PRIVACY DECLARATION

 

WEBSITE PRIVACY POLICY

Regulation (EU) 679/2016 General Data Protection Regulation

 

   Hereby, Philipp Group S.r.l.s. intends to inform the users that visit the “www.caringcocktail.com” website (hereinafter, the “Website”) about the policy adopted in Personal Data Protection matters, by emphasising its commitment and attention paid in reference to the protection of privacy for the Website’s visitors. Please read our Privacy Policy carefully, which applies when you access the Website and simply decide to browse it by using our services without purchasing any product, and when you decide to make purchases.

Furthermore, if you have not already done so, please read the www.caringcocktail.com “Website’s Conditions of Use”, since they also enclose significant information on the security systems adopted by the Website.

Browsing the Website is free of charge and does not require any registration, except for some areas within which the user may freely and expressly provide us with some personal data in order to have access to specifically identified services. If the user intends to provide us with his/her personal data to access other services, the same shall be expressly informed, pursuant to Regulation (EU) 679/2016 General Data Protection Regulation (the “Regulation”), with an indication (for instance) of the purposes and the modalities in which Philipp Group S.r.l.s. uses the data, as well as his/her right to request, at any time, the deletion or update of the data. Pursuant to and for the purposes of Article 13 of Regulation (EU) 679/2016 General Data Protection Regulation Philipp Group S.r.l.s. Provides you with the following information.

 

 

1. Identity and contact details of the Data Controller

The www.caringcocktail.com website (hereinafter, the “Website”) is managed by Philipp Group S.r.l.s., with registered office in Via Jacopo dal Verme, 11, 20159, Milano (MI), Italy. Tax Code, VAT number and Milano Companies Register No. 09610670961, tel. +39 346 358 9930,

email: caringcocktail@email.it  (“CARING COCKTAIL”), in its capacity as Data Controller pursuant to the Regulation.

 

2. Types of personal data subject to processing

You do not have to register in order to access the Website. However, the Website includes sections that require registration or the use of a username and password, or services that require your personal data (e.g. to proceed with the online shop, to access the newsletter services, to contact us, etc.) [1]. 

With reference to the data relating to browsing on the Website, please also see point 6 below on the Profiling tools used by the Website. 

 

3. Purposes and legal basis of the processing

The data is collected and processed for purposes strictly connected with using the Website, its services and the online purchase of products. The purposes for using the data are specified in detail in the specific policies provided by the Website for all cases of data collection. Therefore, we kindly ask you to read the policies that provide, in each instance, the features of the processing that will be carried out by Caring Cocktail (e.g. for the subscription to the newsletter service, for access to “Caring Cocktail”, for sending requests through the “Contact us” section, etc.) or by the Caring Cocktail retail companies (e.g. for the online sale of Caring Cocktail branded products). In particular, your data will be processed in order to manage your orders and to guarantee the use of the Services (including post-sale services) requested through the Website, to fulfil the related statutory obligations, to manage our customers’ loyalty activities through Caring Cocktail, to reply to any of your requests, as well as, based on your consent, to start marketing activities and analysis of your preferences.

The processing of your data shall comply with the privacy provisions[2].

 

4.   Providing your personal data is optional 

The provision of your personal data is optional in general. Only in certain cases, failure to provide us with your personal data may result in the inability to access specific services and to satisfy your requests (e.g. registration - and the provision of your personal data, email, delivery address, credit/debit card data or banking details and telephone number - is necessary to proceed with the online purchasing of products); failure to provide such data may, therefore, make it impossible for Caring Cocktail to permit access to the Website’s services or to satisfy its users’ requests.

The data required in each instance is indicated in the data collection forms on the Website - marked with an asterisk (*) - and the consequences deriving from failure to provide such data are mentioned in the specific data policies on the data collection pages.

 

5. Data processing procedures and scope of communication

The data maybe processed both electronically and on paper (e.g. for the management of purchases on the Website). Caring Cocktail guarantees the lawful and accurate processing of the personal data provided through the Website, in full compliance with the applicable laws, and the utmost confidentiality of the data provided on your registration.

The data shall not be disclosed and shall be processed by staff expressly authorised to manage the Website of the Digital & E-Commerce.

Exclusively for organisational and operational purposes, we have appointed some service providers for the management of the Website, who act as external processing officers of users’ personal data for purposes strictly connected and related to the performance of the services provided. A complete list of external data processing officers may be requested at caringcocktail@email.it 

Finally, according to the services requested through the Website, the data may be communicated to companies that provide us with services[3] useful in the management of purchases.

 

6. Connection to other websites 

This policy is provided only for the www.caringcocktail.com website and not for other websites possibly visited by the user through links. Caring Cocktail shall not be deemed liable for the personal data provided by the users to external parties or to any websites connected to this Website.

