For those who visit the DFP International srl websites
This page describes some management rules of the DFP International srl websites, with reference to the personal data of the users who consult them. These rules apply in all cases in which you access our sites by browsing the pages without registering and without completing or entering data in web forms. By visiting the DFP International srl websites, you accept the terms and conditions set out below. If you believe you do not accept these terms, please do not access or use the contents and services offered through our sites.
• What types of data do we collect during user browsing?
• What are Cookies and how do we use them?
• With whom do we share navigation information?
For those who use web services which require personal data
Information on the processing of personal data pursuant to and for the purposes of art. 13 legislative decree 196/03 and art. 13 of EU regulation 2016/679
• Spontaneous sending of emails
• Filling out web forms
• Processing methods and purposes
• Consent to treatment
• Communication and dissemination
• Rights of the interested party
• Data Controller and Data Processors
• Non-EU transfer of Users' Personal Data
What types of data we collect during the user's navigation?
While you visit our sites, the computer systems used to operate them acquire, during their normal operation, some data whose transmission is implicit and necessary for the functioning of the Internet. This is information that is not collected to be associated with identified subjects, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes, for example, the IP addresses or domain names of the computers used by users who connect to the sites, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used in submitting 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, error, etc.) and other parameters relating to the operating system and the computer environment of the user. DFP International srl uses this data for the sole purpose of obtaining anonymous statistical information on the use of the sites and to check their correct functioning. The data could be used to ascertain responsibility in the event of hypothetical computer crimes. Except for this eventuality, these data persist on our computer systems for a time normally not exceeding thirty days. On DFP International srl websites it is also possible to find social buttons/widgets, i.e. those particular "buttons" depicting social network icons (for example, Facebook and Twitter) and interactive social walls (e.g. walls presenting photos from Instagram via hashtags) that present content from social networks. These "buttons" allow users who are browsing the DFP International srl sites to reach and interact directly with the social networks with a "click". Thanks to your click on the social buttons/widgets and/or on the interactive social walls, the social network acquires the data relating to your visit. Except for these cases, in which you spontaneously click to share your navigation data with the chosen social networks, DFP International srl does not share any navigation information or user data acquired through its sites with the social networks accessible thanks to Social buttons/widgets and interactive social walls. For any further information on the interactive social walls and social buttons/widgets used by our sites, write to us at: firstname.lastname@example.org
With whom do we share navigation information?
The data acquired during navigation may be known by third-party companies that provide DFP International srl companies with IT assistance and data processing services (for example in the case of hosting activities entrusted to third parties and connected to the use of our websites) appointed for this purpose as Data Processing Managers. The list of persons appointed as Data Processors can be obtained by writing to the address email@example.com. The data may then be known and processed within the companies of DFP International srl by the personnel in charge of the processing to the extent that this is necessary for the performance of their duties, performing only the operations necessary for the execution of the same. In the event of an express request and in the circumstances authorized by law, the data may be communicated by DFP International srl to the Public Security Authorities and the Police forces. No navigation data is disclosed in any way.
Spontaneous sending of emails
When you spontaneously send an e-mail to one of the e-mail addresses indicated on our sites, we acquire the sender's address and any other personal data that you have entered in the message and in the attachments. The e-mail boxes corresponding to the addresses indicated on our sites and any other DFP International srl e-mail box are not personal in nature, not even when they bear the name and/or surname of a natural person. They belong to the corporate organization and have the primary purpose of allowing the effective performance of work activities within the companies of DFP International srl. This means that messages forwarded to DFP International srl e-mail boxes will be known not only by the recipient, but also by other people belonging to the organization. By forwarding e-mails to the e-mail addresses indicated on our sites, you declare that you have read and accepted the treatment conditions contained in this policy.
Filling out web forms
When you access the DFP International srl websites and decide to use their services in an interactive way (e.g. newsletter request, registration to sites and communities, purchases, participation in events, campaigns, etc.), you may be asked to fill in forms web with some of your personal data, we provide you with some useful information below to know how we treat the data you send us.
