PRIVACY INFORMATION STATEMENT
In compliance with Leg. Dec. 30 June 2003 no. 196 (Privacy Code) and subsequent variations, we are providing the necessary information regarding personal data processing provided by you. This information is not considered valid for other websites visited through links on websites belonging to the Controller, which is not considered in any way responsible for third-party websites. This refers to a disclosure that is made pursuant to Art. 13 of Italian Legislative Decree no. 196/2003 – Personal Data Protection Code in accordance with Directive 95/46/CE . This information is also inspired by Recommendation no. 2/2001 that the European authorities for personal data protection, collected in the Group established by art. 29 of Directive no. 95/46/CE, adopted on 17 May 2001 to identify several minimum requirements for collecting personal data on-line, and, in particular, the methods, times and nature of the information that the Data Controller must provide to users when they connect to website pages, regardless of the purposes of connecting, as well as what is provided for by Directive 2002/58/CE, as updated by Directive 2009/136/CE, regarding Cookies.
1. THE DATA “CONTROLLER”, under the terms of Article 28 of the Code regarding personal data protection is Moleskine Srl – Viale Piceno, 17 – 20129 Milan, in the person of its legal representative pro tempore.
THE DATA PROCESSOR, pursuant to Article 29 of the Code regarding personal data protection, is the Marketing and Communication Director at Moleskine Srl
PLACE DATA IS PROCESSED
Processing is carried out at the Data Controller’s premises and at appointed service providers, e.g. for maintenance and storage.
2.TYPES OF DATA PROCESSED
Personal and identifying data.
Personal data, any information about a physical person, identified or identifiable, indirectly or otherwise, by reference to any other information, including a personal identification number; identifying data, personal data that allows for the direct identification of the data subject (for example, first name, surname, date of birth, postal address, email address, telephone number, etc.).
The computer systems and software procedures put in place for the functioning of this website shall, during the course of their normal operation, obtain certain personal data the transmission of which is implicit in the use of Internet protocols and communication.
This involves information that is not collected for the purposes of association with designated interested parties, but which due to its very nature may, following procession and the cross-referencing with data held by third parties, make it possible to identify the users.
This class of data includes the IP addresses or domain names of the computers used by the users who connect to the site, the addresses in URI form (Uniform Resource Identifier) of the resources requested, the time of the request, the method used in order 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 (successful completion, error, etc.) and other parameters relating to the user’s operating system and computer environment.
Personal data may be used for defence by the Controller of the Application in court or in the preliminary stages to its possible establishment, of abuses in the use of the same or of connected services. The data may be used in order to ascertain responsibility in the event of possible instances of cyber-crime against the sites of the Controller.
Maintenance. Personal data may be processed with additional methods and purposes connected to maintenance.
Data provided voluntarily by the user
The optional, explicit and voluntary sending of email to the addresses shown by the Controller and/or through the completion of data collection forms.
Minors may not provide personal data. Moleskine Srl shall in no way be responsible for possible false declarations that may be provided by minors, and in any event, should the false nature of the declaration be ascertained, Moleskine Srl shall immediately cancel all personal data and any material acquired. The Data Controller shall facilitate requests inherent to the personal data of minors, in terms of Art. 7, 8, 9 and 10 of the Privacy Code in respect of whoever exercises parental responsibility or the legal guardian.
Third parties’ data
Should you provide us with the personal data of a third party (e.g. family members, and other parties in general), you must ensure that they have been informed and where applicable, provided their consent to the use of said data according to this disclosure.
Specific information could be presented in dedicated areas, related to special services or processing of Data provided by the Controller.
Please see the cookies policy at the following link
3. PURPOSES OF PROCESSING
Data of a personal nature shall be processed for the following purposes:
A) – browsing on this website; – contact request; REGISTRATION of the data subject through data collection forms in dedicated areas on the sites and/or App of the Controller to enlist the Controller’s services; – organisational administrative-accounting activities.
