This website (hereinafter the "Application") collects certain Personal Data of its Users.


Data Controller (hereinafter the "Data Controller")

Brumi srl

VAT number IT07822200155

Email address of the Owner: info@gioielleriagagliardi.it



Types of Data collected

Personal Data collected by this Application, either independently or through third parties, includes Personal Data: Cookies; Usage Data; First Name; Last Name; Country; Email; City.


Full details on each type of data collected are provided in the dedicated sections of this privacy policy or by means of specific information texts displayed before the data collection.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.

Unless otherwise specified, all Data required by this Application is mandatory. If you refuse to provide it, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain Data as optional, Users are free to refrain from communicating such Data, without affecting the availability of the Service or its operation.

Should Users have any doubts about which Data is mandatory, they are encouraged to contact the Data Controller.

Any use of Cookies - or other tracking tools - by this Application or by the owners of third party services used by this Application, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees to have the right to communicate or disseminate them, releasing the Owner from any responsibility towards third parties.


Methods and place of processing of the collected Data

Treatment modalities

The Owner adopts appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.

The processing is carried out by computer and/or telematic means, with organizational methods and logics strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting providers, computer companies, communication agencies) may have access to the Data also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.


Legal basis of the treatment

The Owner processes Personal Data relating to the User if one of the following conditions is met:

  • the User has given his/her consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, until the User objects ("opt-out") to such processing. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
  • the processing is necessary for the execution of a contract with the User and/or the execution of pre-contractual measures;
  • the processing is necessary to fulfil a legal obligation to which the Data Controller is subject;
  • the processing is necessary for the performance of a task in the public interest or for the exercise of public authority vested in the Data Controller;
  • the processing is necessary for the pursuit of the legitimate interest of the Owner or of third parties.
  • However, it is always possible to ask the Owner to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, provided for in a contract or necessary to conclude a contract.

Place

The Data are processed at the headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For further information, please contact the Owner.

The User's Personal Data may be transferred to a country other than that in which the User is located. For further information on the location of the processing, the User may refer to the section on details of the processing of Personal Data.

The User has the right to obtain information about the legal basis for the transfer of Data outside the European Union or to an international organisation governed by public international law or consisting of two or more countries.


Period of preservation

The Data are processed and stored for the time required for the purposes for which they were collected.


Therefore:

Personal Data collected for purposes related to the execution of a contract between the Data Controller and the User will be retained until the execution of such contract is completed.

Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User may obtain further information about the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.

When the processing is based on the User's consent, the Owner may retain the Personal Data for a longer period of time until such consent is revoked. In addition, the Data Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period Personal Data will be deleted. Therefore, at the end of this period the right of access, deletion, rectification and the right to portability of the Data may no longer be exercised.


Purposes of the Processing of Collected Data

User Data is collected to allow the Owner to provide its Services, as well as for the following purposes: Viewing content from external platforms, Interaction with social networks and external platforms, Contact the User, Statistics, Traffic optimization and distribution, Hosting and backend infrastructure and Tag Management.

To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant for each purpose, the User may refer to the relevant sections of this document.


Details on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • Mailing list or newsletter (this Website)

Upon registration to the mailing list or newsletter, the User's email address is automatically added to a list of contacts to which email messages containing information, including commercial and promotional information, relating to this Website may be sent. Your email address may also be added to this list as a result of your registration on this Website or after you make a purchase.

Personal Data collected: email and name.

  • Management of payments

Payment processing services allow this Website to process payments by credit card, bank transfer or other means. The data used for payment is acquired directly from the operator of the payment service requested without being processed in any way by this Website.

Some of these services may also allow the scheduled sending of messages to the User, such as emails containing invoices or payment notifications.

PayPal (Paypal)

PayPal is a payment service provided by PayPal Inc., which allows the User to make payments online.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of treatment: See the privacy policy of Paypal - Privacy Policy.


  • Protection from SPAM

This type of service analyzes the traffic of this Web Site, potentially containing Personal Data of the Users, in order to filter it from parts of traffic, messages and content recognized as SPAM.

