Privacy

Information note and request for consent for personal data processing
Information Note document pursuant to and for the effects of Article 13 of the Legislative Decree No. 196 of 30 June, 2003

In compliance with Legislative Decree No. 196 of 30 June, 2003 (Privacy Consolidation Act), we hereby provide you with the required information regarding the aims and methods of processing of your personal data, provided by you, as well as the extent of communication and diffusion of the same, to the nature of the data in our possession and their conferment.

Moleskine S.r.l.  handles the personal information of its users with particular care. The present information note on privacy establishes the policy of Moleskine S.r.l. relating to privacy that regulates the area protected by password of the sites owned by Moleskine S.r.l. by means of which Moleskine S.r.l. gathers personal data. Accessing or making use of any of the sites above referred to, the user, moreover, expressly accepts the conditions esytablished in the present policy relating to privacy. In case of disagreement with any whatsoever term of this policy on privacy,
you are requested not to use the sites or not to provide your own personal data. Some of the services could be conditioned on the provision of such personal data.

Personal data
For the purposes envisioned by the present policy on privacy, “Personal Data” signifies all that information by which the user can be personally identified, and includes, solely as an example and not exhaustive, the given name, family name, address, telephone numbers (land and mobile), e-mail address, age, date of birth, sex, occupation, the data and details of the products, preferences of products, satisfaction with regard to products, language, driving experience and the like, photos and accounts, etc.

The policy on privacy of Moleskine S.r.l. regulates the processing of the user’s personal data, including as an example and not exhaustive, the gathering, the use, the storing and protection of the information provided by and/or collected on the user for the purposes here below indicated

Purposes of processing for which consent is given where requested (Art. 23 of Legislative Decree 196/03)

a) management of inherent data processing:
- registration on the present website for the acquisition of products;
- activity strictly connected with and instrumental in the management of the rapport of on-line purchasing – also through external subjects, such as by way of example: T-Buy srl (MI) – and conclusion of a contract, performance of the operations based on obligations derived from the concluded contract, accounting activity (issuing invoices, arrangements for payments), transfer of data abroad to EU countries, within the limits of the law;
- furnishing goods and for the protection of the position of creditor derived by them and thus to permit the carrying out of all the activities relating to the performance of the contractual agreement and fulfilment of the relative services and obligations, as well as statistical surveys in anonymous form;
- treatment of requests for information;

 b) management of inherent data processing:
 -  promotional communications, also personalised for information activity, through the sending of advertising posters and hard copy promotional documentation, e-mail, newsletters, invitations;
- any programmes and prize contests;
Without obtaining the prior consent of the user, the personal data of the same will not be used for the purposes referred to in Par. b).At the time of providing personal information, the user has the possibility to opt in favour of such service.
. For all other purposes, the user’s consent will be requested

Processing and storage procedures

Processing will be carried out by automated electronic and/or manual means, with procedures and tools adjusted to guarantee maximum security and confidentiality, operated by persons appropriately charged with observing the provisions of Articles 31 and following, Legislative Decree No. 196/03. They will be stored at our offices in Milan or at the offices of third parties to be identified from time to time to handle the services to be furnished for periods strictly necessary for the purposes above cited and in any event not exceeding the period prescribed under law. In compliance with existing regulations, specific security measures are observed to prevent the loss of data, illicit or improper use and unauthorised access.
Personal data for contractual administrative-accounting purposes will be stored for a period not exceeding the administrative purposes for which they were collected and successively processed, while they will be stored for the purposes of profiling or of marketing for a period not exceeding, respectively, for twelve or twenty-four months from their registration, apart from actual transformation to an anonymous form.

Limits on communication and diffusion

Data of a personal nature and only eventually of a sensitive nature, subject to processing, will not be diffused; they can, instead, be communicated by Moleskine S.r.l.  for the above listed purposes to companies contractually tied to Moleskine S.r.l.  or forming part of its distribution network, eventually also being located in other European Union countries, and in that case they will be processed by them exclusively for the above-said purposes. Personal data may be transferred abroad to countries not part of the EU within the scope and limits envisioned by Articles 43 and 44, sub letter b), L.D. 196/03.
: Data may be communicated to third parties included in the following categories;
- subjects that provide services for the management of the IT systems used by Moleskine S.r.l.  and of the telecommunication network and to the company, T-Buy Srl (MI), for e-commerce;
- subjects, also external, for management and archiving hard copy and/or IT documentation;
- service companies handling acquisition, registration and processing of data arising from documents, or mediums supplied and originating from the same customers and having the object of mass working in relation to payments,  effects, cheques and other titles;
- subjects that perform activities of assistance to customers, also by internet (i.e. call centres, help desks, etc.);
- professionals, offices or companies in the ambit of relationships of assistance and consultation, also for the control of company organisational management;
- for companies contractually ties to Moleskine S.r.l.;
- public administration authorities for the verification of observance of fiscal and civil obligations;
- banks and credit and insurance institutions to effectuate financial activities (payments, collections) and insurance;
- Subjects that carry out performance of control, review and certification of the activities brought into being by Moleskine S.r.l., also in the customers’ interest.
- for the purposes of Par. b), personal data may be communicated to outside companies for activities of commercial communication for the account of Moleskine S.r.l.
The subjects included in the above categories perform the functions of responsibility for processing data, or operate in total autonomy as a separate processing owner.


The list of the eventual subjects in charge is available at the offices of Moleskine S.r.l in Milan. All additional communications or diffusion will only come about with your prior explicit consent.
Storing and transmission of personal data by the internet is protected by updated technological means commonly in use.

