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.
2. DATA CONTROLLER AND DATA PROCESSING MANAGER
The data controller is Moleskine SpA, with registered office at Viale Stelvio, 66, 20159 Milan (Italy).
The data processing manager is IT Net S.p.A., with registered office at Via Cesare Giulio Viola, no. 48, 00148 Rome (Italy). The updated list of processing managers appointed by the company is available on the Moleskine SpA website.
Data processing will be carried out by employees or staff of the company or the processing manager company, working in the sphere of their companies, as processing officers.
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.
Profiling and Marketing: for profiling for the purpose of marketing of the interested party and for conducting market research and for satisfaction surveys. Promotional communications via email even those customized for informational activity concerning: 1) market research or other sample research; 2) analysis of consumer habits or choices, commercial activity, economic/statistical analysis; 3) creation of professional profiles related to customers or consumers. Keep in mind that for the purposes of profiling and marketing, personal data will be retained for a period of no more than twelve and twenty-four months, respectively, from their registration, unless they are actually converted to anonymous form.
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 "MoleskineREG" 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
Upload Images and Videos: the user's personal data will be processed for the purposes of identifying the user who proceeds to upload photographic or video contents to the website and, with the express consent of the user, for purposes related to sending descriptive, promotional and informative materials of the Moleskine world and products.
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.
At the time of registering with any section of the website, the user is prompted to read the Privacy Information made available under the terms of the Data Protection Act and to confirm his/her consent for processing of the data provided on that occasion, for the purposes described time by time. This consent is mandatory in order to complete the user's registration with the website and the use of the services requested and, in contrast, is always optional with reference to sending promotional and/or information material relating to Moleskine activities and products.
Failure to provide the data and related consent will not allow the Controller to grant the services intended for the user described in the attached purpose. Failure to provide non-mandatory data not indicated on the forms with * will not allow the use of said data for the intended purpose.
5. SCOPE OF DATA CIRCULATION
The personal data provided by the users will be processed by Moleskine SpA or by the parties it appoints directly to conduct market research studies, polls, interviews or other promotional and customer satisfaction initiatives, under its own responsibility, in Italy, Europe or countries outside Europe, except for data entered at the time of a contact request with a foreign distributor, which are automatically transferred to the distributor in question in its country.
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. BROWSING DATA
The computer systems and software procedures used for operation of the websites acquire, during normal operation, some data whose transmission is implicit in the use of Internet communication protocols.
This is information that is not collected to be associated with identified data subjects, but that could, by its very nature, through processing and associations with data held by third parties, permit users to be identified.
This category of data includes IP addresses or domain names of the computers used by the users who connect to the website, Uniform Resource Identifier (URI) address of the resources requested, the time of the request, the method used 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 (success, error, etc.) and other parameters relating to the user's operating system and computer environment.
These data are not circulated, but are used for the sole purposes of obtaining anonymous statistical information on the use of the websites and to control their correct operation, and are kept for the times defined by legal regulations on the subject. The data could, however, be used for checking liability in the event of cases of computer crimes involving website damage.
No personal data of the users are acquired for this purpose from the website.
The use of session cookies (which are not permanently stored on the user's computer and are cleared when the browser is closed) is strictly limited to transmission of session usernames (made up of random numbers generated by the server) necessary to allow secure and efficient searching on the website.
Session cookies used in the sites avoid recourse to use of other potentially harmful computer techniques for user browsing privacy and are aimed solely at helping users browse the website, permitting, in particular, frequent users' data to be stored for site access. Most commonly used browsers however feature an option to disable cookies.
8. PROCESSING METHOD
Data processing will be performed using appropriate tools and procedures to guarantee security and privacy in accordance with the law, and may be carried out both through hard copy supports or with the aid of digital media.
Specific security measures are observed to prevent the loss of data, illegal and incorrect usage and unauthorised access.
Personal data will be retained for a period not to exceed its intended scope, unless as stipulated for the purpose of profiling and marketing.
9. RIGHTS OF THE DATA SUBJECT
Users are entitled to obtain confirmation of the existence or otherwise of their data at any time and to be informed of their content and source, the processing purposes and methods, and - in the event of processing with electronic tools - the applied processing logic, checking the accuracy of their data or requesting corrections and updates (art. 7 of Leg. D. no. 196/2003)
Section 7: (Right to Access Personal Data and Other Rights)
1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.
2. A data subject shall have the right to be informed:
a) of the source of the personal data;
b) of the purposes and methods of the processing;
c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;
d) of the identification data concerning data controller, data processors and the representative designated as per Section 5 (2);
e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said in their capacity as designated representative(s) in the State's territory, data processor(s) or person(s) in charge of the processing.
3. A data subject shall have the right to obtain
a) updating, rectification or, where interested therein, integration of the data;
b) erasure, anonymization 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 whit the right that is to be protected.
4. A data subject shall have the right to object, in whole or in part,
a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
b) to 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.
*** Under the terms of the same article, users are entitled to request deletion, conversion to anonymous form or blocking of data processed in infringement of the law, as well as to oppose, for legitimate reasons, the processing of their data.
Processing of users' personal data will take place in compliance with Italian law and will be governed by the provisions of Italian law (Leg. D. no. 196/2003).
Users' rights can be exercised by sending a written request to Moleskine SpA, Viale Stelvio 66 , 20159 Milan (Italy), or an e-mail to: firstname.lastname@example.org, writing to the processing manager at the Marketing office.
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.
Milan, 7th March 2011