Privacy e Cookie Policy

Information about personal data collected from the data subject according to article 13 of the European Privacy Regulation: General Data Protection Regulation

According to the article 13 of EU 2016/679 regulation, and following the principle of transparency, we hereby give the following information, so that the user is aware of the conditions and procedures by which their data are treated.

1. The Data Controller
The Data Controller and Data Protection Officer is Xerjoff Group S.p.a VAT Number 09547650011, registered office  is located in Via Tenivelli 29 Moncalieri – 10024 – TO – Italy. Operational Headquarter Via Leonardo da Vinci 29, 10095 Grugliasco TO Italy. Contact information: telephone: +39-011-414.36.16, email address:gdpr@xerjoff.com.

The Data Protection Officer (DPO) can be reached at the following e-mail address: gdpr@xerjoff.com

 

2. Purpose of the data processing, legal basis.
The personal data provided by the user via our internet website are collected and processed for the following purposes:

a) to be able to carry out customer relationship management according to contract arrangements;
b) to send periodical newsletters and advertising material via email to customers, on the basis of their explicit consent;
c) to send customers updates on our activities, and notices about newly posted materials on our website, or blog, on the basis of their explicit consent;
d) to send customers information on sales promotions, invitations to events, training courses, special offers, or invitations to take part in market analysis and research surveys, on the basis of their explicit consent.

The legal basis regulating the processing of the data is the enactment of a contract, of which the data subject is party, or the execution of pre-contractual measures, if carried out on the request of the data subject.
In b), c), and d) above, the legal basis is the explicit consent, freely provided by the data subject.
If the data controller  wishes to process the data with a different purpose from the original one at the moment of their collection, prior to doing so, he shall provide the subject with information on such further processing, together with any further additional and relevant information.

 

3. Conferring of personal data

Conferring the data for purposes indicated in a) above, is voluntary, but refusing to do so will cause Xerjoff Group to be unable to fulfil its contract obligations.
As far as the purposes indicated in b), c), and d) above, the conferment is also voluntary and their use is subject to explicit consent. If consent is not provided, Xerjoff Group will not be able to send newsletters, advertising material, invitations to events, or any other commercial initiative.

 

4. Recipients, actual and potential, of personal data

The data can be processed by processors who have been authorized by the data controller, in compliance with  the above-mentioned purposes and according to existing privacy laws.

If necessary or required to carry out the above-mentioned purposes, the collected data can be processed by third parties appointed as external data processors, or, when applicable, expressly appointed as independent owners, namely:

  • professionals, individual companies, companies such as transport companies and couriers, associations or professional practices providing support and  consultancy services to our Company,
  • companies, authorities, and associations dealing with services related to the above-mentioned purposes (i.e. credit card payment processing, IT systems maintenance)
  • Financial administration, public security companies and/or other entities named in execution of the EU/EEA fiscal and legal provisions

The complete list of the entitled Data Processors can be requested to the Data Controller

 

5. Data transfer to a third country

Personal data are processed within the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For further information, you can contact the Data Controller.

If for technical and / or operational reasons it is necessary to make use of subjects located outside the European Union, we inform you as of now that these subjects will be appointed as Data Processors pursuant to and for the purposes of art. 28 of the Regulations or Joint Data Controllers pursuant to art. 26 of the Regulations and the transfer of Personal Data to these subjects, limited to the performance of specific processing activities, will be regulated in accordance with the provisions of Chapter V of the Regulations. All necessary precautions will therefore be taken in order to ensure the most complete protection of the Data Subject’s Personal Data. The Company also uses cloud services provided by third country companies recognized as adequate in terms of Data Confidentiality, Integrity and Availability.

 

 

6. Methods of processing and data retention period

The collected data will be processed either by electronic means, whether IT or telematic ones, or via manual processing, according to processing methods strictly related to the purposes for which the data have been collected and, in any case, in such a way that their safety is ensured.
The personal data processed for the purposes mentioned in 2 a) above, will be processed for the time necessary to carry out the contract’s purposes, and for further 5 years, for tax and administrative purposes.
The personal data processed for the purposes mentioned in 2 b), c), and d) above will be processed for a maximum period of 24 months starting from the registration to the website, or the termination of the consent procedure.
The customer has also the right to withdraw your consent at any given time without infringing the lawfulness of the data processing carried out prior to the withdrawal.

 

7. Automated Processing and profiling purpose

The data controller does not use any automated processes aimed at user’s profiling.

 

8. Data subject’s rights related to data processing

We hereby specify that, with regard to your personal data, you can exercise any of the rights listed below:
1. the right to access your personal data;
2. the right to rectify, cancel or restrict the data forming the subject-matter of the processing;
3. the right to refuse the processing;
4. the right to data portability (applicable only to electronic data), as per EU Regulation 2016/679, article 20.

