Privacy Policy

Privacy notice and policy

Version of  03/04/2017

Welcome to the site www.agl.com of The Italian Sisters Inc. (the “Site”). The Site is owned by The Italian Sisters Inc., with registered offices at 130 West 57th Street, 7th Floor, Suite 7C New York, NY 10019 (“The Italian Sisters”) and is operated and maintained, as regards it e-commerce section, by Triboo Digitale S.r.l., with registered offices at Viale Sarca 336, 20126 Milan, Italy, Fiscal Code, VAT no. and registration no. at the Registry of Companies of Milan 02912880966, in its capacity as seller (“TRIBOO DIGITALE”) and, as regards the contents of its institutional sections, by The Italian Sisters. This privacy notice and policy (“Privacy Policy”) is provided in accordance with article 13 of Legislative Decree no. 196/2003 (the “Privacy Code”) and explains the ways and purposes of the processing of your personal data (“Personal Data”) made via the Site.

This Privacy Policy is subject to updates and variations made from time to time by the data controllers processing your Personal Data, in their own discretion, also as a consequence of variations in applicable laws and/or regulations. Please check this Privacy Policy regularly to ensure that you are also aware of any variations or amendments made to it. Your use of the Site and/or your purchase of the products of The Italian Sisters will be subject to the Privacy Policy posted on the Website from time to time and in force at the time of such use and/or such purchase.

A.        PRIVACY NOTICE AND POLICY OF THE ITALIAN SISTERS 

1.         Data Controller

With reference to the processing of your Personal Data as a consequence of your access and use of the Site, including your mere navigation of the Site, your use of the Contacts and/or Customer Care area of the Site and your request to receive The Italian Sisters’ newsletter, the data controller of your Personal Data is The Italian Sisters Inc., with registered offices at the address above indicated.

With reference to the processing of your Personal Data for the purchase of the products of The Italian Sisters and the related commercial transactions via the e-commerce section of the Site, including your registration on the Site, the data controller is, also and separately, TRIBOO DIGITALE, in its capacity as seller of the Products of The Italian Sisters via the e-commerce section of the Site, with registered offices at the address above indicated.

The following provisions explain the processing of Personal Data made by The Italian Sisters.

Should you wish to know which of your Personal Data are held by The Italian Sisters, we invite you to contact The Italian Sisters in accordance with article 6 below.

The Site may contain links to sites of third parties that are neither controlled nor monitored by The Italian Sisters. We invite you to take note that access and use of such sites of third parties may be subject to acceptance by you of additional privacy notice(s) prepared by such third party data controllers and we invite you to carefully read such notice(s) prior to use such sites of third parties.


2.         Processed Personal Data

Navigation data

As regards navigation data, we inform you that computer systems and software procedures used for the provision of the Site may collect, during their normal operation, certain Personal Data the transmission of which is implied in the use of protocols of Internet communications. These Personal Data are not collected to be associated with a specific identified person, but, by their own nature and through processing and association with data of third parties, may permit your identification. This category of data comprises the IP addresses or domain names of the computers used by you when you access the Site, the addresses in URL notation of the required resources, the time of the request, the method used to forward the request to the server, the size of the file received in reply, the digit code showing the state of the reply given by the server (success, error, etc.) and other parameters of your operating system and technological environment.

These data are used only to obtain anonymous statistical information about the use of the Site (for example the number of accesses) and to check its correct performance and are deleted after processing within the period of time set by applicable laws.

Data voluntarily provided

We inform you that you may access and navigate the Site without being requested to voluntarily provide any of your Personal Data.

In respect of Personal Data that you may voluntarily provide in using the Site, we inform you that the Personal Data you may provide to subscribe for The Italian Sisters’ newsletter or by means of the Contacts and/or Customer Care section of the Site may comprise your name, surname, genre, email address, as well as information about you that is included in the messages that you may send to The Italian Sisters.

Sensitive Data

The Italian Sisters recommends that you do not transmit Personal Data or information that may be classified as sensitive data pursuant to the Privacy Code (that is data that are capable of providing information concerning health, sexual orientation, political and religious convictions). The Italian Sisters will ignore any sensitive data contained in the messages that you may send to The Italian Sisters through the Contacts section of the Site, unless you provide your written consent to the use of such sensitive data by sending a consent release in accordance with article 6 below.

