Decree 196/2003 - Data Protection Law for users of the Coccinelle S.p.A website and which can be viewed online at: www.coccinelle.com.

The policy only applies to this site and does not apply to other sites that the user may visit through links from this website.

The policy outlines certain minimum requirements for the collection of personal data online, and, in particular, the methods, timeframes, and the type of information that data controllers must provide users when they visit webpages, regardless of the purpose of their visit.


DATA CONTROLLER

The data of identified or identifiable persons using this website may be processed.

The Data Controller is Coccinelle S.p.A., Via Lega dei Carrettieri 6, 43038 – Sala Baganza (Parma), email address: privacy.reserved@coccinelle.com.


DATA PROCESSED

Browsing data

During normal operations, the IT systems and software procedures used to run this website will collect certain personal data. The transmission of this data is implicit in the use of Internet communication protocols.

This information is not collected to link the data subjects identified, however, by its very nature, it may identify users through the processing and cross-referencing of the data.

This data category includes the computer IP addresses or domain names of the users connecting to the website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in reply, the numerical code indicating the status of the response from the server (successful, error, etc.) and other parameters relating to the user's operating system and computer environment.

This data is used only to obtain anonymous statistical information regarding site usage and to check its correct functioning and is immediately deleted after processing. The data may be used to ascertain responsibility in the case of potential computer crimes against the site. Other than for this eventuality, data on website visits is not retained for more than seven days.

Data provided voluntarily by the user

The optional, explicit and voluntary sending of communications and requests to the addresses on this website entail the subsequent collection of the sender's contact details required to respond to them, in addition to all the personal data contained in the communications.

Data may be collected when the user subscribes to the newsletter, or creates their own account or makes an online purchase. Mandatory data required to provide the requested service is marked with an asterix (*).


PURPOSE OF DATA PROCESSING AND ITS LEGAL BASIS

Response to user requests

Data is processed to respond to user requests sent to the website addresses, or by filling in website forms (e.g.: general information; customer help).

The legality of this data processing is based on the requirement to execute a contract of which the user is a party and/or to implement pre-contractual measures undertaken at the user's own request, as well as complying with the related legal obligations.

Data processing as described above is necessary: it would be impossible to respond to user requests without it.

Commercial newsletters

Where the user subscribes to the commercial newsletter service, their data is processed by emailing informative communications which also contain commercial and promotional information about the data controller's business and its products.

The legality of this data processing is based on the requirement to execute a contract of which the user is a party and/or to implement pre-contractual measures undertaken at the user's own request, as well as complying with the related legal obligations.

Data processing as described above is necessary: it would be impossible to accept the subscription to the commercial newsletter without it.

The user can cancel the service, at any given time, by following the procedures indicated in each newsletter and/or by writing to the addresses listed at the bottom of this policy document.

Account

Where the user creates their own personal account, their data is processed to allow them to register on the website and to manage their own reserved area, as well as to send informative communications which also contain commercial and promotional information about the data controller's business and products. The data controller can receive identity and contact information about the user, if they login through Facebook and Google+. The personal account requires the use of authentication credentials only known to the user which they are required to store securely and for which they are wholly and solely responsible.

Registration on the website provides several benefits for the user, such as invitations to exclusive promotions, birthday discounts, as well as a more simplified check-out procedure for online purchases. The creation of an account is not obligatory/necessary to make online purchases.

The legality of data processing is based on the requirement to execute a contract of which the user is a party, and/or to implement pre-contractual conditions undertaken at the user's own request, as well as complying with the related legal obligations. With regard to the sending of commercial and promotional informative communications, the legal basis for this data processing is Coccinelle S.p.A's legitimate interest in promoting its business and its products, and is compatible with the position of the data subjects because it is reasonable to believe that the user who sets up an account on the website is interested in receiving information about Coccinelle S.p.A.'s business and promotions.

Once consent is given to data collection at registration, this data (including data regarding favourite/wishlist products) is processed automatically for profiling purposes, namely to analyse the user's consumer choices with the aim of personalising the commercial and promotional communications which the data controller sends, and to better assist the user in both their Coccinelle online and in-shop purchases, by suggesting products that might interest them. This profiling does not imply automated decision-making legally impacting the user. Consent is optional and is not required to create an account; if consent is given, it can be withdrawn, at any time, without prejudice to the legal processing of data based on the consent given prior to its withdrawal, by following the procedure indicated at the bottom of these same communications, or by writing to the data controller: Via Lega dei Carrettieri 6, 43038 – Sala Baganza (Parma), or by emailing: privacy.reserved@coccinelle.com. In the case where the choice in relation to consent is submitted several times (for example, an account was set up and a purchase made) the last choice will be the prevailing choice.

Processing of user data is solely required to create a personal account. The user can opt out, at any given time, from receiving commercial and promotional communications from the data controller and this will not impact on the existence of the account (notwithstanding that the user can always request to cancel this at any given time). However, the user will lose the option to receive offers that might be of interest to them. The user can opt out by following the procedure indicated at the bottom of these same communications or by writing to the data controller at the following address: Via Lega dei Carrettieri 6, 43038 – Sala Baganza (Parma), or by emailing: privacy.reserved@coccinelle.com.

Online purchases

Where the user makes online purchases, their data is processed (i) to manage their orders (which includes emailing information and service communications regarding the status of the order; the execution of the related shipments; pre and post-sales customer services), as well as (ii) sending informative communications containing commercial and promotional information about the data controller's business and products, and (iii) to email customer satisfaction surveys and questionnaires in order to improve the products and services offered by Coccinelle S.p.A. The results of these surveys are anonymous unless the user consents otherwise. User consent is requested and obtained at the end of the survey.

