How we process personal data

GENERAL INFORMATION ON OUR PRIVACY POLICY This section describes how the processing is managed and constitutes information provided in accordance with the regulations on the Protection of Personal Data. The Data Controller is the company MB Retail S.r.l., S.S. Trossi 49, 13848 Verrone (Biella) C.F. and P.I. 02084130026, which determines the purposes and means of the processing. 2. PURPOSES OF THE PROCESSING AND LEGAL BASIS 2.1. COLLECTION OF DATA MB Retail S.r.l. collects personal data and other information directly from its users during the online registration process, through web pages dedicated to new commercial initiatives or through the purchase order of products on the site for the conclusion of e-commerce transactions.

This data is processed by MB Retail S.r.l. within the limits and for the purposes illustrated in the information presented to the user in the specific data collection section or in this Privacy Policy, including the possible communication to third parties for purposes instrumental to the provision of the service requested by the user (as better specified in the paragraph "To whom we communicate personal data"). 2.2. PURPOSE Users' personal data is collected and processed by MB Retail S.r.l. for purposes strictly connected with the use of the website, its services (including marketing activities) and the purchase of products.

In particular, personal data may be processed for the following purposes: to provide registration services and access to reserved areas or specific services (as part of the website registration process, we collect your e-mail address, personal and/or shipping data and password using the relevant online registration forms); where expressly requested, to send you the newsletter by e-mail; for purposes necessary to provide you with all the information and assistance regarding services and/or the purchase of products on the website (to provide assistance services, we collect personal data as part of Customer Service in the "Contact Us" section); to allow us to refine the process of purchasing products on the site (we collect personal data, such as personal details, e-mail address, postal address, credit card and bank details, telephone number using the order form); to provide information about problems with navigation, browser compatibility and viewing or loading web pages on the site (this is collected and processed as part of the request for technical support services); to prevent or detect fraudulent activities or abuse harmful to the site; to allow MB Retail S.r.l. to provide all the information and assistance about the services and/or purchase of products on the site to exercise its rights (as for example, the right of defence in court); to save their favourite products on the wish list; to book appointments with our tailors at our points of sale; subject to express and specific consent, for marketing, analysis and profiling activities such as: information and/or commercial promotion by mail (or flyer) and telephone or by electronic communications such as e-mail, sms messages and other automated systems available for this purpose, aimed at making new products known and improving the services offered; market research and surveys on the quality of services and customer satisfaction, also using specialized companies, with the aim of improving the offer of products and services; profiling aimed at analysing needs, tastes, choices and consumption habits, also through electronic processing, to provide communications on products or services in line with users' preferences and interests; analysis on aggregated data of user behaviour or analysis of user behaviour on the website.

 The processing of data for marketing and profiling purposes requires specific and distinct consent; however, for other purposes, the Data Controller may process personal data even without the user's consent in some cases provided for by law (for example, when this is necessary to comply with a legal obligation) or when it is necessary to comply with contractual obligations towards the user (for example, if the user has purchased products on the site) or has requested to use specific services through our site.

1. NATURE OF DATA The provision of personal data to MB Retail S.r.l. (in particular personal data, e-mail address, postal address and telephone number) is necessary for the conclusion of the contract for the purchase of products on the site. Any refusal to provide the data necessary for these purposes may make it impossible to execute the contract for the purchase of products on the site or to provide the other services available - such as providing assistance services - or to correctly fulfil legal and regulatory obligations. The communication to the Owner of further data, other than those of compulsory conferment, for the purposes of fulfilling its legal or contractual obligations or for the provision of certain services on request is, on the other hand, optional and does not entail any consequences for the use of the site and its services or for the purchase of products. Depending on the case and, if necessary, from time to time the user will be duly informed of the mandatory or optional nature of the provision of personal data to the Owner. Failure to provide optional personal data will not lead to any obligation or disadvantage. 4. RIGHTS OF THE INTERESTED PARTIES Users have the right at any time to obtain confirmation of the existence or otherwise of personal data concerning them and their communication in an intelligible form. The interested party has the right to be informed of: the content and source of the personal data; the purposes and methods of processing; the logic applied to the processing carried out with the help of electronic means; the identification data concerning data controller and data processors; the duration of the storage in relation to the specific categories of data processed; the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as data processors or persons in charge of the processing. The interested party also has the right to obtain: the updating, rectification or, when they are interested, the integration of the data; the cancellation, transformation into anonymous form or limiting of the data processed (e.g. if processed unlawfully), including data whose retention is unnecessary for the purposes for which the data was collected or subsequently processed; the portability of the data to another data controller; the opposition to the processing (e.g., if the data is processed unlawfully), for the sending of advertising or direct marketing material or for carrying out of market research or commercial communications); opposition to any automated decision-making process (including profiling); revocation of any consent given, where applicable (please note that the revocation of consent does not affect the lawfulness of the processing based on the consent given before the revocation); certification that the operations referred to in the previous points have been brought to the attention, also as regards their content, to those to whom the data was communicated or disseminated, unless this requirement proves impossible or involves the use of means manifestly disproportionate to the protected right. In part, this information is contained in our Privacy Policy; to find out more, you can contact our customer service at info@modestobertotto.com.