In particular for the following processing:
contact us: the user’s personal data, provided during registration, will be processed solely for purposes connected to the forwarded information request.
moleskinerie: use of customisation tools provided to users. Information that the user processes through the aforesaid tools, generates an image file – made available to the use as print output – which is retained solely for technical needs, for a period of time not exceeding 10 days; a term within which it will also be deleted.
ecriture infinie: uploading content by the user to join the art project.
myAnalogCloud: interactive game for the user
Journalists: the user’s personal data will be processed for the purpose of qualifying the user as a journalist and, as such, granting him/her access to a restricted area within which he/she will find informational text and photographic material intended to be used in communications about Moleskine.
Moleskine will provide a single sign-on of service: the user will be able to register one time only to receive all the services available on the Controller’s sites, including access to “mymoleskine”. Once the user has created his/her Moleskine profile, they can add their photo to the profile and change the name to a nickname which will appear with comments, messages and other publications; the User’s data must be updated in case of change. The User undertakes to ensure the secrecy and confidentiality of the ID and password connected to the Moleskine profile and to use log-in credentials personally, without communicating to third parties. The User is solely responsible for the proper retention and the retention of the information in question, and undertakes henceforth to honour all obligations undertaken through their use. In the event of the theft or loss of the data needed to enter the site area, the user will change these credentials, thus preventing their use by unauthorized third parties.
Interacting with private messages. Registered users will be able to send private messages to other users. Sent and received messages shall be stored for a period that shall not exceed the purposes for which the data has been collected or subsequently processed.
API CODES third parties in “mymoleskine”. The community will have third parties’ API code. The application programming interface (API), in computer programming, signifies every set of procedures available to the programmer, usually grouped to form a set of specific tools for completing a determined task within a certain programme (e.g. Drop-Box’s Moleskine Cloud, photo editing tools, IFTTT for sharing content with social networks to create chains of simple conditional instructions (so-called “recipes”), which are activated based on changes to other websites and social media services – such as Facebook, Goolge, Pinterest, Instagram. Once the user performs an action on “mymoleskine” he/she can decide to set up a resulting reaction of other social network accounts. All comments and/or other types of actions undertaken on third-party websites or other social networks and channels will be subject to the terms and conditions and privacy policies of the third parties.
Registered trademarks: in this case, personal data is processed to initiate the procedure for the granting (and any subsequent revocation) of authorization to the user to use the “Moleskine ” registered trademark on the web.
Work with us: the data provided is processed for the purpose of evaluating the possibility of establishing a working relationship between the user and Moleskine Srl and for the purposes of selecting personnel. Even if there is no follow-up to the contact established by providing a resume or other data, these will be stored by Moleskine Srl for a period of one year from the date of their acquisition, after which time they will be deleted.
Retailers: the user’s personal data will be processed for the purpose of qualifying the user as a professional retailer and, as such, granting him/her access to restricted areas of the website, within which he/she will find text and photographic material to be used for information or communications related to Moleskine. Data requested in the Retailer Contact Form is acquired and processed for the sole purpose of performing an initial examination of the user’s qualities for the purpose of evaluating his/her application to assume the role of Moleskine Retailer. Much of the data requested is optional; however, not providing it can make it impossible to evaluate the application positively. Even if there is no follow-up to the contact established by providing this data, these will be stored by Moleskine Srl for a period of two years from the date of their acquisition, after which time they will be deleted.
Distributors: the user’s personal data will be processed for the purpose of qualifying him/her as a Moleskine Distributor and, as such, granting him/her access to restricted areas of the website within which he/she will find text and photographic material to be used for information or communications related to Moleskine. Data and information requested in the Distributor Contact Form is acquired and processed for the sole purpose of performing an initial examination of the user’s qualities for the purpose of evaluating his/her application to assume the role of Moleskine Distributor. Much of the data requested is optional; however, not providing it can make it impossible to evaluate the application positively. Even if there is no follow-up to the contact established by providing this data, these will be stored by Moleskine Srl for a period of two years from the date of their acquisition, after which time they will be deleted.
Contact our distributors: in this case, the purpose of processing is solely to put the user in contact with a certain Moleskine distributor in the world.
