In accordance with D. Lgs. 196/2003 and UE Regulation 2016/679 (GDPR)
Nelesti S.r.l., wich sells products and services under the “Boarini Milanesi” label, collects, stores, processes, uses and discloses personal information about you in connection with your use of the www.boarini-milanesi.com website and the Maison’s apps, your visits to our stores/showrooms or social media pages and all of your interactions with us.
1. The type of information we collect
For the purposes described in this Policy, Nelesti S.r.l. may collect the following categories of personal information:
- Identification and Contact information (such as name, address, date and place of birth, phone number or e-mail address, social media IDs), provided by you to sign up for an online account or fill out a customer information card in store, to participate in an event, to make a purchase, to request a VAT-refund or any other
service both in store and online;
- Payment information: for instance credit card details, bank account numbers, Paypal account details or other payment details which you must provide to receive products or services you have ordered from us;
- Demographic information like your gender and birthday;
- Preferences and interests which you choose to disclose in the course of your privileged contacts or encounters with our client advisors (which may include your preferences about our collections or other luxury brands, your size, your lifestyle, or basic information on your family circle and habits, your job and hobbies, etc.);
- Information about your purchases online or in stores. This could include the products you purchased and their prices;
- If you use our websites, we may collect information about the browser you are using, and your browsing behaviour, including information obtained by cookies;
- Your image when you visit our stores (as CCTVS might be in place), or your voice when you call our Clients Services (calls may be recorded);
- If you use our mobile apps, we may collect your GPS location, subject to your consent when required. We might also look how often you use the app and where you downloaded it. We may collect information about the browser you are using, and your browsing behaviour;
- We may also collect information posted on third party websites or social media platforms about Boarini Milanesi products and services, when necessary for the purposes defined hereunder.
Your personal information is collected either directly from you (e.g., if you create an account on one of our sites/apps or make a purchase or otherwise interact with our client advisors in stores or with our Client Services), or from you passively (e.g., when using tracking tools like browser cookies), or from third parties (e.g. through social media platforms).
If you choose not to submit any personal information when requested to perform a contract or when required by law, you will not be able to receive the product or service you ordered or otherwise register on our web sites, apps or other media.
2. How we use your personal information
We use the information described above for the purposes specified at the time of collection or hereafter in this Policy:
- to provide you with our services, to process your order, respond to your requests or questions, and manage your complaints: for example, we use your information to process your order and deliver your products or we may use your information to send you information you requested, or to communicate with you about your account or our relationship: we may contact you about changes to the site or about service updates. We may also contact you about feedback or about this Policy or website terms. In such case, the legal basis for the data processing is the performance of the contract we have with you or our need to take steps further to a request you made prior to entering into a contract.
- To provide you with personalised pre- and after-sales services, such as personal shopping services, style advice services, warranty and customer services, etc. In such case, the legal basis for the data processing is the performance of the contract we have with you or our need to take steps further to a request you made prior to entering into a contract.
- To keep you updated and informed on all the news regarding our products and services (newsletter service provided via email, telephone, Whatsapp, etc.). In such case, the legal basis for the data processing is the legitimate interests pursued by our company to keep our clients updated and provide excellent customer relationship services.
- To improve our understanding of your interests and concerns, and to improve our understanding of your use of our products: we may use your information to make our website, apps and products/services better. We may use your information to customize your experience with us and to tailor our marketing activities to fit your needs and interests. In such case, the legal basis for the data processing is the legitimate interests pursued by our company to better serve our clients and respond to their needs and requests.
- For security purposes: we may use information to protect our company, our customers, our associates, and our websites or apps against fraud, theft or any wrongdoing which may affect our activity. In such case, the legal basis for the data processing is the legitimate interests pursued by our company to ensure the security of our activities, both online and offline.
- For anti-counterfeiting purposes, and fight against illegal resale channels for Boarini Milanesi products in violation of our company’s general terms and conditions of sale and our distribution network. In such case, the legal basis for the data processing is the legitimate interests pursued by our company to fight counterfeiting and all illegal activities.
- For analytics purposes, we may use your information to analyse the e-reputation of Boarini Milanesi or our products and to measure the effectiveness of our online or offline campaigns or events. In such case, the legal basis for the data processing is the legitimate interests pursued by our company to preserve Boarini Milanesi’s image and optimise our marketing campaigns.
- Other purposes related to the relationship we have with you: we use information to maintain transaction and other business records for legal, administrative, insurance and audit purposes. We also use information to meet legal, insurance and processing requirements. In such case, the legal basis for the data processing is the compliance with a legal obligation to which our company is subject.
3. Whether the provision of personal data is a statutory or contractual requirement, or a Requirement necessary to enter into a contract and the possible consequences of failure to Provide such data
The provision of the information described in section 2, letters a), b) and h) is a contractual requirement or a requirement necessary to enter into a contract with us, in order for us to provide you with the services or products you requested or would like to know more about. If you fail to provide such data, we will not be able to provide you the services, information or products you requested.
The provision of the information described in section 2, letters c), d) is necessary in order for us to keep you updated and informed on all the news regarding our products and services and to customize your experience with us and to tailor our marketing activities to fit your needs and interests. If you fail to provide such data, we will not be able to provide you with our newsletter services, personalised shopping experience services, customised marketing services, etc.