The right to object to the processing of personal data for marketing purposes can be exercised both through the so-called automated means of contact (e.g. e-mail, sms, whatsapp or other social media, etc. ...), and through traditional methods (mail and telephone); this right may be exercised in whole or in part (e.g. only through communications by mail or telephone or by opposing only the sending of promotional communications made through automated tools such as e-mail, sms), even independently through the specific services made available to the user (e.g. by unchecking the checkbox of the newsletter in the reserved area). The interested party always has the right to lodge a complaint with the Guarantor Authority for the protection of personal data for the exercise of his rights or for any other matter relating to the processing of their personal data. 6. COMMUNICATION OF PERSONAL DATA For purely organisational and functional needs and for purposes strictly connected and related to the provision of our services (including the sale of products), personal data may be made available to third-party companies, contractually linked to the Data Controller, which perform specific services, as Data Processors (e.g. forwarding agents or companies that perform activities or provide marketing services). These parties, in their capacity as Data Processors, will process personal data exclusively on behalf of MB Retail S.r.l. and exclusively for the purposes indicated in this Privacy Policy and in any case in compliance with the law and any consent given. For a complete list of data processors, you can contact our customer service department in the "Contact Us" section or write to info@modestobertotto.com. Personal data will not be communicated, transferred or transferred to third parties for purposes not permitted by law or without express consent. In addition to the companies acting as data processors, personal data are also made available to third parties (autonomous data controllers) who process the data autonomously solely for the purpose of executing the contract for the purchase of products on the Site and for ancillary purposes and related to the provision of services requested by the user (for example, for transactions relating to purchases, the credit institution for the execution of electronic payment services at a distance, by credit/debit card). The data will not be disseminated.

This excludes, in any case, the communication or dissemination of data required, in accordance with the law, by police forces, judicial authorities, information and security bodies or other public entities for purposes of defence or State security or the prevention, detection or prosecution of criminal offences. 7. DATA PROCESSING PERIOD Personal data is processed for the time strictly necessary to achieve the purposes and means listed above. The criteria used to determine the storage period are established by: specific legal regulations, which regulate the activities of MB Retail S.r.l.; period of stay as a newsletter subscriber (for marketing) in the absence of voluntary unsubscription; tax regulations regarding the processing of administrative-accounting data (10 years); in particular, for financial data (e.g. payments, refunds, etc.) the storage period required by applicable tax and accounting laws is applied. With reference to data collected for commercial purposes, on the other hand, details of purchases referring to identifiable users are kept for 12 months (from the date of acquisition of such information) for the purposes of sending targeted commercial communications (profiling) and for 24 months for the purposes of carrying out direct marketing activities. The data subject to profiling, therefore, may be stored for this purpose only for a period not exceeding twelve months from their registration, except for the actual transformation into anonymous form which does not allow, even indirectly or by connecting other databases, to identify the persons concerned (the profiling activity will be carried out using data strictly necessary to achieve the stated purposes).

The personal data of the "registered" user, on the other hand, will be kept until: 12 months after account closure; 10 years after the last use on our site (e.g. access to the personal area, purchase made by a logged-in user, etc.), if the user does not close the account. Finally, the customer's personal data may be stored even until the time allowed by Italian law to protect the legitimate interests of the owner company (art. 2947, paragraphs 1 and 3 of the Italian Civil Code). 8. PROCESSING BASED ON AUTOMATED DECISIONS AND PROFILING For more information on the processing of personal data based on automated decisions and profiling you can consult our Cookie Policy. By subscribing to one of our services (e.g. in the "register" section of the site) through the authentication methods on social media (e.g. Facebook) or Google, MB Retail S.r.l. will be able to access certain personal data (e.g. name, surname, e-mail etc.) present in the social media account or user profile according to the conditions of use applicable by these platforms. We may also collect some of your personal data when you interact with third party social media features, such as "Like" or "Pixel". Except in the cases indicated above and relating to profiling of user behaviour on the site and the analysis of consumer tastes and habits, MB Retail S.r.l. does not carry out any other automated processing of personal data that could produce decision-making effects that could affect the user's legal sphere. 9. APPLICABLE LAW AND CONTACTS This Privacy Policy is governed by European law and Italian law (Personal Data Protection Code, Legislative Decree no. 196 of 30 June 2003 and subsequent amendments) governing the processing of personal data of users of this Site. These regulations ensure that the processing of personal data is carried out in respect of fundamental rights and freedoms, as well as the dignity of the person concerned, with particular reference to confidentiality, personal identity and the right to protection of personal data. 10. AMENDMENTS AND UPDATES TO THIS PRIVACY POLICY The Owner will take care to modify or simply update, in whole or in part, the Privacy Policy of the Site also in consideration of the amendment of the rules of law or regulations that govern this matter and protect the rights of users. Changes and updates to the Privacy Policy of the site will be made available in this section of the site as soon as they are adopted. Last updated October 2018.