1. DATA CONTROLLERS AND JOINT CONTROLLERS OF THE PROCESSING
Elite is the Data Controller of the processing of Data collected through this Website;
Exclusively in relation to Facebook Business Tools, (by way of example only, Facebook Cookies, plug-ins and Pixels) Gianni Elite S.r.l. and Facebook Ireland Limited, with registered office at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereinafter "Facebook") act as joint data controllers, on the basis of a specific Joint Controllership Agreement, in order to measure the level of interaction between the websites visited according to the preferences of the Data Subjects and to provide targeted advertising within the social network. Further information on how Facebook Ireland processes Data, including the legal basis to which Facebook Ireland refers and how to exercise your rights vis-à-vis Facebook Ireland, can be found in Facebook Ireland's Data Policy at Facebook Data Policy
2. THE DATA PROTECTION OFFICER
Pursuant to Article 37 GDPR, the Data Controller has designated the Data Protection Officer, (hereinafter only "DPO"), who can be reached at the following address: email@example.com
3. PERSONAL DATA PROCESSED
The following Data are processed:
Browsing data: Such as IP addresses or domain names of computers used by users who connect to the Website, URI (Uniform Resource Identifier) addresses of requested resources, the transmission of which is implicit in the use of Internet communication protocols. This information is not collected to be associated with data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. These data are used only to obtain anonymous statistical information on the use of the Website and to check its correct functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the Website: to this effect, the data on web contacts could be kept in accordance with and limited to this purpose. Starting from the IP address and the domain name of the computers used, it will be possible, limited to the purpose of ascertaining responsibility, to trace back further identification data of the user (in particular, name, surname, e-mail address, telephone number, etc.);
Data voluntarily supplied by the user: Such as identification data, like name, surname, e-mail, telephone number, tax code, etc, any other data supplied, for example, when registering on the Website in the special section, or when filling in any data collection forms on the Website, or when requesting the supply/activation of a Elite service, such as the Newsletter Service.
4. MINIMUM AGE
The protection of the safety and privacy of minors is very important to us. By registering on the Website in the appropriate section, as well as when filling out any data collection forms on the Website or when requesting the supply/registration to the Newsletter service, the Data Subject confirms that he/she is 16 years of age or, in any case, that he/she is not younger than the age indicated by the legislation of the country of residence that provides for other age limits.
5.PURPOSES AND LEGAL BASES OF DATA PROCESSING
Personal data provided by Data Subjects through the Elite Website are collected and processed for the following purposes and legal bases:
A. without prior consent for the purposes of the service and, in particular, to:
1. the execution of the contract and/or pre-contractual commitments, namely:
The use of the Website and any technical assistance;
The management of a contact request by the Data Subject;
Registration and access to the "My Elite" reserved area by the Data Subject;
Management of payments and/or finalisation of product purchase orders;
2. the fulfillment by the Data Controller of legal obligations, such as:
Compliance with the obligations provided for by laws, regulations or national and European legislation or imposed by the competent authorities
3. the pursuit of a legitimate interest of the Data Controller:
The management and maintenance of the Website: the interest of the Data Controller relates to the general interest of a company in guaranteeing business operations, also through the operation of the Website, and possible improvements in the service offered.
Preventing or detecting fraudulent activities or abuses harmful to the Website, as well as exercising the rights of the Data Controller in court and manage the litigation: the interest of the Data Controller refers to the general, real and current interest not to suffer damages as a result of illegal conduct of others, as well as the right of action (art. 24 Italian Constitutional Chart) and, as such, is socially recognized as prevailing over the interests of the data subjects;
The sending to the data subject, when already our customer, of commercial communications relating to services and products of the Data Controller similar to those you have already used; the interest of the Data Controller refers to the general interest of a company to promote its services and is considered legitimate because it is in line with the reasonable expectations of the data subjects, taking into account the relationship between them and the Data Controller itself. Each e-mail sent will allow the data subjects, by clicking on the appropriate link, to refuse further sending.
B. Only by prior consent to:
1.Marketing purposes, in particular to:
Send promotional messages following the activation of the newsletter service, and commercial proposals (by mail, e-mail, operator telephone, fax, sms, mms, social media, social chat) relating to Elite products and services, for the sending of advertising material on Elite products and services, as well as catalogs and brochures or invitations to events, and in general commercial communications on Elite and its initiatives, as well as for carrying out market research and surveying the degree of customer satisfaction.
2. Profiling purposes, namely:
To analyse the Data collected, including by automated means, and use it to process, communicate and allow Data Subject to take advantage of services, initiatives and personalised offers designed according to Data Subject's interests, habits and propensity to consume. The Data Controller may also use the data of the Data Subject to create "clusters" (homogeneous groups made up of profiles that present a degree of correlation) depending on the habits and propensities of consumption in order to develop targeted digital campaigns in line with the preferences of individual users.The Data Controller may analyse the Data also to carry out surveys. To this end, we can also use dedicated automated software (e.g. CRM)
3. Purpose of using Facebook tools for measuring and analyzing interactions with web pages visited by Data Subjects and providing targeted advertising on Facebook's social network, specifically:
The Company and Facebook Ireland Limited will process, as Joint Data Controllers as described in paragraph 1. the data relating to the interactions with the websites visited by the Interested Parties through the use of Facebook Business Tools (by way of example only, Cookies, plug-ins and Facebook Pixel). In particular, the Elite Website uses social plug-ins. Social Plug-ins are special tools that make it possible to incorporate Social Network functions directly into the Website (e.g. the Facebook "like" function). When you visit a page on our Website and interact with the plug-in (e.g. by clicking the "Like" button) or leave a comment, the corresponding information is transmitted from your browser directly to the social networking platform (in this case Facebook) and stored there. Further information on how Facebook Ireland processes the Data, including the legal basis to which Facebook Ireland refers and on how to exercise your rights towards Facebook Ireland, can be found in Facebook Ireland's Data Policy at Facebook Data Policy.
