PRIVACY POLICY
1. FOREWORD
This privacy policy describes the procedures and aims of data processing, pursuant to the Italian privacy law, Legislative Decree no. 196/2003 - Personal Data Protection Code, relating to the corporate website
www.moleskine.com (hereinafter the
"Website")
This information is provided pursuant to article 13 of the Privacy Code, in compliance with Recommendation no. 2/2001 (on certain minimum requirements for collecting personal data on-line in the European Union, adopted on 17th May by the working party on the protection of individuals with regard to the processing of personal data) and is intended for all those accessing the Websites.
The information contained in this privacy policy, unless otherwise indicated, applies just to the Website. The managers of the Website such as the authors of its contents are not responsible for the content of other websites that can be accessed by links in the Website.
2. DATA CONTROLLER AND PROCESSOR
The Data Controller is Moleskine S.r.l. with registered office in Viale Stelvio 66, 20159 Milan (Italy).
The data processor is IT Net S.p.A., whose registered office is at Via Cesare Giulio Viola 48, 00148 Rome (Italy). The up-to-date list of data processors nominated by the company is available at the offices of Moleskine s.r.l.
Users' data will be processed by the company's employees or by its consultants or by the company nominated as data processor, thus operating within their ambit, in their capacity as persons in charge for data processing.
3. DATA PROCESSED AND PURPOSES OF DATA PROCESSING
The mere consultation of the Websites does not in itself entail the collection and processing of users' personal data.
See sections 6 and 7 of this privacy policy concerning the relevance for privacy purposes of browsing data and cookies.
Data subject to collection within the Website are normally limited to users' name, surname, address and e-mail address.
In the sole case in which the collection of data is finalised to a professional or commercial relationship, further data identifying the person and/or the Company and their activity could be asked. In no cases sensitive data will be collected.
Where not otherwise stated, the conferment of data requested from time to time shall be understood to be obligatory for the purpose of completing access procedures to restricted areas of the website or for other specific functions.
As far as the processing's aims are concerned, they are diversified in function of the different sections of the Website in which the communication of personal data is requested. In particular:
Contact Us: user's personal data, communicated during its registration, will be processed exclusively for aims related to his request of information and, under his explicit consent, for the delivery of descriptive and promotional materials concerning Moleskine world and products.
Newsletter: user's personal data will be processed for the aim to provide him with the periodic delivery of the Moleskine Newsletter and, under his explicit consent, for the delivery of descriptive and promotional materials concerning Moleskine world and products.
MSK: the use of the customisation tools placed at the users' disposal does not entail the actual acquisition of their personal data. However, the information processed by the user through the use of said tools will generate an image file - given to the user as a printout - which is stored exclusively for technical reasons, for a period of at most 10 days before being deleted. In any case, Moleskine guarantees that any data, information and contents in general provided by the user shall not be handled during this period.
Journalists: the personal data of the user will be processed for purposes of assuring the User is a journalist and to allow him or her, in this capacity, access to a reserved area in which he or she will find information materials - texts and photographs - intended for use in communications on Moleskine. Also in this case, conditionally upon the express consent of the user, the data may be processed for purposes associated with the sending of descriptive, promotional and informative materials on the world and products of Moleskine.
myMoleskine: user's personal data will be processed for the aim of his identification as it uploads pictures of personalised notebooks and, under its explicit consent, for the delivery of descriptive and promotional materials concerning Moleskine world and products.
Should those pictures regard the user and/or third persons, the definition of personal data will be extended also to them. Anyhow, the user guarantees that he obtained the explicit consent of such third parties for the publishing and diffusion of those images by means of the Website.
Brand and Trademark: in this case, user's personal data will be processed in order to start the procedure for the release (and eventual further revocation) of an authorisation for the use of the trademark "Moleskine®".
Work with us: the conferred data are processed in order to assess a possible business relationship between the user and Moleskine s.r.l. and for purposes of staff selection. Also in the absence of a follow-up to the contact established via the conferment of the CV or other data, the latter shall be kept by Moleskine s.r.l. for the period of one year following their acquisition, after which they shall be deleted.
Retailers: the personal data of the user will be processed for the purpose of assuring he or she is a professional Retailer and to allow him or her, in this capacity, access to the reserved areas of the Site in which he or she will find materials - texts and photographs - which may be used for information or communication activities associated with Moleskine. Under user's explicit consent, personal data could be processed for the delivery of descriptive and promotional materials concerning Moleskine world and products.
The data requested on the
Retailer Contact Form are acquired and processed for the sole purpose of performing the first examination of the user's characteristics so as to assess his candidacy to become a Moleskine Retailer. The requested data are largely optional; however failure to provide them may make it impossible to accept the proposed candidate.