Processing methods and purposes
To access services and content provided through our sites, you may be asked for personal data such as, for example, name, surname, address of residence/domicile, e-mail, date of birth, etc. Through the web forms available on the sites we never ask you for data of a sensitive nature (e.g. relating to revealing racial and ethnic origin, religious, philosophical, political beliefs, state of health, sex life, etc.) or judicial (data relating to criminal records, or relating to the status of defendant or suspect, etc.). Data processing will take place through the use of IT, telematic and paper tools and supports in compliance with the provisions of the law aimed at guaranteeing security and confidentiality, as well as the accuracy, updating and relevance of the data with respect to the stated purposes . You yourself can help us ensure that your data is always accurate by communicating updates to us at firstname.lastname@example.org. The data you release to us will be processed by the employees expressly designated by the Data Controller as persons in charge and/or responsible for the processing, according to the respective authorization profiles assigned. Persons in charge and managers will be able to carry out the operations of consultation, use, processing, comparison and any other appropriate operation, even automated, only in cases in which they have been expressly authorized to do so. We will process the personal data that you release to us only for the specific purpose and strictly pertinent to each single service requested and used. In all cases where we intend to use your data for additional or different purposes than the provision of the requested service, before proceeding with the processing we will ask your consent. The provision of data for some specific purposes (e.g. subscription to the newsletter, registration in restricted areas, purchase of products, customer care, direct marketing, profiling, loyalty programs and "Fidelity Card") will involve entering the data within of the Custom Relation Management (CRM) computer system of DFP International srl dedicated to customer management accessed only by personnel specifically appointed by DFP International srl. Below is a list of the services available on our sites for which we ask you to provide us with your personal data. For each service, the purpose of the processing is indicated.
Subscribe to the newsletter:
The newsletter is a communication with promotional and advertising content sent to all interested parties who request it. On some of our sites, subscribing to the newsletter implies sending promotional communications that are not generalized but targeted based on the language, gender and country of origin of the interested party. This means that we process the data we receive in order to divide subscribers into distinct groups by language, gender and country of origin so that the newsletter sent is as close as possible to what you have requested and which may interest you. The data you communicate to us for subscription to the Newsletter will be kept as long as we do not receive a request for unsubscription from you; in this case we will delete your data from our databases within 72 hours of the unsubscribe request. The sending of these commercial communications will be carried out only with your consent which will constitute the legal basis with which we will carry out the processing of your data.
Participation in demonstrations, events, competitions and initiatives extraordinary and temporary issues
We will use the data to allow you to participate in the specific initiatives you intend to join from time to time. For each event, we will provide you with specific information which will describe the type of data processed, their retention times and the specific processing purposes. We will collect your data only with your consent which will constitute the legal basis with which we will carry out the treatment of the same.
Registrations to reserved areas web community
Only with your consent, we will use your personal data to allow you to create your own reserved area on our sites and to participate in virtual community initiatives (e.g. creating wish lists, sharing your content with other users through DFP International sites srl, purchase history, email preferences, etc.). We remind you that registering with our web communities allows you to access many of the other services on the sites more quickly, but it is not a mandatory condition for being able to use them. e.g. you can receive the newsletter or make purchases even without being registered. In case of non-use of the account for more than 2 years, we will cancel it and the data relating to it.
Purchase of products
The data you provide to us will be used to process your purchase orders and related activities (sending of goods, invoicing, payment management and related activities, etc.). The completion of the sales contract will therefore constitute the legal basis with which we will process your personal data which will be kept for the time necessary to fulfill the obligations imposed by law in relation to the performance of the sales activity.
Apply for a job position
When you send your CV spontaneously or to respond to an open search, we will use your data, subject to your consent, to carry out the necessary selection and recruitment activities. When completing the web application form, we will provide you with specific information. Your CV will be kept for 48 months starting from the receipt of your application, after which time it will be deleted from our databases.
Requests for information or contact
(e.g. request for commercial and technical information, contact requests, order fulfillment status, product availability, etc.)
The data you give us will be used to send you only what you have requested. Your data will be kept only for the time necessary to process your request, after which they will be deleted from our databases.