The legal basis for data processing comprises:

- data processing as per (i), which is based on the requirement to execute a contract of which the user is a party, and/or to implement pre-contractual measures undertaken at the user's own request, as well as to comply with the related legal obligations;

- in relation to data processing referred to in (ii) and (iii), this is based on Coccinelle S.p.A's legitimate interest in promoting and improving its business and products, which is compatible with the position of the data subjects, because it is reasonable to believe that the user who makes a purchase on the website wishes to continue to receive information about Coccinelle S.p.A's business and promotions as well as to express their opinion on their own shopping experience.

Having consented to data collection at the time of registration, this data (including data related to the products purchased) is processed automatically for profiling purposes, namely to analyse the user's consumer choices with the aim of personalising the commercial and promotional communications the data collector sends, as well as to better assist the user in their online and in-shop Coccinelle purchases, by suggesting products that might be of interest to them. This profiling does not imply automated decision-making legally impacting the user. Consent is optional and is not required to make an online purchase. Consent can be withdrawn, at any time, without prejudice to the legal processing of data based on the consent given prior to its withdrawal, by following the procedure indicated at the bottom of these same communications or by writing to: Via Lega dei Carrettieri 6, 43038 – Sala Baganza (Parma), or by emailing: privacy.reserved@coccinelle.com. In the case where the choice in relation to consent is given several times (for example, several purchases are made or an account is created and a purchase made), the last choice will prevail.

The processing of user data is solely required to complete the purchasing procedure for the subsequent delivery of products as well as to provide customer services. The user can opt out at any time from receiving commercial and promotional information from the data controller as well as opting out of customer satisfaction surveys and questionnaires. The only consequence of this choice is that the user will lose the opportunity to receive offers that might be of interest to them and their ability to contribute towards improving the data controller's products and services. The user can opt out by following the procedure indicated at the bottom of these same communications or by writing to the data controller at the following address: Via Lega dei Carrettieri 6, 43038 – Sala Baganza (Parma), or by emailing: privacy.reserved@coccinelle.com.


DATA PROCESSING - METHODS

Data is processed on the basis of the relevant operational instructions provided by the data controller, and is solely processed by data controller personnel and employees, or by companies expressly appointed as data controllers. Including:

- The Level Group Srl, with registered offices in Piazza Arcole, 4 20143, Milan (MI), which provide services for the administration and operational management of the platform used;

- companies affiliated to Coccinelle S.p.A.'s commercial network and franchised shops. These companies will be provided with the data on users who have created an account on the website and/or who have made an online purchase in order to help users who visit Coccinelle shops regarding their purchases both in terms of customer service and guarantees. The affiliated companies, not present in Italy that have offices based in the European Union and / or benefit from a decision of adequacy from the European Commission and, in the absence of, have signed the standard contractual clauses approved by the European Commission as a control measure for the transfer of personal data abroad.

Specific and appropriate security measures are adopted to prevent the loss of data, illegal or improper use of data, as well as unauthorised access to this data.


DATA COMMUNICATION

Where there exists a specific purpose for data processing, data may be communicated to third-party suppliers of ancillary services (e.g. marketing agencies who organise and send commercial and promotional communications; transport and shipping companies who manage the delivery of online purchases). These entities will process the data on a case by case basis, as independent data controllers, or as data managers based on the specific written mandate granted to them by the data controller.

One of these is The Level Group Srl, with their offices based in Piazza Arcole, 4 - 20143, Milano (MI), to whom the necessary information will be communicated once the purchase order has been fulfilled for the execution, in particular, of the delivery management activities, sending information and service messages on the status of orders, invoicing and the collection of payments. The Level Group Srl will handle the processing of such data as an autonomous holder, according to the personal data processing information available here. The user is invited to consult this information before submitting his/her purchase order through the website www.coccinelle.com


TRANSFER OF DATA TO THIRD-PARTY COUNTRIES

Data may be transferred abroad where the user requests that the online purchases be delivered outside of Italy: in this case, the transfer of data shall occur (in the case of delivery to countries which do not benefit from an adequacy decision of the European Commission, and, therefore, these countries do not offer an appropriate level of personal data protection) based on the dispensation resulting from the need to enforce a contract between the data controller and the user.


RIGHTS OF DATA SUBJECTS

At any given time, (where applicable), users have the right to request access their data and to rectify, erase, limit and object to its processing, to withdraw any potential consent without prejudice to the legality of the data processing carried out on the basis of the consent given prior to the withdrawal, in addition to the right to the transportability of their data. They have also the right to make a complaint to the Data Protection Authority or take an action in a Court of Law.

At any given time, users may also request the full list of the recipients of their data.

Please send requests to the address below: Via Lega dei Carrettieri 6, 43038 – Sala Baganza (Parma), and/or by email to: privacy.reserved@coccinelle.com.

Requests for clarification regarding the characteristics of the data processing can also be sent to the same addresses.


ADDITIONS

Where substantial changes are made to this policy, the data controller will send an email notification and/or will publish a notice on its website to indicate the changes and gather any potential requests to exercise the rights described above.


UTILIZZO DEI COOKIES

For information on how cookies are used, please refer to the extended cookie policy published on this site, based on the Provision issued by the Italian Data Protection Authority on May 8, 2014, which supplements and completes this document.