Privacy Policy

PRIVACY NOTICE AND POLICY

Version of 25/05/2018

Welcome to the site www.agl.com of Attilio Giusti Leombruni (the “Site”). The site is owned by Attilio Giusti Leombruni S.p.A., with registered offices in Viale Bettino Craxi, 1, 63812 Montegranaro (FM), Italy, Tax Code and VAT no. 01125410447 (“AGL”) and is operated and maintained, with regards to its e-commerce section, by Triboo Digitale S.r.l., with registered offices in Viale Sarca 336, 20126 Milan, Italy, Tax Code and VAT no. and registration number in the Business Registry of Milan 02912880966, in its quality of seller (“TRIBOO DIGITALE”) and, with regards to the content of its institutional areas, by AGL. This privacy policy notice (the “Privacy Policy”) is provided to you pursuant to art. 13 and art. 14 of EU Regulation 679/2016 (the “GDPR”) and describes the modalities and purposes of the processing of your personal data (“Personal Data”) made via the Site.  {0>

This Privacy policy is subject to updates and/or variations made from time to time by the data controllers of 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 and amendments made to it. Your use of the Site and/or your purchase of the Products of AGL through the e-commerce section of the Site will be subject to the Privacy Policy posted from time to time on the Site and in force at the time of such use and/or such purchase. 


A.        PRIVACY NOTICE AND AGL’S INFORMATIVE NOTE AND PRIVACY POLICY OF AGL

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 browsing of the Site, your use of the Contact and/or Customer Care section of the Site and your request to receive AGL’s newsletter, the data controller of your Personal Data is Attilio Giusti Leombruni S.p.A., with registered offices at the abovementioned address.

With reference to the processing of your Personal Data for the purchase of the Products of AGL and the related sale transactions through the e-commerce section of the Site, including your registration on the Site, the separate data controller is TRIBOO DIGITALE, in its quality of seller of the Products of AGL through the e-commerce section of the Site, with registered offices at the abovementioned address. 

The provisions below illustrate the processing of your Personal Data made by AGL .

Should you wish to know which of your Personal Data is stored by AGL, please contact AGL as set forth by point 6 below.

The Site may contain links to sites of third parties that are neither controlled nor monitored by AGL. Please note that access to and use of such sites of third parties may be subject to your acceptance of the additional privacy policies provided by third-party owners, hence we recommend to carefully read said policies prior to use such sites of third parties.


2.         Types of processed Personal Data

Browsing data

With regards to browsing data, we inform you that the technological and software systems used for the operation of the Site collect, during their normal operation, certain Personal Data the transmission of which is implied in the use of Internet communication protocols. Said Personal Data are not collected to be associated with identified data subjects, but, by their own nature and through processing and association with data held by third parties, may permit your identification. This category of Personal Data includes the IP addresses or domain names of the computers that you use to access the Site, URL addresses of requested resources, time of the request, method used to submit the request to the server, size of the response file, numeric code indicating the status of the server’s response (successful, error, etc.) and other parameters concerning your operating system and technological environment. 

The said Personal Data are used only to obtain anonymous statistic information on the use of the Site (e.g. number of visits) and to monitor proper operation and are deleted after processing, within the period of time set by applicable laws. 

Data provided voluntarily

We inform you that it is possible to access and browse the Site without being requested to voluntarily provide any of your Personal Data.  

With regards instead to the Personal Data that you may voluntarily provide when using the Site, we inform you that the Personal Data may indicate to subscribe to AGL’s newsletter or by means of the Contact and/or Customer Care section of the Site may include your name, surname, gender, email address, as well as information about you that is included in the messages that you may transmit to AGL.

Data disclosed by other data controllers

We inform you that, pursuant to point 4 (d) of paragraph B of this Privacy Policy, AGL may receive your Personal Data and data concerning your Product purchases through the e-commerce section of the Site. AGL will process the afore-cited data in its quality of separate data controller for the purposes set forth by point 4 of this paragraph A.

