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Privacy policy

This information notice (or 'privacy policy') is provided in compliance with current legislation on the protection of personal data and, in particular, pursuant to EU Regulation 2016/679 (GDPR) and Legislative Decree 196/2003 (Personal Data Protection Code, so-called 'Privacy Code') with reference to the processing of the personal data of visitors to the site http://www.brandtrotter.net/. The site is owned and managed by the company under Italian law Brand Trotter S.r.l. This privacy policy is made only for this site and not for third party websites that may be consulted by the user through links.

1. data controller

The data controller is Brand Trotter S.r.l, Via Francesco Dall'Ongaro, 24, Milan, Italy; P.IVA 10681470968 E-mail: info@brandtrotter.net

2. purposes and methods of processing

Following consultation of this site and the use of one or more services, data relating to identified or identifiable natural persons may be processed. Any personal data acquired, always in compliance with the regulations in force, will be processed solely for the following purposes: a) for purposes strictly connected and instrumental to allowing access to and use of the site, its functions and the services requested; b) to fulfil obligations provided for by law and by European regulations; c) for operational and management requirements internal to soc. Brand Trotter S.r. l and inherent to the services and/or products offered; d) for the creation of the user's personal account; e) to provide the newsletter service; In the event of an explicit and optional manifestation of consent, the data collected for the purposes referred to in paragraph 1, will also be processed for direct marketing purposes by the Data Controller, in particular for the sending of informative, commercial or advertising material relating to the services and/or products offered by Brand Trotter S.r.l, also by e-mail, sms, mms and fax. The data will be processed lawfully and fairly and used only for the purposes referred to in the preceding paragraphs. The data will be processed using instruments that are suitable for guaranteeing the security and confidentiality of the personal data and may be processed using paper and/or automated instruments for storing, managing and transmitting the data.

3. nature of the provision of data and consequences of refusal

The provision of personal data is compulsory exclusively for the purposes set forth in Article 2, paragraph 1, in order to allow the use of the site and the services connected to and requested by the user, possibly subject to the provision of information for each additional service, which will in any case be provided to users in the manner established by law. It will still be possible to consult the site without providing any personal data, but certain functions will not be available and certain services cannot be provided. The provision of data and the granting of consent for processing for the purposes referred to in Article 2, paragraph 1, letters d), e) and f), and paragraph 2, is optional: in the absence of the user's request and/or the granting of his/her explicit consent, these services will not be provided, but there are no other consequences. If you do not intend to provide your consent for the purposes set out in Section 2, paragraph 2, you may still use the site and services for the purposes set out in Section 2, paragraph 1. In other words, the consequences of a refusal to answer or to give consent are always explicit and are connected to each service provided: for example, a refusal to process this information may prevent consultation of the site with all its functions (in the case of cookies), the sending of the newsletter (in the case of Art. 2, paragraph 1, letter e) or the receipt of advertising material (in the case of Art. 2, paragraph 2). In any case, the user may consult the website also without providing personal data and denying consent to the processing, where required; in this case, however, some functions or features of the site may be disabled.

4. place of data processing

The processing operations connected to the web services referred to in this site are carried out at the Brand Trotter head office, subject to explicit exceptions, and are handled only by technical staff expressly appointed for the purpose by the Data Controller.