 

7. “Profiling” and/or customisation tools

Caring Cocktail does not carry out any promotional and/or advertising communication activity without the user’s prior express consent thereto.

The Website uses “cookies”, both technical cookies (intended to facilitate browsing and using the Website), and profiling cookies (intended to analyse the users and their behaviour and preferences, and to provide them with customised advertising).

For a detailed explanation on the cookies used by the Website and the steps to follow in order to disable them, please read our Cookie Policy.

 

8. Place of data processing and transfers outside the European Union

The processing related to the services provided by the Website is carried out at the office of Philipp Group S.r.l.s. located in Via Jacopo dal Verme, 11, 20159, Milano (MI), Italy. The data collected and processed through the Website may be subject to transfer to non-European Union Countries that host Caring Cocktail stores, a list of which is published on our website, www.caringcocktail.com, or where our management-related Website service providers are established.

The applicable provisions establish that your specific consent is not necessary to transfer data to third party countries since the transfer is carried out based on the adoption of adequate guarantees pursuant to Articles 46 and 47 of the Regulation, such as the adoption of standard contract clauses approved by the European Commission as applied to the relations with the retail companies that manage the Caring Cocktail stores worldwide and with our service providers.

The transfer of your data to any third party country, where applicable, shall be compliant with the guarantees, measures and rights established under the Regulation. Through a simple request to the references indicated in paragraph j), you may receive further information about the transfer of your data and the guarantees regarding their protection, as well as about the means of obtaining a copy of such data or the place where they were made available.

 

9. Data storage duration

Your data will be processed for the duration prescribed in the specific disclosures provided on collecting such data [4].

As to the duration of storage of relevant data by means of profiling tools (e.g. cookies), please see our Cookie Policy.

 

10. Rights of the interested parties

By means of notice to be sent to Philipp Group S.r.l.s., Via Jacopo dal Verme, 11, 20159, Milano (MI), Italy, caringcocktail@email.it, you may, at any time, exercise your rights[5] under Articles 15 to 22 of the Regulation, which include the right to know what data we are processing, the procedures we are following and the purposes we are using them for, as well as the right to change the data you have provided us with or to delete it, to request us to limit the use of your data, to request us to receive or to transmit your data, without prejudice to your right to change (any of) your consents thereto. Moreover, you may always oppose that your data be processed, in particular, for purposes related to the marketing or analyses of your preferences.

 

11. Who you may file a complaint with

We hereby remind you that, in case you consider that the processing of your personal data infringes the regulatory provisions, you may file a complaint with the Authority for personal data protection (www.garanteprivacy.it), or with the Authority for personal data protection with jurisdiction in the country you reside habitually, work in or in the place where the alleged infringement took place.

 

12. The Data Protection Officer

The Data Protection Officer appointed by Philipp Group S.r.l.s. may be contacted at the email address: caringcocktail@email.it

                                                                                                                                                                                      

13. Applicable law

This Privacy Policy is governed by Regulation (EU) 679/2016, which ensures that the personal data processing be carried out in accordance with the fundamental rights and freedoms, as well as with the dignity of the interested party, with particular reference to the confidentiality, personal identity and to the right to personal data protection.

 

14. Review clause

Caring Cocktail reserves the right to review, amend or merely update, in whole or in part, at its sole discretion, in any way and/or at any time, without prior notice, this Privacy Policy, also in accordance with any statutory or regulatory amendments to personal data protection provisions. The amendments and updates of the Privacy Policy may be, as the case may require, notified to the users by means of (i) emails to users registered with the Website and/or (ii) published on the Website Home Page, and they shall be binding as of their publication and/or notification. Therefore, please visit this section regularly in order to check the latest publication and update of the Privacy Policy or check your email inbox.

The full text of Regulation (EU) 679/2016 may be accessed on the website of the Authority for the Personal Data Protection www.garanteprivacy.it.

 

Footnotes:

 

[1] Should Caring Cocktail collect information and personal data, it shall, in each instance, inform its users, in advance, about the purposes for which such data are requested and the modalities by which these data will be used. If necessary, Caring Cocktail will request the user’s specific consent to the use of the data. By mere way of example, the personal data that may be requested are the name and surname, the telephone number, the email address and other information that the user accepts to provide in order to use the Website services by filling in a specific registration form. Caring Cocktail will use the personal data collected online only for the purposes indicated on registration.

The data concerning the connection to, and the browsing of, the Website (such as the URI-Uniform Resource Identifier addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received as reply, the numerical code related to the reply status from the server (successfully completed, error, etc.) and other parameters related to the operating system used by the user’s device) are collected only for gathering anonymous statistical data on the use of the Website and for monitoring its correct operation; such data are deleted immediately after being processed. Such data may be employed to ascertain any liability in case of cyber-crimes against the Website: otherwise, the data shall be deleted as soon as the time needed to provide the services on Website elapses. 

