PRIVACY POLICY

pursuant to Articles 13 and 14 of the EU Regulation 2016/679, General Data Protection Regulation
(“Regulation” or “GDPR”)

This privacy policy is provided pursuant to Articles 13 and 14 of EU Regulation 2016/679, General Data Protection Regulation (“GDPR”), in relation to the processing of personal data collected through or via the website https://www.borbonese.com/  (hereinafter, the “Website”), owned by BORBONESE S.p.A., acting as data controller, and operationally managed by DROP S.r.l., acting as data processor.

This notice is addressed to all the individuals who interact with the web pages of the Website. 

Users are invited to read this notice carefully.

Data Controller

BORBONESE S.P.A.

via Privata Cesare Mangili n. 2

20121 - Milano

VAT No. 01703261204 – TIN No. 80013140373

Types of Data We Process

In addition to what is provided elsewhere on this Website (particularly with reference to “Cookies”), the following data may be collected and processed through the Website, by using its functionalities and/or by subscribing to the services offered therein:

A. Browsing Data: These are data automatically recorded by the server during each visit to the Website, such as IP addresses, login information or domain names of the computers used by users connecting to the Website, the type and version of the browser used, time zone, geolocation, URI (Uniform Resource Identifier) addresses of requested resources, time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the server’s response (successful, error, etc.), and other parameters relating to the user’s operating system and IT environment;

B. Common and Identifying Personal Data: These are data intentionally provided by the user. This category includes, for example: first and last name, date of birth, billing and shipping address, e-mail address, other contact information (e.g., telephone number), copy of an identity document, and any additional data or information contained in messages sent to the contacts indicated on the Website or through contact forms published in it.

The Website does not contain information, functionalities, or services directly intended for minors. Minors must not provide information or personal data without the consent of those exercising parental responsibility over them. Should the Company become aware that personal data has been provided by or relates to minors, the Company will immediately delete such data.

No special categories of personal data (“sensitive data”) are processed, meaning data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data, data concerning health, or data concerning sex life or sexual orientation.

For What Purposes Do We Collect Data?

The processing of personal data is carried out exclusively for the following purposes:

(i) Fulfilment of pre-contractual and/or contractual measures (Art. 6(b) GDPR) - To provide the services or information requested through the Website and/or through forms made available therein, and therefore to correctly and promptly fulfil all obligations arising from pre-contractual and contractual relationships with the user and related interactions This includes: user registration on the Website; access to and use of services reserved for registered users; submission of purchase orders through the Website; conclusion, management, and fulfilment of purchase orders placed by the user; accounting management of orders and returns; provision of after-sales services customer support services; and in general, handling user requests and interactions within the commercial relationship.

(ii) Compliance with legal obligations (Art. 6(c) GDPR)  – To comply with obligations arising from applicable national and/or EU laws or regulations, including tax obligations, as well as orders issued by competent authorities.

(iii) Legitimate interests of the Company (art. 6 lett. d) GDPR) – For the establishment, exercise, or defence of legal claims before any authority or competent body; to improve, customise, or modify the Website’s services and offerings; to verify the effectiveness of marketing campaigns; to enhance data protection.

(iv) Based on the user’s consent (art. 6 lett. a) GDPR) – For the provision of advertising materials and/or newsletters for marketing purposes; for commercial communications via telephone, SMS, or e-mail regarding the Company’s promotional and commercial initiatives; for market research and customer satisfaction surveys. To this extent, personal data is processed only if the user specifically and voluntarily requests to subscribe to such services.

Mandatory or Optional Nature of Data Provision and Consent:

Providing data for the purposes under points (i) and (iv) above (performance of contractual obligations and consent for commercial/promotional communications) is optional. However, since such processing is necessary for the provision and use of the services offered through the Website, failure to provide, partial provision, or inaccurate provision of such data will make it impossible, depending on the case, to use and/or fulfil specific user requests.

Third Parties Who May Process Your Data

Data may be communicated to the following categories of recipients (“recipients”): 

1. all subjects (including Public Authorities) who have access to personal data by virtue of legal or administrative provisions; 

2. all subjects, public and/or private, natural or legal persons, whose communication is necessary or functional for the correct fulfilment of contractual or legal obligations. 

