PRIVACY POLICY BARBERINO OUTLET
This information is provided pursuant to articles 13 and 14 of European Regulation 2016/679 (hereinafter, “Regulation”) to those who interact with the web services of: e https://www.barberinooutlet.com website (hereinafter, “Site”), and to those who visit and interact with the pages of the social networks referred to the Barberino Outlet and managed by BMG BARBERINO SRL (including, but not limited to, Instagram, Facebook, WeChat, etc., hereinafter referred to as “Social Pages”). Please note, however, that when interacting with the Social Pages, the privacy policy of the relevant social network provider also applies.
BMG BARBERINO SRL and the social network provider act, as the case may be, as joint controllers or independent data controllers of the data collected through the Social Pages: BMG BARBERINO SRL is only responsible for the processing of data relating to users who contact it directly (for example, through the chat service of the Social Page) or interact with the same through the Social Pages, while the provider of the social network holds the data controller of user data to allow the use of the social network and the use of its features. BMG BARBERINO SRL is therefore not responsible for the data provided by users for registration on the social network or relating to its use by the user. Furthermore, this information does not concern other sites, pages or online services that can be reached via hypertext links that may be published on the Site but refer to resources outside the domain https://www.barberinooutlet.
1. DATA CONTROLLER and DATA PROCESSOR
The Data Controller of personal data is BMG BARBERINO SRL (hereinafter, for the sake of brevity, also referred to as BMG), with registered office in via A. Manzoni 38 – 20121 Milan (MI), VAT no. 05176070489, in the person of the legal representative p.t., Email: privacy@barberinooutlet.com. The Data Controller has appointed the DPO, who can be reached at the e-mail address dpo@barberinooutlet.com or by writing to the Data Controller’s registered office. The person responsible for the processing of personal data, as it is responsible for the commercial management and promotion as well as the management of relations with users of the Outlet, is Promos S.r.l. – Tax Code/VAT number: 03123920179 – Via San Zeno, 173 – 25124 Brescia (BS), Phone: +39 030 2422862 – Fax: +39 030 2422870, Email: privacy@promosgroup.it. The Manager has also appointed the DPO, who can be reached at the e-mail address dpo@promosgroup.it or by writing to his office.
2. THE PRINCIPLES OF PROCESSING
In processing users’ personal data, BMG will apply the internationally recognized principles of privacy protection, i.e. lawfulness, fairness and transparency. Personal data will be collected for specified, explicit and legitimate purposes (purpose limitation) and will be adequate, relevant and limited to the purposes for which they are processed (data minimization). They will always be updated and accurate and stored for a period of time not exceeding what is necessary for the pursuit of the purposes of the owner (storage limitation), after which they will be deleted. Finally, they will be processed by adopting all appropriate security measures to ensure their integrity and non-accessibility by unauthorized third parties (integrity, confidentiality and unavailability).
3. DATA PROCESSED
When using the Website or interacting with BMG’s Social Pages (in particular when you proactively contact BMG via the Social Page’s chat service) we inform you that BMG may collect and process information concerning you that allows you to be identified (either directly or jointly with other information), such as your name, nickname, identification number, online ID. The personal data that BMG may process through the Website and/or the Social Pages include:
a) Data acquired during navigation
The computer systems and software procedures used to operate the Site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.
This is information not collected to be associated with identified users, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP address or domain names of the computers used by those who connect to the Site, the URI (Uniform Resource Identifier) address of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response given by the server (successful, error, etc.) and other parameters related to the operating system and the computer environment of the users. The data is used for the sole purpose of obtaining anonymous statistical information on the use of the website, and to check that it is working properly. The data could also be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the Site. In no case is BMG responsible for browsing data on any social networks in which the Social Pages are present and which is collected directly by the provider of the social network itself.
b) Data provided voluntarily by users
BMG also collects personal data provided voluntarily by users (in particular name and surname, nickname, email address) when interacting with the services of the Site and/or with the Social Pages (for example, chat), or when filling in data collection forms, including any information that the user provides when making a request. Or, again, in the event of a request for the newsletter, participation in initiatives carried out on the Site, information and sending of communications.