Data pertaining to special categories

AGL invites you not to transmit Personal Data or information that may be classified as data pertaining to special categories in pursuance of art. 9 of the GDPR (that is Personal Data that provide information about the state of health, sexual orientation, political and religious beliefs). AGL will ignore any data possibly pertaining to special categories that may be contained in the messages that you may transmit to AGL through the Contact section of the Site or by otherwise contacting AGL, unless you provide your consent in writing to the use of said data pertaining to special categories by sending a specific consent statement in accordance with the modalities set forth in point 6 below. 

3.         Cookies

We invite you to read the section dedicated to the cookies used by the Site.       

4.         Modalities and purposes of processing of Personal Data

Purposes of Personal Data processing

Personal Data provided will be collected and processed by AGL solely for the following purposes: 

(a)       purposes connected to the services requested through the Site: for the management of the Site’s operation and security and the provision of services requested through the Site, e.g. through the Contact and/or Customer Care section of the Site or following your request to receive AGL's newsletter, as well as for the performance of all the obligations deriving from the relationship established with you and applicable laws and/or regulations, including on administrative—accounting and public security matters, and the protection of the rights of AGL or the users of the Site. In this case, the legal basis for data processing is the rendering of a requested performance or service and your consent is not required;

 (b)       administrative-accounting purposes related to the services offered through the Site and/or by companies affiliated to and/or appointed by AGL to provide the same services. In this case, the legal basis for data processing is the rendering of a requested performance or service or the performance of legal obligations and your consent is not required;

(c)        subject to your prior consent, if such consent is required by applicable laws and it being free and optional, for marketing the purposes of studying your purchase preferences and marketing purposes, such as market and/or marketing researches, including presentations of new Products of AGL, promotions and/or product offers of AGL or of third parties in which AGL takes part, also by means of automated systems such as email (direct email marketing), facsimile, sms or MMS, market or consumer surveys researches, including the (i) transmission of newsletters and/or notices (e.g. initiatives, contests, new launches of AGL’s Products and/or sites); (ii) promotions (e.g. of AGL's Products and/or third party's products).

Provision of Personal Data

With the exception of browsing data, you are free to provide your Personal Data through the Site, by means of the Contact and/or Customer Care section of the Site or by requesting to receive AGL's newsletter. However, your decision not to provide said Personal Data may result in the impossibility for you to receive the service you requested with your message sent to AGL.

With regards to the processing purposes indicated at previous letters (a) and (b), your transmission of a message to AGL through the Contact and/or Customer Care section of the Site or to request the transmission of the newsletter implies that you are aware that your Personal Data will be processed for said purposes and, since such processing is aimed at the performance of the relationship established with you and/or for purposes of legal, administrative and accounting nature, your consent to said processing is not required.

With regards, instead, to the purposes indicated at previous letter (c), if applicable laws so require, you will be requested to expressly consent to the processing of Personal Data for said purposes. Your decision not to consent to the processing of your Personal Data for said purposes may result in the impossibility for you to receive the notices and/or materials as above described.

In any event, you are entitled to object at any time to the processing of your Personal Data for the purposes indicated in previous letter (c) and choose to no longer receive notices and/or materials, even if of specific interest to you.

Modalities and duration of Personal Data Processing

Processing of Personal Data will be principally made by means of electronic and/or automated tools, with modalities and tools able to ensure the security and confidentiality of same, in compliance with the provisions of applicable laws. In particular, all technical, technological, organisational, logistic and procedural security measures , as provided by the GDPR, will be adopted in order to ensure the minimum level of protection required by law. The information collected and processing purposes will be pertinent to and not in excess of the type of services rendered. Your Personal Data will also be managed and protected in environments access to which is under constant monitoring.

The lieu of the processing of your Personal Data is the registered offices of AGL or, if necessary, the offices of the persons indicated at art. 5 below.

Your Personal Data collected by the Site or provided by you voluntarily as a user, will be stored by AGL for the period of time required to attain the abovementioned purposes, without prejudice to the need to store data to perform obligations deriving from applicable laws, also after completion of the processing operations.

