PRIVACY & COOKIE POLICY

INFORMATION NOTICE PURSUANT TO ART. 13 OF EU REGULATION 2016/679 – GDPR – INFORMATION ON THE PROCESSING OF PERSONAL DATA COLLECTED FROM THE DATA SUBJECT

IN COMPLIANCE WITH THE GENERAL DATA PROTECTION REGULATION (EU) 2016/679, WE HEREBY PROVIDE THE REQUIRED INFORMATION REGARDING THE PROCESSING OF PERSONAL DATA PROVIDED. THIS NOTICE DOES NOT APPLY TO OTHER WEBSITES THAT MAY BE ACCESSED THROUGH LINKS AVAILABLE ON WEBSITES UNDER THE DATA CONTROLLER’S DOMAIN, AND THE DATA CONTROLLER SHALL NOT BE HELD RESPONSIBLE IN ANY WAY FOR THIRD-PARTY WEBSITES.

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THIS INFORMATION NOTICE IS PROVIDED PURSUANT TO ART. 13 OF THE GENERAL DATA PROTECTION REGULATION (EU) 2016/679 – GDPR. IT ALSO TAKES INTO ACCOUNT RECOMMENDATION NO. 2/2001 ADOPTED ON MAY 17, 2001 BY THE EUROPEAN DATA PROTECTION AUTHORITIES MEETING WITHIN THE WORKING PARTY ESTABLISHED UNDER ART. 29 OF DIRECTIVE 95/46/EC, WHICH IDENTIFIED CERTAIN MINIMUM REQUIREMENTS FOR THE ONLINE COLLECTION OF PERSONAL DATA, PARTICULARLY REGARDING THE METHODS, TIMING, AND NATURE OF THE INFORMATION THAT DATA CONTROLLERS MUST PROVIDE TO USERS WHEN THEY ACCESS WEB PAGES, REGARDLESS OF THE PURPOSE OF THE CONNECTION, AS WELL AS DIRECTIVE 2002/58/EC, AS AMENDED BY DIRECTIVE 2009/136/EC, REGARDING COOKIES AND THE ITALIAN DATA PROTECTION AUTHORITY’S PROVISION “SIMPLIFIED PROCEDURES FOR THE INFORMATION NOTICE AND ACQUISITION OF CONSENT FOR THE USE OF COOKIES – MAY 8, 2014” AND SUBSEQUENT CLARIFICATIONS.

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PERSONAL DATA (ART. 4 GDPR)

“PERSONAL DATA” MEANS 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 THAT PERSON’S PHYSICAL, PHYSIOLOGICAL, GENETIC, MENTAL, ECONOMIC, CULTURAL, OR SOCIAL IDENTITY.

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SPECIFIC INFORMATION NOTICES

SPECIFIC INFORMATION NOTICES MAY BE PROVIDED ON CERTAIN PAGES OF THE WEBSITE IN RELATION TO PARTICULAR SERVICES OR PROCESSING ACTIVITIES INVOLVING THE DATA PROVIDED.

DATA CONTROLLER

PURSUANT TO ARTS. 4 AND 24 OF THE GDPR, THE DATA CONTROLLER IS MARIELLA MARTINATO SAS – VIA TORINO 33 – 35010 TREBASELEGHE, REPRESENTED BY ITS LEGAL REPRESENTATIVE PRO TEMPORE. THE DATA CONTROLLER’S CONTACT EMAIL IS INFO@MARTINATO.COM.

DATA PROTECTION OFFICER (DPO)

THE DATA PROTECTION OFFICER (DPO) IS APPOINTED PURSUANT TO ARTS. 37–39 OF EU REGULATION 2016/679. THE DPO’S CONTACT EMAIL IS INFO@MARTINATO.COM.