Additionally, for the purposes described above, personal data will be processed by Drop S.r.l., with registered office in Montegranaro (FM), via Sandro Pertini no. 1, 63812, Tax Code and VAT No. 01383870431, provider of Website management services and the entity concluding sales with users on the Website. Drop S.r.l. will process personal data a) as an independent data controller, for the purposes and in the manner indicated in its own privacy notice available in the Website footer; or b) as a data processor pursuant to Article 28 GDPR, for certain purposes and in the manner specified in this notice.

Personal data may also be processed by Company employees duly authorised to do so, and/or by external parties operating on behalf of the Company, such as —by way of example —, 

• legal and tax professionals and consultants, statutory auditors or auditing firms, members of the Supervisory Authorities;

• carriers or couriers responsible for product delivery;

• companies or professionals responsible for developing, processing, producing, and/or sending documentation or informational materials.

These subjects will process data as independent controllers or external processors depending on their relationship with the Company.

Transfer of Data

Cookie Policy

Pursuant to the “Guidelines on cookies and other tracking tools” of the Italian Data Protection Authority dated 10 June 2021

The website www.borbonese.com (hereinafter, the “Website”) of Borbonese S.p.A., with registered office in via Privata Cesare Mangili no. 2, 20121 – Milan, VAT No. 01703261204 – NIT 80013140373 (hereinafter, the “Company” or the “Controller”) uses cookies to personalize content and advertising, to provide social media functionalities, to analyse data traffic and, in general, to ensure the best possible browsing experience.

This policy is addressed to all individuals interacting with the web pages of the Website. 

Users are invited to read this policy carefully.

Data Controller

BORBONESE S.P.A.

via Privata Cesare Mangili n. 2

20121 - Milano

P.IVA 01703261204 – NIT 80013140373

What is a cookie

A cookie is a small text string that the websites visited by the user – or websites or web servers other than the one being visited (so‑called “third parties”) – place and store on a terminal device available to the user. Cookies allow certain information to be stored, such as language preferences or login credentials; they allow recognition of the device accessing the Website (but not the person using it), as well as navigation between pages without interruptions, remembering the preferences expressed and improving the user’s browsing experience. Some types of cookies may also ensure that online advertisements displayed are more relevant to the user and/or consistent with the user’s interests.

1.first‑party, when installed directly by the domain visited (in the case of this Website, by the Company); or

2.third‑party, when installed by different domains, for example for statistical, advertising or integration purposes with external services.

Purposes of cookies use

Cookies are used for the following purposes:

1. enabling efficient navigation across the pages of the Website;

2. remembering the preferences expressed by the user;

3. improving the quality and performance of the contents and services offered;

4. analysing the use of the Website and the methods of interaction by users;

5. displaying content and advertisements potentially relevant or of interest to the user, where the user has provided consent for such purpose

Types of cookies used by the Website and their function

The Website uses the following types of cookies:

• Technical or strictly necessary cookies

These are essential for the operation of the Website and to allow the user to use the requested services. They cannot be disabled through the Website. 

• Navigation or session cookies

These are used to allow access to the reserved area of the Website and to place purchase orders on the Website. 

• Analytics and performance cookies

These allow aggregated information to be collected on the use of the Website (e.g., number of visitors and pages visited) (for example, Google Analytics, for which reference is made to the related privacy and cookie policies), in order to improve performance and content. The data collected does not allow the user to be directly identified.

• Functionality cookies

These allow the Website to remember the choices made by the user (such as language or geographical area selected, as well as the products chosen for purchase and placed in the virtual shopping cart, storing them until the next access to the Website) and to offer personalised functionalities. Without such cookies, certain functionalities may be limited.

• Third‑party cookies

These are used by the Company’s partners and are functional to the presentation of advertising banners relating to the Website when the user browses other websites, showing the last products viewed and/or purchased by the user on the Website. These cookies are also used to display to the user browsing the Website products that may be of interest and/or similar to those previously viewed, based on the user’s browsing history. The use of these cookies enables the connection to the user’s computer and/or other devices and the tracing of stored data, as such cookies connect to the browser installed on the user’s device during browsing. 

