Lead Acquisition Privacy Policy
Dear Mrs./Mr/Ms.,
the following explains how personal data provided by you when subscribing to the newsletter are processed.
1. DATA CONTROLLER
The Data Controller is Missoni S.p.A., in the person of its legal representative, with its registered office in Via Luigi Rossi 52, 21040, Sumirago (VA), Italy (hereinafter “Missoni”, “Company” or “Data Controller”).
2. DATA PROTECTION OFFICER
Due to the processing activities carried out, the Company has deemed it necessary to appoint a Data Protection Officer, who can be contacted at dpo@missoni.it, Via Luigi Rossi 52, 21040, Sumirago (VA), Italy or at the email address privacy@missoni.it.
3. PERSONAL DATA PROCESSED
As part of your registration for the Newsletter, the Controller may process common personal data, such as in particular anagraphical and contact data relating to you (i.e. name, surname, e-mail address, etc.). If you give your consent to profiling activities, further information relating to your purchases, preferences, etc. may be used.
| Finalità | Base giuridica | Natura | |
|---|---|---|---|
|
A. |
Subscription to the newsletter and receive information of commercial nature(i). This purpose includes the possibility to subscribe to our newsletter and receive communications and information of commercial and direct marketing nature on our Services and offers, on discounts and on any other promotional and loyalty initiative adopted, both through traditional and fully automated contact systems, such as, through the use of your email address. |
(i) Express Consent |
The provision of your personal data is optional. Failure to authorize the processing of your personal data may not allow you to take full advantage of the benefits we offer to our community through information of advertising, commercial and direct marketing nature. |
|
B. |
Receive offers, discounts and other benefits based on profiling(i). This purpose includes the possibility of receiving offers, discounts and any other benefit and promotional initiative modeled on your specific needs and propensity to purchase, including participation in loyalty programs, which provide for the purpose of their operation, the recording, identification and profiling of data relating to your purchase volumes, habits and consumption choices. |
(i) Express Consent |
The provision of your personal data is optional. Failure to authorize their processing may not allow us to send you personalized communications based on your habits and choices. |
4. DATA RETENTION PERIOD
Regarding the processing of your personal data for direct marketing and profiling purposes, the Company has established that it will automatically delete your personal data or transform them into anonymous data in a permanent and non-reversible manner, within 7 years from the registration of the data collected.
This, except in the case where it is necessary to maintain such data to fulfill regulatory obligations, or to ascertain, exercise or defend a right in court.
5. CATEGORIES OF RECIPIENTS OF PERSONAL DATA
The personal data processed will not be disclosed to third parties, but may, however, be shared in relation to the purposes of processing set out above to the following subjects:
- those who can access the personal data according to legal provisions provided by the law of the European Union or the law of the Member State to which the Data Controller is subject;
- data controllers belonging to our business group or entities linked to a central body exclusively for internal administrative purposes;
- subjects that perform ancillary purposes to the activities and services referred to in paragraph 3, i.e. postal services and home delivery agencies, companies offering advertising and marketing services, banking and insurance institutions, legal and notary offices, companies offering IT assistance and consultancy services as well as software design and development, service centers, companies or consultants appointed to provide specific services to the Data Controller, within the limits of the purposes for which the personal data is collected.
In addition, your personal data may also be disclosed to our employees, provided that they are previously appointed as acting under the authority of the Data Controller pursuant to Article 29 of the GDPR, or as Systems Administrator.
6. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES
The Data Controller may transfer your personal data to third countries outside the European Union, for the purpose of managing Missoni database. Such transfer is always subject to an adequacy decision, under article 45 of the GDPR, or to the Standard Contractual Clauses, under article 46 of the GDPR. For more information about the rules for transferring data to countries outside the European Union, including the mechanisms on which we rely, you can visit the European Commission’s website here, or through this link: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX:32021D0914&locale=en. To request a copy of the Standard Contractual Clauses signed by the Data Controller you can send an email to privacy@missoni.it
7. AUTOMATED DECISION-MAKING PROCESSING
Missoni does not use automated decision-making processes without your consent, including profiling as referred to in Article 22, paragraphs 1 and 4 of the GDPR. If you consent to profiling, the data you provide may be used to analyze or predict your likes and dislikes in order to customize the content of marketing communications and offer you personalized products and services. In particular, the analysis may include the number, type, value and regularity of product purchases made over a 7-year period. As a result of this analysis, which may also be carried out automatically, you may be classified in one or more groups with different characteristics and receive communications that Missoni considers personalized to your tastes and preferences. For example, if you purchase, within a 7-year period, only certain types of products for a certain value, you may receive future marketing communications about similar products in a similar price range. Conversely, you may receive fewer communications and promotions about other types of products if you have not purchased them during the relevant period, as the system assumes that these are not products that you can be interested to. On this data processing, prior to its commencement, Missoni has conducted a specific data protection impact assessment to ensure that profiling is carried out with neutrality, accuracy, efficiency and without harmful consequences for the data subject. As required by art. 22, paragraph 3, of the GDPR, the Data Controller implements all the most appropriate measures to protect your rights and freedoms also in case of profiling, in addition to any further and legitimate right as better explained within the following paragraph 8 (“Data Subjects’ Rights”) of this Privacy Policy.
8. DATA SUBJECTS’ RIGHTS
Regarding the processing of your personal data, you, as a data subject, have the right to withdraw your consent at any time and to obtain from the Company access to your personal data. You may also request the Company to rectify or erasure your personal data. Furthermore, you have the right to obtain the restriction of the processing of personal data concerning you, as well as the right to data portability.
In addition to the above, you have the right to object at any time, on grounds relating to your situation, to the processing of your personal data carried out pursuant to Article 6 para. 1, letter e) or f), including profiling on the basis of these provisions, as stated in Article 21 of the GDPR. In addition, where your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data relating to you carried out for such purposes, including profiling insofar as it is related to such direct marketing.
Finally, you have the right to lodge a complaint with a supervisory authority or take legal action if you believe that the processing of your data is in breach of the GDPR.
To exercise any of your rights, you may contact the Data Controller, in the person of the legal representative, by addressing a communication to the registered office in Via Luigi Rossi 52, 21040, Sumirago (VA), Italy, or by sending an email to privacy@missoni.it