PURPOSES AND LEGAL BASIS OF PROCESSING

PERSONAL DATA WILL BE PROCESSED IN COMPLIANCE WITH THE CONDITIONS OF LAWFULNESS SET OUT IN ART. 6 OF EU REGULATION 2016/679 FOR THE FOLLOWING PURPOSES:

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A) SERVICES PROVIDED BY MARIELLA MARTINATO SAS:

• BROWSING THIS WEBSITE;

• CONTACT REQUESTS, CUSTOMER CARE, AND ASSISTANCE REGARDING MARIELLA MARTINATO SAS SERVICES;

• COLLECTION OF DATA TO ACCESS SERVICES PROVIDED BY THE DATA CONTROLLER;

• ONLINE PURCHASES AND RELATED ADMINISTRATIVE AND ACCOUNTING ACTIVITIES, INCLUDING INTERNAL ORGANIZATIONAL, ADMINISTRATIVE, FINANCIAL, AND ACCOUNTING ACTIVITIES, PERFORMANCE OF CONTRACTUAL AND PRE-CONTRACTUAL OBLIGATIONS, INFORMATION ACTIVITIES, SHIPPING, AND RETURNS;

• COMPLETION OF DATA COLLECTION FORMS RELATING TO MARIELLA MARTINATO SAS SERVICES AND ACTIVITIES AIMED AT ENABLING SINGLE AUTHENTICATION OR SINGLE IDENTIFICATION THROUGH A SINGLE SIGN-ON (SSO) SYSTEM.

B) DIRECT MARKETING, NEWSLETTERS, PROMOTIONS, MARKET RESEARCH, CUSTOMER SATISFACTION SURVEYS, AND DIRECT SALES

PERSONAL DATA MAY BE USED TO SEND INFORMATIONAL, PROMOTIONAL, COMMERCIAL, AND ADVERTISING MATERIAL, AS WELL AS INFORMATION REGARDING EVENTS, INITIATIVES, PRODUCTS, SERVICES, OFFERS, AND PROMOTIONS BY MARIELLA MARTINATO SAS, THROUGH AUTOMATED MEANS SUCH AS EMAIL, MMS, SMS, BEACONS, SOCIAL NETWORKS, APPLICATIONS, AS WELL AS TELEPHONE CALLS WITH AN OPERATOR, REGULAR MAIL, OR OTHER COMMUNICATION CHANNELS.

DATA MAY BE ENTERED INTO THE COMPANY CRM. MARIELLA MARTINATO SAS MAY USE NEWSLETTER AND PROMOTIONAL COMMUNICATION SYSTEMS WITH REPORTING FUNCTIONS TO MEASURE AND, WHERE APPROPRIATE, IMPROVE THE RESULTS OF ITS COMMUNICATIONS.

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C) PROFILING

PERSONAL DATA MAY BE PROCESSED TO CREATE A CUSTOMER PROFILE AND ANALYZE CONSUMPTION HABITS, CHOICES, AND PURCHASING BEHAVIOR, WHERE APPLICABLE, IN ORDER TO IMPROVE THE COMMERCIAL OFFER AND SERVICES PROVIDED AND TO ENABLE COMMUNICATIONS THAT MAY BE OF INTEREST TO THE CUSTOMER.

THIS MAY ALSO INCLUDE CUSTOMER CARE ACTIVITIES INVOLVING PERSONALIZED SALES, AFTER-SALES, AND COURTESY SERVICES. THESE PURPOSES MAY ALSO BE PURSUED THROUGH THE INCLUSION OF DATA IN THE COMPANY CRM.

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PROCESSING FOR PURPOSE A) IS BASED ON LEGITIMATE INTEREST PURSUANT TO ART. 6(1)(F) GDPR, TAKING INTO ACCOUNT THE REASONABLE EXPECTATIONS OF THE DATA SUBJECT AT THE TIME AND IN THE CONTEXT IN WHICH THE PERSONAL DATA IS COLLECTED.

PROCESSING FOR PURPOSE B) IS BASED ON CONSENT PURSUANT TO ART. 6(1)(A) GDPR.

PROCESSING FOR PURPOSE C) IS BASED ON CONSENT PURSUANT TO ART. 6(1)(A) GDPR.

RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL DATA

PERSONAL DATA PROVIDED MAY BE DISCLOSED TO RECIPIENTS WHO PROCESS THE DATA AS PROCESSORS PURSUANT TO ART. 28 GDPR AND/OR TO PERSONS ACTING UNDER THE AUTHORITY OF THE DATA CONTROLLER OR PROCESSOR PURSUANT TO ART. 29 GDPR.

