Under the terms and for the purposes of decree Leg. D. no. 196/2003 - Data Protection Act, this Privacy Information describes the methods and aims of management of the data provided by users of the corporate website www.moleskine.com (hereinafter referred to as the "website"), also through the filling out of forms with or without the help our officers.
This Information is published under the terms of art. 13 of the Data Protection Act, and in consideration of Recommendation no. 2/2001 (relating to the minimum requirements for on-line data collection in the European Union, adopted on 17th May by the EC-Group for personal protection relating to personal data processing) and applies to all those who access the website.
Everything set out in this Privacy Information, unless otherwise stated, refers solely to the website. The Site Managers and the content Authors are not liable for the contents of third-party websites directly or indirectly connected through links from the website.
1. THE "DATA CONTROLLER" OF THE PROCESSING, in the terms of Section 28 of Legislative Decree 196/03, of 30 June 2003, containing the Personal Data Protection Code (the "DP Code") is Moleskine SpA, of Viale Stelvio 66, 20159 Milan, in the person of its acting legal representative.
THE DATA PROCESSOR, in the terms of Section 29 of the DP Code, in charge of the processing, is the Head of the Digital Business Office.
2.TYPES OF DATA PROCESSED
Personal and identifying data
Personal Data: any information about a natural person identified or identifiable, indirectly or otherwise, by reference to any other information, including a personal identification number; Identifying Data: Personal Data which allow direct identification of the Data Subject (for example first name, surname, date of birth, postal address, e-mail address, telephone number etc).
In ordinary operation, the computer systems and software procedures set up to operate this website obtain some Personal Data, transmission of which is inherent in the use of the Internet communication protocols. This information is not gathered for linking to identified Data Subjects, but could, by nature, identify the Users via processing and linking with data held by third parties. This category of data includes IP addresses or domain names of computers used by Users who visit the website, addresses (in URI - Uniform Address Identifier - notation) of requested resources, time of request, method used to submit the request to the server, size of file obtained in response, digital code indicating status of reply given by the server (successful, error etc.) and other parameters relating to the user's operating system and computer environment.
The User's Personal Data may be used in the Application Controller's defence in court, or in preliminaries to the possible institution of legal proceedings, against misuse of the Application, or of its connected services, by the User. The User's Personal Data may be used to establish responsibility in case of any information technology offences detrimental to the website.
Maintenance. The User's Personal Data may be processed by additional means and for additional purposes relating to maintenance.
Data voluntarily supplied by the User
The optional, explicit and voluntary sending of e-mail to the addresses shown at this website and/or the completion of data collection forms entail the subsequent acquisition of the sender's address, which is necessary to answer the requests, and of any other Personal Data entered therein.
Specific Information Notices
Specific Information Notices may be presented on the website pages in relation to particular services or processing of Data supplied by the User or by the Data Subject.
The software applications used may contain cookie technology. The main function of cookies is to aid navigation by the User. Cookies may supply information about navigation within the website and allow the operation of certain services requiring identification of the User's footprint across various pages of the website. For any access to the portal, regardless of the presence of a cookie, the type of browser (e.g. Internet Explorer, Netscape), operating system (e.g. Macintosh, Windows) and host and the visitor's URL of origin are recorded, in addition to the data on the requested page. Users in any case have the option of setting their browsers to inform them when they receive a cookie and thus of deciding whether to delete it. Further information on cookies can be found at the websites of the browser providers.
Types of cookie
Cookies are subdivided into "session" and "persistent" cookies. "Session" cookies, once downloaded, are deleted on closure of the browser. "Persistent" cookies, on the other hand, are stored on the user's/visitor's hard disk until expiry.
First-party cookies are only legible on the domain which created them. Third-party cookies are created and legible by domains external to the present website. The software used for each website and platform creates a cookie for each user. This cookie generates statistics about use, e.g. via Google Analytics, which are held at Google, Inc.
For the functioning of the cookies in Google Analytics, please see the official documentation supplied by Google at the following URL: http://code.google.com/apis/analytics/docs/concepts/gaConceptsCookies.html
3. DATA PROCESSED AND PURPOSE OF THE PROCESSING
Simply visiting the website does not, in itself, lead to the collection or processing of users' personal data. In any event, please refer to sections 6 and 7 of this privacy information for details regarding the importance, for the purposes of privacy, of the browsing data and cookies.
The data that are collected and then processed are normally limited to the user's forename and surname, his/her address, e-mail address, date of birth and country of residence.
If the provision of data leads to the establishment of a professional or commercial collaboration, further identification details of the person and/or the company and the activity performed by the latter may be requested. In no case is data defined as sensitive by current regulations to be collected.
In order to be 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. Although providing this description is obligatory, it will not undergo any processing operations other than publication and diffusion on the Site.