5. types of data processed/specific processing

Depending on the service provided, different types of personal data may be processed, as specified in this article. Please note that, where the data entered by the user also concern other persons, the user must have this notice read in advance by such persons as well. The processing of the data of children under sixteen years of age may only take place with the consent of their parents or legal guardian. In the absence of such consent, in the event of receipt of data from a minor, the data controller reserves the right to delete such data. Therefore, in the use of our services, those concerned are requested not to enter data relating to minors under the age of sixteen; in any case, such data may be used in limited cases such as, for example, for communications to public authorities. 5.1 Browsing data the computer systems and software procedures used to operate this site acquire, in the course of their normal operation, certain personal data whose transmission is implicit in browsing the websites. This information is not collected to be associated with identified interested parties; however, by its very nature it could, through processing and association with data held by third parties, allow users to be identified. These include the IP addresses or domain names of the computers used by users who connect to the site, the URL addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server and other parameters relating to the operating system and platform used by the user. The above data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct operation; they are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the site: apart from this eventuality, at present the data on web contacts do not persist for more than seven days. With regard to cookies, please refer to Section 5.4 below. 5.2.1 Data provided voluntarily by the user (communications - site registration) The optional, explicit and voluntary sending of communications by means of the contact forms on the site or by e-mail to the addresses indicated on this site entails the subsequent acquisition of the data communicated by the sender, including his or her e-mail address, and consent to receive any messages in response to his or her requests. To this end, only the personal data necessary to identify the user and to provide the service requested by the same (in particular, name, surname and e-mail address) are collected. The data thus provided by the user to Brand Trotter S.r.l are used solely for the purpose of satisfying or responding to the requests transmitted and are communicated to third parties expressly authorised by the Data Controller only if necessary for this purpose. Specific information notices prepared for particular services on request will be reported on the relevant pages of the site. 5.2.2 Data provided voluntarily by the user (to receive communications for marketing and/or commercial promotion purposes) Each interested party may voluntarily provide their personal data to Brand Trotter S.r.l in order to receive commercial or promotional information, however denominated, by means of both digital and paper communications. In the sole case in which the e-mail address is provided by the data subject in the context of the sale of a product or service, the e-mail address thus provided may be used for the direct sale of further similar products or services, pursuant to art. 130, paragraph 4 of Legislative Decree no. 196/2003, without the need for the data subject's express prior consent (so-called 'soft spam'). In every communication of this kind, however, the data subject is reminded that he or she may withdraw consent at any time and without formalities. Data processed for marketing purposes shall be deleted at the request of the data subject, who may revoke consent at any time, as explained in more detail in Section 9 below. 5.3. The Brand Trotter S.r.l newsletter is sent by e-mail to those who explicitly request it by filling in the specific form on this site and thereby authorising Brand Trotter S.r.l. to process their personal data for the aforesaid purpose. Consent: The provision of the data requested for this purpose (email and, if necessary, selection of pre-established categories of areas of interest) is compulsory only in order to receive the newsletter: refusal to provide such data will make it impossible to use the newsletter service, but there are no other consequences. Purpose: The personal data provided by users are used for the sole purpose of sending the newsletter and will not be disclosed to third parties. Modalities: The data collected are processed using IT tools. Suitable security measures are observed to prevent data loss, illegal or incorrect use and unauthorised access. Unsubscription from the service: to stop receiving the newsletter, simply select the unsubscribe link at the end of each e-mail received or send a request to the e-mail address: info@brandtrotter.net. The unsubscription is handled automatically, so that, following the request to unsubscribe from the service, further newsletters may be received, the sending of which was planned before the request was received, but for a maximum period of 72 hours. 5.4.1 Cookies What are they? Cookies are pieces of information stored by your browser when you visit a website with any suitable device (such as a PC, tablet or smartphone). Each cookie contains various data (e.g. the name of the server it comes from, a numeric identifier, etc.), can remain in the system for the duration of a session (until the browser is closed) or for long periods and may contain a unique identifier. What are they used for? Cookies are used for different purposes depending on their type: some are strictly necessary for the proper functionality of a website (technical cookies), while others optimise its performance to offer a better user experience or enable the acquisition of statistics on the use of the site, such as analytics cookies, or allow personalised advertising to be displayed, such as profiling cookies. Consent: any consent given by the user is stored by Brand Trotter S.r.l as far as it is concerned, by means of a technical cookie, which lasts 12 months. The user is informed both by means of the short information (banner displayed until consent is given or denied, as explained in section 5.4.4. 'How to disable cookies?') and by means of this extended information notice; in addition, section 5.4.3 provides links to the privacy policies of third parties, also for the purpose of disabling them (where directly available through them). How to disable them? You can disable cookies either through your browser settings (section 5.4.4 'How to disable cookies?') or through the mechanisms made available by certain third parties (section 5.4.3 'Cookies used on the site'). 5.4.2 General types of cookies used on the site technical cookies: these are essential for the site to function properly. Analytical cookies (third party): these are used for the purposes of aggregate analysis of visits to the site, through the use of a third-party service. Profiling cookies (third party): these are used to create profiles of the user and are used to send advertising messages in line with the preferences expressed by the user when browsing the web, through the use of a third-party service. 5.4.3 Cookies used on the site First-party cookies: only technical cookies are used for the purpose of storing the user's consent to the use of cookies (duration: 12 months) and to store the user's session data (duration: 12 months). Third-party cookies: cookies provided by the third parties listed below are used on the site along with links to their respective privacy policies (also for disabling them). Analytical cookies: Google Analytics http://www.google.com/intl/it_ALL/ analytics/learn/privacy.html https://tools.google.com/dlpage/gaoptout Profiling cookies: Google Inc.: http://www.google.com/policies/technologies/cookies/ https:// maps.google.it/intl/en/policies/technologies/product-privacy/ http://www.google.com/ settings/ads (for disabling profiling based on Google ads). Addthis: http://www.addthis.com/privacy http://www.addthis.com/privacy/opt-out (for disabling -opt-out) For cookies resulting from sharing via social networks, please refer to each of them (because the cookies are related to the same): Facebook: https://www.facebook.com/about/privacy/cookies Google+: https:// www.google.com/policies/technologies/cookies/ Linkedin: https://www.linkedin.com/ legal/cookie-policy Twitter: https://twitter.com/it/privacy Whatsapp: https:// www.whatsapp.com/legal/?l=it#cookies 5.4.4 How to disable cookies? Browser control: Commonly used browsers (e.g., Internet Explorer, Firefox, Chrome, Safari) accept cookies by default, but this setting can be changed by the user at any time. This applies to both PCs and mobile devices such as tablets and smartphones: it is a generally and widely supported function. Therefore, cookies can easily be deactivated or disabled by accessing the options or preferences of the browser used, and generally third-party cookies can also be blocked; in general, such options will only take effect for that browser and on that device, unless options to unify preferences on different devices are active. Specific instructions can be found on the options or help page of the browser itself. Disabling technical cookies, however, may affect the full and/or proper functioning of several sites, including this site. As a rule, the browsers used today: - offer a 'Do not track' option, which is supported by some (but not all) websites. In this way, some websites may no longer collect certain browsing data; - offer the option of anonymous or incognito browsing: in this way, no data will be collected in the browser and no browsing history will be saved, but browsing data will still be collected by the operator of the website visited; - allow you to delete all or part of the stored cookies, but on the next visit to a website, they will normally be installed if this option is not blocked. We provide links to the support pages of the most widely used browsers (with instructions on how to disable cookies on those browsers): - Firefox (https://support.mozilla.org/it/kb/Attivare_e_disattivare_i_cookie) - Internet Explorer (http://windows.microsoft.com/it-it/internet-explorer/delete-manage- cookies#ie=ie-11) - Safari (iOS) (https://support.apple.com/it-it/HT201265 ) - Chrome (desktop) (https://support.google.com/chrome/answer/95647?hl=it) - Chrome (Android and iOS) (https://support.google.com/chrome/answer/2392971?hl=it) Third-party cookies: third-party cookies can be disabled either in the manner described above or by referring to each third party (by following the links indicated in the previous paragraph). Online tools: please note that from http://www.youronlinechoices.com/ it/ it is possible not only to acquire further information on cookies, but also to check the installation of numerous cookies on your browser/device and, where supported, also to disable them.