In the sections of the Website where users’ personal data are collected, there is always a link to this Privacy Policy or to other specific information on the processing of personal data, where applicable.
c) Cookies
At the following link https://www.barberinooutlet.com/cookie-policy/. Please refer to the specific Cookies Policy of the Site for all the necessary information on the type and methods of use of cookies and similar tracking tools.
d) Specific information
In the case of further collection of personal data, specific information will be provided to the data subjects.
4. PURPOSE AND LEGAL BASIS OF THE PROCESSING.
The data collected will be processed for the following purposes:
a) Browsing the Site.
PURPOSE: to allow users to browse the Site.
LEGAL BASIS: need to execute specific requests from the interested parties and to execute contracts to which the aforementioned are parties.
NATURE OF THE PROVISION: necessary if you want to browse the Site and use the related services.
b) Browsing and interaction with the Social Pages.
PURPOSE: to allow users to consult the Social Pages and possibly interact with BMG. LEGAL
BASIS: need to implement specific requests from the interested parties.
NATURE OF THE PROVISION: necessary if you want to browse the Social Pages and interact with BMG. If the user does not wish to provide the data to BMG, the user may not interact with BMG through the Social Pages. Please note that the processing for this purpose is carried out by BMG in some cases as a joint controller with the social network provider.
c) Newsletters and other marketing activities.
PURPOSE: to allow users to subscribe to the newsletter and other communications of the Data Controller on promotions, offers, initiatives, etc. via e-mail, SMS, MMS or other types of messages (instant messaging), as well as by traditional means (telephone calls through an operator, paper mail).
LEGAL BASIS: the consent of the users. Once they have given their consent, in order not to receive promotional communications, users can communicate their opposition at any time. To do this, simply use the “Unsubscribe” mode present in each email that is sent.
NATURE OF THE PROVISION: the provision of data in order to subscribe to the newsletter or to receive other promotional communications from the data controller is optional; any failure to provide consent will make it impossible for BMG to send the relevant communications.
d) Legal Purposes
PURPOSE: to allow BMG to comply with any legal and regulatory obligations. LEGAL BASIS: the legal or regulatory provision applicable from time to time.
e) Purposes of Legitimate Interest
PURPOSE: to carry out activities functional to the sale of companies and business units, acquisitions, mergers, demergers or other transformations and for the execution of such transactions, as well as to assert and defend BMG’s rights against users and third parties in any dispute.
LEGAL BASIS:
BMG’s legitimate interest, adequately balanced with the interests of the data subjects in light of the limits imposed on such processing.
NATURE OF THE PROVISION: not mandatory. You will have the right to object to processing for these purposes, in the manner set out in this policy, without prejudice to BMG’s overriding interest in continuing the processing and unless the processing is necessary to exercise or defend BMG’s rights in court.
5. METHODS AND DURATION OF PROCESSING
Users’ personal data are collected and processed by electronic means and, to a more limited extent by manual tools and only for the time necessary to achieve the purposes of the data controller.
The processing logics and procedures are related to the purposes specified in this Privacy Policy. Depending on the specific purpose of processing, personal data is accessible to personnel authorized to process it, as well as to data processors. Fully automated decision-making processes that produce legal effects for users or significantly affect their persons are not used.
Users’ personal data will be processed for the time necessary to manage their interaction with the Site and the Social Pages, to follow up on a request received through the Site and/or the Social Pages themselves and to ensure the use of the related goods and/or services and therefore for the entire duration of the applicable contract. Once these purposes have been exhausted, the data will be stored for the time required by law for administrative, accounting and tax purposes and to assert any contractual rights, in accordance with the applicable legal provision.
The data processed for marketing purposes are stored for 7 years from their collection, without prejudice to the possibility of revoking the consent previously given and/or opposing the processing by users, in accordance with the most recent provisions of the Italian Data Protection Authority.
Finally, data collected for the purposes of legitimate interest is stored for a period of 10 years from the time of collection in the case of processing aimed at asserting and defending BMG’s rights against users and third parties in any dispute, with respect to processing aimed at carrying out activities functional to the sale of business and business units, acquisitions, mergers, demergers or other transformations and for the execution of such transactions, the retention periods listed above will apply with respect to the main processing that takes place.
