With this privacy policy we intend to provide, pursuant to Articles 13 and 14 of the General Data Protection Regulation – GDPR (Reg. (EU) No. 679/2016), the information necessary to illustrate how we will collect, use and process the personal data of individuals (hereinafter “Personal Data” or also just “Data”) who consult and/or visit the website www.jackwolfskinlivigno.com (hereinafter the “Site”) and/or access the related services, with or without registration (individuals, hereinafter jointly referred to as “Users” or, individually, “User”).

The processing of Data carried out by Us will be constantly marked by the respect of the principles placed to protect the personal data of individuals and confidentiality, as established by the GDPR and, if necessary, by the National Privacy Code (D. Lgs. 196/2003 s.m.i.). This policy is easily available to Users, at any time, by visiting the appropriate section at the bottom of the home page of the Site. We invite Users to periodically consult our notice, which may be subject to modifications and/or updates, also due to changes in the applicable regulatory framework. DISCLAIMER: this notice only concerns the processing of Personal Data carried out by Us through the Site, thus excluding those processing operations that may be carried out by third parties if Users, including through links or plug-ins on the Site, interact directly with said third parties or are referred to their websites. For more information, see section C) of this policy.

The Data Controller, which is responsible to Users for the correct and lawful processing of Personal Data carried out through the Site, is TIDIELLE S.r.l. (hereinafter “Controller”, “TIDIELLE” or “We”), C.F. 92020760143, with registered office in Via Ostaria 434 – 23041 Livigno (SO), contact email: info@jackwolfskinlivigno.com, telephone: +39 0342 997765.
The Data Protection Officer appointed by us can be reached at the following email address: info@jackwolfskinlivigno.com

The Data that may be processed by us include only Data spontaneously provided by Users, namely:

1. contact data (name and email address) that Users voluntarily transmit to us by filling in the form available in the “Contact” section of the Site, or by sending us an email to info@jackwolfskinlivigno.com or by contacting us otherwise (e.g., by telephone), as well as all other Personal Data that may be included and contained in the message that will be sent to us by Users, or that may be communicated to us in the course of the telephone conversation;
2. the email address of Users who voluntarily decide, upon giving appropriate consent, to receive our marketing and promotional communications, through the “Subscribe to Newsletter” section;
3. Personal Data relating to third parties, which may be disclosed to TIDIELLE by Users interacting with Us through the Site (for example, when a User sends Us a request for information on behalf of another person or which contains personal data of the latter). Such Personal Data, where provided, will be equated by Us with the corresponding category of Personal Data provided by Users (as set forth in i. or ii. above), it being understood that, in such case, the User shall act as autonomous controller of the processing of said Personal Data and, by providing said Personal Data to TDIELLE, shall guarantee to the latter, assuming all responsibility in this regard, that said data: are precise, correct and accurate; have been acquired in compliance with applicable privacy regulations; and could be legitimately communicated to TIDIELLE by virtue of suitable legal basis (e.g. in the presence of suitable consent of the persons concerned).

(a) The Data referred to in 2(i) above will be processed to enable us to respond to inquiries and/or contact requests received.

(b) The Data referred to in point 2(ii) above will be processed by Us to carry out marketing and promotional activities in the exclusive interest of TIDIELLE, through automated tools (email), and, in particular, to send to Users who have given their consent:

– newsletters, brochures, catalogs and presentations;
– promotional materials related to products offered for sale by TIDIELLE;
– invitations to special events;
– studies, market research and statistical surveys.

(a) Scope of Circulation of Personal Data.

As part of the processing of Data for the purposes set forth in Section 3 above, Personal Data may be processed, on our behalf, or otherwise made accessible or disclosed to third parties in the following categories:

– providers of automatic newsletter software (MailChimp operated by The Rocket Science Group LLC);
– email service providers (Gmail – Google);
– in case of emergency or if requested, Public Safety and Judicial Authorities.

The aforementioned third parties, where necessary, have been appointed by Us as Data Processors pursuant to Article 28 of the GDPR. An updated list of the appointed Processors will be provided upon request, to be sent using the contact details indicated under point 1.

Within our corporate organization, Data will be communicated to and processed by management, point-of-sale employees and the system administrator. All of the aforementioned individuals will be duly authorized and instructed by Us to process, pursuant to Article 29 of the GDPR and Article 2-quaterdecies of the Privacy Code.

(b) Transfer abroad of Personal Data.

Since our automatic newsletter and email service providers are based in countries outside the EEA (European Economic Area), Personal Data provided by Users may be subject to transfer abroad. In any case, such transfer will take place in the presence of adequate safeguards and in compliance with all the principles dictated by the GDPR. In this regard, we point out that both The Rocket Science Group LLC and Google Inc. comply with and adhere to the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information transferred from the European Union and Switzerland to the United States. For more information about the Privacy Shield program and to review the certifications of the aforementioned companies, we invite Users to visit https://www.privacyshield.gov/.

(a) Data processed for the purpose mentioned in 3(a) will be kept for as long as is strictly necessary to respond to the information and/or contact requests received.

(b) Data processed for the purpose mentioned in 3(b) will be retained for 24 months after the relevant registration in our systems. In general, after the above retention periods have elapsed, Personal Data will be deleted or otherwise anonymized.