6. data retention period

The data provided will be retained for the time prescribed by law and, in any case, for the time strictly necessary to carry out the activities for which they were collected (for example, the data communicated via the 'Leave a message' form will be deleted after processing the relevant request) and/or until the consent given for the purposes referred to in Article 2, paragraph 2 is revoked. The personal data collected will in any case be stored for no longer than twenty-four months for the marketing purposes referred to in Art. 2, paragraph 2 (subject to any amendments and/or additions to the reference legislation on the protection of personal data that will be expressly notified to you).

7. categories of recipients of personal data

For the purposes set out in art. 2, where necessary only with prior consent, the data may be communicated to third parties whose collaboration Brand Trotter S.r.l. may and/or must avail itself of for the performance of the services offered. The data acquired via the web, or in any case deriving from web services, may be communicated to the technological and instrumental partners that the Data Controller uses to provide the services requested by users/visitors, always in compliance with the purposes indicated in art. 2. The data collected for the purposes set out above may also be communicated to associated companies or companies belonging to the same corporate group as the Data Controller and to subjects authorised to do so by provisions of law and European regulations. A list of the subjects to whom the Controller communicates the personal data collected for the aforesaid purposes is available to the interested parties at the Controller's premises and may be obtained upon written request sent to the Controller.

8. rights of the data subjects

The data subject is the natural person, identified or identifiable, to whom the personal data being processed refer. We inform you that, as a data subject, you have the right to request at any time from the Data Controller what data is being processed concerning you, how it was collected, in what manner and for what purpose it is being processed (right of access) in order to verify its correctness and to check the lawfulness of the processing carried out by the Data Controller. He/she may also exercise all the rights recognised by current national and European legislation on the protection of personal data (by Legislative Decree 196/2003 and EU Reg. no. 2016/679 and subsequent amendments and additions): in particular, he/she may at any time request the correction and updating of incorrect or inaccurate data, the restriction of processing carried out and the cancellation of the same (right to be forgotten), as well as lodge a complaint with the Data Protection Authority. Lastly, with regard to personal data processed by automated means, you have the right to receive the data concerning you in a structured and commonly used format and to transmit them, if necessary, to another data controller (right to data portability). Any request regarding the processing of your personal data and any communication relating to the exercise of your rights may be addressed to the Data Controller using the appropriate 'Contact Us' form on the website http:// www.brandtrotter.net/ or by sending a communication by e-mail to the address: info@brandtrotter.net; or by post to Brand Trotter S.r.l, Via Francesco Dall'Ongaro, 24 Milano 20133 (MI) Italy.

9. right of revocation and objection

Each data subject is also recognised the right to revoke the consent given at any time, without prejudice to the lawfulness of the processing carried out by the Controller prior to such revocation. The data subject is also recognised at all times as having the right to object to the processing of his/her data if it is carried out for the purposes of direct marketing as set out in Section 2(2); in this case, once the notice of withdrawal of consent has been received, his/her data shall no longer be processed for such purposes (right to object).

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