Luigi Fedeli e Figlio S.r.l. wishes to inform you that pursuant to Art.13 of the Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data (hereinafter, “European Regulation”) has the necessity to proceed with the processing of personal data automatically collected or provided through your navigation or use of the website https://www.fedelicashmere.com/ (hereinafter, “Website”).

1. DATA CONTROLLER

The Data Controller is Luigi Fedeli e Figlio S.r.l. in the person of the legal representative, domiciled at the registered office of Via Arosio n. 4, Monza (MB) (hereinafter, “Fedeli” or “Data Controller”).

2. TYPES OF PROCESSED DATA

Data provided voluntarily by the user 

To enable your use of the Website and its Services, including the possibility of creating and using your personal area, as well as to complete online purchases or to contact Fedeli for specific requests (hereinafter, “Services”), the Data Collector requires to have knowledge of and process some of your personal data, such as your name and surname and your email address.

The discretionary, explicit and voluntary delivery of email messages, likewise the registration and completion of purchases on the Website, as well as the forward of requests, entail the acquisition of your identification data, your phone number, your address and your email address, similarly to other possible data inserted in the message or forms to be completed if sent.

Surfing Data 

The computer systems and software implemented on the Website acquire, during their normal operation, some personal data whose transmission is implicit in the use of communication protocols of the Internet.

This category of data includes IP addresses or domain names of the computers used by users connecting to the site, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used to submit 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 (success, error, etc.) and other parameters relating to the operating system and the user’s computer environment.

These data, necessary for the use of the Website, are processed for the sole purpose of obtaining statistical information on the Services use (most visited pages, number of visitors per hour or day, geographical areas of origin, etc.) and to ensure the proper functioning of the Services offered.

The navigation data are not stored for more than seven days and are deleted immediately after their aggregation, without prejudice to the possible requests of judicial authorities to ascertain criminal offenses.

3. PROCESSING PURPOSE AND LEGAL BASIS

The personal data which the Data Controller collects, are exclusively those provided by you during the navigation of the Website and the use of its Services, including those aiming at allowing online purchases through a personal account. These data are exclusively used for:

1. allowing the use of our Website and its Services, such as the possibility of registration and completion of online purchases.

The legal basis for the data processing is (i) the execution of a contract you are part of, (ii) the compliance with a legal obligation to which the controller is subject.

1. allowing the delivery of news always kept up to date on Fedeli’s activities and promotions, delivering advertising material and/or communications and information of commercial nature and direct marketing of our Services and products, on the related offers, on discounts and any other promotional and loyalty initiative adopted, likewise to allow the delivery of newsletters both through traditional methods of contact and through totally automated ones, such as, for example, through the use of your address and/or email address.

The legal basis for the data processing is your express consent.

1. allowing to receive offers, discounts and other benefits and promotional initiatives based on your specific needs and purchase propensities, also participating to loyalty programs which require for their functioning the registration, individualization and profiling of the personal data related to purchase volumes, habits and consumption choices.

The legal basis for the data processing is your express consent.

Your personal data may be memorized either through IT tools or and paper based means.

4. DATA RETENTION OF PERSONAL DATA

The Data Controller will keep your personal data for no longer than what is deemed necessary to achieve the purposes for which they have been collected and processed.

With this purpose the surfing data and those acquired through the use of the Website are not stored for more than seven days.

Regarding processing for direct marketing and/or profiling purposes, in compliance with the applicable legislation and if explicitly authorized by you, the Data Controller provides for the automatic erasure of your personal data or ensures that they are permanently transformed in an anonymous form which will not be reversible, within 24 months from the registration of data collected for marketing purposes and within 12 months from the registration of data collected for profiling purposes.

For any further personal data, not being able to accurately determine the retention period, the Data Controller will ground the processing of your personal data on the principles of adequacy, relevance and data minimization, pursuant to the European Regulations, verifying on an annual basis the need for storage. Therefore, once the purpose for which the data has been collected and processed has been fulfilled, it will be removed from our systems and records and/or will be adequately rendered anonymous to ensure you cannot be identified.

The abovementioned clauses shall not prevent us from storing such data in order to comply with the regulatory obligations, or to ascertain exercise or defend our rights before the Judicial bodies.

5. CATEGORIES OF RECIPIENTS OF THE PERSONAL DATA

The processed data will not be disclosed to third parties. However, third parties may acquire knowledge about your data during the abovementioned processing activities.

• individuals who may access data pursuant to European Union law or the law of a Member State to which the Data Controller is subject to;
• subjects performing within the borders of the European Union, in complete autonomy, as separate Data Controllers, or as Data Processors appointed for this purpose by Fedeli, purposes auxiliary to those activities and Services under para. 3, such as postal services and shipping and delivery agencies, companies offering publicity and marketing services, IT support and consultation in charge of planning and implementing software and websites, companies offering services useful to personalize and optimize our services, including those aiming at delivering and managing client services, law firms, societies which offer services, our commercial partners, societies which offer services useful to analyze and develop data (including those related to interactions between users and our services) and elaborate and conduct market research, service centers, societies or consultants charged to provide further services to the Data Controller within the limits of the purpose for which data has been collected.