Only in the cases where providing data leads to the establishment of a professional or commercial collaboration may further identification details of the person and/or the company and the activity performed by the latter be requested. In no case is the collection of data defined as sensitive by current regulations planned.
Unless otherwise stated, providing the data requested from time to time is mandatory for the purpose of upgrading the procedures of access to the reserved areas of the website or to other specific functions.
The required or optional nature of the provision of data that Moleskine reserves the right to request in future also from users who have already registered, will be specified from time to time, together with the purposes justifying the request for such further information to be provided.
The aims of data processing are varied, depending on the section of the website containing the request for data to be provided. In particular:
Contact us: the user's personal data, provided at the time of registration, will be processed solely for purposes connected with the request for information submitted and, after express consent from the user himself/herself, for purposes related to sending descriptive, promotional and informative material of the Moleskine world and products.
Newsletter: the user's personal data will be processed for the purpose of sending the Moleskine Newsletter and, after express consent from the user, for purposes related to sending descriptive, promotional and informative material of the Moleskine world and products.
MSK: use of the customization tools made available to users does not presuppose the acquisition, as such, of any personal data concerning them. The information that the user himself/herself prepares through the aforesaid tools, however, generates an image file - made available to the user as a print output - which is retained solely for technical requirements for a period of no more than 10 days, after which time it will be deleted. During this period the data, information and contents in general, provided by the user will not be subjected to processing.
Journalists: the user's personal data will be processed in order to qualify the User as a journalist and, as such, allow him/her access to a reserved area in which he/she will find information in the form of text and photographs intended to be used for Moleskine communications. In this case too, after express consent from the user, the data may be processed for purposes related to sending descriptive, promotional and informative material of the Moleskine world and products.
myMoleskine: the personal data will be processed to identify users, allow them to become members of the Community, involve them in market research studies, online polls, interviews and other commercial-type initiatives relating to Moleskine products and, after express consent, transmitting descriptive, promotional and informative material of the Moleskine world and products.
If the images uploaded by the user depict the latter or third-parties, for the purposes of this Privacy Information the definition of personal data extends also to such images. In relation to images of third parties, the user anyway guarantees Moleskine that their consent has been obtained to publish and distribute said images on the website and for their use by Moleskine SpA as stipulated in the related Conditions of Use.
Registered trademarks: in this case, personal data are processed in order to start the procedure for the issue (and any subsequent cancellation) of authorization to the user for use of the registered trademark "Moleskine" on the web.
Work with Us: the data provided are processed in order to assess the possibility of entering into a working relationship between the user and Moleskine SpA and for the purposes of recruiting personnel. Also, if there is no follow-up to the contact established by sending a CV or other data, said information will be retained by Moleskine SpA for a period of one year from their acquisition, after which they will be deleted.
Retailers: users' personal data will be processed in order to qualify them as professional Retailers and, as such, allow them to access reserved areas of the website, in which they will find text and photographs to use for information or communication activities related to Moleskine. After express consent from the user, the data may be processed for purposes relating to sending descriptive, promotional and informative material of the Moleskine world and products.
The data requested on the Retailer Contact Form are acquired and processed for the sole purposes or carrying out an initial examination of the user's characteristics in order to assess him/her as a candidate for the role of Moleskine Retailer. The data requested are largely optional; however, if they are not provided, it may be impossible to arrive at a positive appraisal of the candidate.
If there is no follow-up to the contact established by providing these data, they will be kept by Moleskine SpA for a period of two years from the date when they were acquired, after which they will be deleted
Distributors: users' personal data will be processed in order to qualify them as Moleskine Distributors and, as such, allow them to access the reserved areas of the website, in which they will find text and photographs to use for information or communication activities related to Moleskine. After express consent from the user, the data may be processed for purposes relating to sending descriptive, promotional and informative material of the Moleskine world and products.
The data and the information requested on the Distributor Contact Form are acquired and processed for the sole purpose of carrying out an initial examination of the user's characteristics in order to assess him/her as a candidate for the role of Moleskine Distributor. The data requested are largely optional; however, if they are not provided, it may be impossible to arrive at a positive appraisal of the candidate.
Also, if there is no follow-up to the contact established by providing these data, they will be kept by Moleskine SpA for a period of two years from the date when they were acquired, after which they will be deleted
Contact our distributors: in this case, the purpose of processing is solely that of putting the user in contact with a certain Moleskine distributor in the world and, after express consent from the user, of allowing descriptive, promotional and informative material of the Moleskine world and products to be sent; the provision of these data by the user is also a direct advantage for the distributor, to whom the data processing consent given by the user is extended
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 regards the information relating to prospective buyers, which is normally limited to their personal data and address, this is intended solely to identify the user if this becomes necessary and if permitted in accordance with the terms of the prevailing laws.
