Information note and request for consent for personal data processing.

Information Note document pursuant to and for the effects of Article 13 of the Legislative Decree No. 196 of 30 June, 2003.

In compliance with Legislative Decree No. 196 of 30 June, 2003 (Privacy Consolidation Act), we hereby provide you with the required information regarding the aims and methods of processing of your personal data, provided by you, as well as the extent of communication and diffusion of the same, to the nature of the data in our possession and their conferment.

 

Almostthere Srl handles the personal information of its users with particular care. The present information note on privacy establishes the policy of Almostthere Srl relating to privacy that regulates the area protected by password of the site owned by Almostthere Srl by mean of which Almostthere Srl gathers personal data. Accessing or making use of the site, the user, moreover, expressly accepts the conditions established in the present policy relating to privacy. In case of disagreement with any whatsoever term of this policy on privacy, you are requested not to use the site or not to provide your own personal data. Some of the services could be conditioned on the provision of such personal data.

1.      Personal data

For the purposes envisioned by the present policy on privacy, “Personal Data” signifies all that information by which the user can be personally identified, and includes, solely as an example and not exhaustive, the given name, family name, address, telephone numbers (land and mobile), e-mail address, age, date of birth, sex, occupation, the data and details of the products, preferences of products, satisfaction with regard to products, language, driving experience and the like, photos and accounts, etc.

 

The policy on privacy of Almostthere Srl regulates the processing of the user’s personal data, including as an example and not exhaustive, the gathering, the use, the storing and protection of the information provided by and/or collected on the user for the purposes here below indicated

2.      Purposes of processing for which consent is given where requested

(Art. 23 of Legislative Decree 196/03)

a)     management of inherent data processing:

• registration on the present website for the acquisition of products;
• activity strictly connected with and instrumental in the management of the rapport of on-line purchasing – also through external subjects and conclusion of a contract, performance of the operations based on obligations derived from the concluded contract, accounting activity (issuing invoices, arrangements for payments), transfer of data abroad to EU countries, within the limits of the law;
• furnishing goods and for the protection of the position of creditor derived by them and thus to permit the carrying out of all the activities relating to the performance of the contractual agreement and fulfilment of the relative services and obligations, as well as statistical surveys in anonymous form;
• treatment of requests for information;

 

b) management of inherent data processing:

• promotional communications, also personalised for information activity, through the sending of advertising posters and hard copy promotional documentation, e-mail, newsletters, invitations;
• any programmes and prize contests;

 

Without obtaining the prior consent of the user, the personal data of the same will not be used for the purposes referred to in Par. b).At the time of providing personal information, the user has the possibility to opt in favour of such service.

For all other purposes, the user’s consent will be requested

3.      Processing and storage procedures

Processing will be carried out by automated electronic and/or manual means, with procedures and tools adjusted to guarantee maximum security and confidentiality, operated by persons appropriately charged with observing the provisions of Articles 31 and following, Legislative Decree No. 196/03. They will be stored at our offices in Milan or at the offices of third parties to be identified from time to time to handle the services to be furnished for periods strictly necessary for the purposes above cited and in any event not exceeding the period prescribed under law. In compliance with existing regulations, specific security measures are observed to prevent the loss of data, illicit or improper use and unauthorized access.

Personal data for contractual administrative-accounting purposes will be stored for a period not exceeding the administrative purposes for which they were collected and successively processed, while they will be stored for the purposes of profiling or of marketing for a period not exceeding, respectively, for twelve or twenty-four months from their registration, apart from actual transformation to an anonymous form.

4.      Limits on communication and diffusion

Data of a personal nature and only eventually of a sensitive nature, subject to processing, will not be diffused; they can, instead, be communicated by Almostthere Srl for the above listed purposes to companies contractually tied to Almostthere Srl or forming part of its distribution network, eventually also being located in other European Union countries, and in that case they will be processed by them exclusively for the above-said purposes. Personal data may be transferred abroad to countries not part of the EU within the scope and limits envisioned by Articles 43 and 44, sub letter b), L.D. 196/03.