Google reCAPTCHA (Google Inc.)

Google reCAPTCHA is a SPAM protection service provided by Google Inc.

The use of the reCAPTCHA system is subject to Google's privacy policy and terms of use.

Personal Data collected: Cookies and Usage Data.

Place of Processing: United States - Privacy Policy. Subject to the Privacy Shield.



  • Tag Management

This type of services is functional to the centralized management of tags or scripts used on this Application.

The use of such services involves the flow of User Data through them and, where appropriate, their retention.


  • Google Tag Manager (Google LLC)

Google Tag Manager is a tag management service provided by Google LLC.

Personal Data Collected: Cookies; Usage Data.


  • Hosting and backend infrastructure

This type of services has the function of hosting Data and files that allow this Application to work, allow its distribution and provide a ready-to-use infrastructure to deliver specific functionality of this Application.

Some of these services operate through servers located geographically in different locations, making it difficult to determine the exact location where Personal Data is stored.


  • Interaction with social networks and external platforms

This type of services allows interactions with social networks, or with other external platforms, directly from the pages of this Application.

The interactions and information acquired by this Application are in any case subject to the User's privacy settings for each social network.

This type of service may however collect traffic data for the pages where the service is installed, even when Users do not use it.

It is recommended to log out of the respective services to ensure that the data processed on this Application is not reconnected to the User's profile.


  • Like button and Facebook social widgets (Facebook, Inc.)

The "Like" button and Facebook social widgets are social network interaction services provided by Facebook, Inc.

Personal Data Collected: Cookies; Usage Data.

Place of Processing: USA - Privacy Policy.


  • Tweet button and social widgets of Twitter (Twitter, Inc.)

The Tweet button and social widgets of Twitter are services of interaction with the social network Twitter, provided by Twitter, Inc.

Personal Data Collected: Cookies; Usage Data.

Place of Processing: USA - Privacy Policy.


  • Pin it" button and social widgets of Pinterest

The "Pin it" button and social widgets of Pinterest are interaction services with the Pinterest platform, provided by Pinterest Inc.

Personal data collected: Cookies; Usage data.

Place of processing: USA - Privacy Policy.


  • Traffic optimization and distribution

This type of services allows this Application to distribute its contents through servers located in the territory and to optimize its performance.

The Personal Data processed depends on the characteristics and the way these services are implemented, which by their very nature filter communications between this Application and the User's browser.

Given the distributed nature of this system, it is difficult to determine the places where the contents, which may contain Personal Data of the User, are transferred.


  • Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to keep track of the User's behaviour.


  • Google Analytics with anonymized IP (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. ("Google"). Google uses the Personal Data collected for the purpose of tracking and analyzing the use of this Application, compiling reports and sharing it with other services developed by Google.

Google may use Personal Data to contextualize and personalize ads in its advertising network.

This integration of Google Analytics makes your IP address anonymous. Anonymisation works by shortening your IP address within the borders of European Union Member States or other countries that are parties to the Agreement on the European Economic Area. Only in exceptional cases, the IP address will be sent to Google's servers and shortened within the United States.

Personal data collected: Cookies; Usage data.

Place of processing: USA - Privacy Policy - Opt Out.


  • Monitoring Facebook Ads conversions (Facebook pixels) (Facebook, Inc.)

Facebook Ads (Facebook Pixels) Conversion Monitoring is a statistics service provided by Facebook, Inc. that links data from the Facebook ad network with the actions performed within this Application. Facebook Pixel monitors conversions that can be attributed to Facebook, Instagram and Audience Network ads.

Personal data collected: Cookies; Usage data.

Place of Processing: United States - Privacy Policy. Subject adhering to the Privacy Shield.


  • Display of content from external platforms

This type of services allows you to view content hosted on external platforms directly from the pages of this Application and to interact with them.

If a service of this type is installed, it is possible that, even if Users do not use the service, it will collect traffic data related to the pages where it is installed.


  • Google Maps Widgets (Google Inc.)

Google Maps is a map viewing service managed by Google Inc. that allows this Application to integrate such content within its pages.

Personal data collected: Cookies; Usage data.