Your Personal Data provided by you voluntarily as a user for informative purposes or for the transmission of updates and news concerning sale initiatives, contests, other advertising and promotional material, as well as to inform you about initiatives and other events, will be stored for a period of 24 months, without prejudice to the other purposes set forth by this policy that may require using the data for a longer period of time.

5.         Disclosure and dissemination of Personal Data

Your Personal Data may be disclosed to:

 (a)       all the persons (including legal, administrative and tax consultants, Public Authorities, etc.) who are granted access to Personal Data by reason of legal and/or administrative measures or to whom data must be disclosed in performance of contractual obligations undertaken towards you or deriving from applicable laws and/or regulations;

 (b)       companies and/or persons and/or consultants and/or professionals and/or suppliers, including Internet providers who cooperate with AGL to attain the purposes of the processing of Personal Data, including TRIBOO DIGITALE and persons engaged to manage and maintain the Site or engaged by AGL for the provision of the services offered therein; persons in charge of the transmission of advertising and informative material;

 (c)        affiliated companies, parent companies or subsidiaries of AGL, assignees and/or licensees, also of businesses and/or business units, of AGL.

The abovementioned persons will act in their quality of separate data controllers or data processors of the processing of Personal Data, as the case may be. A list of data processors is available at AGL’s offices and may be obtained upon request, by sending an email to the following email address: eboutique@agl.com.

Processing by third parties shall in any event be made in accordance with correctness applicable laws, including the GDPR.

Your Personal Data will not be disseminated other than in anonymous and aggregate form, for statistic or research purposes.

6.         Rights of the data subject

Pursuant to art. 15-22 of the GDPR, you are inter alia entitled to:

 (a)       access to and obtain confirmation of the existence of your Personal Data and their communication to you in intelligible form;

 (b)       obtain from AGL indications on the source of your Personal Data, their processing purposes and modalities, the logic applied in case of processing carried out with electronic tools; indications on the persons or categories of persons to whom Personal Data may be disclosed or who may, in their quality of processors or persons in charge of processing, become aware of same;

(c)        obtain the update, rectification or integration of your Personal Data; the erasure, restriction, transformation in anonymous data or blocking of your Personal Data that have been processed unlawfully, including data that must be stored in connection with the purposes for which they were collected or subsequently processed; obtain Personal Data portability; revoke consent previously granted;

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

We also inform you that, pursuant to art. 77 of the GDPR, in the event you consider that your Personal Data have been processed in breach of the provisions of the GDPR, you have the right to file a claim before  a supervising authority, notably in the member State where you habitually reside, where you work or where the alleged breach occurred. Said authority, with regards to the Italian territory, is the Garante for the protection of personal data. 

You may exercise the afore-cited rights by contacting AGL at the abovementioned address, via the Contact and/or Customer Care section of AGL site, or by sending a message at the following email: eboutique@agl.com.

7.         Applicable law

AGL’s informative notice and privacy policy are regulated by the GDPR and its implementing Italian laws.

8.         Versions

AGL’s informative notice and privacy policy are published on the Site in Italian, English, German and Russian. In the event of any inconsistency between said versions, you agree that the Italian version of AGL’s informative notice and privacy policy will prevail.

 

 

B.        PRIVACY NOTICE AND PRIVACY POLICY OF TRIBOO DIGITALE

1.         Data controller

With reference to the processing of your Personal Data for the purchase of Products of AGL and the related sale transactions through the e-commerce section of the Site, including your registration on the Site, the management of orders, sale and delivery of Products, handling of returns, warranties and other activities required for the sale of Products through the e-commerce section of the Site, the separate data controller of your Personal Data is TRIBOO DIGITALE, in its quality of seller of the Products of AGL through the e-commerce section of the Site, with registered offices at the abovementioned address. 

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

Should you wish to know which of your Personal Data is stored by TRIBOO DIGITALE, please contact TRIBOO DIGITALE as set forth by point 6 below.

The Site may contain links to sites of third parties that are neither controlled nor monitored by TRIBOO DIGITALE. Please note that access to and use of said sites of third parties may be subject to your acceptance of the additional privacy policies provided by third-party owners, hence we recommend to carefully read said policies prior to use such sites of third parties.

