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Privacy and cookie policy

Information to data subjects pursuant to Article 13, Legislative Decree 196/2003


The data controller
This policy applies to the www.pupa.it, www.pupastyle.it, imparfum.pupa.it, and imlimpstick.pupa.it websites (each the “Website”, together the “Websites” and any web app of the PUPA Milano brand. The data controller, in accordance with Article 28 of Legislative Decree 196/2003 (hereafter the “Personal Data Protection Code” or “Code”), is MICYS COMPANY SpA (hereinafter also referred to as “Pupa”) with its registered office in Monza, Italy, via Appiani 25 and its headquarters (hereinafter “Headquarters”) in Casatenovo (LC), via de Gasperi 22, VAT IT02089840967, tax code 0208984096, registered in the Business Registers of Monza and Brianza No.02089840967.

The purposes of the processing
As explained in greater detail in the sections that allow for subscription to the services reserved for users of the website through the provision of personal data, the data of the data subjects is processed in order to respond to requests expressly made by the same. In particular, all the collection and subsequent data processing is performed with the purpose of achieving the following:
sharing content on the site;
customer relationship management (CRM);
generic requests for information;
participation in promotional initiatives - such as loyalty and fidelity cards/coupons offered to customers;
use of the Pupa App available on the Apple Store for both the iPhone and iPad or other Pupa applications developed on different platforms (e.g. Facebook, Twitter, etc.).
Pupa does not use the information provided by users for purposes other than those connected to the service, including those listed above for which the data subject has subscribed, or only within the limits set out from time to time in the possible further specific information for the data subjects in order to support a different and particular service requested by the user.

Who processes the data
For ends related to the provision of the service to which the user has subscribed, the data will be made available to third parties who will act as autonomous data controllers providing services instrumental to fulfill the request of the user (for example, a company that delivers purchased products) or to whom the communication of the data is required in order to comply with laws or regulations.
Some controllers have been appointed. In particular, an external data processor has been appointed for hosting functions:
Mr. S. Leguti, Marketing Multimedia Srl - www.pupa.it
The following individuals were designated as internal data processors: 
Valerio Gatti, CEO, Micys Company Spa
Barbara Rizzo, Director of Human Resources, Micys Company Spa
Lavinia Fazio, PR & Digital Strategist, Micys Company Spa
The updated list of data processors is available upon simple request to the Data Controller.
Personal data will be made available to persons specifically authorized by the controller, persons nominated in charge of the processing, who carry out the processing indispensable for the pursuit of the above purposes. Categories of persons in charge of the processing include administrators, individuals in the communication, accounting, legal, technical maintenance of information systems, and/or marketing departments depending on the specific request made by the user through this website.
Your data may be transferred abroad to other countries of the European Union or to countries considered safe by the European Commission, or even to non-EU countries not included in the list of safe countries: in the latter case, we will stipulate in advance, with the individual subjects who would process the data outside the EU, the specific arrangements for the protection of your privacy, including the standard clauses given by the European Commission decision of 5 February 2010.

How we process data

All processing performed in the site environment will be carried out using electronic or telematic communications instruments, but may also be processed by paper/manual means.
The data will be processed according to the purposes for which the data were collected and in compliance with current security standards for the aforementioned purposes or those specified from time to time in additional information presented to the user.
The personal data will be processed for the time strictly necessary to achieve the purposes for which they were collected.

Types of personal data and optional conferment
The forms on this site that can be filled in cover both data that are strictly necessary for the provision of the service, the failure to specify such data will not allow for the request to be fulfilled, and data that can be provided voluntarily which are not strictly necessary to respond to the request.    

Navigation data
The computer systems and software procedures used to operate this website acquire some personal data during their normal operation whose transmission is implicit in the communication protocols of the Internet. This information is not collected in order to be associated with identified data subjects, but by their very nature could identify users through processing and association with data held by third parties.
This category of data includes IP addresses or domain names of computers used by users connecting to the site, the URI (Uniform Resource Identifier) of requested resources, the time of request, the method used to submit the request to the server, the file size obtained in response, the numerical code indicating the status of response from the server (successful, error, etc.) and other parameters regarding the operating system and computer environment of the user.
These data are used only to obtain anonymous statistical information about the site and to check its correct functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in case of computer crimes against the site and only in that case would they be stored for more than seven days.

