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This privacy notice is provided pursuant to Article 13 of Regulation (EU) 2016/679 (hereinafter also referred to as the "Regulation" or "GDPR") by Brunello Cucinelli S.p.A., with registered office in Corciano (PG, Italy), Solomeo hamlet, Viale Parco dell’Industria no. 5 (hereinafter also referred to as "Brunello Cucinelli" or the "Data Controller"), in its capacity as Data Controller.
The Data Controller can be contacted at the address of the registered office indicated above or by writing to privacy@brunellocucinelli.it.
The Data Protection Officer (hereinafter the "DPO") can be contacted at the email address dpo@brunellocucinelli.it or by ordinary mail at the address of the Data Controller, located in Corciano (PG, Italy), Solomeo hamlet, Viale Parco dell’Industria no. 5.
In this notice, we will explain the purposes and methods by which Brunello Cucinelli collects and processes your personal data, the categories of data that are processed, the rights of data subjects, and how they can be exercised.
1. Categories of Personal Data
If you decide to consent to receiving commercial communications from Brunello Cucinelli, the company will acquire and process the following types of personal data:
• Identification data (name, surname);
• Contact data (phone number, email address);
(hereinafter, the "Data").
The provision of the Data is optional; however, without it, Brunello Cucinelli will not be able to send you the commercial communications indicated in paragraph 2 below.
The Data indicated above will be processed exclusively for the purposes and within the limits described below.
2. Purposes and Legal Basis of Processing
a. For direct marketing purposes
With your explicit consent, Brunello Cucinelli will process your Data to send you commercial and promotional communications and offers on Brunello Cucinelli products and services - through traditional means (postal mail and operator-assisted phone calls) and non-traditional means (email, SMS, instant messaging, and chat).
For this purpose, Brunello Cucinelli will process your Data based on your explicit consent, pursuant to Article 6, paragraph 1, letter a) of the Regulation. It should be noted that the Data Controller collects a single consent for the marketing purposes described here, in accordance with the General Provision of the Data Protection Authority "Guidelines on promotional activities and combating spam" of July 4, 2013. If, in any case, you wish to withdraw your consent or object to the processing of your data for marketing purposes carried out with some or all of the contact means indicated above, you may do so at any time by contacting the Data Controller at the addresses indicated in paragraph 1 of this notice, without prejudice to the lawfulness of the processing carried out before the withdrawal/objection.
Once provided, the Data may be processed by the Data Controller for the following additional purposes:
b. For compliance purposes
Brunello Cucinelli will process your Data to comply with legal obligations, regulations, or national and EU legislation, including the provisions of sector supervisory authorities and/or judicial and/or administrative authorities (including compliance with accounting and tax obligations as well as those related to the purposes of crime prevention and suppression, public order, and civil protection, including in the context of counter-terrorism).
For this purpose and when necessary, Brunello Cucinelli will process your Data pursuant to Article 6, paragraph 1, letter c) of the Regulation.
c. For defensive purposes
Brunello Cucinelli will process your Data, if necessary, to ascertain, exercise, or defend a right in court or in extrajudicial proceedings, including debt collection.
For this purpose, Brunello Cucinelli will process your Data pursuant to Article 6, paragraph 1, letter f) of the Regulation.
3. Categories of Recipients to Whom Personal Data May Be Disclosed and Purpose of Disclosure
Your Data may be shared with:
• Third parties acting as data processors pursuant to Articles 4.8) and 28 of the Regulation, such as companies conducting market research and surveys; companies specializing in planning and managing communication projects responsible for managing direct marketing activities on behalf of Brunello Cucinelli, etc.
• The updated and complete list of data processors can be requested from the Data Controller at the addresses indicated in this notice;
• Entities acting as independent data controllers pursuant to Article 4.7) of the Regulation (e.g., entities performing control, audit, and certification activities on behalf of Brunello Cucinelli, also in the interest of its clients and users, etc.);
• Persons authorized by the Data Controller to process data pursuant to Articles 29 and 32.4 of the Regulation and Article 2-quaterdecies of the Privacy Code;
• Entities, bodies, or authorities, independent data controllers, to whom it is mandatory to disclose your personal data by law and/or by order of the authorities.
No form of dissemination of your Data to unspecified subjects is envisaged.
4. Duration of Processing and Data Retention Period
Your Data will be retained only for the time strictly necessary for the purposes for which it is collected, respecting the principles of minimization and limitation of retention as per Articles 5.1.c) and e) of the Regulation.
With reference to the direct marketing purpose mentioned in paragraph 3, letter a), your identification and contact data will be processed until you withdraw the consent you have given pursuant to Article 7 of the Regulation.
The Data Controller reserves the right, in any case, to retain your Data also to comply with regulatory obligations to which it is subject and, if necessary, for the time necessary to meet defensive needs in court and in extrajudicial proceedings.
5. Transfer of Data Outside the European Union
Some of your personal data may be shared with recipients located in a third country outside the European Economic Area or an international organization. The Data Controller ensures that the processing of your personal data by these recipients is carried out in compliance with the GDPR. In particular, transfers will be based on an adequacy decision by the European Commission or on Standard Contractual Clauses approved by the European Commission or on another suitable legal basis, in compliance with the recommendations 01/2020 adopted on November 10, 2020, by the European Data Protection Board.More information is available from the Data Controller or the DPO by writing to the addresses indicated above.
6. Rights of Data Subjects
As a data subject, you have the right to request from the Data Controller, at any time, access to your Data pursuant to Article 15 of the GDPR, rectification pursuant to Article 16 of the GDPR, or erasure of the same pursuant to Article 17 of the GDPR, or to request the restriction of processing pursuant to Article 18 of the GDPR, or to obtain in a structured, commonly used, and machine-readable format the data concerning you in the cases provided for by Article 20 of the Regulation. You may withdraw, at any time, pursuant to Article 7 of the Regulation, the consent already given, without prejudice to the lawfulness of the processing carried out before the withdrawal of consent, by writing to Brunello Cucinelli at the addresses indicated.
You may also lodge a complaint with the Data Protection Authority, as provided for by Article 77 of the Regulation, or take appropriate legal action pursuant to Article 79 of the GDPR if you believe that the processing of your Data by the Data Controller is in violation of the applicable law.