3.         Cookies

We invite you to read the dedicated section on the cookies used on the Site

4.         Ways and purposes of Personal Data processing

Purposes of Personal Data processing

Personal Data provided will be collected and processed by The Italian Sisters solely for the purposes indicated below:

(a)       purposes connected with the services requested via the Site: for the management of the operations and security of the Site and the provision of services requested via the Site, for example through the Contact and/or Customer Care Section or following your request to received The Italian Sisters' newsletter, as well as for the performance of the obligations deriving from the relationship established with you and applicable laws and/or regulations, including on accounting-administrative and public security matters, and the protection of the rights of The Italian Sisters or the users of the Site;

(b)       accounting-administrative purposes connected with the services provided via the Site and/or by companies that are affiliated to or engaged by The Italian Sisters for the provision of the same services;

(c)        subject to your prior consent, if such consent is required by the Privacy Code and it being free and optional, for marketing purposes, such as market and/or marketing researches, including presentation of new products of The Italian Sisters, promotions and/or offers of products of The Italian Sisters and/or of third parties to which The Italian Sisters participates, also by means of automated systems such as e-mail (direct e-mail marketing), facsimile, sms or MMS, market and/or consumer surveys, including (i) transmission of newsletters and/or communications (eg. initiatives, contests, new product and/or site launches); (ii) promotions (eg. of products of The Italian Sisters and/or products of third parties);

Provision of Personal Data

With the exception of navigation data, you are free to provide Personal Data via the Site, through the Contact and/or Customer Care section of the Site or requesting to receive The Italian Sisters' newsletter. However, your failure to provide such Personal Data may result in the impossibility to obtain what you requested with your message sent to The Italian Sisters.

As regards the purposes of processing indicated at previous points (a) and (b), your transmission of a message to The Italian Sisters via the Contact and/or Customer Care section of the Site or to request the transmission of the newsletter implies your acknowledgment of the processing of your Personal Data for said purposes and, since such processing is aimed at the performance of the relationship established with you and/or for purposes of a legal, accounting or administrative nature, your consent to said processing is not required.

As regards, instead, the purposes indicated at previous point (c), if so required by the Privacy Code, you will be requested to expressly consent to the processing of Personal Data for such purposes. Failure by you to consent to the processing of Personal Data for such purposes will result in the impossibility for you to receive commercial communications and/or materials as above described.

In any event, you shall be entitled to object at any time to the processing of Personal Data for the purposes indicated at previous point (c) and choose to no longer receive commercial communications and/or materials, even if of specific interest to you.

Ways of Personal Data processing

The processing of Personal Data will be made principally by means of automated and/or electronic systems, with the modalities and means that are able to guarantee the security and confidentiality of same, in accordance with the provisions of the Privacy Code. In particular, all technical, informatics, organizational, logistic and procedural security measures, as provided by the Privacy Code, shall be adopted so as to guarantee the minimum level of protection provided by the law. Information collected and processing ways shall be pertinent to and not in excess of the type of services rendered. Your Personal Data shall also be managed and protected in an environment which access to is under constant control.

The lieu of processing of Personal Data is the registered offices of The Italian Sisters or, if necessary, the offices of the persons indicated at article 5 below.

5.         Communication and dissemination of Personal Data

Your Personal Data may be communicated:

(a)       to all the persons (including legal, administrative and taxation consultants, Public Authorities, etc.) who are granted access to Personal Data in accordance with normative and/or administrative measures or to whom communication is necessary in performance of contractual obligations with you  or deriving from applicable laws and/or regulations;

(b)       to companies and/or persons and/or consultants and/or professionals and/or suppliers, including Internet providers, who cooperate with The Italian Sisters for the attainment of the purposes of processing of Personal Data, including TRIBOO DIGITALE and persons engaged to manage and maintain the Site or engaged by The Italian Sisters for the provision of the service offered therein; persons in charge of the transmission of informative and promotional materials;

(c)        to affiliated parent or subsidiary companies of The Italian Sisters, assignees and/or licensees, including of businesses or business units, of The Italian Sisters.