• Profiling and targeting cookies

These are used to track the user’s browsing activity and create user profiles based on interests shown through browsing, in order to propose consistent advertising content, including on third‑party websites. They do not directly store identifying data but rely on the identification of the device or browser. The Website includes third‑party cookies accessing user data exclusively in aggregated form, for which reference is made to the respective privacy and cookie policies (which may be amended and updated): 

http://www.google.com/intl/en/policies/technologies/ads/

http://www.google.com/intl/en/policies/privacy/

http://www.google.com/intl/it/policies/technologies/ads/

http://www.google.com/intl/it/policies/privacy/ 

http://legal.yandex.com/privacy/

https://www.nextroll.com/privacy

http://www.criteo.com/privacy/

https://x.com/privacy?lang=it

https://policies.google.com/technologies/cookies?hl=en&utm_source=ucb

https://www.linkedin.com/legal/cookie_policy

Managing cookie preferences and disabling cookies

Refusing certain categories of cookies may affect the user’s browsing experience or the availability of certain services.

Preferences must be set separately for each browser and for each device used.

The user may set and manage preferences, or block cookies, by activating the setting in the browser that allows refusal of the placement of various categories of cookies. Below are the paths to manage cookies for the following browsers:  

• Internet Explorer: https://support.microsoft.com/it-it/topic/descrizione-dei-cookie-ad01aa7e-66c9-8ab2-7898-6652c100999d

• Mozilla Firefox: https://support.mozilla.org/it/kb/Bloccare%20i%20cookie 

• Safari: https://www.apple.com/legal/privacy/it/cookies/

Google Chrome:  https://support.google.com/chrome/answer/95647?hl=it&co=GENIE.Platform%3DDesktop

Drop Privacy Policy

Privacy Policy pursuant to Art. 14 of GDPR 2016/679

Drop S.r.l. (hereinafter “Drop”) cares about the protection of your personal data and your privacy, and as Data Controller for the purposes specified below, would like to provide you with the details on how your personal data is managed in compliance with the provisions stipulated in Art. 14 of EU Regulation 2016/679 (GDPR). 

This policy shall be updated whenever changes are made to the current method of managing your personal data, in compliance with legal provisions and/or company decisions.

We inform you that your personal data shall be processed by Drop exclusively for administrative and fiscal purposes, implementing the security measures deemed most appropriate to guarantee the protection of such data during the processing and storage activities.

This policy does not concern the handling of personal data performed by Borbonese S.p.A. (as independent data controller and independent entity with respect to Drop), whose policy can be consulted here.

Our duty and your privacy:

Drop would like to provide you with a series of information that you need to be aware of, not only to comply with the obligations provided for by the GDPR, but also because transparency and honesty are an integral part of what we stand for as a company.

TABLE OF CONTENTS:

• About us

• Our responsibility

• When and how we collect your data

• The type of data we collect

• Why we collect your data

• How we process your data

• Your rights

• Where your data is kept

• How long we keep your data for

• Third parties who can process your data 

About us

For the management of your data relating solely to administrative and fiscal activities deriving from the sale of products, the Data Controller is Drop S.r.l., with registered office at Via Sandro Pertini n. 1, 63812 Montegranaro (FM), Tax ID and VAT number 01383870431.

You may contact us for any information or requests via the following email address: privacy@drop.it.

If appropriate, you may also contact our Data Protection Officer via the following email address: dpo@drop.it. 

The updated link of Processors and subjects appointed to carry out processing activities is kept at the Data Controller’s registered office.

Our responsibility

We inform you that your data shall be legally processed in line with our decisions regarding the modalities and purposes of such processing.

We kindly ask you to read through this privacy policy carefully to ensure that you are fully informed regarding the way in which we process your personal data.

When and how we collect your data:

Your data shall only be collected when it is specifically communicated to Borbonese S.p.A when a product is purchased on www.borbonese.com. You may decide not to communicate your data, and in this case, you may continue to browse the website, however we shall not be able to provide you with any services without your personal data.

The type of data we collect

Pursuant to Art. 4 of EU Regulation 2016/679 (GDPR), “personal data” means any information relating to a natural person who can be identified directly or indirectly.

