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PRIVACY POLICY

Information on the processing of personal data pursuant to art. 13-14 EU Reg. 2016/679

This policy is intended for all the people who visit and interact with this website owned by IL GUFO S.P.A. and companies belonging to the group "IL GUFO" ("IL GUFO" or the "Company") and is given only for this site and not for other web sites accessed through links contained on this site, so called "Web Store", where you will have the opportunity to make any purchases online.

The Web Store is managed on behalf of IL GUFO, by TRIBOO’ DIGITALE S.r.L. based in Viale Sarca 336, Building 16, Milan FC/VAT N. 02912880966 (hereinafter"TRIBOO’ DIGITALE"), a company that sells products branded "IL GUFO" marketed on the Store and operates the ecommerce site together with IL GUFO as joint holder. 

TRIBOÒ DIGITALE is responsible for the management of sales and transactions carried out in the context of the Store IL GUFO (for example: order management, sales and delivery of products, returns and guarantees management and other activities necessary to sell products through the Store). 

Treatments administered in co-ownership: In order to access restricted services, including the purchase of products, your registration to the Store is needed; in this framework IL GUFO and TRIBOO’ DIGITALE will process only the personal data provided during registration and for the any conclusion of the purchase agreement through the Store such as "Joint Holders" in accordance with the provisions of the Lgs. Decree. 30th June 2003, nr. 196 as amended by Lgs. Decree 101/2018 (the "Privacy Code") and of the EU regulation 679/2016 (the "Regulation").

In this regard, the joint holders have concluded a special agreement by which they defined the respective responsibilities with regard to compliance with the obligations arising from the Regulation and the Privacy Code; adequate information on the main content of the agreement will be accessible to you by contacting the Co-holders of data processing through the references indicated below.

It is understood that, regardless of the agreement, you will be able in every case to exercise your rights under the Regulation and Privacy Code against any Data controller. 

Treatments that are managed by the IL GUFO as independent holder: Autonomous holder of processing of the data that may be provided by subscribing to the newsletter of this site and/or filling out coupons at one of the Stores of the Group IL GUFO or IL GUFO S.P.A. with registered office in Italy, Viale Galilei 3/A, Asolo (TV) is also 
The independent holder of the data provided for marketing and / or profiling purposes.

Il GUFO and TRIBOO DIGITALE, each for its own part, will not respond in any way for the unlawful processing of your data made by third parties. Therefore, for the exercise of the rights referred to in paragraph "Rights of the interested party" please refer to the specific information that must be provided by these third parties acting as autonomous data controllers.

 

PRIVACY OF MINORS PROTECTION

This Web Store addresses to a general audience, however the services are intended for people aged 18 or more.

IL GUFO and TRIBOO DIGITALE, each for its own part, do not ask and do not collect or deliberately collect or disclose personal data provided by people under the age of 18 online or released by them at IL GUFO stores.

At the request of the Users, IL GUFO and TRIBOO DIGITALE, each for its own part, will promptly delete all personal data inadvertently collected and relating to subjects under the age of 18. In the event that the interested party is not of the requested age, please do not register or proceed with the help of a parent.

 
PERSONAL INFORMATION VOLUNTARILY PROVIDED BY YOU

  1. The personal data the co-holders could collect through the Web Store include:

a) contact information (name, postal address, e-mail address and cell phone number or any other phone, fiscal code);

b) username and password when registering to the Web store; 

The personal data that are necessary for the pursuit of the processing purposes described in this paragraph 1 are indicated with an asterisk in the registration form on the Site.

 

  1. The personal data that IL GUFO may collect through the Web Store and / or other means, as an independent holder, includes:
    a) information about purchases and transactions (data exclusively related to the value and frequency of purchases and the kind of products purchased), only upon your express consent.

 

PURPOSES OF THE PROCESSING

The data you provide on this occasion will be used to enable to allow the Co-holders (and / or IL GUFO in autonomy) to meet your specific requests and to perform the services required and in particular:

 

Delivery and performance of the contract of purchase or support service

The data, marked with an asterisk on the Web store and provided by you are required to carry out the transaction for the sale of goods and service request.