DATA MAY BE DISCLOSED TO COMPANIES CONTRACTUALLY LINKED TO MARIELLA MARTINATO SAS, AFFILIATED AND/OR CONTROLLED COMPANIES WITHIN THE EUROPEAN UNION AND IN NON-EU COUNTRIES, IN COMPLIANCE WITH APPLICABLE LAW.

DATA MAY ALSO BE DISCLOSED TO:

• SALES AND DISTRIBUTION NETWORKS;

• PROVIDERS OF INFORMATION SYSTEMS, TELECOMMUNICATIONS, EMAIL, CRM, MAILING LIST, E-COMMERCE PLATFORM, APP, AND CALL CENTER SERVICES;

• THIRD PARTIES SUPPORTING ONLINE PURCHASES, ADMINISTRATIVE AND ACCOUNTING ACTIVITIES, SHIPPING, AND RETURNS, INCLUDING BANKS, INSURANCE COMPANIES, AND COURIERS;

• PROFESSIONAL FIRMS OR COMPANIES PROVIDING CONSULTING AND ASSISTANCE SERVICES;

• COMPETENT AUTHORITIES WHERE REQUIRED BY LAW OR BY PUBLIC AUTHORITIES.

THE UPDATED LIST OF DATA PROCESSORS IS AVAILABLE AT THE REGISTERED OFFICE OF MARIELLA MARTINATO SAS – VIA TORINO 33 – 35010 TREBASELEGHE (PD), OR BY WRITING TO INFO@MARTINATO.COM.

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TRANSFER OF DATA TO A THIRD COUNTRY AND/OR INTERNATIONAL ORGANIZATION AND SAFEGUARDS

TO MANAGE ITS E-COMMERCE ACTIVITIES, MARIELLA MARTINATO SAS MAY USE CLOUD PLATFORMS PROVIDED BY THIRD-PARTY OPERATORS ACTING AS SUB-PROCESSORS.

FOR INFORMATION REGARDING THE SAFEGUARDS APPLICABLE TO DATA TRANSFERS, PLEASE WRITE TO INFO@MARTINATO.COM.

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DATA RETENTION PERIOD OR CRITERIA USED TO DETERMINE THE PERIOD

PROCESSING WILL BE CARRIED OUT BY AUTOMATED AND MANUAL MEANS, USING METHODS AND TOOLS DESIGNED TO ENSURE THE HIGHEST LEVEL OF SECURITY AND CONFIDENTIALITY, BY PERSONS SPECIFICALLY AUTHORIZED TO DO SO.

IN ACCORDANCE WITH ART. 5(1)(E) OF EU REGULATION 2016/679, PERSONAL DATA WILL BE KEPT IN A FORM THAT PERMITS IDENTIFICATION OF DATA SUBJECTS FOR NO LONGER THAN IS NECESSARY FOR THE PURPOSES FOR WHICH THE PERSONAL DATA IS PROCESSED.

DATA RETENTION PERIODS INCLUDE:

• WEBSITE BROWSING: SEE COOKIE POLICY;

• CONTACT REQUESTS: MAXIMUM 1 YEAR;

• REGISTERED AREA / LOGIN: MAXIMUM 2 YEARS;

• PERSONNEL SELECTION DATA: MAXIMUM 2 YEARS;

• NEWSLETTERS OR PROMOTIONAL EMAIL COMMUNICATIONS: MAXIMUM 24 MONTHS;

• ONLINE SALES: 10 YEARS.

FURTHER INFORMATION REGARDING RETENTION CRITERIA MAY BE REQUESTED BY WRITING TO INFO@MARTINATO.COM.

DATA SUBJECT RIGHTS

YOU MAY EXERCISE YOUR RIGHTS UNDER EU REGULATION 2016/679 BY CONTACTING THE DATA CONTROLLER AT INFO@MARTINATO.COM OR BY WRITING TO THE REGISTERED OFFICE INDICATED ABOVE.

YOU HAVE THE RIGHT AT ANY TIME TO REQUEST:

• ACCESS TO YOUR PERSONAL DATA (ART. 15);

• RECTIFICATION (ART. 16);

• ERASURE (ART. 17);

• RESTRICTION OF PROCESSING (ART. 18);

• OBJECTION TO PROCESSING BASED ON LEGITIMATE INTEREST (ART. 21);

• DATA PORTABILITY (ART. 20).

