1. Personal data processing. Data processor
The present policy is drafted by Grimoldi S.r.l., who has its registered office in Piazza Duomo 21 – 20121 Milano, Italia VAT number 00722480159 and registered in the Commercial Register in Milan with registration number MI-75656 (referred to as the "Owner" in the following policy), in quality of data controller of personal information of the users (referred to as "Users") that navigate and benefit from the services available on the internet site www.grimoldijewels.com (referred to as the "Site" or the "Services"), to provide the privacy statement pursuant to article 13 of the EU General Data Protection Regulation 2016/679 published on April 27th 2016 (referred to as "Regulation" or "Applicable Law"). This Site and its connected Services are reserved to subjects who are eighteen or older in age.
- By sending a note to the registered office of the Owner in Piazza Duomo 21 – 20121 Milano
- By sending an e-mail to the address email@example.com
Grimoldi acts as owner of data processing in relation to personal data conferred by the user in case of registration to the website www.grimoldijewels.com (Site), namely in the occasion of a purchase of products on Site. This policy is destined also to any subject that interacts with the pages of the Site without carrying out any registration.
2. Purpose of the processing
Grimoldi will treat the personal data provided by the user for the following purposes:
(a) To consent the registration to the Site and enjoy the services reserved to the registered users. The legal basis of the data treatment is your consent to treatment of your data for subscription to the Site and access to the services reserved to registered users;
(b) In the case in which the user makes use of the e-commerce services provided by Grimoldi on the site:
1. To permit Grimoldi the correct implementation of all operations connected to the online purchase and, therefore, to consent Grimoldi to respect the purchase rules designed with the client. The legal basis of the purchase is the essence of a sales contract;
2. limited to the email address provided by the user for the purpose of the purchase of a product from the website, to permit the direct sale of similar products (so-called soft spamming), assuming that the user does not object to such treatment. The legal basis of such processing, is Grimoldi's absolute legitimate interest in sending these types of data;
(c) to reply to emails regarding a client's request or the helping service chat available on the website. The legal basis of this processing, is Grimoldi's legitimate interest to follow up on the user's requests;
(d) for administrative and accounting purposes related to a client's registration on the site and to successfully finalize an online purchase, as well as fulfilling all legal obligations;
(e) under consensus of the user to send out newsletters and for carrying out market surveys, also aimed at assessing the degree of the user's satisfaction and lastly, to send advertising about Grimoldi's or other parties' products and services, through the use of e-mail, fax, sms, MMS or traditional means (eg.: per post or phone call). The legal basis of this processing is the user's consent to receive this type of communication;
(f) for statistical purposes.
The processing of personal data concerning the user, will be mainly carried out through the help of electronic or automated means, according to the methods and with the tools suitable to guarantee the highest level of security and confidentiality of the data, in compliance with the provisions of the GDPR. All technical, organizational and procedural security measures, will be adopted, in order to guarantee the minimum standards of data protection required by law, which only allows the person in charge to access the user's data. Furthermore, the data will be managed under a constantly protected environment.
Data related to credit cards
In order to make a payment on the website through credit card, the user must enter the data related to the credit card (card number, holder, expiry date and security code). This information, will be taken from the payment service provider who will act as an independent data processor and controller, without passing through Grimoldi's server, therefore, Grimoldi will not process such data in any way. Lastly, the user will have the option to save the credit card information for future purchases on Grimoldi's website, this, will be done directly from the payment service provider (Grimoldi will not be involved in any way).
Sensible data and judicial data are not part of Grimoldi's processing treatment.
IP addresses and log files
Grimoldi will keep the log files and IP addresses used when making a purchase, within the terms required by law, to prevent and guarantee any fraud during the online transactions.
Access to the site is possible without needing the transfer of any personal data. Nevertheless, the computer systems and the softwares used for the activity of the site automatically acquire certain personal data, which is implicit with the use of internet.
Such information is not collected with the purpose of associating it with the user's personal data, and through the elaboration or association of such data, the system is able to identify the user.
This category includes IP addresses or the user's domain name used on the computer utilised to access the website, URL addresses, access time, the method used to submit the request to the server, the file size, etc. These data are only used to derive anonymous statistical information on the use of the website (such as the amounts of accesses) and to verify the correct functioning of the website and is deleted straight after processing. This process does not include the processing of any identification data.
3. Data transfer and the consequences in case of lack of consent to processing
The input of data for the following purposes (a), (b.1) and (d) of Article 2 is optional. However, since such processing is necessary to allow registration to the website and the only purchase service, any refusal by the user to provide the data in question, will result in the user not being able to register and conclude any online purchase.
The input of data for the purpose of point (c) of article 2 is optional. Nevertheless, as such processing is necessary to enable the user to respond to his/her requests, any refusal by the user to provide the data in question, will mean that F.B. is unable to respond to such requests.
Consent to the processing of your data for marketing, prophylactic and transfer purposes is optional. Failure to agree will have the following consequences:
Failure to agree to the processing marketing data will result in the user being unable to receive advertisements related to Grimoldi products and/or services and/or third parties and the inability for Grimoldi to carry out market surveys, including the user's satisfaction survey and to send them newsletters;
Failure to process personal data for profiling purposes, will result in the inability for Grimoldi to develop a commercial profile of the user, normally created through the collection of choices and purchasing habits on the site, as well as advertisements related to Grimoldi and/or third party goods.
- The user may withdraw his consent for marketing and prophylactic purposes by contacting Grimoldi by sending a note to the legal headquarter in Piazza Duomo 21, 20121, Milan or by sending an email to firstname.lastname@example.org
4. The communication of data
Personal data provided by the user for the purposes described in Article 2 above, may be given to the following people:
- Grimoldi's staff members to carry out administrative and accounting services to control the user's situation;
- Entities responsible for managing online payment transactions;
- All public and private entities, whenever the communication is necessary or functional to the correct fulfillment of the contractual obligations in relation to the services provided through the site, as well as to law obligations;
- To people responsible for the delivery and withdrawal of the purchased products;
- All those entities who have access to the data under regulatory or administrative ways.
All personal data provided by the user for the access to the website and any purchases, shall not be widespread. The updated list of all people in charge for the treatment of the user's data can be viewed at the legal headquarters of Grimoldi.
5. Data retention
The user's data, will only be kept during the time required to ensure the proper delivery of the services. In the case the user wants to end his/her registration to the website, the personal data will only be kept for a trimester for administrative purposes, unless there are any specific legal obligations or for public security reasons. To close a user's account, he/she will have to contact Grimoldi by either sending a post note at the legal headquarters in Piazza Duomo, 21, 20121, Milano or an email to email@example.com. The data will be kept for the purposes mentioned in the note or email sent by the user (e) for the duration mentioned in article 2 above, for the time allowed by law and from the person in charge of the protection of personal data. Before this period, Grimoldi may request the user to renew his consent to the processing of his/her data or to keep them in order to create anonymous statistical data.
6. Privacy rights of the user
Grimoldi informs the user that he/she has the right to:
- Request Grimoldi to access to personal data and to correct, delete and to oppose to the processing of such information;
- Withdraw the consent to the processing of personal data, regardless if it had been accepted previously;
- File a complaint on any authority in charge of controlling personal data.
The rights mentioned above, can be put into place if requested to the person responsible for the treatment of such data, whose contacts are mentioned in article 1.
Last updated: Saturday 7th of May 2022