1. Our Policy
Everyone is entitled to the protection of the personal data concerning them. MONCLER respects users’ rights to be informed with regard to data collection and to other operations to process their personal data. In using data that may directly or indirectly identify you personally (“Personal Data”), we will apply a principle of strict necessity. For this reason, we have designed the Site in such a way that the use of your Personal Data will be kept to a minimum and we do not process your personal data when we can provide you with services through the use of anonymous data (such as market research aimed at improving our services) or by other means which allow you to be identified only when it is strictly necessary or upon request by competent public authorities or the police (for example, in the case of traffic data or your IP address).
2. Types of processed data
2.1. Navigation Data
Visiting and consulting the Site does not generally involve collection and processing of your Personal Data. The Personal Data processing of users who visit and consult the Site is limited to the so-called navigation data which transmission is necessary for the functioning of computer systems and of programs essentials for the operation of the Site but which, by their very nature and in conjunction with other data, may permit the identification of users. This category includes, for example, the IP addresses (Internet Protocol) or the domain names of the computer used to visit the Site, as well as other parameters concerning the operating system used by the user to connect to the Site. The collection of navigation data occurs automatically and inevitably and can only be used to obtain statistical information on the use of the Site and to verify its proper functioning. Navigation data are immediately deleted after their processing. If expressly requested, such data may be used by the Public Authority to ascertain liability in the event of computer offenses committed against the Site and/or third parties, in accordance with the procedures in force at the competent Authorities. Except for this possibility, navigation data described above are only temporarily kept in compliance with the applicable regulations.
2.2. Data voluntarily provided by the user
In addition, MONCLER collects and processes Personal Data voluntarily provided by you that consist of those data collected through the sending of e-mail, the interaction with the Site’s features and the request for services offered by the Site. Personal Data that MONCLER collects and processes include name, surname, gender, nationality and e-mail.
3. Who collects your Personal Data, how and for what purposes
3.1. Data Controller and Data Processor
Industries S.p.A., based in Via Stendhal 47, Milan - 20144 - Tel. 02/422041 is the Controller of the Personal Data of the Site's users. The Data Processor, to whom you can at any time turn to exercise the rights pursuant to Art. 15 - 22 of the GDPR, is Vegan Solutions S.r.l., domiciled at the Processor's offices and available at the following e-mail address: email@example.com. For exclusively organizational and functional needs, we have appointed additional Processors of the users’ Personal Data code.moncler.com, for closely related and connected purposes with the provision of services on code.moncler.com. These Processors have been chosen because they have proven to have experience, capability and reliability and to provide a suitable guarantee of full compliance with the applicable treatment provisions, including the data security profile. Processors carry out the users’ Personal Data processing of code.moncler.com as instructed by MONCLER. Periodically, we verify that Processors have timely performed their assigned tasks and that they continue to provide appropriate guarantees of full compliance with the provisions on Personal Data protection.
To have the complete list of Data Processors, please contact MONCLER by sending an e-mail to the following e-mail address: firstname.lastname@example.org.
3.1. Means and purposes for processing Personal Data
Your Personal Data will be processed both manually and with the help of electronic instruments. Your Personal Data will be kept in the form that allows you to be identified for the time strictly needed for the purposes for which the Data was collected and subsequently processed, and, in any event, within the legal limits. In particular, your Personal Data (name, surname, e-mail, nationality, gender) may be processed for the following purposes:
(i) for purposes necessary to provide the verification service of the authenticity of your purchased items (Anti-Counterfeiting Service); for purposes needed to manage and to respond to your requests for information and/or materials and to your questions; to provide the services required through the Site, including the registration, and to manage the initiatives organized through the Site; to comply with legal obligations, regulations and European Union legislation and the exercise of rights in court;
(ii) only with your specific and express consent, for marketing operations, market research, commercial or advertising communications related to products, services, events, offers and promotions of MONCLER through automated tools (such as email, SMS, MMS, push notifications and social network) and traditional ones (paper mail and phone calls with operator), sending the Newsletter by e-mail. You will always be able to indicate the contact details that you prefer among the above mentioned and you will have the opportunity at any time to oppose to the processing of your Data for commercial purposes and to no longer receive promotional and/or commercial materials and information;
- (iii) with your specific and express consent, information referring to preferences, habits, lifestyles, individual and group profiles definition (profiling purposes) can be collected with the aim of sending personalized communications.
To ensure that your Personal Data be always accurate and up-to-date, relevant and complete, please notify us of any changes to the following e-mail address: email@example.com. Your Personal Data will not be disclosed to third parties for purposes not permitted by law or without your express consent where required by applicable law.