6. RECIPIENTS OF PERSONAL DATA
Personal data may be communicated to third parties who carry out activities necessary for the provision of the services offered on the Site, who will process the data as data processors or independent data controllers. Precisely, the following subjects or categories of subjects will process the data:
• Companies related to the owner or business partners that provide IT services;
• service providers who act on behalf of the owner on the basis of contractual agreements, in order to carry out activities related to the administrative, commercial and advertising management of the Outlet;
• Companies and consultants, in the field of legal, accounting and tax assistance and advice;
• Entities that provide services for the management of the information system and telecommunications networks, including e-mail;
• Competent authorities for the fulfilment of legal obligations;
• Participating outlet shops and refreshment points.
The data processed for the purposes of loyalty and sending newsletters and other commercial communications are not communicated to third parties but may be processed by external companies as data processors, pursuant to art. 28 Regulation.
Through the icons of the Social Networks present on the Site, or by browsing the Social Pages, some user data may also be transmitted to Social Networks. With respect to these processing, which are carried out outside this Site, please refer to the specific privacy policies of the provider of the social network used. All the foregoing subjects are obliged to use the information received only for the processing purposes indicated above, to keep it confidential, intact and not available to unauthorized third parties. User data is not disseminated.
7. TRANSFER OF PERSONAL DATA
Your data is not transferred to countries located outside the European Economic Area. In the event that it is necessary to transfer the data outside the European Economic Area to a third country or an international organization that does not guarantee an adequate level of protection as provided for by the European Commission, the Data Controller will adopt an appropriate mechanism for the transfer and the guarantees required for the purposes of the transfer itself, pursuant to articles 44 et seq. of the European Regulation.
8. RIGHTS OF DATA SUBJECTS
Articles 15 to 22 of the Regulation confer on users, as data subjects, the exercise of specific rights. Art. 15 recognizes the right of users to access their personal data and to obtain a copy of it. The right to obtain a copy of the data must not prejudice the rights and freedoms of others. By requesting access, users have the right to obtain confirmation from the data controller whether or not their personal data is being processed and to know the purposes and categories of data processed the third parties to whom the data are communicated and whether the data are transferred to a non-European country with adequate safeguards. Users also have the right to know how long their personal data will be stored, with respect to the purposes indicated above.
With respect to their personal data, users have the right to request the rectification of inaccurate data and the integration of incomplete data, cancellation (right to be forgotten) under the conditions indicated by art. 17, Regulation, the limitation of processing and data portability.
Users also have the right to object at any time or to withdraw their consent to the processing carried out for marketing purposes.
To stop receiving marketing communications (e.g. e-mails, text messages) it will be sufficient to write an e-mail at any time to the address privacy@barberinooutlet.com the subject “unsubscribe me” or use unsubscribe systems present in the e-mails.
The Data Controller will also provide users with certification that the operations resulting from the above requests have been brought to the attention of those to whom the data may have been communicated, except in the case in which this fulfilment proves impossible or involves the use of means manifestly disproportionate to the rights protected.
To exercise the above rights, it is necessary to contact the Data Controller at the e-mail address privacy@barberinooutlet.com, or at the address of its registered office.
To provide a response, users may need to be identified by asking them to provide a copy of their ID. The holder will provide a written response without undue delay and, in any case, no later than one month from receipt of the request itself.
9. COMPLAINT TO THE DATA PROTECTION AUTHORITY
Users who believe that the processing of their personal data violates the provisions of the Regulation or the internal legislation on the protection of personal data, have the right to lodge a complaint with the Guarantor Authority for the Protection of Personal Data based in Rome, pursuant to art. 77, Regulation, as well as taking action before the judicial authority.
10. UPDATES
This privacy policy may be subject to changes and/or additions because of any subsequent amendments and/or additions to regulations, the updating or provision of new services or technological innovations. Any changes will be posted on the Site and, where appropriate, notified to users by email.
Version 0.1 April 2025