WITHDRAWAL OF CONSENT

WHERE PROCESSING IS BASED ON CONSENT, YOU HAVE THE RIGHT TO WITHDRAW YOUR CONSENT AT ANY TIME WITHOUT AFFECTING THE LAWFULNESS OF PROCESSING BASED ON CONSENT BEFORE ITS WITHDRAWAL.

TO OBJECT TO PROCESSING OR EXERCISE YOUR OTHER RIGHTS, YOU MAY WRITE TO INFO@MARTINATO.COM.

TO STOP RECEIVING AUTOMATED DIRECT MARKETING COMMUNICATIONS SUCH AS EMAIL, SMS, MMS, OR SOCIAL NETWORK COMMUNICATIONS, YOU MAY USE THE AUTOMATIC UNSUBSCRIBE FUNCTIONS PROVIDED OR WRITE TO INFO@MARTINATO.COM.

YOU ALSO HAVE THE RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY.

THERE IS NO AUTOMATED DECISION-MAKING PROCESS.

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NATURE OF DATA PROVISION AND REFUSAL

THE PROVISION OF DATA FOR THE PURPOSES REFERRED TO UNDER POINT A) IS OPTIONAL BUT NECESSARY. FAILURE TO PROVIDE THE DATA REQUIRED FOR THESE PURPOSES WILL MAKE IT IMPOSSIBLE TO USE THE SERVICES PROVIDED BY THE DATA CONTROLLER.

THE PROVISION OF DATA AND CONSENT TO PROCESSING FOR THE PURPOSES REFERRED TO UNDER POINTS B) AND/OR C) IS OPTIONAL. REFUSAL TO PROVIDE CONSENT FOR THESE PURPOSES WILL HAVE NO NEGATIVE CONSEQUENCES WITH REGARD TO THE PURPOSES REFERRED TO UNDER POINT A).

PROFILING AND MARKETING ACTIVITIES ARE OPTIONAL AND WILL ONLY BE CARRIED OUT WITH THE DATA SUBJECT’S SPECIFIC CONSENT, WHERE THE DATA SUBJECT CHOOSES TO CONSENT TO PROFILING AND THE INCLUSION OF THEIR DATA IN THE CRM.

INCLUSION OF DATA IN THE CRM IS OPTIONAL AND WILL MAKE THE DATA VISIBLE TO AUTHORIZED PROCESSORS AND PERSONS WHO HAVE ACCESS TO THE SYSTEM.

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CHANGES TO THE PRIVACY POLICY

THE DATA CONTROLLER RESERVES THE RIGHT TO MODIFY, UPDATE, ADD, OR REMOVE PARTS OF THIS PRIVACY POLICY AT ITS DISCRETION AND AT ANY TIME.

DATA SUBJECTS ARE ADVISED TO PERIODICALLY CHECK FOR CHANGES. TO FACILITATE THIS, THE PRIVACY POLICY WILL INDICATE THE DATE OF ITS LATEST UPDATE.

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SOCIAL LOGIN

SOCIAL LOGIN IS A TECHNOLOGY THAT ALLOWS USERS TO AUTOMATICALLY SHARE CERTAIN PERSONAL DATA STORED WITHIN A SOCIAL NETWORK WITH THE OPERATOR OF A WEBSITE.

FOR EXAMPLE, USERS MAY USE THIS TECHNOLOGY TO REGISTER MORE QUICKLY ON A WEBSITE, PARTICIPATE IN AN ONLINE CONTEST, OR COMPLETE AN ONLINE PURCHASE.

WITH THE USER’S PRIOR AUTHORIZATION, THE SOCIAL NETWORK WILL SEND THE WEBSITE OPERATOR THE PERSONAL DATA NECESSARY FOR REGISTRATION, PARTICIPATION IN THE CONTEST, ONLINE PURCHASE, OR OTHER REQUESTED ACTIVITY, WITHOUT THE USER HAVING TO ENTER THE REQUIRED DATA MANUALLY.

FOR DETAILED INFORMATION PURSUANT TO ART. 13 GDPR REGARDING THE PROCESSING OF PERSONAL DATA WHEN USING THIS TECHNOLOGY, PLEASE REFER TO THE WEBSITES OF THE THIRD-PARTY PROVIDERS OPERATING THE RELEVANT SOCIAL LOGIN SERVICE.

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