The above indicated persons shall act in their capacity of autonomous data controllers, data supervisors or persons in charge of data processing of the Personal Data, as the case may be. A list of data supervisors of Personal Data is available at The Italian Sisters' registered offices and may be accessed upon request by sending an email to the following e-mail address: eboutique@agl.com

Except in anonymous or aggregated form and for purposes of statistics or research, your Personal Data shall not be disseminated.

6.         Rights in respect of your Personal Data

Pursuant to article 7 of the Privacy Code, you are inter alia entitled to:

(a)       obtain confirmation as to whether your Personal Data are held by The Italian Sisters and their communication to you in intelligible form;

(b)       obtain information from The Italian Sisters concerning the source of collection of Personal Data, ways and purposes of their processing, logic applied to their processing if made by electronic systems; information on the persons or categories of persons to whom the Personal Data may be communicated and/or who may become aware of same in their capacity as data supervisors or persons in charge of data processing;

(c)        obtain the update, rectification or integration of your Personal Data; the deletion, transformation into anonym data, or blockage of Personal Data that have been processed unlawfully, including data that must be stored in connection with the purposes for which they were collected or processed;

(d)       object, in whole or in part, for legitimate reasons, to the processing of your Personal Data described at previous article 4, point (c).

You may exercise the above referred rights by contacting The Italian Sisters at the address above indicated, via the Contact and/or Customer Care section, or at the following e-mail address: eboutique@agl.com

7.         Applicable law

The privacy notice and policy of The Italian Sisters are governed by the laws of Italy.

8.         Versions

The privacy notice and policy of The Italian Sisters are published on the Site in Italian, English, German and Russian. In the event of discrepancy between these versions, you agree that the Italian version of the privacy notice and policy of The Italian Sisters shall prevail.

B.       PRIVACY NOTICE AND POLICY OF TRIBOO DIGITALE

1.         Data controller

With reference to the processing of your Personal Data for the purchase of the products of The Italian Sisters and the related commercial transactions via the e-commerce section of the Site, including your registration on the Site, the management of orders, the sale and delivery of the products via the e-commerce section of the Site, the management of returns and warranties and other activities necessary for the sale of the products via the e-commerce section of the Site, the data controller is, also and separately, TRIBOO DIGITALE, in its capacity as seller of the products of The Italian Sisters via the e-commerce section of the Site, with registered offices at the address above indicated.

The following provisions explain the processing of Personal Data made by TRIBOO DIGITALE.

Should you wish to know which of your Personal Data are held by TRIBOO DIGITALE, we invite you to contact TRIBOO DIGITALE in accordance with article 6 below.

The Site may contain links to sites of third parties that are neither controlled nor monitored by TRIBOO DIGITALE. We invite you to take note that access and use of such sites of third parties may be subject to acceptance by you of additional privacy notice(s) prepared by such third party data controllers and we invite you to carefully read such notice(s) prior to use such sites of third parties.

2.         Processed Personal Data

Navigation data

As regards navigation data, we inform you that computer systems and software procedures used for the provision of the Site may collect, during their normal operation, certain Personal Data the transmission of which is implied in the use of protocols of Internet communications. These Personal Data are not collected to be associated with a specific identified person, but, by their own nature and through processing and association with data of third parties, may permit your identification. This category of data comprises the IP addresses or domain names of the computers used by you when you access the Site, the addresses in URL notation of the required resources, the time of the request, the method used to forward the request to the server, the size of the file received in reply, the digit code showing the state of the reply given by the server (success, error, etc.) and other parameters of your operating system and technological environment.

These data are used only to obtain anonymous statistical information about the use of the Site (for example the number of accesses) and to check its correct performance and are deleted after processing within the period of time set by applicable laws.

Data voluntarily provided

We inform you that you may access and navigate the Site without being requested to voluntarily provide any of your Personal Data.

In respect of Personal Data that you may voluntarily provide for the purposes of registration on the e-commerce section of the Site and/or by means of the order form for the conclusion and performance of commercial transactions concerning the purchase of the Products via the e-commerce section of the Site and/or via the Contact and/or Customer Care section of the Site, we inform you that the Personal Data you may provide may comprise your name, surname, email address, telephone number, your credit card data or your bank coordinates, as well as information about you that is included in the messages that you may send to TRIBOO DIGITALE.