 

Data may be communicated to third parties included in the following categories:

• subjects that provide services for the management of the IT systems used by Almostthere Srl and of the telecommunication network and for e-commerce;
• subjects, also external, for management and archiving hard copy and/or IT documentation;
• service companies handling acquisition, registration and processing of data arising from documents, or mediums supplied and originating from the same customers and having the object of mass working in relation to payments, effects, cheques and other titles;
• subjects that perform activities of assistance to customers, also by internet (i.e. call centres, help desks, etc.);
• professionals, offices or companies in the ambit of relationships of assistance and consultation, also for the control of company organizational management;
• for companies contractually ties to Almostthere Srl;
• public administration authorities for the verification of observance of fiscal and civil obligations;
• banks and credit and insurance institutions to effectuate financial activities (payments, collections) and insurance;
• Subjects that carry out performance of control, review and certification of the activities brought into being by Almostthere Srl, also in the customers’ interest.

 

For the purposes of Par. b), personal data may be communicated to outside companies for activities of commercial communication for the account of Almostthere Srl

 

The subjects included in the above categories perform the functions of responsibility for processing data, or operate in total autonomy as a separate processing owner.

 

The list of the eventual subjects in charge is available at the offices of Almostthere Srl in Milan. All additional communications or diffusion will only come about with your prior explicit consent.

 

Storing and transmission of personal data by the internet is protected by updated technological means commonly in use.

5.      Nature of the conferment

The providing of data for the purposes referred to in Paragraph a) is obligatory even if not the result of a regulatory requirement, inasmuch as it is required for registration on the present site and/or to conclude and effect execution of the relative contract for purchase of goods. Any refusal to consent to processing for the purposes listed above in Paragraph a) renders it impossible to register and purchase products at the Almostthere Srl website through which Almostthere Srl collects personal data.

 

The eventual refusal of consent with respect to Paragraph a) renders impossible the activities strictly related to and instrumental in managing relations with Almostthere Srl, which will also find itself in the position of not being able to provide the goods themselves, or necessary for the discharge of contractual obligations. The owner hereby notes, moreover, that any non-communication, or erroneous communication, of one of the required data, has the following consequences:

• the impossibility of the owner to guarantee the completion of the registration on the present site and the adequacy of the processing itself to the eventual contractual pact for which the same was executed;
• the possible failed correspondence of the results of the same processing to the eventual obligations imposed by the fiscal, administrative and civil regulations to which they are addressed.

In the case where the data indicated as “obligatory” are not inserted in the registration module, it will not be possible, therefore, to complete the registration procedure.

 

The conferment of data for the purposes of Paragraph b) is optional, i.e. it is not required as a matter of law: the failure to provide data for such purposes will have as its only consequence the impossibility to be contacted by Almostthere Srl for promotional communications, also personalized for information activities.

The refusal of consent for the purposes set forth above in Paragraph b), will not have any negative consequences with regard to your request and to effect execution of the relative contract (the purposes referred to in Paragraph a).

You may claim your rights according to Articles 7, 8, 9 and 10 of L.D. No. 196 of 30 June, 2003 by contacting the owner or the processing manager at Almostthere Srl.

6.      Cookies

Use of cookies on the website www.almostthere.eu

What are cookies?

Cookies are tiny text files stored on your computer when you visit certain web pages. At store.moleskine.com we use cookies to keep track of what you have in your basket, and to remember you when you return to our site.

To order products on store.moleskine.com, you need to have cookies enabled. If you don’t want to accept cookies, you’ll still be able to browse the site and use it for research purposes. Most web browsers have cookies enabled, but see in the end of this paragraph how to alter your cookies settings.