 

 

[2] The processing of your data shall be carried out:

- pursuant to Article 6, paragraph 1, letters b) and c) of the Regulation in order to manage your orders and to guarantee the use of the Services (including post-sale services) requested through the Website, to fulfil the related statutory obligations, to manage our customers’ loyalty activities through Caring Cocktail, to satisfy any of your requests;

- in accordance with your consent, pursuant to Article 6, paragraph 1, letter a) of the Regulation, to carry out activities related to the marketing and analysis of your preferences.

In any case, the processing shall be performed in compliance with the applicable provisions - and the amendments and/or supplements thereto - issued by the Authority for the Personal Data Protection (which include Fidelity cards and guarantees for consumers. The data protection Authority’s rules for fidelity programmes of 24 February 2005 and the Guidelines for promotional activities and against spam of 4 July 2013, as well as the general decision on cookies Identification of the simplified procedures for the policy and acquisition of consent for the use of cookies of 8 May 2014).

 

[3] Your data will be disclosed to:

  1. payment management companies;

  2. product shipping and delivery companies;

  3. legal, tax and auditing experts.

 

 

[4] Your data collected through the “Contact us” section on the Website shall be processed for the time needed to correctly manage your request and shall be deleted afterwards.

Should you decide to create a customer account by registering with the Caring Cocktail section, your data will be processed for as long as your account is active. You may close your account at any time and your request will be managed immediately or, in case of a pending purchase order, immediately after the execution of the same. Should your account be inactive for three (3) years, Caring Cocktail will contact you to find out whether you wish to keep your account active or not. In case you decide to close your account, the latter will be closed, and your data will be deleted.

The data concerning the details of your purchases will, however, be processed for promotional analysis purposes for a maximum term of 7 years following the registration of the same (according to the authorisation issued by the Authority for the Personal Data Protection of 22 December 2015; afterwards, the data will be deleted or anonymised.

Your banking details will be safely stored for the time needed to confirm your order and the related payment, and they will be deleted afterwards. In the case of failure to pay, your data will be processed for the duration of the claim and, afterwards, for a period ranging from 3 to 5 years, according to the type of claim.

The data processed for sending you communications on Caring Cocktail branded products, news and events will be stored for three (3) years following the collection date or the date of your last contact with Caring Cocktail. Upon maturity of such period, Caring Cocktailwill contact you to find out whether you wish to continue receiving communications on Caring Cocktail products, services, offers, news and events. In the event you revoke your consent provided for marketing purposes, your data shall be promptly deleted.

 

[5] Articles 15 to 22 of the Regulation provide for specific rights, which include:

  • the right to obtain confirmation of whether or not your personal data are being processed;

  • the right to be granted access to your personal data and the information indicated by Article 15 of the Regulation;

  • the right to correct your inaccurate personal data without undue delay or to supplement your incomplete personal data;

  • the right to delete your personal data without undue delay;

  • the right to be granted restrictions on the processing of your personal data;

  • the right to be informed of any corrections or deletion or restrictions concerning the processing carried out in relation to your personal data;

  • the right to receive your personal data on an automatic device in a structured, ordinary and legible format;

  • the right to oppose, at any time, for reasons related to a particular situation, the processing of your personal data.

You have the right to revoke, at any time without prejudice, any consents provided for processing and to oppose our analysis-related activities.

Moreover, pursuant to Article 21 of the Regulation, you shall be entitled, at any time, to oppose, for reasons related to your particular situation, the processing of your personal data carried out to pursue the legitimate interest of the Data Controller pursuant to Article 6, paragraph 1, letter f of the Regulation.

 

 

ONLINE STORE PRIVACY POLICY

Article 13 of Regulation (EU) 679/2016 General Data Protection Regulation

 

a) Who processes your personal data:

Philipp Group S.r.l.s., with registered office in Via Jacopo dal Verme, 11, 20159, Milano (MI), Italy. Tax Code, VAT number and Milano Companies Register No. 09610670961, tel. +39 346 358 9930, email: caringcocktail@email.it, which deals with the sale of the Caring Cocktail branded products in your country, is the company that, in its capacity as Data Controller, collects and processes your personal data, pursuant to Regulation (EU) 679/2016 General Data Protection Regulation (the “Regulation”).

 

b) Why we process your personal data:

The data you provide us with by completing your purchase order on the www.caringcocktail.com website is required for:

  1. completing the sale of the products selected by you and for fulfilling the agreement signed with you, as well as for exercising our related rights, even in Court;

  2. fulfilling the statutory obligations, the regulation and the Community provisions regarding your purchase (e.g. in tax, accounting, anti-money laundering, anti-fraud matters);

  3. managing the services related to your purchase at the post-sale stage (e.g. Customers Service).