Regarding the procedures for the exercise of the above-mentioned rights, please write to the following mail address gdpr@xerjoff.com . Before replying, we could ask for an identity verification Your request will be processed within thirty (30) days.9. Complaints

We hereby inform the data subject that you have the right to file a complaint to the Controlling Authority, in case you think that your data have been illegitimately processed. For further information, please go to the official website of the Italian Privacy authority at: www.garanteprivacy.it

 

COOKIE POLICY

 

WHAT IS A COOKIE AND WHAT IS IT FOR?

A cookie is a small text file that is sent to the browser and saved on the user’s device, when the user visit or browse the website www.xerjoff.com, hereinafter referred to as “website”. Cookies allow the site to function efficiently and improve its performance, including through the collection and analysis of aggregated information, which allow the website manager to understand how to improve the structure of the website and its sections. Through cookies, it is also possible to collect information for statistical purposes, mainly to customize the user’s browsing experience, remembering the user’s preferences (for example, the language preferences).

To ensure the proper functioning of the Website and the correct display of the pages, scripts are used in external domains, which do not involve, in any case, the installation of cookies, nor other tracking tools.

WHAT COOKIES DO WE USE?

TECHNICAL COOKIES

Technical cookies can be divided into navigation or session cookies, those cookies are used to guarantee the normal navigation and usage of the Website (allowing, for example, to coordinate the forms that make up the pages of the Website or correlate the pages visited at the same working session) and cookie analytics, similar to technical cookies only if used for the purpose of optimizing the Website directly by the website manager (called analytical cookies of the first party) that can collect information in aggregate form on the number of users and how they visit the Website (for example, to make statistics of the most visited pages, to collect aggregated data of visits by operating system, by browser, etc.).

The use of session cookies is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) and data of use of the software necessary to allow the safe and efficient exploration of the website: the variables (so-called cookies) of the session can avoid the use of computer techniques potentially detrimental to the confidentiality of the navigation of users and do not allow the acquisition of personal identifying data of the user. Session cookies are not persistently stored on the user’s device but are recorded locally for periods of time established according to session variables (whose values stored on the device’s hard drive can still be deleted; it is also possible to disable cookies following the indications provided by the main browsers).

No cookies are used for user profiling, nor are other tracking methods used.

ANALYZING DATA THROUGH GOOGLE ANALYTICS

The Website uses the Google Analytics tool. This is a tool that through the use of cookies (performance cookies), collects anonymous browsing data for the purpose of examining the use of the Website by users, compiling reports on activities on the Website and providing other information, including the number of visitors and the pages visited.

The Website does not use (and does not allow third parties to use) Google’s analytics tool to monitor or collect personal identification information. Google does not associate the IP address with any other data held by Google or attempt to link an IP address with a user’s identity.

For more information on how to use and manage cookies associated with Google Analytics, you can consult google’s cookie policy at the following link: https://policies.google.com/technologies/cookies?hl=it&gl=it.

THIRD-PARTY COOKIES

Third-party cookies are sent from third-party domains and from partner sites that offer their functionality between the pages of the Site. The management of information collected by “third parties” is governed by the relevant third-party privacy and cookie policies. Therefore, the use of the data collected by these external operators through cookies is subject to their respective privacy policies. The use of third-party cookies is limited to what is necessary for the safe and efficient navigation of the Website and does not involve the direct acquisition by the Data Controller of the processing of personal identifying data of the user.

During the navigation on the Website, the user can also receive cookies on his device that are sent to interact directly with social platforms.

The Website incorporates Facebook buttons and widgets, Instagram. These services allow you to make interactions with social networks or other external platforms, directly from the pages of the third-party Website.

The interactions and information acquired through these tools are, in any case, subject to the user’s privacy settings related to each social network, and accessible exclusively to the operators of the same platforms.

For more information on how to process the data collected by social networks, please refer to the privacy policies of the providers of the same services, and in particular:

HOW DO I DISABLE COOKIES?

Most browsers are configured to accept, control, or possibly disable cookies through settings. Please note, however, that the disabling, even partial, of technical cookies could compromise the functioning of the Website and/or limit its functionality.

The disabling of third-party cookies, on the other hand, does not in any way affect the navigability on the Website.

Below reported you will find the links with the instructions provided by the main browsers for the management and disabling of the cookies:

 

COOKIE ENABLEMENT AND DISABLEMENT BY USING THIRD PARTY SERVICES

In addition to being able to use the tools provided by the browser to activate or disable individual cookies, we inform you that the www.youronlinechoices.com website lists the main providers that work with website managers to collect and use information useful for the use of behavioral advertising. To deactivate or activate all companies or alternatively adjust preferences individually for each company you can use the identification and deactivation tool at the following internet page.