The personal data that we process are: your name and surname, your physical address and, if different, your address for tax purposes, your tax code and your email address.

We shall not collect any data regarding you as a person (i.e. personal data revealing your racial or ethnic origin, your political opinions, your religious or philosophical beliefs, your trade union membership, genetic data, biometric data, or data concerning your health, sex life or sexual orientation).

Why do we collect your data?

We shall only process your data for specific reasons, and only if there is a legal basis that justifies us doing so. 

In particular, your data shall be processed by Drop in its capacity as Data Controller solely for the administrative and fiscal purposes related to the purchase of products on www.borbonese.com, the legal basis for which is the performance of the contract of sale and the relevant legal obligations, in compliance with Art. 6 of EU Regulation 2016/679 (GDPR).

How we process your data

Processing modalities are the technical and organisational methods used by us to ensure the suitable and secure management and storage of your data. Your data shall be processed using electronic means. Your data shall only be accessible to authorised staff (identified as Designated Individuals and/or Data Processors), through the granting of specific and individual access permissions. 

We guarantee that your data shall be processed with maximum security: we have adopted suitable physical, digital and organisational measures to ensure the protection of your personal data.

Your rights

You have the right:

1. to access your data. 

This means you have the right to ask for additional information regarding:

• the data categories we are processing;

• the purpose of the processing;

• the categories of the potential recipients to whom your data may be communicated;

• the period for which your data is stored, or, in the absence of this information, the criteria used to determine this period;

• your other rights regarding the use of your data.

We shall provide you with the relevant information as promptly as possible within a maximum of one month from your request, as long as this does not infringe upon the rights and freedoms of other subjects (for example another person’s right to confidentiality) and that there are no legal obligations that prevent it. We shall inform you in the event that we are unable to satisfy your request for any reason;

1. to correct your data if it is incorrect or not up to date;

2. to obtain the erasure of your personal data (right to be forgotten). 

You may, at any time, ask us to remove your personal data in our possession, if the storage of your personal data is no longer necessary for the purposes of processing and there is no legal obligation or other compelling legitimate reason.

The correspondence relating to the exercising of your right shall, in any event, be kept for a maximum of 5 years as proof;

1. to the portability of your data, i.e. the right to transfer your data from one electronic system to another;

2. to object, at any time, to the further processing of your personal data carried out by us on the basis of a legitimate interest of ours;

1.  to file a complaint with the supervisory authority. 

But before doing that, contact us! We will be happy to resolve any problems relating to the processing of your personal data.

You may exercise your rights at any time by sending an email to the following address: privacy@drop.it

Drop guarantees your rights even if it is processing your personal data on behalf of a third party. If we are processing your data on behalf of a third party, we guarantee that any requests to exercise your rights shall be forwarded to them without undue delay.

If you think that there has been a breach of your personal data, please contact us immediately at privacy@drop.it or contact our Data Protection Officer at dpo@drop.it

Where your data is kept

Your data shall be processed within the European Union and shall not be transferred to countries outside of the EU. 

If we need to transfer and/or store your data outside of the EU, you shall be duly informed. In this event, we shall adopt all suitable measures to guarantee the maximum protection of your data.

 Your data shall be stored electronically. The original documentation shall be kept:

• at the administrative department at our registered office;

• with online communication and email providers;

• with the Digital Storage delegate pursuant to the 2022 Agid Guidelines on the Storage of Digital Documents;

• potential Sub-Processors, pursuant to Art. 28, paragraph 4 of EU Regulation 2016/679 (GDPR).

How long do we keep your data for?

All data relating to the fulfillment of administrative and tax-related purposes shall be stored for 10 (ten) years in compliance with the relevant legal provisions.

Therefore, we shall stop actively processing your data after 10 years from your last purchase, unless there are legal obligations under which we must store your data for longer than this.

Third parties who can process your data

In order to perform our activities, we have to rely on third parties to host our applications, communicate with our customers, manage our emails, etc. We assure you that we only collaborate with the best players on the market who offer these types of services. We only share your data with them when necessary to ensure the maximum functionality of our services and in accordance with the security measures and best practices described in this Privacy Policy.

For more information contact us at: privacy@drop.it or dpo@drop.it