The provision of the information described in the remaining letters of section 2 is on a voluntary basis. In such case, if you fail to provide the information requested, you will still be able to obtain the products/services you requested but the specific activities indicated in the corresponding letters of section 2 will not be carried out.
4. Methods of data processing
The processing of tour personal data will be carried out in accordance with the principles of fairness, lawfulness and transparency with manual, paper, computerized and automated systems.
5. Retention period
Your personal information will not be kept in a form that allows you to be identified for any longer than is reasonably considered necessary by Nelesti S.r.l. for achieving the purposes for which it was collected or processed or as it is established in the applicable laws related to data retention periods. The data retention term of your personal data collected by us is determined per purpose of data processing according to the following criteria. Data collected for the specific purposes defined in section 2 will be stored only:
- For three (3) years since our last contact, if you are a prospect (i.e., you have not made any purchase with us but you are interested in Boarini Milanesi products and services);
- For the duration of your commercial relationship with our company and 10 years thereafter if you are a client (i.e., you have made a purchase of our products or services);
- As far as our newsletter services are concerned, the data will be processed until you request to be cancelled from our newsletter service.
- with our company’s or our group’s authorized personnel with a need to have access to the information in different company areas;
- with service providers and agents who perform services on our behalf: for example, we share information with service providers and professional consultants that help us operate our websites and IT infrastructure, take care of our legal activities, manage our company, implement strategies in different company sectors, take care of the accounting procedures, etc.
- with service providers or consultants that manage payments and tax free refunds;
- with any third party as part of any business restructuring or reorganization (including dissolution, liquidation, M&As, etc.).
- when we are required to do so by law or when it is necessary to comply with applicable law: for example we might share information to respond to a court order or to comply with an obligation which we are subject to.
- Cookies which are functional to the collection of information which allows us to facilitate your browsing experience (such as languages preferences, memorizing log-in, or saving the content of your shopping basket or wish list).
- Cookies used to collect information on your behaviour by collecting referring URLS (where our visitors come from, which banners they clicked on and which directed them to our website), pages accessed, times of website visits. Such information allows us to enhance our website and apps functionalities, have a better understanding of the products and services you prefer, and offer you more personalized content on our website/apps.
- Cookies used for web analytics to measure the website activity and determine which areas of the website attract the highest number of visits, hence improving the visibility of our content.
- Cookies used to ensure security of online transactions/purchases.
- We may include in our website or apps functions used to share content with third parties or to let other persons know that you browsed our website. Such is the case of the “Like” and “Share” functionalities offered by social network platforms (“Facebook”, “Twitter”, etc).
- Social networks which offer these functionalities may identify you even though you have not used these functionalities on our website. Indeed, such functionalities allow social network platforms to track information about your browsing on our website whenever your social network account is active while browsing our website.
- The right of access;
- The right to rectification;
- The right to erasure (‘right to be forgotten’);
- The right to restriction of processing;
- The right to data portability;
- The right to object;
- The right to lodge a complaint to the competent supervisory authority.
In case of legal disputes, your personal information may be stored until the end of such litigation, including any potential periods for appeal, and will then be deleted or archived as indicated by the applicable laws.
Your personal data will then be anonymized or deleted.
6. Who we share your personal information with
Your personal information will be processed in accordance with the principles of fairness, lawfulness and transparency.
We do not disclose or otherwise share your personal information we collect, except:
7. Tracking tools and cookies
We may collect information through cookies, web beacons and other automated means. A cookie is a text file which is stored in a dedicated area of your device’s hard drive, for instance when you visit an online boutique, when you read an email or while installing or using a mobile app. A cookie allows its sender to identify the device on which it is stored during the period of validity of consent, which does not exceed 13 months.
We might use the following types of cookies:
Our websites or apps may contain third party cookies (delivered by advertising agencies, analytics and marketing services providers, etc.), used to collect browsing information on your devices, including data used to measure the efficiency of our advertising campaigns on third party websites. Third party cookies are subject to said third party privacy policies. We hereby inform you about the purpose of these cookies and how you can manage them, to the extent we are aware thereof:
We do not control how these platforms collect your personal data while you are browsing our website. We invite you to read the Privacy policies of these social networks to find out how they use the information they collect (including for advertising purposes). The Privacy policies of social media platforms provide information about how to manage your preferences on your social networks account.
Except for functional or security cookies, the use of cookie on a device depends on the user’s choice, which can be made and modified whenever you wish to.
Such is the case if we can no longer recognize the type of browser your device is using as well as other important settings (language, display settings or country of connection, etc.). We cannot be held liable for the minimized access to our services as a result of cookies you previously deleted or rejected.
8. Your rights
In accordance with UE Reg. 679/2016, we would like to inform you that you will be able to exercise your rights, as specified below, at any time:
To exercise these rights or learn more about them, please contact us at: email@example.com.
9. Data controller
The data controller, that you can contact to ecercise your rights, is Nelesti S.r.l. whose registered office is in Casalecchio di Reno (Bologna), Italy at Via del Lavoro, 71, registered in the Companies Register of Bologna, VAT nr. IT03557401209.
To exercise your rights or request information regarding the processing of data you can contact us using the following email address: firstname.lastname@example.org.
Casalecchio di Reno, 25th may 2018