Welcome to the www.cellularlinegroup.com website (the “Site”).
The processing of Personal Data of website users will be performed in Italy and conducted in accordance with applicable European legislation and the Personal Data Protection Code (Legislative Decree 30 June 2003, No. 196), which governs the processing of personal data by anyone who resides or has a registered office in Italy. The Data Controller is Cellular Italia S.p.A. a single-member company, with registered seat in Reggio Emilia, via G. Lambrakis no. 1/A, tax code, VAT no. and Reggio Emilia Business Register no. 08026760960, (“Cellular Italia” or the “Data Controller”). Triboo Digitale Srl – with registered office in Viale Sarca 336 – Edificio 16, post code 20126, Milan (MI) Italy, tax code, VAT number and Milan Business Register no. 02912880966 (“Triboo Digitale”) which is only responsible for managing the sales and transactions on the Site, (for instance, management of product orders, sales and deliveries, returns and warranty management and all other activities related to the sales of products via the Site). To conduct such activities functional to the sale of products via the Site, 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). Therefore, Cellular Italia is the exclusive Data Controller for personal data in relation to all further activities which are not functional to the sale of the products via the Site (such as, by way of example only, the sending of advertising material, commercial communications, promotions, marketing, user profiling).
1. THE POLICY
2. WHO PROCESSES YOUR PERSONAL DATA, HOW AND FOR WHAT PURPOSES
The personal data provided on the Site shall be processed exclusively by Triboo Digitale in order to manage, conclude and process the commercial transactions concerning the purchase of products via the Site (General Purpose) and/or the Data Controller, upon receiving express and specific consent of the user, to conduct marking and/or profiling activities on the consumer habits and selections of the user (“Marketing Purposes” and together with the General Purposes, the “Purposes”). The Data Controller and TD decide the respective purpose and processing methods to be implemented and the tools to be used as far as security measures are concerned. For purely organisational and functional requirements, we have appointed some Chief Processors to manage user Personal Data, for purposes strictly linked and related to the provision of services on the Site, including the sale of products. Such Chief Data Processors have been selected on account of their experience, capabilities and reliability, thorough compliance with the provisions in force applying to processing as also related to security matters. Chief Data Processors process the Personal Data of Site users following the instructions provided respectively by the Data Controller and Triboo Digitale.
Please contact the Customer Care service for a complete list of those assigned to processing your Personal Data or send an email to the Data Controller at firstname.lastname@example.org; or to Triboo Digitale at the following address: email@example.com.
In particular, to achieve our General Purposes, and as part of the process when purchasing products on the Site,we collect Personal Data (e.g. name and surname, e-mail address, mailing address, credit card and bank details, telephone number) via the product order form available on the Site.
Personal Data are mainly processed in electronic format and in certain cases also in paper format, such as for instance, when the processing of personal data is necessary to prevent fraud on the Site.
Personal Data shall be retained in the form that allows you to be identified for the time strictly necessary for the purpose for which the data were collected and subsequently processed and, in any case within the limits foreseen by the laws in force. To ensure that Personal Data is always accurate and updated, pertinent and complete, you are asked to kindly notify us of any changes to the same sending us an email to: firstname.lastname@example.org.
Further to what already provided for above, Personal data shall not be disclosed to third parties for purposes not permitted by law or without your express consent.
Personal data is made available to third parties, for ancillary purposes related to the provision of services required by the user (for example, for purchase related transactions). For further details on this aspect, please consult paragraph 4 (Whom we disclose Personal Data to). Users can at any time obtain an updated list of Chief Data Processors by sending a request to the Data Controller at the e-mail address email@example.com; or to Triboo Digitale at the following email address: firstname.lastname@example.org.
Your personal data can be disclosed to Police forces or Judicial authorities, for instance pursuant to Site anti-fraud services, in accordance with the laws in force and whenever requested. Your Personal Data will also be accessible to Chief Data Processors as indicated in paragraph 2 and for the specific purposes listed therein. Personal data will not be transferred abroad to Countries other than those belonging to the European Union, which do not guarantee a sufficient level of privacy protection. If the above should be necessary to achieve our Purposes, we will ensure that the transfer of Personal Data to Countries which do not belong to the European Union and do not guarantee adequate levels of protection, will only be implemented after such parties and the Data Controller and/or Triboo Digitale have all signed specific contracts containing clauses for the protection of Personal Data, in accordance with applicable law and regulations.
The purposes for which your Personal Data are processed shall be specifically disclosed each time in the Information Note text provided on the page where the same are requested to confer their Personal Data.
There may be cases where the Data Controller and/or Triboo Digitale processes third-party personal data communicated directly by the Data Controller and/or Triboo Digitale users, e.g. when the user intends to tell a friend about a service or product on sale at the Site, or when the user purchases a product to be sent to a friend or when the subject paying for the purchase is different to the subject to whom it will be delivered.