Data provided voluntarily by the user
The personal data normally required for the use of the site’s services are biographical, contact information and data related to instruments and payment details. The optional, explicit and voluntary sending of e-mails to addresses listed on this website or the completion of electronic contact forms involves the acquisition of the sender’s email address as it is necessary to respond to requests, as well as any other data included in the message. Specific information will be progressively reported or displayed on web pages dedicated to particular requested services. Normally sensitive data pursuant to Article 4 of Legislative Decree 196/2003 (in the case of processing of sensitive data for certain services, a special information notice will be issued and specific consent to the interested user will be requested) is not processed.

Cookies and other reading/recording technologies of information on the user’s terminal 
We may use cookies (small text files transferred from the web server to your computer) and other technologies for reading and/or storing information on the user's device such as fingerprinting, email trackers or Clear GIF/Beacons, whose purpose is to inform the server of user access to a particular web page and other news obtained from the system’s legible parameters via functions contained in the Web page to make it easier to customize the browsing experience of users and, in some cases with their consent, to enrich user profiling for advertising and/or commercial purposes. Cookies can be “temporary” (or session cookies, eliminated at the end of the connection) or “permanent” (saved on the user’s hard disk until the user deletes them).


The cookies used by our website and our app are divided into two types identified by the Italian Data Protection Authority ("Data Protection Authority") with the so-called “Cookies” general measure of 8 May 2014, of which the data controller complies with the regulations in terms of information to data subjects and the necessity/modality of obtaining consent. In particular, this information notice is also the extension of the synthetic banners already displayed to the user at the time of connection to the website and/or upon instillation of the app.
 

For each of the sites governed by this policy, the following information concerning cookies/other profiling technologies used is provided.

A. On the basis of the aforementioned measure of the Italian Data Protection Authority, the www.pupa.it website and app use:


“Technical cookies”, which are strictly necessary for the operation of the site/app and/or the provision of a service explicitly requested by the user. This category includes analytic cookies employed by the controller of the site to gather information in aggregate form concerning the number of users and how they visit the site. This type of cookies does not require your consent unless you expressly deny it for one or all types of technical cookies (listed below):

Session/navigation cookies: guarantee normal navigation and use of the website;
Functional cookies: help ensure user navigation based on criteria selected by the same (e.g. language) for the sole purpose of improving the service;

“Profiling cookies” from us and/or from third-parties, that is, cookies that are potentially aimed at creating/enriching user profiles and used in order to send and/or display advertising messages in line with the preferences shown by the user during navigation. For the use of this type of cookies, the (optional) consent of the user is always necessary. The user can choose the cookies or profiling technologies like fingerprinting/Clear GIF/Beacon profiling to give consent to. When it comes to cookies or so-called third-party technologies, those installed/used on the site by third parties with respect to each controller, the user gives or denies consent directly to the owner of the cookie and/or technology in question, to which the controller makes mere reference through links.
 
The following profiling/non-technical cookies and/or other technologies such as beacons/ Clear GIF/email trackers are used: 
- Owners
None

- Third party

Google Analytics: allows for the collection and analysis of information relative to the use of the website by users (e.g. the number of web pages visited). These cookies do not collect information to be used for commercial purposes.
For more information, please click here.
You can disable Google Analytics by installing the opt-out component provided by Google on your browser. To disable Google Analytics click here.
DoubleClick: allows for the assessment the efficiency and performance of an advertising campaign directed to the pages of our site to improve the message in future campaigns.
For more information, please click here.
YouTube: Embedding code to visualize video. For more information, please click here.
Facebook: Facebook connector. For more information, please click here
Add this: Tool for tracing shares of site content on social networks. For more information, please click here.
Google Ad words and Google Remarketing: For more information click here.

It’s also possible to manage/disable cookies directly from the browser settings, or through the http://www.youronlinechoices.com/uk/ portal.
For more information on how to set preferences on the use of cookies through your web browser, you can refer to the following instructions:


Internet Explorer
Firefox
Chrome
Safari
 
To object to the use of profiling tools other than cookies (such as beacons/Clear Gif/email trackers), contact the data controller at the following email address privacy@pec.pupa.it

The use of persistent cookies and session cookies (which are not stored permanently on the user’s computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to enable a safe and efficient exploration of the site. The so-called session cookies are used by the website to avoid the use of other technologies that could compromise the privacy of users and do not allow for the acquisition of personal data that may identify the user.

Rights of data subjects

The subjects to whom the personal data belong have the right at any time to obtain confirmation of the existence of such data and to know its content and origin, verify its accuracy or request its integration or updating, or correction (art. 7 of Legislative Decree 196/2003).

According to the same article, one has the right to request the cancellation, anonymization or the blocking of data processed in violation of the law, and to oppose any case, for legitimate reasons, their processing. Requests should be sent to the physical address of the data controller or by email to privacy@pec.pupa.it

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