The legal reference for the processing of your data will be the execution of the sale agreement signed with you and its related services, as well as of the fulfilment of the related statutory obligations pursuant to Article 6, paragraph 1, letters b) and c) of the Regulation.

 

c) Your consent:

The processing of your data will be performed without the need for your consent according to Article 6, paragraph 1, letters b) and c) of the Regulation.

 

d) All data requested are necessary:

Please provide us with all the data required as “compulsory” (*), since it is necessary for the management of your purchases and related services (e.g. delivery); in case of missing or incomplete compilation, your purchases cannot be completed. Failure to compile the data indicated as “optional” will have no consequences.

Should you provide us with data of third parties (e.g. your relatives, other customers or potential customers), make sure that said third parties have been informed and have consented to the use of their data in accordance with the provisions under this policy.

 

e) How we process your data:

Your data will be processed mainly electronically in order to manage your purchases.

Your data will be processed pursuant to the applicable laws and, in any case, in a manner that guarantees their protection and confidentiality and prevents unauthorised disclosure, use, alteration or deletion thereof.

 

f) Duration of your personal data’s storage:

Your data will be processed for the time necessary to manage your purchases and related services (e.g. Customers Service), as well as - limited to the necessary data - for the time required to fulfil the statutory tax and accounting obligations; subsequently, the data will be deleted or anonymised.

 

g) Who processes your personal data:

Your personal data will not be disclosed. In order to manage your purchases, your data will be made known (within their respective roles) to the people authorised to process it in the CRM, Digital and E-commerce, Finance and Legal Departments of Philipp Group S.r.l.s., as well as, in case you choose to pick up your purchase at the store, to the appointed sales staff. Moreover, your data may be made known to companies that provide us with services[1] useful to manage your purchases and related services.

 

h) Your data is transferred outside the European Union:

In order to allow us to correctly manage your purchases and related services, your personal data

may be subject to transfer to countries outside the European Union that host Caring Cocktail stores, the list of which is published on our website www.caringcocktail.com or to countries where our sales related service providers are established.

The applicable provisions establish that your specific consent is not required to transfer data to third party countries since the transfer is carried out based on the adoption of adequate guarantees pursuant to Articles 46 and 47 of the Regulation, such as the adoption of standard contract clauses approved by the European Commission as applied to the relations with the retail companies that manage the Caring Cocktail stores worldwide and with our service providers.

The transfer of your data to any other third party country, where applicable, shall be compliant with the guarantees, measures and rights established under the Regulation. Through a simple request to the references indicated in paragraph j), you may receive further information about the transfer of your data and the guarantees regarding their protection, as well as about the means for obtaining a copy of such data or the place where they were made available.

  1. Your rights:

By means of notice to be sent to the internal Officer of the CRM Department, email caringcocktail@email.it, Philipp Group S.r.l.s., Via Jacopo dal Verme, 11, 20159, Milano (MI), Italy, you may, at any time, exercise your rights [2] under the Articles from 15 to 22 of the Regulation, which include the right to know what data we are processing, the procedures we are following and the purposes we are using them for, as well as the right to change the data you have provided us with or to delete it, to request us to limit the use of your data, to request to receive or to transfer your data to another data controller.

 

j) Who you can file a complaint with:

We hereby remind you that, in case you consider that the processing of your personal data infringes the regulatory provisions, you may file a complaint with the Authority for personal data protection (www.garanteprivacy.it), or with the Authority for personal data protection with jurisdiction in the country you reside habitually, work in, or in the place where the alleged infringement took place.

 

Footnotes

[1] Your data will be made known, in their capacity as External Processing Officers, to Philipp Group S.r.l.s., with registered office in Via Jacopo dal Verme, 11, 20159, Milano (MI), Italy. Tax Code, VAT number and Milano Companies Register No. 09610670961, which manages the website www.caringcocktail.com and the “Customers Service”, also with the use of external service providers;

Your data will be communicated to:

  1. payment management companies;

  2. product shipping and delivery companies;

  3. legal, tax and auditing experts.

 

[2] Articles from 15 to 22 of the Regulation provide for specific rights, which include:

  • the right to obtain confirmation of whether or not your personal data is being processed;

  • the right to be granted access to your personal data and the information indicated by Article 15 of the Regulation;

  • the right to correct your inaccurate personal data without undue delay or to supplement your incomplete personal data;

  • the right to delete your personal data without undue delay;

  • the right to be granted restrictions on the processing of your personal data;

  • the right to be informed of any corrections or deletion or restrictions concerning the processing carried out in relation to your personal data;

  • the right to receive your personal data on an automatic device in a structured, ordinary and legible format;

  • the right to oppose, at any time, for reasons related to a particular situation, the processing of your personal data.

© 2019 Philipp Group S.r.l.s.  -  All rights reserved  -  Partita IVA: 09610670961

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