Moleskine Artist Marketplace: this section may be used to collect the personal data of Artists wishing to market their own works based on Moleskine products and the data of users interested in buying such works. As for the data and information provided by Artists upon registration, consisting of personal data or information about their works, this shall be processed in order to permit the identification of the Artist in the cases provided for under the prevailing laws and for purposes associated with the presentation and sale of their own works through the Moleskine Artist Marketplace. In order to the registered as an Artist and gain access to the Moleskine Artist Marketplace, the User shall be asked to provide additional optional information – such as their Facebook and/or Twitter account – as well as a brief biographical description where not indicated otherwise, the request to provide data from time to time is to be regarded necessary for the purpose of perfecting the procedures to access restricted areas of the site or other specific functions.
B) for DIRECT MARKETING, newsletters, market research or other sampling research and direct sales, surveying the level of satisfaction, to receive – by automated means email, MMS or SMS messages, activation with beacons, or other types or messages, social networks and applications, as well as by operator-made telephone calls and paper mail or any other means – informational, promotional, commercial and advertising material and material related to events and initiatives on products, services, offers and promotions, from Moleskine Srl also through the managing companies in charge of processing. A list of the companies may be requested from email@example.com. The data will be included in the corporate CRM. In order to compare and possibly improve its communication results, Moleskine Srl uses systems to send out newsletters and promotional notices with reports. Based on these reports, Moleskine Srl can ascertain, for example: the number of readers, openings, single “clickers” and clicks; the operating devices and system used to read the communication; details on the activities of individual users; details of the emails sent, emails received or not received, from those sent out; All this data is used to compare and possibly improve communication results.
C) for PROFILING activities, to compile your profile and analyse your habits and consumer choices and purchasing behaviour, so as to improve the sales and services offered, enabling us to send you communications that could interest you. The processing of personal data could refer to customer care activities, comprising offers for personalised services at the points of sale and after sales, as well as complimentary services. These purposes are also pursued with the data being entered in the corporate CRM and acquired data shall also be processed by the persons in charge of the processing at Moleskine stores worldwide.
4. METHODS OF PROCESSING – RETENTION
Processing will be done using automated and manual methods, with procedures and tools aimed at guaranteeing maximum security and confidentiality, by parties specially appointed in compliance with art. 31 and foll. Leg. Dec. 196/03. The data shall be stored for a period that shall not exceed the purposes for which the data has been collected and subsequently processed and based on applicable privacy regulations.
5. EXTENT OF DISCLOSURE AND DISTRIBUTION
Who the data is shared with. Data shall be circulated only for Moleskine services for which they become necessary (Artist Marketplace and mymoleskine community), and can be communicated to companies contracted to Moleskine Srl, to associated and/or subsidiary companies within the European Union, in compliance with applicable regulations. Personal data may also be transferred abroad to non-EU countries, making it possible for you to benefit from the Programme services at all Moleskine stores worldwide, even via the managing companies. Should certain countries not guarantee adequate security standards, we shall put in place the protection measures required by applicable regulations on the protection of personal data, and we shall divulge these to third parties only when this is required by law or regulations in this regard. Data may be communicated to third parties falling under the following categories: – parties that provide services for managing the computer system used by Moleskine Srl and the telecommunication networks (including email, CRM Data Base management and mailing lists, e-commerce platforms); – offices or companies within the scope of assistance and consulting services; – the relevant authorities for compliance with legislative requirements and/or directives issued by public bodies, on request. Parties belonging to the categories above cover the function of Data Processor or operate completely independently as distinctive Data Controllers. The list of data processors is constantly updated and available at Moleskine Srl – head office at Viale Piceno, 17 – 20129 Milan or by writing to firstname.lastname@example.org
Some data and information provided by the Artists in the Moleskine Artist Marketplace – such as their photograph, their biographical information, their Facebook and/or Twitter accounts, their email address and all information describing the works offered for sale – shall be disclosed to users of the Marketplace, together with the Artist’s own user name, through publication, and therefore dissemination, on the Site.