4. Purpose of using Facebook services for measuring the interests and habits of the Website's audience and providing targeted advertising on the Facebook social network:
The Company will process Data relating to the interests, preferences and behavior of the Data Subjects on the Website by means of the Facebook Custom Audience product, in order to provide targeted advertising within the Facebook social network. This processing involves, if consent is given by the Data Subjects, the communication of data to Facebook in order to proceed with the creation of custom audience lists and the subsequent delivery of targeted advertising. For this processing, Facebook acts as the Company's data processor. For more information on the product, please consult Facebook's Terms and Conditions at the following link Facebook T&C.
6. DATA PROVISION
The provision of Data with respect to the purposes referred to in paragraph A) is mandatory and any refusal will make it impossible for the Company to carry out the contractual obligations undertaken and the execution of legal obligations, or to respond to your requests. As regards the purposes referred to in letter B) the provision of personal data is optional and their use is conditional on the release of an explicit consent by the Data Subject. Any refusal to grant consent has no effect other than that of not being able to inform the interested parties about initiatives of the Company that might interest them and of not being able to proceed with the analysis of their purchasing habits and preferences, as well as the use of measurement tools and interaction with Facebook.
7. MODALITIES OF PROCESSING ACTIVITIES
The processing of Data of Data Subjects is carried out - with electronic modalities - by means of the operations of collection, registration, updating, organization, conservation, consultation, elaboration, modification, selection, extraction, comparison, use, interconnection, blocking, cancellation and destruction of the Data. Data will be processed by the Company and its employees using computer systems (as well as manual means) in accordance with the principles of fairness, loyalty and transparency provided for by the applicable legislation on personal data protection and protecting the confidentiality of the Data Subject and his/her rights through the adoption of appropriate technical and organizational measures to ensure a level of security appropriate to the risk. Specific security measures are observed to prevent data loss, illegal or incorrect use and unauthorized access.
8. DATA RETENTION
With reference to the purposes set forth in points A) of par. 5 (Purposes of the processing), Data will be processed for the entire duration of the relationship in order to achieve the aforementioned purposes. Data functional to the fulfilment of eventual legal obligations will be stored also afterwards, in compliance with such obligations and in accordance with the retention periods provided for by the applicable regulations from time to time.
For Data provided for the purposes of B, nos. 1. (marketing) and 2. (profiling) referred to in par. 5 (Purposes of the processing), due to the fact that the personal data stored relate purchases of 'high-end' products and that the average annual frequency of purchase, for each customer, is spaced out over time, Data provided by you will be retained for a maximum period of 7 years, considering that this time span is appropriate and proportionate to both the purposes that are intended to be achieved and the type of personal data being processed. Upon expiry of this period, the data will be deleted or made anonymous and in any case the Data Subjects may always provide new consent to the processing to the Company for the same purposes.
For the Data provided for the purposes under point B, no. 3. (use of Facebook Business Tools) of par. 5 (Purposes of the processing), the Data will be processed in accordance with the provisions of Facebook's Data Policy, available at Facebook Data Policy
For the Data provided for the purposes set forth in point B, no. 4 (use of Facebook custom audience services) of par. 5 (Purposes of the processing), the Data will be processed by Elite for the duration of its contractual relationship with Facebook and until the Data Subject's consent is modified or the Data Subject requests cancellation.
9. EXTRA EU DATA TRANSFERS
10. DATA SUBJECTS' RIGHTS
Data Subjects may exercise, in relation to the data processing described therein, the rights provided for by the European Regulation (Articles 15-21), including the right:
To receive confirmation of the existence of their personal data and access to their content (rights of access);
To update, modify and/or correct your personal data (right of rectification);
To request the deletion or limitation of data processed in violation of the law, including data whose retention is unnecessary for the purposes for which the data were collected or otherwise processed (right to be forgotten and right to limitation);
To object the processing of personal data (right to object);To withdraw consent, where given, without prejudice to the lawfulness of the processing based on the consent given before withdrawal;
To lodge a complaint with the Supervisory Authority in the event of breach of personal data protection regulations;
To receive a copy of the personal data provided to the Company in a structured, commonly used and machine-readable format, and request that such data be transmitted to another data controller (right to data portability).
11. REDIRECT TO EXTERNAL SITES
Elite’s Websites use so-called social plug-ins. Social Plug-ins are special tools that allow to incorporate Social Network functionality directly into the Website (e.g. the Facebook’s “Like” function). All social plug-ins on the Website are identified by the respective logo owned by the social network platform.
Elite's Websites may also contain links, including hyperlinks, widgets, banners, cross-references to external sites and/or platforms operated by parties other than Elite. For information on the purposes, type and manner of collection, processing, use and storage of personal data by such platforms, please consult their respective privacy policies.