Informative

PRIVACY POLICY

Pursuant to art. 13 of Legislative Decree no. 196 of 30 June 2003 ("Privacy Code"), art. 13 of European Regulation no. 679 of 2016 (the "Privacy Regulation"), as well as Recommendation no. 2 of 2001 adopted pursuant to art. 29 of Directive no. 95/46/EC,

SANSONE SRL intends to inform you and all users and/or visitors of the website www.modahofficial.com (respectively the “Users” and the “Site”), regarding the use of personal data, log files and cookies collected through the Site itself.

1. 1. Data Controller, Data Processors and Data Protection Officer

The data controller is KIRIN COMPANY SRL (CF and VAT number 02404140978),

with registered office in A.Volta 5 - 51031 - Agliana (PT)

tel. 0574 623425, e-mail info@modahofficial.com (hereinafter the “Owner”).

The updated list of designated Data Processors can be provided upon request by interested parties and/or Users.

1. 2. Information automatically collected by the Site - Cookies

a) Information collected automatically

Like all websites, our Site also uses log files, which store information collected automatically during your visits. The computer systems and software procedures used to operate the Site automatically acquire certain information during use, the transmission of which is implicit in the use of Internet communication protocols.

The information collected is as follows:

  • Internet Protocol (IP) address or domain name of the device you are using;

  • type of browser and parameters of the device used to connect to the Site;

  • the URI (Uniform Resource Identifier) ​​addresses of the requested resources or the method used to submit the request to the server;

  • name of the Internet service provider (ISP);

  • date and time of visit;

  • User's referral and exit web page;

  • possibly the number of clicks;

  • the size of the file obtained in response;

  • the numeric code indicating the status of the response given by the server (successful, error, etc.);

  • other parameters relating to the operating system and computing environment of your device.

This information is processed automatically and collected exclusively in aggregate form in order to verify the correct functioning of the Site.

b) Cookies

The Site uses cookies. Cookies are text files stored on a computer that allow us to record certain parameters and data communicated to the computer system through your browser. These tools therefore allow us to analyze your usage habits on the Site for various purposes: performing computer authentication, monitoring sessions, storing information on specific configurations regarding users accessing the server, storing preferences, etc.

Cookies are divided into:

  1. Technical cookies: These are used for navigation or to provide a service you have requested. Without these cookies, some operations could not be performed or would be more complex and/or less secure.

  2. Profiling cookies: These are used to track your browsing and create profiles of your tastes, habits, choices, etc. This allows advertising messages to be sent to your device that match your preferences as expressed during previous online browsing.

Your consent is not required for the installation of technical cookies. Your consent is required for the installation of profiling cookies. If you do not want your device to receive and store profiling cookies, you can change your browser's security settings. Through your browser settings, you can decide whether to delete and/or prevent the installation of cookies on your device.

Please note, however, that by disabling the use of profiling cookies, you will not be able to fully benefit from some of the Site's features.

While browsing the Site, you may also receive cookies on your device that are sent from other sites or web servers (hereinafter "Third Parties"). The Third Parties that use cookies on our Site are:

  • GA Audiences, whose privacy policy can be found at the following address:

    • DoubleClick, whose information can be found at the following address:

      • Facebook Custom Audience, whose information can be found at the following address:

        • Facebook Connect, whose information can be found at the following address:

          • Google Analytics, whose information can be found at the following address:

            • Google Tag Manager, whose information can be found at the following address:

              • Awin, whose information can be found at the following address:

By using the Site, you accept the use of Cookies and consent to the processing of data collected by Third Parties.

1. 3. The personal data you provide us using the Site: for what purposes we process them.

We need your data to allow you, through the use of the Site, to:

a) access the website www.modahofficial.com (hereinafter the “Site”) and use the following services (the “Site Services”):

- online purchase, using the electronic commerce platform service (hereinafter "E-commerce"), which allows you, among other things, to have the packages containing the products marketed by the Owner (hereinafter the "Products") delivered to the address indicated by you;

- updates, via email, regarding all our promotional and marketing initiatives, including direct marketing, including, for example, information regarding the latest collections, events and advertising campaigns organised by the Data Controller (the “Newsletter”);

Your data is processed for the following purposes:

(i) execute your purchase orders for Products online through the Site, fulfill the related administrative and accounting obligations (e.g. for order processing, correspondence, invoicing) and arrange for their delivery through the platform

