Privacy

PRIVACY POLICY

Conti Thun Srl, with registered office in via Masserino 2, 25080 Puegnago, Italy, VAT number IT03911850984 (hereinafter, the "Data Controller"), owner of the website www.contithun.com (hereinafter, the "Website"), as data controller of the personal data of users who browse and are registered on the Website (hereinafter, the "Users") provides the following privacy policy pursuant to art. 13 of EU Regulation 2016/679 of 27 April 2016 (hereinafter, "Regulation" or "Applicable Regulations").

 

The Data Controller takes the utmost care to protect its Users' right to privacy and personal data. For all information regarding this privacy policy, Users can contact the Data Controller at any time, using the means described in paragraph 8 below.

 

  1. Purposes of the processing

 

Users' personal data will be processed lawfully by the Data Controller pursuant to Article 6 of the Regulations for the following processing purposes: 

 

  1. a)       navigation of the site, in relation to the possibility of collecting User data necessary at a technical level, such as the IP address, while browsing the site.
  2. b)      legal obligations, i.e., for the fulfilment of obligations required by law, an authority, a regulation or European legislation.
  3. c)     response to your requests for information, received by us through the provided contact form.
  4. d) online purchases; data necessary for the finalisation of purchases from the e-commerce portal.

The provision of personal data for the processing purposes indicated above is optional but necessary, as failure to provide them will make it impossible for the User to browse the Website, register with the Website or make use of the services offered by the Data Controller through the Site.

 

Marketing

With the User's free and optional consent, some of the personal data (i.e. first name, surname, email address, full shipping address, etc.) may be also processed by Conti Thun Srl for marketing purposes (sending information and/or promotional material regarding the products or services provided by the undersigned company, including free gifts and samples; for conducting market research aimed, for example, at the analysis of habits and consumption choices and commercial communication, as well as for evaluating the degree of satisfaction of the products and services offered).

 

Where consent has been given, the User may at any time revoke their consent by making a request to the Data Controller as indicated in paragraph 8 below. Furthermore, the User can easily refuse further sending of promotional communications via email by clicking on the withdrawal of consent link included in each promotional email and newsletter. Once consent has been withdrawn, the Data Controller will send an email to the User to confirm the withdrawal of consent. Should the User wish to withdraw their consent to receive promotional communications by telephone, while continuing to receive promotional communications by email, or vice versa, they should send a request to the Data Controller as indicated in paragraph 8 below.

 

The Data Controller informs Users that, after exercising the right to object to sending of promotional material and newsletters via email, it is possible, due to technical and operational reasons (e.g., completion of contact lists shortly before the Data Controller’s receipt of the objection), that they may continue to receive some additional promotional messages. If you continue to receive promotional messages and newsletters 7 days after exercising the right to object, please report the problem to the Data Controller, using the contacts details given in paragraph 8 below.

 

Profiling

With the User's free and optional consent, their personal data (i.e., personal and contact data, and information regarding the services in which the User has expressed interest) may also be processed by Conti Thun Srl for profiling purposes, namely to reconstruct the User's tastes and consumption habits, based on purchase choices and the information optionally provided during registration on the ecommerce website. Where consent has been given, the User may at any time revoke their consent by making a request to the Data Controller as indicated in paragraph 8 below.

 

Communication of data to the Partners of Conti Thun Srl

With the User's free and optional consent, their personal data (i.e., name, surname, address, email address, telephone number, etc.) will be communicated to partner companies of CONTI THUN Srl, belonging to the following product categories: large-scale organised distribution, clothing, publishing, electronics and IT, finance and insurance, tourism and accommodation facilities, grocery, couponing, cosmetics and pharmaceuticals, gifts, non-profit organisations and foundations, event organisation and training agencies.