DFP International srl offers you an assistance service – usually provided via live – chat, telephone, email – aimed at helping its customers before, during and after the purchase of a product or service. In some cases, to use the Customer Care service, we may need to ask you for your personal data when this is necessary to respond to requests for clarification, information on purchases, shipments, returns, payments, products and/or services, to manage complaints, process the request to join loyalty programs, etc. Only with your consent, we may collect your personal data through questionnaires aimed at measuring the degree of satisfaction with the services provided through Customer care. We will also process your data for the purposes described below only with your specific consent which you can revoke at any time by writing to the mail: email@example.com
We may ask for your consent to use your data to send you targeted communications (e.g. birthday wishes), or generalized promotions and advertising messages, as well as to carry out market research and survey activities (e.g. through questionnaires) of your degree of satisfaction with our products and services, through the traditional mail service, e-mail, SMS, landline and mobile phone, etc. Your consent to receive these communications will be valid both for sending through the use of automated systems without the intervention of an operator (e.g. email, sms), and for traditional methods of contact (e.g. paper mail). You can always, by writing an email to firstname.lastname@example.org, revoke your consent to the processing of your data for this purpose, even separately, by choosing for example to receive only advertising by paper mail and refuse that sent via automated systems. We point out that the Privacy Code (art. 130, paragraph 4, legislative decree 196/2003) allows the so-called "soft spam". This means that without having to obtain your express consent, we can use the e-mail address you provided in the context of a previous purchase, for the purpose of direct sale of our products similar to those you have already purchased, provided that you do not object to such use by sending an email to email@example.com. Apart from the hypotheses of "soft spam", we will collect your personal data for sending commercial communications only with your consent.
Only with your consent, in some cases we may use the data you provide us to use individual services (for example to request the newsletter or to make purchases) for the so-called "profiling", i.e. the analysis of the social composition of consumers based on age, gender, country of origin, profession, consumption habits, etc. Profiling involves processing the data you release to create groups of consumers divided into market segments based on a minimum set of elements (e.g. gender, country of origin), up to more advanced profiles based on preferences , online behavior and previous purchases. This activity has a dual purpose: to allow us to develop products and services with characteristics in line with the preferences of our consumers and to allow us to send you advertising communications as close as possible to your tastes and interests. You can revoke your consent at any time by writing an email to firstname.lastname@example.org. The data relating to your online behavior and previous purchases will be kept for 365 days, after which they will be deleted from our databases.
We make discounts, advantages and reserved services available to customers who wish to use them, which can only be used by adhering to specific loyalty programs and/or becoming holders of a "Loyalty Card". Adherence to these programs involves the provision of personal data such as name, surname, nationality, date of birth, cookies, details of purchases made, data relating to financial transactions, etc. Our loyalty programs are based on the accumulation of points deriving from the purchases of individual consumers. The increase in points allows the consumer to access increasing benefits according to the methods described in the Program Participation Regulations. The processing of the consumer's personal data in the case of loyalty programs will be limited to the activities strictly necessary for the provision of the requested service (e.g. attribution of the advantages associated with joining the loyalty program, communications via e-mail or ordinary mail relating to the performance of the program). Adherence to the loyalty program will therefore constitute the legal basis with which we will process your data. In cases where you join our loyalty programs, the data relating to the details of your purchases will be kept for a maximum of 12 months, after which the data will be automatically deleted or permanently made anonymous.
Communication of data to third parties
Only with your consent will we transmit your data to other companies belonging to the fashion, luxury and retail categories who will be able to send you commercial communications and promotional offers relating to their products.
Consent to treatment
In all cases in which your consent is required for the processing of your data, we will collect it in advance specifically for the individual purposes, in an expressly free and unconditional form.
Communication and dissemination
DFP International srl communicates your personal data to third parties only when this is necessary and functional to the achievement of the data processing purpose pursued according to the service you requested, and in any case proceeds with the communication only after informing you, and where necessary, have collected your consent to do so. In general, the data collected through the individual services and for the purposes indicated in this statement are normally communicated to the following categories of subjects:
• subjects to whom the right to access them is granted by law or regulation (e.g.
public security authorities and police forces);
• companies belonging to DFP International srl by way of parents, subsidiaries or affiliates;
• sales outlets of DFP International srl;
• data processing and IT services companies (e.g. web hosting, data entry, infrastructure management and maintenance and IT services, e-mail marketing, Acquirers, etc.);
• companies and studios providing consultancy services;
• third-party companies belonging to the fashion, luxury and retail for sending them commercial communications only with the specific consent of the interested party.