Please note that cookies can’t harm your computer. We don’t store personally identifiable information such as credit card details in cookies we create, but we do use encrypted information gathered from them to help improve your experience of the site. For example, they help us to identify and resolve errors, or to determine relevant related products to show you when you’re browsing.

We have relationships with carefully-selected and monitored suppliers who may also set cookies during your visit but not can be used for remarketing purposes – in other words not to show you different products and services based on what you appear to be interested in.

We’re giving you this information as part of our initiative to comply with recent legislation, and to make sure we’re honest and clear about your privacy when using our website. We know you’d expect nothing less from us, and please be assured that we’re working on a number of other privacy and cookie-related improvements to the website.

You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices. eu for a video about cookies visit www.google.co.uk/ goodtoknow/data-on-the-web/cookies

Cookies can perform different functions, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience.

The cookies used on this website have been categorised based on the categories found in the ICC UK Cookie guide. A list of all the categories of cookies used on this website is set out below.

 

Strictly necessary cookies

These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.

Strictly necessary cookies be used to store a unique identifier to manage and identify the user as unique to otherusers currently viewing the website, in order to provide a consistent and accurate service to the user.

Examples include:

• Remembering previous actions (e.g. entered text) when navigating back to a page in the same session;
• Managing and passing security tokens to different services within a website to identify the visitor’s status (e.g. logged in or not);
• To maintain tokens for the implementation of secure areas of the website;
• To route customers to specificversions/applications of a service, such as might be used during a technical migration;

 

Performance cookies

These cookies can be first or third party, session or persistent cookies, their usage is limited to performance and website improvement. These cookies collect information about how a visitor uses the site, such as pages visited. These cookies do not collect information that can identify the user. Any information that these cookies collect is aggregated anonymously and are used only to improve the functioning of the site.

Examples include:

• Web analytics, the data collected is limited to the website operator’s use only, for managing the performance and design of the site. These cookies can be third-party cookies but the information will be for the exclusive use ofthe publisher of the website visited;
• Affiliate tracking — where the cookie is used exclusively to letaffiliates know that a visitor to a site visited a partner site some time later and if that visit resulted in the use or purchase of a product or service, including details of the product andservice purchased. Affiliate tracking cookies allow the affiliate to improve the effectiveness of their site;
• Error management — Measuring errors presented on a website, typically this will be to support service improvement or complaint management and will generally be closely linked with web analytics;
• Testing designs — Testing variations of design, typically using A/B or multivariate testing, to ensure a consistent look and feel is maintained for the user of the site in the current and subsequent sessions.

By using www.almostthere.eu, you agree that we can place these types of cookies on your device.

 

Functionality cookies

These cookies can be first party, third party, session or persistent cookies. These cookies will typically be the result of a user action, but might also be implemented in the delivery of a service not explicitly requested but offered to the user. They can also be used to prevent the user being offered a service again that had previously been offered to that user and rejected. Furthermore, these cookies allow the site to remember the user’s choices (such as username, language, country of origin, etc.. Etc..). The information these cookies collect is anonymous and cannot track user behavior on other sites.

Examples include:

• remembering settings a user has applied to a website such as layout, font size, preferences, coloursetc;
• remembering a choice such as not to be asked again to fill in a questionnaire.
• detecting if a service has already been offered, such as offering a tutorial on future visits to the website;
• Providing information to allow an optional service to function such as offering a live chat session.
• Fulfilling a request by the user such as submitting a comment.

 

By using www.almostthere.eu you agree that we can place these types of cookies on your device.

www.almostthere.eu reserves the right to use cookies, consent of the user when the applicable law or regulation so provides, to facilitate navigation on this site and customize the information that will appear. www.almostthere.eu also reserves the right to use similar systems to collect information about users of the site, such as IP address, type of Internet browser and operating system used and / or web pages visited by a user, for statistical purposes or safety. Name site may collect this information to track site usage and improve certain aspects.

Most browsers automatically accept cookies, but you can also choose not to accept them. We recommend not to disable this function, since this would prevent moving freely from page to page and enjoy all the specifics of the site.