 

The Data Controller's partners, as independent data controllers, will process the User's personal data for their own marketing purposes (direct sales, sending of advertising material and commercial communication), and may contact the User by mail, email, telephone (landline and/or mobile, with automated call or call communication systems with and/or without the intervention of an operator) and/or SMS and/or MMS to propose to the User the purchase of products and/or services offered by the same categories of third-party companies and/or by other companies and to present the User with offers, promotions and commercial opportunities. Once the transfer has taken place, the Data Controller's Partner is required, pursuant to art. 14 comma 3 of the Regulation, to provide Users with all the information specified in art. 14 of the Regulation. If consent is not given, the possibility of registering on the Website will not be affected in any way.

 

Where consent has been given, the User may at any time revoke their consent by making a request to the Data Controller as indicated in paragraph 8 below. The Data Controller informs Users that their personal data will be processed by the Data Controller's Partners as independent data controllers, based on a specific privacy policy that will be issued to Users by the Data Controller's Partners. Any requests not to receive further commercial communications from the Data Controller's Partners, to whom the data have already been communicated by the Data Controller, must therefore be addressed directly to them.

 

  1. Processing methods, mandatory provision and data retention times

Users' personal data will be processed using manual and IT tools, with methods strictly related to the purposes of the processing, in order to ensure the security and confidentiality of the data. The personal data of the Website Users will be kept for the time strictly necessary to achieve the main purposes described above in Section 1, or necessary, in any case, for the protection under Civil Law of the interests of both the Users and the Data Controller. The payment details submitted to complete online purchases are managed by a service provider certified for the execution of transactions, and Conti Thun Srl does not manage, store or process in any way information such as credit card numbers or credentials of online payment systems.

 

For the purposes described in sections "c" and "d", the provision of data is optional and any refusal to provide them or to grant consent shall prevent the undersigned company from proceeding with the direct marketing, profiling or online purchase activities indicated therein. In the cases referred to in paragraphs 2 and 3 above, Users' personal data will be stored for the time strictly necessary to achieve the purposes described therein and, in any case, within the limits of the Applicable Regulations.

 

Legal basis of data processing

With regard to the purposes indicated in points 1/a, 1/c and 1/d, the legal basis of the processing is the execution of the services provided through the Website and requested by you (pursuant to Article 6, paragraph 1b of the Privacy Regulation 2016/679); with regard to the purpose indicated in point 1/b of the previous paragraph, the legal basis of the processing is to fulfil a legal obligation to which the Data Controller is subject (pursuant to Article 6, paragraph 1c of the Privacy Regulation 2016/679). With regard to the purposes referred to in paragraphs 2, 3 and 4, the legal basis is optional consent by the User (pursuant to art. 6, paragraph 1a of the Privacy Regulation 2016/679).

 

Scope of communication and dissemination of the data

Users' personal data may be disclosed to the Data Controller's employees and/or collaborators assigned to managing the Website. These persons, who are formally authorised by the Data Controller, will process the User's data exclusively for the purposes indicated in this policy and in compliance with the provisions of the Applicable Regulations.

 

Users' personal data may also be disclosed to third parties who handle personal data as External Data Processors on the Data Controller's behalf, such as IT and logistic service providers necessary for the operation of the Website, outsourcing or cloud computing service providers, professionals and consultants. Users have the right to obtain a list of any data processors appointed by the Data Controller, by making a request to the Data Controller as indicated in paragraph 8 below.

 

  1. Rights of the data subjects

Users may exercise their rights pursuant to the Applicable Regulations by contacting the Data Controller as follows:

 

Sending a registered letter with acknowledgement of receipt to the registered office of the Data Controller, CONTI THUN Srl.

Sending an e-mail to info@contithun.it; 

Pursuant to the Applicable Regulations, users may exercise the rights referred to in art. 15 and following of the Regulation, in the manner specified by art. 12 of the same.


If the user believes that the processing of their data is in breach of the Regulations, they have the right to file a complaint with the Supervisory Authority (in the Member State in which the Data Subject normally resides, works or where the alleged violation has occurred). The Italian Supervisory Authority is the Guarantor for the protection of personal data - http://www.garanteprivacy.it/ - garante@gpdp.it