MONCLER may end up processing Personal Data from third parties that have been directly communicated by its own users to MONCLER. In all of these cases, if provided for, please make sure you receive the consent of such individuals before disclosing their personal data to MONCLER and make sure you inform them about the processing of their Data, because you will be the sole person liable in connection with the disclosure of information and data regarding such third parties if they have not provided you with their express consent thereto, as well as solely liable for any improper or unlawful use of that information. In any event, MONCLER shall fulfill any obligation to inform third parties required by law and, when necessary, shall request their express consent upon registering in its archives the personal information of the user indicated.
4. What happens if you do not release to MONCLER your Personal Data
Granting your Personal Data to MONCLER is necessary with respect to the provision of the Anti-Counterfeiting Service and the provision of other services rendered on the Site on your request or to perform obligations required by law and other regulations (purpose of point 3.2(i) above).
Any refusal to indicate some of your Data required for the above purposes to MONCLER entails the inability to answer questions and requests for information and/or materials, to provide the authenticity control service of the products you purchase or to provide other services available on the Site or, moreover, to comply with legal and regulatory obligations. Failure to provide Data may thus constitute, depending on the case, a legitimate and justified reason for not providing services offered through the Site.
Disclosure of further Personal Data to MONCLER for the purposes of point 3.2(ii), other than that required is, on the contrary, optional and does not have any effect on the use of the Site, register, ask for information, use the Anti-Counterfeiting Service and other services available on the Site. In some circumstances and if required, from time to time we will duly inform you if the Personal Data you are disclosing to MONCLER is compulsory or optional. We will point out to you whether the disclosure of your data is compulsory or optional by marking with an appropriate symbol (*) the information that is compulsory or data needed for providing the required services.
5. To whom your personal data will be disclosed
Personal Data may be disclosed to the Data Processor of the processing indicated above, to third party companies that provide, on behalf of MONCLER, specific services as Data Processors appointed by MONCLER only when such purpose does not exceed the purposes for which your personal data was collected and subsequently processed and, in any case, according to applicable laws and regulations.
In addition your Data may be disclosed to public bodies, authorities, institutions, banks, credit institutions and legitimate recipients in compliance with laws and regulations; they may be made accessible to self-employed professionals and collaborators, also organized in associated form, third parties suppliers of professional and technical service for the processing purposes referred to in paragraph 3.2 that assist MONCLER in legal, tax, social security, accounting and/or organization's field, who will act as Data Processors or Persons in charge of the Processing, as the case may be, without prejudice to the adoption of Personal Data security and protection measures pursuant to current legislation.
Your Personal Data may also be disclosed to third parties in the event of extraordinary transactions (e.g. mergers, acquisitions, transfer of business, etc.) by MONCLER. Only the information necessary to perform their respective functions will be provided to such those persons. Such third parties will commit to use the information received only for purposes for processing specified above, to keep them confidential and secure and to comply with the protection of Personal Data required by law or regulations and any instructions given by MONCLER.
Personal Data may also be transferred abroad to persons established in countries that are not members of the European Union (e.g. other Moncler Group’s companies) that do not guarantee an adequate level of protection pursuant to the Privacy CodeLaw. In such cases, MONCLER transfers Personal Data to such third countries after the adoption of the measures laid down in Art. 44 and subsequent of the GDPR in order to legitimate the transfer and ensure adequate protection to transferred Personal Data.
Data will not be disclosed, disseminated or transferred to third parties without informing you of such disclosure/dissemination/transfer, without your consent and, in any case, in accordance with the law.
6. Automatic data collection mechanisms - Cookies
7. Security measures
Nevertheless, MONCLER cannot guarantee to you that the security measures adopted for the protection of the Site and for Data and information transmission will limit or exclude any risk of unauthorised access or of loss of Data. It is advisable that your computer be provided with software devices that protect network Data transmission/receipt (such as updated antivirus systems) and that your Internet service provider take appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering).
8. Your right to access data and other rights
You always have the right to obtain from MONCLER:
- a. the updating, correction or, when you have an interest in such, the integration of your Personal Data;
- b. the deletion or, transformation into an anonymous form of your Personal Data which has been unlawfully processed, including Data which does not need to be stored for the purposes for which it was collected or subsequently processed;
- c. the confirmation that the operations under letters a) and b) have been reported, even with regard to their content, to whom the data was disclosed or disseminated;
- d. the data portability;
- e. not to be subject to a decision based solely on automated processing, including profiling.
You are nevertheless entitled to ask for limitation and object, in whole or in part:
- for legitimate reasons, to the processing of your Personal Data, even if it is related to the purposes for which it was collected;
- to the processing of your Personal Data for advertising or direct marketing purposes or in order to carry out marketing research or commercial communications.
You have also the right to revoke the consent at any time, as well as to file a complaint with the competent supervisory authority (in Italy the Garante per la protezione dei dati personali).
You may freely exercise your rights at any time by sending your request to MONCLER at the firstname.lastname@example.org e-mail address to which we shall respond in an appropriate and timely manner.
9. Links to other websites
If you wish to receive further information on how MONCLER process your Personal Data, please send an e-mail to the following e-mail address: email@example.com