6. NATURE OF SUPPLY AND REFUSAL
Except for what is specified for browsing data, you are free to provide personal data. The transfer of data for the purposes stated under point A) above is optional, but necessary. The refusal to supply the necessary data regarding point A) makes closely connected, instrumental activities impossible, for example, obtaining what is requested or using the services of the Data Controller. The transfer and consent to processing for the purposes under point B) and/or C) is optional. Any refusal to provide consent for the purposes detailed under points B) and/or C) above, does not result in any negative consequence regarding the purposes referred to in point A). Profiling and marketing activities are only an eventuality and shall only be done with the specific consent of the data subject, should the party consent to the profiling of their data with these being entered into the CRM. Entering data into the CRM is optional and shall result in this becoming automatically visible to those that have access, or the data processors and persons in charge of the processing at the various points of sale worldwide.
For the newsletter registration areas only, providing personal data for point B) is necessary. Any refusal to provide data related to point B) for the newsletter area only makes it impossible to receive marketing communications (as indicated in the purpose under point B).
7. RIGHTS OF DATA SUBJECTS
You can assert your rights as stated in art. 7, 8, 9 and 10 of Leg. Dec. 30 June 2003 no. 196, applying to the data controller, or to the data processor, by contacting our head office, or by sending an email to email@example.com. You are entitled to obtain confirmation, at any time, whether data exist and to know their content and origin, check their accuracy or request supplementation, updating or correction (article 7 of the Personal Data Protection Code). Based on this article, you are entitled to ask for the cancellation, transformation into an anonymous format or the blocking of data processed in violation of the law, as well as object to the data processing for legitimate reasons. Should you contact the data controller, please provide your email address, name, address and/or telephone numbers, so that the request may be managed correctly. Your rights may be exercised by dispatch of a simple written communication to be addressed to Moleskine Srl, Viale Piceno 17, 20129 Milan (Italy). As an alternative to automatic-cancellation systems, in order to stop receiving electronic direct marketing (e-mails, SMS, MMS, social networks), you can send an email at any time to firstname.lastname@example.org with the subject line “cancellation from electronic communications”. To object to profiling processing, send an email to email@example.com with the subject line “no profiling”. If you do not want to receive traditional direct marketing (telephone calls from operators, paper-based mail) send an email to firstname.lastname@example.org the subject line “cancellation of traditional”. If you do not want to receive any direct marketing communication, send an email to email@example.com with the subject line “cancellation of marketing” and we will not disturb you further.
8. CHANGES TO THE PRIVACY INFORMATION NOTICE
The data controller reserves the right at any time to amend, update, add or remove sections of this privacy disclosure at its discretion. The Data Subject must check periodically for any changes. To facilitate such checking, the Information Notice will contain the date of updating of the Information Notice. Use of the website after publication of the changes will constitute acceptance of these changes.
9. FACEBOOK SOCIAL PLUGINS AND OTHER SOCIAL NETWORKS
Our web pages and APPS may contain plug-ins of social networks (e.g. Facebook, Twitter, Google+, Pinterest, etc…). If you access one of our web pages equipped with such a plug-in, the Internet browser will connect directly to the social network’s servers and the plug-in will be displayed on your screen via the connection with the browser. If an interested user of a social network visits our web pages, while they are connected to their own social account, their personal data could be associated with the social account. Even if the plug-in functions are used, the information will be associated with the social account. Additional information on the collection and use of data by social networks in general, as well as on the rights and methods available to protect the privacy of the interested party in this context, are on the account’s social network pages, on data protection. If the interested party does not wish to associate the visit to our web pages to their social accounts, they must log off the social network, before visiting them. Details on processing Personal Data and services provided by third parties. Personal Data is collected for the following purposes and using the following services: Interacting with social networks and external platforms. These services make it possible to interact with social networks, or with other external platforms. The interactions and information acquired are, in any case, subject to the User’s privacy settings for each social network. In the event that an interaction service is installed with the social networks, it is possible that, even if the Users do not use the service, it may collect traffic data related to the pages where it is installed.
Any translation of this document into a language other than Italian is provided solely for information purposes. In the event of any discrepancies, the only legally valid and binding version regulating the use of the Site shall be the Italian version of this document.
Date updated: 03.10.2017