 

Marketing activities

The data you supply by filling out the contact form may be used – only with and on the basis of, your prior, clear and express consent  – by "IL GUFO" for the following purposes:

(i) offering promotions, discounts, benefits and other services, as well as sending commercial or promotional information or free products, participation in exhibitions or events, conducting market research and notification of all special initiatives dedicated to customers of IL GUFO; 

(ii) analysis of your consumer choices (so-called "profiling") through the identification of the type and frequency of purchases made by you on-line and / or at the stores of the IL GUFO Group, also in order to serve you better at the time of any future purchases at one of the Group's stores and to pursue the purposes referred to in the preceding paragraph. 

The data may also be processed for statistical and historical purposes. 


Newsletter

After obtaining your prior, free and express consent you can subscribe to our newsletter and receive information in connection with promotions, news and events of IL GUFO.

 

Coupon

Also, at the time of a purchase at one of the Group's stores,you could be offered the opportunity, entirely optional, to give us some of your data by filling out a special printed coupon, and this in order to improve the service that the Group IL GUFO intends to offer its clients. 
The data you may provide by filling in the coupon at one of the Group's stores and/or signing up for our newsletter will be used – only with and on the basis of, your prior, clear and express consent  – by IL GUFO for the following purposes: 
(i) offering promotions, discounts, benefits and other services, as well as sending commercial or promotional information or free products, participation in exhibitions or events, conducting market research and notification of all special initiatives dedicated to customers of the Group IL GUFO; 

(ii) analysis of your consumer choices (so-called "profiling") through the identification of the type and frequency of purchases made by you on-line and / or at the stores of the IL GUFO Group, also in order to serve you better at the time of any future purchases at one of the Group's stores and to pursue the purposes referred to in the preceding paragraph. 


The data may also be processed for statistical and historical purposes. 

 

STORAGE TIMES

Your data will be stored by the Co-holders and for the period strictly necessary to ensure the proper delivery of purchased services – without prejudice to the need for conservation for a longer period in compliance with the applicable, also accounting, law. 

The data processed by IL GUFO for the purposes of profiling and/or marketing (always, of course, as long as we have acquired your explicit approval), will be retained until the any withdrawal of consent to the processing of personal data and, as far as the data processed for the purposes of profiling are concerned, no later than 12 months after your latest purchase, and 24 months for marketing purposes.

At the time of the revocation of consent, or, if prior to it, at the expiry of the retention period of the data collected for the purposes of profiling, the same will be automatically deleted or made permanently anonymous and our Company may ask you to renew consent to the processing of your data or keep them anonymously for statistical purposes only. 

In any case, you will have the right to revoke your consent to the processing of data for profiling and / or marketing purposes at any time: in any commercial communication there will be a section that will allow you to easily revoke your consent. 

The data transmitted to any service providers will be processed by them for the time strictly necessary for the execution of the tasks entrusted to them. 


PROCESSING METHODS

The processing will be carried out by IL GUFO and TRIBOO DIGITALE, each for its own responsibility, with the aid of telematic, paper and computer tools; this processing will be based on principles of correctness, lawfulness and transparency and protection of your rights and your privacy. In particular, the processing of your data, also for profiling purposes, may also take place through automated processes, for example through comparison and comparative analysis of your purchase choices (types, quantities), during a specific period and / or season and by analysing the type and number of your requests for information on products made in a predetermined time frame. 

The data will be processed in such a way as to minimise the risk of destruction, loss, unauthorised access or processing that is not in accordance with the purposes of collection. 

PROVISION OF DATA AND CONSEQUENCES IN CASE OF NON-CONSENT TO PROCESSING

Failure to provide the data necessary for completing the contact form will make it impossible for IL GUFO to process your request for information. 

Any failure to provide the data required for registration and to be able to access the services of the Web Store and possibly proceed with the on-line purchase will make it impossible to register and, where applicable, make purchases on the Web Store. You will be anyway allowed to browse freely within the site. 

 

Please note, for the sake of completeness, that the information relating to your credit card used for the purchase of our products will not be collected, recorded and / or stored and / or in any way processed by IL GUFO or by TRIBOO DIGITALE, but only by the payment service provider. 

 

Any refusal to provide to IL GUFO the data or the lack of consent to the processing of the same for marketing and / or profiling purposes, will simply make it impossible to process the data for the purposes indicated in these points. 
It is therefore understood that, in any case, the lack of consent to the processing of your data for Marketing and/or profiling purposes won’t prevent you from purchasing products by IL GUFO Group. It will be anyway allowed to browse freely within the site.