2.         Types of processed Personal Data

Browsing data

With regards to browsing data, we inform you that the technological and software systems used for the operation of the Site collect, during their normal operation, certain Personal Data the transmission of which is implied in the use of Internet communication protocols. Said Personal Data are not collected to be associated with identified data subjects, but, by their own nature and through processing and association with data held by third parties, may permit your identification. This category of Personal Data includes the IP addresses or domain names of the computers that you use to access the Site, URL addresses of requested resources, time of request, method used to submit the request to the server, size of the response file, numeric code indicating the status of the server’s response (successful, error, etc.) and other parameters concerning your operating system and technological environment. 

The said Personal Data are used only to obtain anonymous statistic information on the use of the Site (e.g. number of visits) and to monitor proper operation and are deleted after processing, within the period of time set by applicable laws. 

Data provided voluntarily

We inform you that it is possible to access and browse the Site without being requested to voluntarily provide any of your Personal Data.  

With regards instead to Personal Data that you may voluntarily provide to register on the e-commerce section of the Site and/or through the order form for the conclusion and performance of sale transactions concerning the purchase of Products through the e-commerce section of the Site and/or through the Contact and/or Customer Care of the Site, we inform you that the Personal Data provided by you may include your name, surname, email address, telephone number, data of your credit card and your bank details, as well as information about you that is included in the messages that you may transmit to TRIBOO DIGITALE.

Data belonging to particular categories

TRIBOO DIGITALE invites you not to transmit Personal Data or information that may be classified as data pertaining to special categories in pursuance of art. 9 of the GDPR (i.e. Personal Data that provide information about the state of health, sexual orientation, political and religious beliefs). TRIBOO DIGITALE will ignore any data possibly pertaining to special categories that may be contained in the messages that you may transmit to TRIBOO DIGITALE through the Contact section of the Site or by otherwise contacting TRIBOO DIGITALE, unless you provide your consent in writing to the use of said data pertaining to special categories by sending a specific consent statement in accordance with the modalities set forth in  point 6 below. 

3.         Cookies

We invite you to read the section dedicated to the cookies used by the Site.

4.         Modalities and purposes of processing of Personal Data

Purposes of processing of Personal Data

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

(a)       purposes connected to the management of the processes of your registration on the e-commerce section of the Site and/or your contact through the Contact and/or Customer Care section of the Site. In this case, the legal basis for data processing is the rendering of a requested performance or service and your consent is not required;

(b)       purposes connected  to the services requested through the e-commerce section of the Site:  management of the operation and security of said section, management of processes and/or transmission of Product order forms, management, conclusion and performance of sale transactions concerning purchases of Products (e.g. order receipt, checking of the order, payment of the price and related costs, shipping, delivery, returns, etc.), as well as performance of all the obligations deriving from the relationship established with you and applicable laws and/or regulations, including on administrative—accounting and public security matters. In this case, the legal basis for data processing is the is the rendering of a requested performance or service and your consent is not required;

(c)       administrative-accounting purposes related to the services offered through the Site and/or by companies affiliated to and/or appointed by TRIBOO DIGITALE to provide the same services. In this case, the legal basis for data processing is the rendering of a requested performance or service and your consent is not required;

(d)     subject to your prior express and free consent, if required, the purposes of disclosing your Personal Data and data concerning purchases of Products made by you through the e-commerce section of the Site to AGL, which will process such data in quality its of separate data controller, for the purposes set forth by point 4 of previous paragraph A.

Any data processing concerning your credit card and/or bank details for purposes other than the verification of the existence of payment means, charging and management of payment, as well as the management of claims and litigation procedures, is excluded. To this end, the afore-cited data will be processed also by the bank that provides services connected to the management of online payments, as well as the institution that issued the credit card that you will enter to confirm your order of Products, in their quality of separate data controllers.