Sensitive Data

TRIBOO DIGITALE recommends that you do not transmit Personal Data or information that may be classified as sensitive data pursuant to the Privacy Code (that is data that are capable of providing information concerning health, sexual orientation, political and religious convictions). TRIBOO DIGITALE will ignore any sensitive data contained in the messages that you may send to TRIBOO DIGITALE through the Contact section of the Site, unless you provide your written consent to the use of such sensitive data by sending a consent release in accordance with article 6 below.

3.         Cookies

We invite you to read the dedicated section on the cookies used on the Site

4.         Ways and purposes of Personal Data processing

Purposes of Personal Data processing

Personal Data provided will be collected and processed by TRIBOO DIGITALE solely for the purposes indicated below:

(a)       purposes connected with the management of the procedures for your registration on the e-commerce section of the Site and/or your contact via the Contact and/or Customer section of the Site;

(b)       purposes connected with the services requested via the e-commerce section of the Site: for the management of the operations and security of said section the management of procedures and/or transmissions of order forms of the Products, the management, conclusion and performance of commercial transactions concerning the purchase of the Products (eg. order receipt, order verification and verification of payment of price and other related costs, shipping, delivery, returns, etc.), as well as for the performance of the obligations deriving from the relationship established with you and applicable laws and/or regulations, including on accounting-administrative and public security matters;

(b)       accounting-administrative purposes connected with the services provided via the e-commerce section of the Site and/or by companies that are affiliated to or engaged by TRIBOO DIGITALE for the provision of the same services.

Any processing of your credit card data and/or bank coordinates for purposes other than the verification of the subsistence of the means of payment, debiting and management of payments, as well as management of possible claims and/or contentious proceedings is excluded. To this end, the dais data shall be processed by the bank that provides the services connected with on-line payments or the institution that issued the credit card that you shall use to complete your order of the Products.

TRIBOO DIGITALE is not the data controller of the processing of Personal Data for marketing purposes.

Provision of Personal Data

With the exception of navigation data, you are free to provide Personal Data via the e-commerce section of the Site, at the time of your registration on that section and/or at the time of compilation of an order for the Products, or through the Contact and/or Customer Care section of the Site or requesting to receive The Italian Sisters' newsletter. However, your failure to provide such Personal Data may result in the impossibility to conclude and/or perform the commercial transactions via the e-commerce section of the Site and/or obtain what you requested with your message sent to TRIBOO DIGITALE.

In particular, failure by you to provide Personal Data such as biographical data, your e-mail address, your postal address, your telephone number, your credit card data and/or bank coordinates, as well as the Personal Data identified in the e-commerce section by the sign (*), may result in the impossibility to perform the purchase agreement for the Products and/or correctly perform obligations deriving from applicable laws and/or regulations. Failure to provide such Personal data may thus constitute, as the case may be, a legitimate and justified reason not to perform the purchase agreement for the Products via the e-commerce section of the Site.

Provision of Personal Data other than those indicated above is optional and does not entail any effect on the purchase of the Products via the e-commerce section of the Site.

As regards the purposes of processing indicated at previous points (b) and (c), your transmission of an order for the Product implies your acknowledgment of the processing of your Personal Data for said purposes and, since such processing is aimed at the performance of the relationship established with you and/or for purposes of a legal, accounting or administrative nature, your consent to said processing is not required.

As regards, instead, the purposes indicated at previous letter (a), if so required by the Privacy Code, you will be requested to expressly consent to the processing of Personal Data for such purposes. Failure by you to consent to the processing of Personal Data for such purposes will result in the impossibility for you to successfully register on the e-commerce section of the Site and/or transmit a message to TRIBOO DIGITALE via the Contact section of the Site.

Ways of Personal Data processing

The processing of Personal Data will be made principally by means of automated and/or electronic systems and , in certain instances, in paper format, such as for example when the processing of personal data is necessary to prevent frauds on the Site, with the modalities and means that are able to guarantee the security and confidentiality of same, in accordance with the provisions of the Privacy Code. In particular, all technical, informatics, organizational, logistic and procedural security measures, as provided by the Privacy Code, shall be adopted so as to guarantee the minimum level of protection provided by the law. Information collected and processing ways shall be pertinent to and not in excess of the type of services rendered. Your Personal Data shall also be managed and protected in an environment which access to is under constant control.