If you do not want to accept that your computer receives and stores cookies, you can alter your security settings on your web browser (Internet Explorer, Google Chrome, Safari etc.). However, note that certain parts of our Site may only be used fully if your browser allows cookies,if not you won’t be able to add products to your basket and buy them (for exaple). Thus, your reading experience of our Site may be affected negatively by removing and not allowing cookies.

If you wish to alter your cookie settings, by going to your browsers settings, below are short instructions for how to do this in the four most popular browsers:

 

Microsoft Internet Explorer

Click the ‘Tools’ icon in the top right side corner and select ‘Internet options’. In the pop up window select the ‘Privacy’ tab. From here you can adjust your cookie settings.

 

Google Chrome

Click the spanner in the top right side corner and select ‘Settings’. From here select ‘Under the hood’ and change the settings under ‘Privacy’.

 

Mozilla Firefox

From the drop down menu in the top left side corner select ‘Options’. In the pop up window select the ‘Privacy’ tab. From here you can adjust your cookie settings.

 

Safari

From the settings drop down menu in the top right side corner select ‘Preferences’. Select the ‘Security’ tab and from here you can adjust your cookie settings.

 

Almostthere Srl reserves the right to change, modify, add or remove parts of the present policy on privacy, at its own discretion and at any time. The user has the responsibility to periodically check for any changes to this page. Continued use of this site following the posting of changes to the present policy on privacy constitutes acceptance of the same.

You may validate your own rights as expressed in Articles 7,8,9 and 10 of L.D.196 of 30 June, 2003 by contacting the owner (or the responsible party, if nominated) of the processing.

 

7.      Right of access to personal data and other rights

1. The interested party has the right to obtain the confirmation of the existence or not of personal data that concerns him/her, also if not yet registered, and their communication in an intelligible form. 2. The interested party has the right to obtain the indication:

 

a) of the origin of the personal data; b) of the purpose and manner of processing; c) of the logic applied in the case where processing is effectuated with the use of electronic instrument; d) of the identificative details of the owner, the person in charge and the designated representative pursuant to Art. 5, sub 2; e) of the subjects and categories of subjects to which personal data can be communicated or who could come to know of as designated representative in the territory of the state, of persons responsible or in charge. 3. The interested party has the right to obtain: a) the updating, rectification or, if so interested, the addition of data; b) the cancellation, the transformation into anonymous form or the blocking of data processed in violation of the law, including those for which there is no need to store with regard to the purposes for which the data has been collected or subsequently processed; c) The certification that the operations referred to in sub letters a) and b) were brought to the knowledge, also with regard to their contents, from those to whom the data was communicated or diffused, excepting the case where such fulfilment is shown to be impossible or involves the use of manifestly disproportionate means in relation to the right being protected.

4. The interested party has the right to oppose, in whole or in part: a) for legitimate reasons the processing of personal data that concerns him/her, even though pertinent to the scope for which gathered; b) to processing of personal data that concerns him/her with the object of sending advertising material or for direct sales or for market research or commercial communications.

 

For any request for information and/or clarifications, questions or complaints as to processing of personal data, we ask you to do so by writing to the person in charge of processing indicated below:

 

Owner of processing is: Almostthere srlVia Francesco de Sanctis, 34 20141 Milan (Italy).

 

Whenever contact is no longer desired, the use of personal data will immediately cease. Whenever contacting the company, please provide your e-mail address, name, address and/or telephone number, so as to provide for the proper handling of the request.

To be cancelled from our mailing list, it will be enough to write an e-mail at any time to this address: info@almostthere.eu or by mail to Almostthere srlVia Francesco de Sanctis, 34 20141 Milan (Italy), with the subject: “cancellation mailing list”.

The updated list of persons in charge will be communicated on simple request to be sent by e-mail to info@almostthere.eu or by mail to the address given just above.