PRIVACY NOTICE: PROCESSING OF PERSONAL DATA pursuant to Arts. 13/14 of the General Data Protection Regulation (GDPR), European Regulation 2016/679
JL Srl (VAT Registration No. 04634340964, registered office 10 Via Varese, Milan, Italy), owner of the right to use the trademark “Aldo Coppola” and of the website “aldocoppola.com” (“the Website”) recognizes the importance of keeping your data safe.
As Data Controller, therefore, it hereby gives you (“the Data Subject”) notice under Arts. 13/14 of the GDPR, that it will be processing the personal data provided by you or referring to you in accordance with the law. Under applicable laws and regulations, your personal data (personal details, details of residence, contact details, e-mail address, mobile phone number, Internet browsing data, etc.) will be processed according to the principles of accuracy, legality, transparency and the preservation of confidentiality.
To that end we give you notice that browsing on the Website is free and does not require any kind of registration; you will, however, find some areas where you will be asked for certain identifying details which are needed for you to be able to access certain specific services. We observe the principle of strict necessity when processing any data from which you can directly or indirectly be identified.
1) Type of data processed
No registration is needed for access to the Website or for browsing within it.
Nevertheless, there are some sections of the Website where you can find further details of our activities, our promotions and our events; in order to benefit from that service you will be asked to register, providing certain identifying details.
For that purpose you may be asked for personal data such as your first name, last name, date of birth, address, telephone number and email address.
If these details should change in future, we should be grateful if you would contact the Data Processor (details below) to inform us of any such changes, so that we can keep your personal data up to date at all times.
2) Purposes for which personal data are processed
We give you notice that the personal data provided by you or referring to you will be processed by JL Srl for the purpose of providing support if you have requested such support through our Customer Service Department, or so that you can receive further details of our activities, promotions and events.
3) Manner in which personal data are processed
Personal data provided by you or referring to you may be processed by partially or totally automated means, on paper, electronic and/or magnetic media.
The personal data will not be disseminated generally, but may be disclosed or to or come to the knowledge of suitably trained members of the staff of the Data Controller and/or outside organizations working with that company either as Data Processors or as independent Data Controllers. These may for instance include, but may not be limited to, the following:
• companies, firms and/or professional practitioners acting as consultants and/or technical, corporate or IT contractors;
• companies connected with the Aldo Coppola brand, for the provision of goods and/or services and for related activities;
• other persons, if disclosure to those persons is necessary for carrying out the contractual relationship fully and correctly and/or to comply with statutory obligations and/or for the purposes specified above.
4) Optional nature of personal data provision
Providing your personal data on the Website is optional.
5) The Data Controller and the Data Processor
The Data Controller for your personal data is JL Srl, VAT Registration No. 04634340964, registered office 10 Via Varese, Milan, Italy, telephone +39 02 62499320. JL Srl has appointed a Data Processor selected on the basis of its proven experience, capability and reliability, so as to comply fully with current applicable laws and regulations on the processing of personal data. The Data Processor will act on the basis of instructions given by JL Srl, which will conduct regular inspections to check that its conduct is correct. The Data Protection Officer can be contacted at email@example.com or by registered letter to Il Responsabile, c/o Ufficio Privacy, 336 Viale Sarca, Milan.
6) Where and for how long personal data are kept
JL Srl will keep your personal data for as long as needed to respond to your requests, or until your authorization is no longer valid. After that time your data will be frozen for the period required under the applicable laws and regulations in force at the time. We take every necessary precaution to ensure the security of our customers’ information. The data are stored encrypted, and the number of people who have physical or virtual access to them is limited. All the data are stored on servers within the European Union; no data are sent to any jurisdiction outside the EU.
7) Your rights as Data Subject
We also give you notice that you have the right to ask the Data Controller for access to your personal data and to correct or erase it or restrict its processing; you also have the right to object to the processing of personal data and demand its portability. These rights can be exercised as provided for in Arts. 15, 16, 17, 18, 20 and 21 of the GDPR, which we are reproducing here, attached to this Notice, for your convenience. All these rights may be exercised by contacting the Data Controller, but you also have the right to make a complaint to the supervisory authority established by Italian law.
If you need any clarification, or wish to exercise the above rights, you can contact the Data Controller (JL Srl) by contacting the Data Protection Officer (see GDPR Art. 37) in the Privacy Office of JL Srl, 336 Viale Sarca, Milan, Italy or by telephoning +39 02 62499320 or by e-mail to firstname.lastname@example.org.