In particular, some specific services provided through our site also provide for communication to additional categories of subjects, such as:
• purchase of products: Banca Unicredit, Paypal, company shipping, financial institutions, effecting companies mailing and mailing services.
• job application: third-party companies of consultancy for the search and selection of personnel with the purpose of supporting the Owner in the evaluation of profiles and nominations.
DFP International srl normally does not disclose your data. Some services provided by our sites (eg "share my wish list"), however, allow the dissemination of your personal data to other users and services of the Internet; however, this is left to your free choice in this sense and is only possible following your specific and voluntary initiative. In some specific cases, however, we may ask you to release your personal data (including photographic and audio-video images) to allow you to participate in events, contests and thematic initiatives of an extraordinary and temporary nature, which by their intrinsic nature involve communication and dissemination. In these cases we will notify you by asking you to give express and specific consent in this sense.
Rights of the interested party
At any time you can exercise the rights that the law recognizes you. In particular, you can exercise them by writing to: email@example.com
Right of access
You will be able to obtain confirmation from the data controller as to whether or not personal data concerning you is being processed and, if so, obtain a copy of the data being processed.
Right to rectification
You will be able to obtain the rectification (i.e. the modification, integration or updating) of inaccurate personal data concerning you, in case of inaccuracy, incompleteness or obsolescence.
Right to cancel
You can obtain the cancellation of personal data concerning you. The data controller will cancel them without unjustified delay if:
• your personal data is no longer necessary than the purposes for which they were collected or processed;
• as an interested party, you have revoked the consent on which you bases that treatment and there is no other legal basis a foundation of the same;
• as an interested party, you have objected to the treatment and not there is no overriding legitimate reason to proceed with the treatment;
• your personal data has been processed unlawfully;
• your personal data must be erased to comply a legal obligation.
Right to restriction of processing
As an interested party, you have the right to obtain the limitation of the treatment when one of the following hypotheses occurs:
• In case of dispute of the accuracy of your data, for the period necessary for the data controller to verify the accuracy of such personal data;
• The processing is unlawful and you have requested the restriction of their use;
• Although the owner no longer needs it for the purposes of processing, the personal data is necessary for you to the establishment, exercise or defense of a right in court judicial;
• You have objected to the treatment, pending verification in regarding the possible prevalence of the legitimate reasons of the data controller with respect to those of the interested party.
Right to object
You have the right to object at any time to the processing of personal data concerning you based on the legitimate interest of the owner, including profiling. You also have the right to object at any time to the processing of personal data concerning you carried out for direct marketing purposes, including profiling insofar as it is connected to such direct marketing.
Right to data portability
You have the right to receive the personal data concerning you provided to a data controller in a structured, commonly used and automatically readable format and you have the right to transmit such data to another data controller without hindrance from the owner of the treatment to which he provided them if:
The processing is based on consent or on a contract; And the processing is carried out by automated means.
When exercising your rights in relation to data portability, you also have the right to obtain direct data transmission personal data from one data controller to another, if technically doable.
Right to lodge a complaint with a supervisory authority
Where necessary, you can lodge a complaint with the competent Supervisory Authority for the protection of the rights guaranteed to you by Legislative Decree 196/2003 and by the European Regulation 679/2016.
Right to withdraw consent
You have the right to withdraw your consent in relation to all treatments based on it. To exercise this right, you can write to firstname.lastname@example.org at any time
Non-EU transfer of users' personal data
Personal data collected through this website may be transferred outside the EU to be stored on servers of Customer Relationship Management service providers. The transfer is carried out following the stipulation of Standard Contractual Clauses or after verification of the Privacy Shield certification of the service provider (specifically appointed Data Processor. The list of persons appointed as Data Processors can be obtained by writing to the address email@example.com)
Data controller and responsible for the data protection: contacts
The data controller of the personal data of users who consult and use all DFP International srl sites is DFP International srl, with registered office in Milan – Via Savona 97 – Loft C15 – 20144 (MI), Italy. The data controller and the Data Protection Officer can be contacted at the address indicated below: DFP International srl as Data Controller: firstname.lastname@example.org
Last update: October 2018