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.
4. Methods of processing and retention
Parties specifically appointed for the purpose, in the terms of the DP Code Sections 31 onwards, will carry out the processing automatically and manually, by means and instruments designed to guarantee maximum security and confidentiality. The data will be retained for a period no longer than that of the purposes for which they are gathered and subsequently processed.
5. Scope of disclosure and distribution
Your data, undergoing processing, may be passed to companies which have contractual relations with Moleskine SpA in the European Union, in accordance with, and within the limits of, Section 42 of the DP Code, in order to perform the contracts or fulfil related purposes. The data may be disclosed to third parties belonging to the following categories:
- providers of services for the management of the computer system used by Moleskine SpA and of telecommunications networks (including e-mail);
- partnerships or companies offering relations in the fields of support and consultancy;
- authorities competent for compliance with statutory obligations and/or with arrangements of public bodies, on request; and
- IT Net S.p.A., with head office at Via Cesare Giulio Viola 48, 00148 Rome, Italy.
The third parties in the above categories function as Data Processors or act in total autonomy, as separate Data Controllers. The constantly updated list of Data Processors is available at Moleskine SpA head office, Viale Stelvio 66, 20159 Milan. Any further disclosure or distribution will take place only with your explicit consent.
Personal Data disclosed by users will be processed by Moleskine SpA or by third parties, in Italy, Europe or outside Europe. Personal Data entered on the application for contact with a foreign distributor constitute an exception, and are automatically transferred to the distributor in question, in its country of establishment.
Some data and information, supplied by the artists of Moleskine Artist Marketplace, will be made known to Marketplace users in combination with the artist's own nickname, by publication at and, therefore, distribution through, the website. Such data and information will include the artist's photographic image, biographical notes, Facebook and/or Twitter account, e-mail address and all information describing his/her creations offered for sale.
6. Nature of supply and refusal
Save as specified for navigation data, the supply of Personal Data by the User is optional.
On registration at any section of the website, the User is requested to view the Information Notice given under the DP Code and to confirm his/her consent to processing of the data supplied on that occasion, for the purposes described from time to time. Such consent must be deemed mandatory in order to complete the User's registration at the website and allow use of the services requested. With regard to the sending of promotional and/or information material about Moleskine's activities and products, on the other hand, such consent is always optional.
7. RIGHTS OF DATA SUBJECTS
You can assert your rights as stated in Sections 7, 8, 9 and 10 of the DP Code by applying to the Data Controller or Processor, by contacting our head office, or by e-mailing firstname.lastname@example.org 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 (Section 7 of the DP Code). For the purposes of that Section, you are entitled to request erasure, conversion to anonymous form or blocking of data processed in breach of the law, and to oppose the processing thereof in any case, for good cause.
If you do contact the Data Controller, please supply your e-mail address, name, address and/or telephone numbers, to allow correct handling of your request.
Users' rights can be exercised by sending a written request to Moleskine SpA, Viale Stelvio 66, 20159 Milan (Italy), or an e-mail to: email@example.com, writing to the processing manager at the Marketing office.
To stop receiving direct marketing communications at any time, all you have to do is write an e-mail to firstname.lastname@example.org with "marketing cancellation" as the heading, and you will not be inconvenienced further.
8. Changes to the Privacy Information Notice
The Data Controller reserves the right to amend, update, supplement or remove parts of the present Privacy Information Notice at its sole discretion at any time. The Data Subject must check periodically for any amendments. 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.
9. FACEBOOK, SOCIAL PLUG-INS 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 Data Subjects using social networks visit our web pages while connected to their own social account, their Personal Data may be linked to the social account. Even if the plug-in functions are being used, the information will be linked to the social account. Further information on data gathering and use by social networks in general, and on the rights and conditions available to protect the Data Subject's privacy in that context, appears on the data protection pages of the social network on which the account is held. If the Data Subject does not wish the visit to our web pages to be linked to his/her social account, he/she must log off the social network before visiting them.
Details of Personal Data processing and third-party services
Personal Data are gathered for the following purposes, by using the following services: interaction with social networks and external platforms. These services allow interaction with social networks or other external platforms. The interactions and the information obtained are in any case subject to the User's privacy settings relating to all social networks. If a service is installed which interacts with social networks it is possible that the service may gather traffic data relating to the pages on which it is installed, even if the Users are not using the service.
Any translation of this document into a language other than Italian is provided for information purposes only. In the event of discrepancies, the only legally valid and binding version regulating use of the website is the Italian version of this document.
Date updated: 8.1.2014
The Data Controller is: Moleskine SpA, Viale Stelvio 66, 20159 Milan, in the person of its acting legal representative.
The Data Processor is the Head of the Digital Business Office.