Furthermore, our employees may come to knowledge of your personal data, provided these have previously been appointed as acting under the authority of the Data Controller, pursuant to article 29 of the European Regulation, or as a System Administrator.

Any communication of your personal data will take place in full compliance with the European Regulations and the technical and organizational measures of the Data Controller to ensure an adequate level of security.

6. PERSONAL DATA TRANSFER TO THIRD COUNTRIES

The Data Controller does not intend to transfer your personal data to third Countries. The entire data processing will occur within the borders of the European Union.

7. POSSIBLE AUTOMATED DECISION MAKING PROCESSES

If you explicitly authorise the processing of your personal data for the purpose of profiling, the Data Controller will use automated decision making processes to allow you to exploit the advantages, through offers, discounts and any other benefit and promotional initiative modelled on your specific needs and purchase propensities. For the purpose of their functioning such processing activities require the registration, analysis and profiling of (i) identification personal data and (ii) personal data related to purchase volume and habits and consumption choices.

The basis for profiling activities is to send promotions or discounts which keep count of made purchases and based on what could possibly be of your interest.

Pursuant to art. 22, (3) of the European Regulation, the Data Controller implement all the most appropriate measures to protect your rights, your freedoms and your legitimate interest even when the profiling process occurs, as well as any other legitimate right as better explained in para. 9 (“Data Subject’s rights”) of this Privacy Policy. For this reason, the profiling activity will only and exclusively be carried out prior your necessary and explicit consent and a possible lack of consent will not impede the possibility of utilizing the Website and/or make purchases.

8. NATURE OF DATA PROVISION

The provision of personal data for the purposes listed at para 3.A is mandatory and the refusal to provide the required personal data may lead to Fedeli’s impossibility to allow your use of the Website, including the possibility to register and complete online purchases.

The provision of personal data for the purposes listed at para 3.B is discretionary, but the failure to provide them, even if it does not impede the use of the Website may lead to the impossibility of allowing you to exploit to the fullest the advantages offered to our community through information of advertising, commercial and direct marketing nature, to receive our newsletters as well as information on additional services, on events and promotions aimed to be offered to you.

The provision of personal data for the purposes listed at para 3.C is discretionary, but the failure to provide them, even if it does not impede the use of the Website may lead to the impossibility of delivering personalized communications based on purchase volumes as well as habits and consumption choices.

9. DATA SUBJECT’S RIGHTS

Regarding the processing of your personal data pursuant to the European Regulation, as data subjects you are entitled to the following rights

• revoke your consent to data processing at any time. However, it should be noted that revoking the consent will not undermine the legitimacy of any previous processing activity, as provided by article 7, section 3, of the European Regulation;
• request to the Data Controller access to your personal data, as provided by article 15 of European Regulation;
• require the Data Controller to rectify or complete your personal data, by means of a declaration, as provided by article 16 of European Regulation;
• require the Data Controller to erase your personal data, in the cases provided in article 17 of the European Regulation;
• obtain from the Data Controller restriction of processing whenever the cases provided in article 18 of the European Regulation occur;
• receive from the Data Controller your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance as provided by article 20 of the European Regulation;
• object at any time, on grounds relating to your particular situation, to processing of personal data concerning you pursuant to point (e) or (f) of Article 6, para, 1, including profiling based on those provisions, as provided by article 21 of the European Regulation;
• not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, unless the processing is based on your prior consent pursuant Article 22 of the European Regulation. By way of example, any form of automatic personal data processing aimed at analyzing or profiling consumer and purchasing preferences, economic capabilities, interests, reliability, and behavior;
• lodge a complaint with a supervisory authority (Article 77), or the relevant Judicial bodies if you deem that the processing of your personal data relating infringes the General Data Protection Regulation. The complaint may be filed in the Member State of your habitual residence, place of work, or place of alleged infringement.

You may exercise your rights by contacting the Data Controller, in the person of the legal representative, addressing the communication to the office in Via Arosio n. 4, Monza (MB), or at the email address luigifedelisrl@legalmail.it.

10. CONSENT TO DATA PROCESSING

Read and understood the abovementioned policy, I hereby freely and expressly consent to the processing of my personal data for the purpose of para. 3.A aiming at allowing the use of the Website.

Read and understood the abovementioned policy, I hereby freely and expressly

□ AGREE □ DISAGREE

to the processing of my personal data for the purpose of para. 3.B aiming at allowing the delivery of newsletter, commercial communications, promotional and direct marketing, both through traditional contact methods and totally automated ones (with the remaining possibility to manifest in any moment the wish to receive communications for said purposes exclusively through traditional contact methods).

Read and understood the abovementioned policy, I hereby freely and expressly

□ AGREE □ DISAGREE

to the processing of my personal data for the purpose of para. 3.C, including those relative to the delivery of offers, discounts and any other benefit and promotional initiative basing on my specific needs and purchase propensities.