E-commerce (e.g., delivery and/or collection, any requests for information, complaints, etc.);

(ii) comply with legal obligations;

(iii) carry out the technical management of the Site;

(iv) provide you with the Newsletter service (the information on which is given in the last part of this text);

(v) analyze your preferences, habits, interests and consumer choices, including the type, frequency and location of purchases, in order to develop statistics, create specific user profiles and carry out predictive activities in relation to your future consumption (hereinafter, the “Profiling Activity”);

The processing of data for the aforementioned purposes will be carried out in compliance with the Privacy Code, the Privacy Regulation and all specific sector regulations, including the provisions of the "Rules of the Guarantor for loyalty programs" of 24 February 2005 and the "Guidelines on the processing of personal data for online profiling" of 19 March 2015.

In compliance with the "Guidelines on promotional activities and combating spam" of July 4, 2013, we highlight that any consent you may give for the sending of commercial, promotional, and marketing communications via automated tools will also extend to traditional contact methods.

The data you provide will be processed primarily using IT tools under the authority of the Data Controller, by persons specifically appointed, authorized, and trained in processing pursuant to Article 30 of the Privacy Code and Articles 28 and 29 of the Privacy Regulation. We inform you that appropriate security measures are implemented, also pursuant to Articles 5 and 32 of the Privacy Regulation, to prevent data loss, illicit or improper use, and unauthorized access.

1. 4. Mandatory or optional nature of consent to provide data, the consequences of any refusal and the legal basis of the processing

Please note that for the purposes referred to in points (i), (ii), and (iii) of the previous article 3, the provision of your personal data is mandatory, as failure to provide it will prevent you from using the Site Services offered through the Site, including the transport, delivery, and/or collection of Products through the E-commerce platform.

However, providing your personal data is not mandatory but optional for the purposes referred to in points (iv) and (v) of Article 3 above. Failure to provide data for the purposes indicated above will prevent us from providing you with the Newsletter and carrying out the Profiling Activity. To this end, you are free to decide whether or not to provide your consent for these purposes as well, without this impeding your ability to access the Site Services.

Please remember that, in any case and at any time, you may request the Data Controller to delete your data by simply sending a simple communication, without any particular formalities, to the contact details listed in Article 1 above.

With reference to the purposes referred to in points (i), (ii), and (iii) of Article 3 above, the legal basis for the processing is the performance of the services provided through the Site and requested by you (pursuant to Article 6, paragraph 1, letter b) of the Privacy Regulation and Article 24, paragraph 1, letter b) of the Privacy Code); instead, with reference to the purposes referred to in points (iv) and (vi) of Article 3 above, the legal basis for the processing is your freely given consent (pursuant to Article 6, paragraph 1, letter a) of the Privacy Regulation and Article 23 of the Privacy Code).

1. 5. To whom and in what context we can transmit your data

Your data may be disclosed within the EU, in full compliance with the provisions of the Privacy Code and the Privacy Regulation, to the following parties:

(i) to the tax authorities and/or other public authorities, where required by law or upon their request;

(ii) to credit institutions for purposes related to the online purchase of the Products;

(iii) to the external structures, individuals and companies that the Data Controller uses to carry out activities connected, instrumental or consequent to the execution of the Site Services - including the cloud computing storage service, transport, delivery and/or collection of the Products through the E-commerce platform - to the sending of the Newsletter and to the Profiling Activity;

(iv) to external consultants (for example, for the management of tax obligations), unless designated in writing as Data Processors.

1. 6. Your rights

Please remember that you may exercise the rights set forth in Article 7 of the Privacy Code and Articles 15, 16, 17, 18, 20, and 21 of the Privacy Regulation at any time by sending a written communication to the Data Controller's contact details listed in Article 1 above. You may, therefore, obtain:

  • confirmation of the existence or otherwise of your personal data, indicating their origin, verifying their accuracy or requesting their updating, rectification, or integration;

  • access, rectification, erasure of data or limitation of processing;

  • the cancellation, transformation into anonymous form or blocking of data processed in violation of the law.

You may also object to the processing of your data.

With regard to the Newsletter, we emphasize that your right to request cessation of processing carried out through automated contact methods also extends to traditional methods. Furthermore, you retain the option to exercise this right only partially, for example by requesting cessation of promotional communications sent through one or more of the contact methods for which you have given your consent.