Nature of the conferment

The providing of data for the purposes referred to in Paragraph a) is obligatory even if not the result of a regulatory requirement, inasmuch as it is required for registration on the present site and/or to conclude and effect execution of the relative contract for purchase of goods. Any refusal to consent to processing for the purposes listed above in Paragraph a) renders it impossible to register and purchase products at the Moleskine S.r.l. websites through which Moleskine S.r.l. collects personal data.

The eventual refusal of consent with respect to Paragraph a) renders impossible the activities strictly related to and instrumental in managing relations with Moleskine S.r.l., which will also find itself in the position of not being able to provide the goods themselves, or necessary for the discharge of contractual obligations. The owner hereby notes, moreover, that any non-communication, or erroneous communication, of one of the required data, has the following consequences:
- the impossibility of the owner to guarantee the completion of the registration on the present site and the adequacy of the processing itself to the eventual contractual pact for which the same was executed;
- the possible failed correspondence of the results of the same processing to the eventual obligations imposed by the fiscal, administrative and civil regulations to which they are addressed.
In the case where the data indicated as “obligatory” are not inserted in the registration module, it will not be possible, therefore, to complete the registration procedure.

The conferment of data for the purposes of Paragraph b) is optional, i.e. it is not required as a matter of law: the failure to provide data for such purposes will have as its only consequence the impossibility to be contacted by Moleskine S.r.l  for promotional communications, also personalised for information activities.
The refusal of consent for the purposes set forth above in Paragraph b), will not have any negative consequences with regard to your request and to effect execution of the relative contract (the purposes referred to in Paragraph a).
You may claim your rights according to Articles 7, 8, 9 and 10 of L.D. No. 196 of 30 June, 2003 by contacting the owner or the processing manager P. Matani at Moleskine S.r.l. - marketing department.

Cookies

With the aim of facilitating the services offered, Moleskine S.r.l.  will utilise "cookies" to provide better and more personalised service. The “cookie” is installed when the browsing session is started. If you do not wish the “cookie” to be memorised on your hard disk, you must configure your browser so as not to accept it, using the recommended procedure for the specific browser, or deleting it directly from your computer. In this case, the speed and quality in the operation of services can worsen.
In the case that you have not activated the option that prevents the installation of "cookies" on your hard disk, you can explore your hard disk by following the instruction manual of the operating system to know each server from which the “cookies” are derived. Moleskine S.r.l. will keep your typical navigation path to adapt our services as much as possible to your preferences. The User expressly consents to the use of “cookies” by Moleskine S.r.l., without having to ask for your consent each time.

Moleskine S.r.l.  reserves the right to change, modify, add or remove parts of the present policy on privacy, at its own discretion and at any time. The user has the responsibility to periodically check for any changes to this page. Continued use of this site following the posting of changes to the present policy on privacy constitutes acceptance of the same.
You may validate your own rights as expressed in Articles 7,8,9 and 10 of L.D.196 of 30 June, 2003 by contacting the owner (or the responsible party, if nominated) of the processing.

Art. 7. Right of access to personal data and other rights
1. The interested party has the right to obtain the confirmation of the existence or not of personal data that concerns him/her, also if not yet registered, and their communication in an intelligible form. 2. The interested party has the right to obtain the indication:

a) of the origin of the personal data; b) of the purpose and manner of processing; c) ofthe logic applied in the case where processing is effectuated with the use of electronic instrument; d) of the identificative details of the owner, the person in charge and the designated representative pursuant to Art. 5, sub 2; e) of the subjects and categories of subjects to which personal data can be communicated or who could come to know of as designated representative in the territory of the state, of persons responsible or in charge. 3. The interested party has the rightto obtain: a) the updating, rectification or, if so interested, the addition of data; b) the cancellation, the transformation into anonymous form or the blocking of data processed in violation of the law, including those for which there is no need to store with regard to the purposes for which the data has been collected or subsequently processed; c) The certification that the operations referred to in sub letters a) and b) were brought to the knowledge, also with regard to their contents, from those to whom the data was communicated or diffused, excepting the case where such fulfilment is shown to be impossible or involves the use of manifestly disproportionate means in relation to the right being protected.
4. The interested party has the right to oppose, in whole or in part: a) for legitimate reasons the processing of personal data that concerns him/her, even though pertinent to the scope for which gathered; b) to processing of personal data  that concerns him/her with the object of sending advertising material or for direct sales or for market research or commercial communications.

For any request for information and/or clarifications, questions or complaints as to processing of personal data, we ask you to do so by writing to the person in charge of processing indicated below:

Owner of processing is: Moleskine S.r.l. - Viale Stelvio, 66 – 20159 Milan, in the person of its legal representative, Arrigo Berni

Person in charge of processing: P. Matani at Moleskine S.r.l. - Marketing department
    
Whenever contact is no longer desired, the use of personal data will immediately cease. Whenever contacting the company, please provide your e-mail address, name, address and/or telephone number, so as to provide for the proper handling of the request.
To be cancelled from our mailing list, it will be enough to write an e-mail at any time to this address: privacy@moleskine.com or by mail to Moleskine S.r.l. - Viale Stelvio, 66 – 20159 Milan, with the subject: “cancellation mailing list”.
The updated list of persons in charge will be communicated on simple request to be sent by e-mail to privacy@moleskine.com or by mail to the address given just above.

Milan, 09 June, 2010

The Owner
 
Moleskine S.r.l.