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PRIVACY INFORMATION NOTE - Art. 13 Leg. Decree 196/2003

PRIVACY INFORMATION NOTE - Art. 13 Leg. Decree 196/2003


Pursuant to this privacy policy, drawn up in compliance with art. 13 of Legislative Decree no. 196 of 30th June 2003, Code on Personal Data Protection (herein after referred to as the “Code”), Thun S.p.A., with legal office in Bolzano, via Galvani no. 29, Tax Code, VAT number and registration in the Business Registry of Bolzano 00833770217 ("Thun S.p.A.") and Triboo Digitale S.r.l., with registered office in Viale Sarca, 336 - 20126, Milan (MI) Italy, Tax Code, VAT number and registration in the Business Registry of Milan 02912880966 (“TD”), in quality of joint Data Controllers (herein after, jointly referred to as “Joint Data Controllers”), intend to provide any useful information concerning processing of personal data concerning visitors of website www.thun.com (herein after referred to as the “Site”) and those who purchase products on said website.

If you wish to complete the registration process and/or use the website services offered to those accessing the reserved areas (e.g: make a purchase and instrumental activities to the same, including operations relating to administrative and tax obligations, sending of newsletters (where requested), please complete the fields below and accept this Information Note. Conferral of data pursuant to the registration form and/or the purchase of products, plus any other personal data requested to complete the payment and shipping formalities, is required to process the order and execute the contract; failure to confer personal data may make it impossible to complete the product purchase procedure and/or receive the requested services. All collected personal data shall be processed mainly using electronic systems, and sometimes paper based systems.

To conduct such activities functional to the sale of products via the website, Triboo Digitale processes, in its capacity as co-Data Controller, and in accordance with the applicable privacy code, user data such as name and surname, residence and information on credit cards used by users (such as first and last name of the card holder, card number, expiration date, security code).

Triboo Digitale processes data of website visitors and customers for the purposes of management of the same, as well as to the conclusion and execution of commercial transactions involving the purchase of products through the Site. Hence, the Data Controller with regards to additional activities not related to the sale of products through this web site (such as for example and not limitedly to, transmission of advertising material, sale communications, promotions) is exclusively Triboo Digitale.


PROCESSING SCOPE

The personal data collected in the forms to register to the Site services and/or data potentially collected when browsing the website will be processed for the following scopes:

(i) to reply to information requests and/or allow registration to the Site, access and execute the services reserved to users registered to the Site and potential, simplified transmission through the Site, of a purchase order concerning products available on the Site and consequent stipulation of the buy and sale agreement;

(ii) prior explicit and specific authorisation of the concerned party, for Thun S.p.A.’s marketing scopes, allowing the transmission of promotional notices, reserved sales, newsletters, novelties, market and/or statistic surveys, customer satisfaction questionnaires. The data will not be diffused nor disclosed;

(iii) prior explicit and specific authorisation of the concerned party, to be transmitted by Thun S.p.A to partner companies for their promotional initiatives and in order for the latter to send their promotional communications on products and services. Thun S.p.A.’s partner firms belong to the so called “large-sale retail sector” or the following product categories: clothing, publishing, electronics and computers, finance and insurances, tourism and accommodation providers, grocery, couponing, cosmetics, pharmaceutical and giftware.

Moreover, Thun S.p.A. can use your data also to send advertising emails on its products and services, in line with your previous purchases, unless you deny said use by exercising your objection right with the methods foreseen below (art. 130, par. 4, Legislative Decree 196/2003).


NATURE OF THE CONFERMENT AND CONSEQUENCES OF A POTENTIAL REFUSAL

Conferment of your data is not compulsory but is necessary to conclude the registration process to the Site and complete the purchase. Should you refuse to confer the afore-cited data, we will not be able to provide the requested services.


PROCESSING METHOD

The Joint Data Controllers decide the data processing scopes, methods and tools to implement to ensure security.

Your personal data will not be transferred outside the European Union. Should this take place, the Data Controller will request your specific consent.

Any use of your credit card data for scopes other than verifying the existence of the payment method, charge, management of payments and potential claims and disputes, is excluded. In view of this scope, the aforementioned data will also be processed by the bank that provides services related to the management of online payments and institute that issued the credit card that you will enter to place your order.


DATA SUPERVISORS

To obtain the complete list of Data Supervisors, please contact Customer Service or send an email to the following email address: privacy@thun.it for Thun S.p.A., and privacy@triboo.it for Triboo Digitale.

The categories of data processors for the aforementioned scopes are the operators in charge to manage the site, accounting, customer service, marketing activities (when consent is granted), information systems and third companies that process data on our behalf (e.g. maintenance of IT services, carriers and shippers, legal consultants, companies that realise and/or manage promotional campaigns, etc.); in conclusion, data can be disclosed to legal authorities.


RIGHTS OF THE CONCERNED PARTY

Pursuant to art. 7 of the Code that for the sake of full disclosure is transcribed at the bottom of this policy, you have the right to obtain data updating, correction, integration, cancellation and transformation in anonymous form. Moreover, you can object the processing of your data for marketing scopes or for the transmission of business communications by contacting Thun S.p.A. at the abovementioned email address or by sending an email at privacy@thun.it and/or Triboo Digitale S.r.l., at the abovementioned mailing address or by sending an email at privacy@triboo.it. You can request the complete and updated list of Data Supervisors with the same methods.

/>Please find below the text of Art. 7 of the Code for easier reference:


Art. 7. Rights to access personal data and other rights

1. The Data Subject has the right to request confirmation as to whether or not personal data concerning you exists, regardless of their being already recorded, and communication of such data in an intelligible form.

2. The Data Subject has the right to obtain indications on:

a) the source of the personal data;

b) the purpose and processing methods;

c) the logic applied to processing if the same is carried out with the use of electronic means;

d) the personal data of the Controller, the Chief Data Processors and the designated representatives pursuant to Art.5 paragraph 2;

e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of such data in their capacity as Designated Representatives for the Country or Chief Data Processors;

3. The Data Subject has the right to obtain:

a) updating, rectification or, where interested therein, integration of the data;

b) erasure, anonymisation or blocking of data that have been processed unlawfully, including data whose retention is necessary for the purpose for which they were collected or subsequently processed;

c) certification to the effect that the operations as per items a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared to the right that is to be protected.

4. The Data Subject is entitled to oppose, totally or partially:

a) for legitimate reasons, the processing of your personal data, despite them being relevant to the purpose of the collection;

b) the processing of your personal data for the distribution of advertising materials or direct sales or for market research or business communications.