Place of processing: USA - Privacy Policy.


  • YouTube Video Widgets (Google Inc.)

YouTube is a video content viewing service operated by Google Inc. that allows this Application to integrate such content within its pages.

Personal data collected: Cookies; Usage data.

Place of Processing: USA - Privacy Policy.


User Rights

Users may exercise certain rights with reference to the Data processed by the Owner.

In particular, the User has the right to:

  • revoke the consent at any time. The User may revoke the consent to the processing of his/her Personal Data previously expressed.
  • oppose the processing of his/her Data. The User may object to the processing of his/her Data when this is done on a legal basis other than consent. Further details on the right to object are indicated in the section below.
  • access to your Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
  • verify and request correction. The User may verify the correctness of his/her Data and request its updating or correction.
  • obtain the limitation of the treatment. When certain conditions are met, the User may request the limitation of the processing of his/her Data. In this case, the Data Controller will not process the Data for any other purpose than their storage.
  • obtain the deletion or removal of his/her Personal Data. When certain conditions are met, the User may request the deletion of his/her Data by the Data Controller.
  • receive your Data or have it transferred to another Data Controller. The User has the right to receive his or her Data in a structured, commonly used and readable format and, where technically feasible, to obtain its transfer without hindrance to another data controller. This provision is applicable when the Data are processed by automated tools and the processing is based on the User's consent, on a contract to which the User is a party or on contractual measures connected to it.
  • lodge a complaint. The User may lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Details of the right of objection

When Personal Data are processed in the public interest, in the exercise of public powers vested in the Owner or to pursue a legitimate interest of the Owner, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that, should their Data be processed for direct marketing purposes, they may object to the processing without giving any reasons. To find out if the Data Controller processes data for direct marketing purposes, Users may refer to the respective sections of this document.


How to exercise your rights

To exercise the User's rights, Users may address a request to the contact details of the Owner indicated in this document. Requests are deposited free of charge and processed by the Owner as soon as possible, in any case within one month.


Further information on the treatment

Defense in court

The User's Personal Data may be used by the Owner in court or in the preparatory stages for its possible establishment for the defense against abuse in the use of this Application or related Services by the User.

The User declares to be aware that the Owner may be obliged to disclose the Data by order of the public authorities.


Specific information

Upon your request, in addition to the information contained in this privacy policy, this Application may provide you with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.


System Log and Maintenance

For operational and maintenance purposes, this Application and any third party services used by it may collect system logs, i.e. files that record interactions and may also contain Personal Data, such as the User IP address.


Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Answer to "Do Not Track" requests

This Application does not support "Do Not Track" requests.

To find out whether any third party services you use support them, please consult their privacy policies.


Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Application and, if technically and legally feasible, by sending a notification to Users through one of the contact details in the Data Controller's possession. Therefore, please consult this page regularly, referring to the date of the last modification indicated at the bottom.


If the changes involve treatments whose legal basis is the consent, the Owner will re-collect the User's consent, if necessary.



Definitions and legal references

Personal Data (or Data)

Personal data is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.


Usage Data

This is the information automatically collected through this Application (also from third party applications integrated in this Application), including: the IP addresses or domain names of the computers used by the User connecting with this Application, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.. ) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the time spent on each page) and details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User's computer environment.


User

The individual using this Application which, unless otherwise specified, coincides with the Interested Party.


Interested Party

The natural person to whom the Personal Data refers.


Data Processor (or Manager)

The natural person, legal entity, public administration and any other body that processes personal data on behalf of the Owner, as set out in this privacy policy.


Data Controller (or Owner)

The natural or legal person, public authority, service or other body that, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.


This Application

The hardware or software tool through which Users' Personal Data is collected and processed.


Service

The Service provided by this Application as defined in the relevant terms (if any) on this site/application.


European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is understood to extend to all current member states of the European Union and the European Economic Area.


Cookie

Small portion of data stored inside the User's device.


Legal references

This privacy policy is drawn up on the basis of multiple legal systems, including Articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this Privacy Policy applies exclusively to this Application.


Last modification. January 2020