Also in the absence of a follow-up to the contact established by the conferment of these data, the latter shall be kept by Moleskine s.r.l. for a period of two years following their acquisition, after which they shall be deleted.
Distributors: the personal data and information provided by the user shall be processed for the purpose of qualifying him as a Moleskine Distributor and, to this end, allowing him to access the restricted areas of the Website within which he will find written and photographic material to use for information or communications activities on behalf of Moleskine. Conditionally upon the express agreement of the user, the data may be processed for purposes related to the sending of descriptive, promotional and informative materials on the world and products of Moleskine.
The data requested on the
Distributor Contact Form are acquired and processed for the sole purpose of performing a first examination of the user's characteristics so as to assess his candidacy to become a Moleskine Distributor.
The requested data are largely optional; however failure to provide them, may make it impossible to accept the proposed candidate.
Also in the absence of a follow-up to the contact established by the conferment of these data, the latter shall be kept by Moleskine s.r.l. for a period of two years following their acquisition, after which they shall be deleted.
Contact our Distributors: in this case, the aim of the processing is only to get the user in touch with a specific Moleskine distributor in the world and under his explicit consent, for the delivery of descriptive and promotional materials concerning Moleskine world and products. The communication of his personal data by the user is intended to be performed also for the direct benefit of the distributor to whom the consent of the user to the processing of his data is extended.
4. CONSENT
During his registration at any section of the Website, the user is invited to read this information and to confirm his consent to the processing of communicated data for the purposes time by time described. Such a consent has intended as
mandatory in order to perform the registration of the user to the Website and the supply of the services requested; on the contrary, the consent is always
optional when it regards the delivery of descriptive and promotional materials concerning Moleskine's activities and products.
5. EXTENT OF DIFFUSION OF PERSONAL DATA
Personal data communicated by users will be processed by Moleskine s.r.l. or by persons directly charged by it and under its responsibility, in the territory of Italy, Europe and outside Europe with the exception of those communicated in occasion of their request to get in touch with foreign distributor which will be automatically transferred to the latter in its own country.
6. BROWSING DATA
During normal operation, the computer systems and software procedures designed to run the Website acquire certain personal data whose transmission is essential to use of Internet Communication Protocols.
This information is not collected to be associated with identified subjects, however, by its nature it could, by means of processing and association with data held by third parties, allow the identification of the user.
This category of data includes IP addresses or the domain names of the computers used by users connecting to the Website, the addresses in URI (Uniform Resource Identifier) of the resources requested, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the number code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user's computer environment.
This data is not diffused, but merely used to obtain anonymous statistical information on use of the Website and to check it is used correctly and is only stored for the timeframes defined by applicable regulations. The data could, however, be used to ascertain responsibility in the event of supposed computer crimes to the detriment of the Website.
7. COOKIES
None of the users' personal data is acquired by the Website for this purpose.
Session cookies (which are not stored permanently on the user's computer and disappear when the browser is closed) are strictly limited to the transmission of session ID data (made up of random numbers generated by the server) required to allow safe and efficient browsing of the Websites.
These session cookies used on the Website prevent the need for other computer techniques that could jeopardise the confidentiality of user browsing and are intended to improve the user's ease of navigation within the Website only, more specifically by storing the user's frequently used data for access to the Websites. Most frequently used browsers allow the user to disable cookies.
8. DATA PROCESSING METHODS
Processing will involve the use of instruments and procedures intended to guarantee safety and confidentiality pursuant to legal provisions and may be performed using both printed and electronic means.
Specific safety measures are observed to prevent the loss of data, unlawful and incorrect use and unauthorised access.
9. THE DATA SUBJECT'S RIGHTS
The user is entitled at any time to receive confirmation as to whether data concerning him/her exists and to be informed of its content, origin and the purpose and methods of processing, and, in the case of electronic processing - to be informed of the logic applied to processing, to verify its accuracy and ask for it to be supplemented and updated, or corrected (article 7, Legislative Decree no. 196/2003). Pursuant to the same article, Data Subjects are entitled to request the deletion, transformation into an anonymous form or freezing of data used in breach of the law, and they may, in any case, oppose processing of the same for legitimate reasons.
The user's personal data will be processed in compliance with and governed by Italian law (Legislative Decree no. 196/2003).
You may exercise your rights by writing to Moleskine S.r.l., Viale Stelvio 66 , 20159 Milan (Italy) or the e-mail address:
privacy@moleskine.com.
10. LANGUAGE
This English version of the Privacy Policy is provided for user information only. In the event of inconsistencies, the only legally valid and binding version governing the use of the Websites is the original Italian version.