Provision of Personal Data

With the exception of browsing data, you are free to provide your Personal Data through the e-commerce section of the Site, whether at the time of your registering on said section and/or at the time of your completing the Product order, or through the Contact and/or Customer Care section of the Site. However, your decision not to provide said Personal Data may result in the impossibility to conclude and/or perform the sale transactions through the e-commerce section of the Site and/or for you to receive the service you requested with you message sent to TRIBOO DIGITALE.

In particular, your decision not to provide your Personal Data such as your personal data, email address, postal address, telephone number, credit card data and/or bank details, as well as Personal Data marked with (*) in the e-commerce section of the Site, may result in the impossibility to perform the Product purchase contract and/or to properly perform obligations under applicable laws and regulations.  Refusal to provide said Personal Data may thus constitute, as the case may be, a legitimate and justified reason not to perform the Product purchase contract through the e-commerce section of the Site.

The provision of Personal Data other than those mentioned above is optional and does not result in any consequence with regards to the purchase of Products through the e-commerce section of the Site.

With regards to the processing purposes indicated at previous letters (b) and (c), your transmission of a Product order implies that you are aware that your Personal Data will be processed for the said purposes and, since the processing of such data is aimed at the performance of the relationship established with you and/or for purposes of legal, administrative and accounting nature, your consent is not required.

With regards, instead, to the purposes scopes indicated at previous letter (a), if applicable laws so require, you will be requested to expressly consent to the processing of Personal Data for said purposes. Your decision not to consent to the processing of your Personal Data for said purposes may result in the impossibility for you to successfully conclude the registration procedure on the e-commerce section of the Site and/or send a message to TRIBOO DIGITALE through the Contact section of the Site.

Modalities and duration of Personal Data Processing methods and duration 

Processing of Personal Data will be principally made by means of electronic and/or automated tools and, in some cases, in paper format, such as when Personal Data processing is required to prevent frauds on the Site, with modalities and tools able to ensure the security and confidentiality of same, in compliance with the provisions of applicable laws. In particular, all technical, technological, organisational, logistic and procedural security measures, as provided by applicable laws, will be adopted to ensure the minimum level of protection required by law. The information collected and processing purposes will be pertinent to and not in excess of the type of services rendered. Your Personal Data will also be managed and protected in environments access to which is under constant monitoring.

The lieu of the processing of your Personal Data is the registered offices of TRIBOO DIGITALE and/or, if necessary, the offices of external data processors (or independent data controllers) indicated in art. 5 below.

Your Personal Data collect by the Site or provided by you voluntarily as a user will be stored by TRIBOO DIGITALE for the period of time required to attain the abovementioned purposes, without prejudice to the need to store data to perform obligations deriving from applicable laws, also after completion of the processing operations.

Security measures

TRIBOO DIGITALE adopted security measures in order to minimize risks of destruction or loss, even accidental, of your Personal Data, unauthorised access or unauthorised or non-compliant with the above purposes processing of your Personal Data.

However, since it is not possible to guarantee that the measures adopted for the security of the Site and transmission of data and information through the Site limit or exclude any risk of unauthorised access or data loss, we invite you to ensure that your computer operates up-to-date antivirus software protecting incoming and outgoing online data transmission, and that your Internet provider implemented firewalls and antispamming filters of filters able to render online data transmission secure.

5.         Disclosure and dissemination of Personal Data

Your Personal Data may be disclosed to:

 (a)       all the persons (including legal, administrative and tax consultants, Public Authorities, etc.) who are granted access to Personal Data by reason of legal and/or administrative measures or to whom data must be disclosed in performance of contractual obligations undertaken towards you or deriving from applicable laws and/or regulations;

 (b)       companies and/or persons and/or consultants and/or professionals and/or suppliers, including Internet providers who cooperate with TRIBOO DIGITALE to attain the purposes of the processing indicated at letters (a), (b) and (c) of previous point 4, and persons entrusted with the management and maintenance of  the Site and/or engaged by TRIBOO DIGITALE to supply the services offered therein.