The provision of Data for the purposes referred to in point 3 above is optional, as it does not represent a legal or contractual obligation for Users, but any refusal to provide Data will prevent TIDIELLE from following up on contact requests received or make it impossible for Users to take advantage of the newsletter services offered through the Site.

Pursuant to Article 32 of the GDPR, TIDIELLE and the entities that process Personal Data on its behalf confirm that they have taken appropriate security measures (technical and organizational) to ensure a level of security appropriate to the risk and to minimize the risks of destruction or loss – even accidental – of Personal Data, as well as unauthorized modification, disclosure and access to it.

However, TIDIELLE cannot guarantee Users that the security measures taken will limit or exclude any risk of unauthorized access or loss, destruction, modification or unauthorized disclosure of Personal Data by devices pertaining to the User, who is therefore invited to equip himself with appropriate software and tools to protect the network transmission of Personal Data, both incoming and outgoing, and to make sure that his Internet service providers have taken appropriate measures for the security of the transmission of Personal Data over the network.

Pursuant to Articles 13(2)(b), (c) and (d), 15, 16, 17, 18, 19, 20 and 21 of the GDPR, we inform each User that the same:

(a) you have the right to ask us for access to your Personal Data together with indications as to the purpose of the processing, the category of the Data processed, the entities or categories of entities to which it has been or will be disclosed (with an indication of whether such entities are located in third countries or are international organizations) when possible the retention period of the Data or the criteria used to determine this period, the existence of your rights to rectification and/or erasure of Personal Data, to restrict processing and to object to processing, your right to lodge a complaint with a supervisory authority, the origin of the Data, and the existence and logic applied in case of automated decision-making. If he exercises this right, and unless otherwise indicated by him, the User will receive a copy in electronic format of his Data subject to processing;

(b) also has the right to obtain:

1. The rectification of your Data if it is inaccurate or incomplete;
2. the deletion of your Data, if any of the conditions set forth in Article 17 of the GDPR exist (e.g.: the Data are no longer necessary in relation to the purposes for which they were collected; the User decides to revoke his or her consent to the processing – where this is the legal basis – and there is no other legal basis for the processing itself; the User objects to the processing and no other legitimate interest of the Data Controller prevails; the User’s Data are processed unlawfully);
3. the limitation of the processing of the Data concerning the User 1) for the time necessary for TIDIELLE to ascertain the accuracy of its Data (in the event that this has been disputed), or 2) when the processing of the Data is unlawful and the User requests, in lieu of the deletion of its Data, the limitation of the relevant processing, or 3) when TIDIELLE no longer needs the User’s Data but the same is necessary for the latter to ascertain, exercise or defend a right in a court of law, or, finally, 4) for the time necessary to assess whether the Owner’s legitimate reasons prevail over those of the User, if the latter has objected to the processing of its Data pursuant to point c) below;
4. its Data in a structured, commonly used and machine-readable format also for the purpose of transmitting it to another data controller, if the processing is based on consent or a contract and is carried out by automated means (so-called right to data portability). If of interest to the User, the latter may ask TIDIELLE to transmit its Data directly to the other owner, if this is technically feasible;

(c) also has the right to object to the processing of its Data, if such processing is carried out pursuant to Art. 6.1 lett. (e) (i.e. to comply with a legal obligation to which the Holder is subject) or lett. (f) (i.e., to pursue a legitimate interest of the Data Controller) of the GDPR, unless there are compelling legitimate grounds for the Data Controller to process, pursuant to Art. 21 of the GDPR;

d) finally, has the right to revoke, at any time, consent to the processing of Data (where this is the legal basis), without thereby affecting the lawfulness of the processing based on the consent given before revocation.

If a User is dissatisfied with the processing of his/her Data by Us, he/she may file a complaint with the Data Protection Authority, following the procedures and directions published on the official website of that authority (www.garanteprivacy.it).

Any rectification or deletion of Data or restriction of processing made at Your request – unless this proves impossible or involves disproportionate effort – will be communicated by Us to each of the recipients to whom Personal Data may have been transmitted in accordance with this Policy.

The exercise of the foregoing rights is not subject to any formal constraints and is free of charge. We may only ask to verify the identity of the User who contacts us before taking further action as a result of your request.

In order to exercise your rights, you may contact TIDIELLE by sending a registered letter with return receipt to the addresses indicated in point 1 above, or by e-mail using the following address: info@jackwolfskinlivigno.com.

The Site contains links to other websites that have no connection to the Site, such as plug-ins linking the Site to social networks Facebook and Instagram. If the User uses one of these plug-ins or links, by “clicking” on them, his or her browser may send the third party owners of these plug-ins or websites some data about him or her (e.g. IP address). Such data will be processed by the aforementioned third parties in accordance with their own privacy policies, which Users are invited to consult at the following links:

Facebook: https://www.facebook.com/about/privacy/update;
Instagram: https://help.instagram.com/519522125107875.

Unless Users voluntarily interact with the plug-ins of the aforementioned social networks or any other links to third-party sites, the Controller will not share or disclose any Personal Data to such third parties.

It is reiterated that this privacy policy does not apply to the processing of Users’ Personal Data carried out by third party owners of the above plug-ins / links, with the result that TIDIELLE disclaims any responsibility in this regard.

The Site uses technical and third-party profiling cookies. For more information please see our Cookie Policy.