7.1) Extract from the General Data Protection Regulation (EU 679/2016): rights of the Data Subject
Article 15 Right of access by the Data Subject The Data Subject shall have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information: (a) the purposes of the processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; (d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (e) the existence of the right to request from the Data Controller rectification or erasure of personal data or restriction of processing of personal data concerning the Data Subject or to object to such processing; (f) the right to lodge a complaint with a supervisory authority; (g) where the personal data are not collected from the Data Subject, any available information as to their source; (h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the Data Subject. 2. Where personal data are transferred to a third country or to an international organisation, the Data Subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer. 3. The Data Controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the Data Subject, the Data Controller may charge a reasonable fee based on administrative costs. Where the Data Subject makes the request by electronic means, and unless otherwise requested by the Data Subject, the information shall be provided in a commonly used electronic form. 4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
Article 16 Right to rectification The Data Subject shall have the right to obtain from the Data Controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the Data Subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Article 17 Right to erasure (“the right to be forgotten”) 1. The Data Subject shall have the right to obtain from the Data Controller the erasure of personal data concerning him or her without undue delay and the Data Controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (b) the Data Subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing; (c) the Data Subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the Data Subject objects to the processing pursuant to Article 21(2); (d) the personal data have been unlawfully processed; (e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the Data Controller is subject; (f) the personal data have been collected in relation to the offer of Information Society services referred to in Article 8(1). 2. Where the Data Controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the Data Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform Data Controllers which are processing the personal data that the Data Subject has requested the erasure by such Data Controllers of any links to, or copy or replication of, those personal data. 3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary: (a) for exercising the right of freedom of expression and information; (b) for compliance with a legal obligation which requires processing by Union or Member State law to which the Data Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller; (c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3); (d) for archiving purposes in the public interest, scientific or historical research purposes or statistics purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or (e) for the establishment, exercise or defence of legal claims.
Article 18 Right to restriction of processing 1. The Data Subject shall have the right to obtain from the Data Controller restriction of processing where one of the following applies: (a) the accuracy of the personal data is contested by the Data Subject, for a period enabling the Data Controller to verify the accuracy of the personal data; (b) the processing is unlawful and the Data Subject opposes the erasure of the personal data and requests the restriction of their use instead; (c) the Data Controller no longer needs the personal data for the purposes of the processing, but they are required by the Data Subject for the establishment, exercise or defence of legal claims; (d) the Data Subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the Data Controller override those of the Data Subject. 2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the Data Subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. 3. A Data Subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the Data Controller before the restriction of processing is lifted.
Article 20 Right to data portability 1. The Data Subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a Data Controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another Data Controller without hindrance from the Data Controller to which the personal data have been provided, where: (a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and (b) the processing is carried out by automated means. 2. In exercising his or her right to data portability pursuant to paragraph 1, the Data Subject shall have the right to have the personal data transmitted directly from one Data Controller to another, where technically feasible. 3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller. 4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.
Article 21 Right to object 1. The Data Subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The Data Controller shall no longer process the personal data unless the Data Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the Data Subject or for the establishment, exercise or defence of legal claims. 2. Where personal data are processed for direct marketing purposes, the Data Subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. 3. Where the Data Subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes. 4. At the latest at the time of the first communication with the Data Subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the Data Subject and shall be presented clearly and separately from any other information. 5. In the context of the use of Information Society services, and notwithstanding Directive 2002/58/EC, the Data Subject may exercise his or her right to object by automated means using technical specifications. 6. Where personal data are processed for scientific or historical research purposes or statistics purposes pursuant to Article 89(1), the Data Subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.2) Withdrawing consent to the processing of personal data
You may withdraw your consent to the processing of your personal data by contacting the Data Controller. You can exercise your rights in relation to the above processing of personal data by means of a simple request sent by registered letter or by email to the Data Processor, whose contact details are given in (5) above; there is no charge, and no formalities. You can appoint another individual, institution, association or organization by written proxy to do this on your behalf, or you can ask a friend to apply along with you. You can also object at any time to the processing of your personal data by asking the Data Processor (as above) to be unsubscribed from our newsletter; again there is no charge.
e-mail address: email@example.com
8)Links to other websites
This Notice applies only to the website www.aldocoppola.com.it , not to any other website which the user may reach through a hyperlink. JL Srl declines all responsibility for personal data provided by users to other persons, websites and/or social networks reached through links from the Website.
Whenever a change affects processing for which consent is the legal basis, the Data Controller will take steps to get the Data Subject’s renewed consent, if necessary.
Last changed: 25 May 2018