 

PROCEDURES AND LEGAL BASES OF PROCESSING

The data may be supplied by you when registering with the Wen Store, collected during visits to our boutiques, supplied in the course of interaction with our digital initiatives (websites, social media), or during events organised by IL GUFO.

IL GUFO processes your personal information based on the following criteria of legitimacy:

-          your consent

-          the legitimate interest of the owner for the performance of its tasks;

-          the execution of a specific contractual request (purchase of the product and service);

-          the fulfilment of legal obligations.

TRIBOO DIGITALE processes your personal information based on the following criteria of legitimacy:

-          the execution of a specific contractual request (purchase of the product and service).

 

 

Rights of the interested person -EU regulation 679/2016 art. 15, 16, 17, 18, 19, 20, 21, 22

1.         The interested party has the right to obtain confirmation of the existence or not of personal data concerning him/herself, even if not yet registered, and their communication in intelligible form.

2.         The interested party has the right to be informed:

•          about the origin of personal data;

•          about the purposes and methods of processing;

•          the logic applied in case of processing with electronic tools;

•          of the identification data concerning data controller, data processors and the representative appointed under article 5, paragraph 2;

•          of the subjects or the categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the territory of the State, managers or agents.

3.         The interested party has the right to obtain:

•          updating, rectification or, where interested, integration of the data;

•          the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;

•          data portability.

4.         The interested party has the right to object, in whole or in part:

•          for legitimate reasons to the processing of personal data, even if pertinent for collection purposes;

•          to the processing of personal data for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication.

 

How to exercise the rights

You may at any time exercise these rights:

a.  With regard to the treatments managed jointly  : sending a registered letter to the address of IL GUFO and / or TRIBOO DIGITALE; or a mail  to IL GUFO at the address privacy@ilgufo.com   and / or an email to TRIBOO DIGITALE at the address  privacy+ilgufo@triboo.it  

  1. b.  With regard to the processing managed by IL GUFO as an independent holder : sending a registered letter to the address of IL GUFO; or a mail at the address privacy@ilgufo.com .

 

DATA CONTROLLER AND DATA PROCESSOR

 

The data controllers are: 

IL GUFO S.P.A. with registered office in viale Galilei 3/A, Asolo (TV)

Tax code and VAT: 03450970268

 

and for treatments administered in co-ownership, also

TRIBOO DIGITALE S.R.L.with registered office in Viale Sarca 336, building 16, Milan

Tax code and VAT: 02912880966

 

Internal Privacy Manager is:

For TRIBOO DIGITALE S.R.L.

The Data Protection Officer, e-mail: lapo.curinigalletti@triboo.it

 

The updated list of external processors is kept at the premises of IL GUFO and TRIBOO DIGITALE.

 

SUBJECTS OR CATEGORIES OF SUBJECTS TO WHOM DATA CAN BE COMMUNICATED AND DISSEMINATION SCOPE OF THE SAME DATA

Your data will not be disclosed. 


The data you provide by filling out the contact form will be accessible to IL GUFO and, for the treatments of their competence, of TRIBOO' DIGITALE employees and collaborators, to the service providers whose collaboration each Company uses only if this is strictly necessary to process and perform the service you requested

They will also be accessible to third parties such as:

-          The subjects who are entrusted with the maintenance / development service of our computer system for the time strictly necessary for the execution of this service. 

-          The public or private subjects, natural or legal persons of which the Data Controller makes use for the performance of the activities instrumental to the attainment of the aforementioned purposes (purely by way of example: suppliers of information services and applications, e-mail marketing platforms, website managers, etc).

-          Independent third parties in charge of the processing in the management of payment, logistics and delivery of products you purchased.

 

Some of the aforementioned individuals may be established also outside the EU. IL GUFO will take the necessary precautions for a legitimate transfer of data. TRIBOO DIGITALE does not transfer your data outside the EU.

 

You can ask at any time information on the transfer of your personal data by contacting the Privacy Manager of IL GUFO.

Interested parties/users have the right to get a list of possible data processing managers appointed by IL GUFO and by TRIBOO DIGITALE, asking each of them to the addresses listed above.

 

CHANGES

IL GUFO and TRIBOO DIGITALE reserve the right to modify or simply update the content of this Privacy Notice, in part or completely, also due to changes in the applicable legislation. We invite you to visit this section regularly to take knowledge of the most recent and updated version of the Privacy policy in order to be informed about the data collected and the use made of them by IL GUFO and TRIBOO DIGITALE.