In particular, your Personal Data may be disclosed to third parties who render, in their quality of separate data controllers and/or data processors,  specific services on behalf of TRIBOO DIGITALE for the performance of the Product purchase contract through the e-commerce section of the Site, such as Global Collect, or for the rendering of payment services via credit card.

One of the data processors of your Personal Data is ThunLogistics S.r.l., via Rita Castagna 1, 46100 Mantova (MN) –Italy, with regards to the processing of your Personal Data that is required required to carry out logistic activities for the shipping and possible return of the Products purchased through the e-commerce section of the Site.

The abovementioned persons will act in their quality of separate data controllers or data Processors, as the case may be. A list of data processors is available at TRIBOO DIGITALE’s offices and may be obtained upon request.

Your Personal Data may also be disclosed by TRIBOO DIGITALE to AGL for administrative-accounting purposes strictly related to the contractual relationship in force between TRIBOO DIGITALE and AGL: the latter will process said data as separate data controller.

Finally, your Personal Data may be disclosed by TRIBOO DIGIALE to AGL, which will always act as a separate data controller, to reply to your specific request of information concerning the Products. In this case, the legal basis for data processing is the need to reply to your requests.

To obtain the complete list of processors processing your Personal Data, please contact Customer Care or send an email to the following address: privacy@triboo.it.

Processing by third parties shall in any event be made in accordance with correctness applicable laws, including the GDPR Save for the disclosure to AGL for the above indicated purposes, your Personal Data will not be disseminated other than in anonymous and aggregate form, for statistic or research purposes.

6.         Rights of the data subject

You may exercise the rights guaranteed by the GDPR (art. 15-22), by contacting TRIBOO DIGITALE as follows:


  • by sending a registered letter with return receipt to the registered offices in Viale Sarca 336, Edificio 16, 20126 Milan;
  • by sending an email at triboospa@legalmail.it;
  • by sending a facsmile at no. +39 02 647414 14;

You may also contact TRIBOO DIGITALE’s Data Protection Officer (DPO), at the following address: lapo.curinigalletti@triboo.it.

Pursuant to the GDPR, TRIBOO DIGITALE informs you that you have the right to obtain the indication of (i) the source of Personal Data; (ii) the purposed and modalities of processing; (iii) the logic applied in case of processing made by means of electronic tools; (iv) identity details of the data controller and data processors; (v) persons or categories of persons to whom Personal Data may be disclosed or who may become aware of same in their quality of data processors.Moreover, you have the right to obtain:

a) the access, updating, rectification or, if of interest to you, integration of data;

b) the erasure, transformation in anonymous form or blocking of data processed in breach of laws, including data no longer required to be stored in relation to the purposes for which they were collected or subsequently processed;

c) confirmation that the operations indicated in letters a) and b) have been  disclosed, also with regards to their content, to the persons to whom data was disclosed or notified, except in the event said obligation becomes impossible to perform or requires the use of means manifestly disproportionate compared to the protected right.

In addition, you have:

a) the right to revoke your consent at any time, in the event processing of data is based on consent;

b) (if applicable) the right to data portability (the right to receive all Personal Data in a structured, commonly used and readable by an automated device format,), the right to restrict the processing of personal data and the  right to erasure ("right to be forgotten");

c) the right to object:

i) in whole or in part, for legitimate reasons, to the processing of Personal Data, even if pertinent to the purposes of their collection.

d) in the event you consider that your Personal Data has been processed in breach of the GDPR, the right to file a claim before a supervising  authority (in the member State in which you habitually reside, where you work or where the alleged breach occurred). The Italian supervisory authority is the Garante for the protection of personal data,  with offices in Piazza di Monte Citorio no. 121, 00186 – Rome (http://www.garanteprivacy.it/).

7.         Applicable law

TRIBOO DIGITALE’s informative notice and privacy policy are regulated by the GDPR and its implementing Italian laws.

8.         Versions

TRIBOO DIGITALE’s informative notice and privacy policy are published on the Website in Italian, English, German and Russian. In the event of any inconsistency between said versions, you agree that the Italian version of TRIBOO DIGITALE’s informative notice and privacy policy will prevail.