The lieu of processing of Personal Data is the registered offices of TRIBOO DIGITALE or, if necessary, the offices of the persons indicated at article 5 below.

Security measures

TRIBOO DIGITALE adopted security measures to reduce to the minimum the risk of destruction or loss, even if accidental, of your Personal Data, unauthorized access to the same or processing of same that is unauthorized or non-compliant with the purposes above indicated. However, since it is not possible to guarantee that the measures adopted for the security of the Site or data or information transmission via the Site limit or exclude any risk of unauthorized access or data loss, we invite you to ensure that your computer is protected by means of updated antivirus software for the protection of on-line data transmission, whether going in or going out, and that your Internet service provider adopted firewalls and anti-spamming filters or filters that are appropriate for the security of on-line data transmission.

5.         Communication and dissemination of Personal Data

Your Personal Data may be communicated:

(a)       to all the persons (including legal, administrative and taxation consultants, Public Authorities, etc.) who are granted access to Personal Data in accordance with normative and/or administrative measures or to whom communication is necessary in performance of contractual obligations with you  or deriving from applicable laws and/or regulations;

(b)       to companies and/or persons and/or consultants and/or professionals and/or suppliers, including Internet providers, who cooperate with TRIBOO DIGITALE for the attainment of the purposes of processing of Personal Data, including The Italian Sisters and persons engaged to manage and maintain the Site or engaged by TRIBOO DIGITALE for the provision of the service offered therein; persons in charge of the transmission of informative and promotional materials;

The above indicated persons shall act in their capacity of autonomous data controllers, data supervisors or persons in charge of data processing of the Personal Data, as the case may be. A list of data supervisors of Personal Data is available at TRIBOO DIGITALE’s registered offices and may be accessed upon request.

In particular, your Personal Data may be communicated to third parties that, in their capacity as data supervisors, provide specific services on behalf of TRIBOO DIGITALE to perform the purchase agreement for the Products via the e-commerce section of the Site, such as for example Global Collect for the provision of services for payment by credit card.

To date one of the data supervisors of your Personal Data is Savino del Bene – FDS Inc., 34 Engelhard Avenue,Avenel, NJ 07001, for the processing of your Personal Data that is necessary for performance of logistic activities aimed at the shipping and possible return of Products purchased via the e-commerce section of the Site.

To receive a complete list of the supervisors processing your Personal Data, we invite you to contact the Customer Care or send an email to the following e-mail address: privacy@triboo.it

Except in anonymous or aggregated form and for purposes of statistics or research, your Personal Data shall not be disseminated.

6.                     Rights in respect of your Personal Data

Pursuant to article 7 of the Privacy Code, you are inter alia entitled to:

(a)       obtain confirmation as to whether your Personal Data are held by TRIBOO DIGITALE and their communication to you in intelligible form;

(b)       obtain information from TRIBOO DIGITALE concerning the source of collection of Personal Data, ways and purposes of their processing, logic applied to their processing if made by electronic systems; information on the persons or categories of persons to whom the Personal Data may be communicated and/or who may become aware of same in their capacity as data supervisors or persons in charge of data processing;

(c)        obtain the update, rectification or integration of your Personal Data; the deletion, transformation into anonym data, or blockage of Personal Data that have been processed unlawfully, including data that must be stored in connection with the purposes for which they were collected or processed;

(You may exercise the above referred rights by contacting TRIBOO DIGITALE at the address above indicated, via the Contact and/or Customer Care section, or at the following e-mail address: privacy@triboo.it.

7.         Applicable law

The privacy notice and policy of TRIBOO DIGITALE are governed by the laws of Italy.

8.         Versions

The privacy notice and policy of TRIBOO DIGITALE are published on the Site in Italian, English, German and Russian. In the event of discrepancy between these versions, you agree that the Italian version of the privacy notice and policy of TRIBOO DIGITALE shall prevail.