1. 7. Duration of Treatment

Subject to legal obligations, personal data will be retained for a specified period, based on criteria based on the nature of the services provided.

Please note that data stored for profiling or marketing purposes (the latter relating to the Newsletter service) will be stored for a period no longer than 12 and 24 months respectively from their registration.

1. 8. Security measures

Through the Site, your data is processed in compliance with applicable law and using appropriate security measures in compliance with the regulations in force, including pursuant to Articles 5 and 32 of the Privacy Regulation.

In this regard, we confirm, among other things, the adoption of appropriate security measures aimed at preventing unauthorized access, theft, disclosure, modification, or unauthorized destruction of your data.

1. 9. Changes to the Privacy Policy

The Data Controller reserves the right to make changes to this Privacy Policy. In such case, you will be promptly informed the next time you use the Site.

Newsletter

INFORMATION PURSUANT TO ART. 13 OF EU Regulation 2016/679 (“GDPR”).

KIRIN COMPANY SRL (CF and VAT number 02404140978), with registered office at A.Volta 5 - 51031 - Agliana (PT) tel. 0574 623425, email info@modahofficial.com. Pursuant to Article 13 of EU Regulation 2016/679 (General Data Protection Regulation), processes personal data as the Data Controller (hereinafter "Controller") and is required to provide certain information regarding the use of personal data and/or sensitive/special data as defined by the aforementioned regulatory provisions. To subscribe to the mailing list that allows you to receive updates from the Data Controller automatically and free of charge via email, you can use the form in the banner and in the dedicated section or through the tablet application at the points of sale.

The newsletter is sent via email to those who explicitly request it by completing the dedicated form and authorizing the undersigned to process their personal data. Providing data is optional. Refusal to provide data will make it impossible to receive the newsletter service and any promotional communications for which specific consent is required.

Purpose of the processing

  1. The personal data provided by users will be used to send the newsletter containing information on the Data Controller's products and events, without explicit promotional or marketing purposes. The data will not be disclosed.

  2. The personal data provided by users who consent to its optional and voluntary use for promotional and marketing purposes may be used for this purpose, including the sending of promotional materials (such as special offers and discounts) by this company. The contact information may also be used for customer satisfaction surveys and statistical purposes. The data will not be disclosed.


Data processing methods and legal basis


The collected data is processed using paper and electronic means. Appropriate and up-to-date security measures are implemented to prevent data loss, illicit or incorrect use, and unauthorized access. Your data will be entered into our contact management system using a "Double Opt-In" management model in accordance with current legislation. An email will be sent to the contact information provided in the service subscription form, which you will need to reply to confirm your subscription. If you do not confirm within 30 days, your subscription will not be completed and the newsletter service will therefore not be activated.


We also inform you that your personal data will be processed in compliance with the methods indicated by the GDPR, which requires, among other things, that the data be processed lawfully and fairly, collected and recorded for specific, explicit, and legitimate purposes, accurate and, if necessary, updated, relevant, complete, and not excessive in relation to the purposes of the processing.

The data will not be disclosed and may be disclosed to

(i) companies that carry out the storage and processing of electronic archives on our behalf;

(ii) companies that take care of the preparation and dispatch of the Newsletter

Your data may be processed by our appointed and identified representatives and managers.

With reference to the purposes referred to in points (1) and (2), the legal basis for the processing is your freely expressed consent (pursuant to Article 6, paragraph 1, letter a of the Privacy Regulation and Article 23 of the Privacy Code).

The rights of the interested party.


You may exercise your rights towards the Data Controller at any time, as provided for by Articles 15 et seq. of the GDPR. The following paragraphs provide instructions on how to exercise your rights.


Consequences of failure to provide or partial provision of data.


Providing your data is optional, and therefore, please be advised that failure to provide it, or even partial provision of the aforementioned data, may jeopardize or hinder the provision of the service you have requested. Failure to provide marketing consent will prevent the Data Controller from sending you direct sales messages and market and customer satisfaction surveys.


Duration of processing and exercise of rights.
We inform you that the data provided will be processed for the duration corresponding to the completion of the service requested by you, or until you request to unsubscribe from the newsletter by sending an informal email containing this request to the email address info@modahofficial.com

The complete form for exercising your rights is available at the EXERCISE OF RIGHTS link, along with instructions for completing it and sending it to the Data Controller.



Data Protection Officer


Please note that the Data Protection Officer, if appointed, will be subject to a specific notice supplementing this one.