3. DENYING CONFERRAL OF PERSONAL DATA AND RELATIVE CONSEQUENCES
Conferral of Personal Data to the Data Controller and/or Triboo Digitale and, in particular, personal data, your email address, your mailing address, your credit card/debit card and bank details and phone number, is required in order to fulfil our General Purposes.
Some of the aforementioned data may be indispensable so as to fulfil the obligations imposed by the law or other regulations, or to provide other services you may have requested as provided on the Site.
Refusal to disclose certain essential Personal Data, identified on the Site by an asterisk (*), may make it impossible to complete all purchase contract phases, and/or fulfil all obligations required by the laws and regulations in force. Failure to disclose certain Data can therefore, according to individual circumstances, constitute a legitimate and justified reason preventing the execution of the purchase contract on the Site or the supply of services via the same.
On the other hand, conferral to Triboo Digitale of additional Personal Data, other than those which are compulsory, is optional and has no impact on the purchase of products on the Site.
4. TO WHOM WE DISCLOSE YOUR PERSONAL DATA
Personal Data may be disclosed and made available to third party companies that provide specific services to the Data Controller and/or Triboo Digitale, as Chief Data Processors or disclosed to other recipients of the data collected by the Data Controller and/or Triboo Digitale, who process data independently for the sole purpose of executing the purchase contract for products on the Site (such as, for instance, Global Collect, for the execution of remote electronic payment services, via credit card/debit card) and only when such a purpose is not inconsistent with the purposes for which your Personal Data was collected and subsequently processed and, in any case, in full compliance with the laws in force.
No Personal Data shall be disclosed, assigned or otherwise transferred to third parties without informing users and obtaining their consent in advance, when required by law.
5. HOW WE COLLECT YOUR DATA ON THE SITE
The Data Controller and/or Triboo Digitale collects Personal Data and other information during the online registration process or when sending order forms to purchase products on the Site so as to execute e-commerce transactions. These data are processed by the Data Controller and/or Triboo Digitale within the limits and purposes illustrated in the Information Notice presented to users in the relative data collection section.
6. SECURITY MEASURES
However, as it is impossible to guarantee that such measures for the security of the Site and the transmission of data and information on the same Site limit or exclude any risk of unauthorised access or dissemination of data, we recommend you check that you have an updated antivirus protection system installed on your computer, which protect incoming and outgoing data, and that your Internet provider uses firewalls and anti-spamming filters where suitable for the security of data transmission on the web.
7. RIGHTS TO ACCESS PERSONAL DATA AND OTHER RIGHTS
You are always entitled to receive 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.
You are always entitled to obtain from the Data Controller and/or Triboo Digitale respectively:
– updating, rectification or, where interested therein, integration of the data;
– erasure, anonymisation or blocking of your personal data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
– certification to the effect that the operations indicated above 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.
You are also entitled to oppose, totally or partially:
– on legitimate grounds, to the processing of personal data concerning you, even though they are relevant to the purpose of the collection;
– to the processing of Personal Data concerning you, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
– You are entitled to exercise your rights at any moment in time, within the terms and conditions of the law, sending such requests by e-mail to Triboo Digitale at email@example.com; we will respond to your mail as soon as possible.
For the complete list and details on your rights, please read the text of art. 7 Legislative Decree no. 196/2003 (hereafter the “Privacy Code”), provided below:
Legislative Decree no. 196 dated June 30th 2003 – Personal Data Protection Code
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 purposes and methods of the processing;
c) the logic applied to the processing, if the latter is carried out with the aid of electronic means;
d) the identification data concerning the Data Controller, data processors and the representative designated as per Section 5(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 Representatives for the Country, Chief Processors or Designated Officers.
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 unnecessary for the purposes for which they have been collected or subsequently processed;
c) certification to the effect that the operations as per letters 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 with the right that is to be protected.
4. The Data Subject is entitled to oppose, totally or partially:
a) on legitimate grounds, the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
b) the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
8. LINKS TO OTHER WEBSITES
The Site provides links to these websites exclusively to assist users in their search and browsing activities and to facilitate links to other websites on the Internet. Posting of such links does not infer that the Data Controller and/or Triboo Digitale recommend the use or browsing of these websites, nor any guarantee of their content, services or merchandise supplied and sold to Internet users.
If you wish to receive further information on how Triboo Digitale processes your Personal Data, please send an e-mail to the Data Controller at the email address firstname.lastname@example.org; or to Triboo Digitale at the following email address: email@example.com. To receive further information and be updated on the rights and the regulations concerning the protection of persons in relation to the processing of Personal Data, please visit the website of the Authority for the Protection of Personal Data at http://www.garanteprivacy.it/
10. APPLICABLE LAW
The Privacy Code ensures that Personal Data are processed by respecting data subjects’ rights, fundamental freedoms and dignity, particularly with regard to confidentiality, personal identity and the right to Personal Data protection.