Statement on the processing of personal data (article 13 of Italian decree D.Lgs.196/2003)

In accordance with art. 13 of Italian Decree N. 196 dated 30 June 2003, the Italian data protection code (“Code”), ROBY & ROBY snc di Mascia Raffaela, Mascia Carmela e Fasolato Roberto, with headquarters in Via Sant'Anna 1 - 10017 Montanaro TO (“ROBY & ROBY”), is the data controller, as per art. 4 of the said Code, and as such provides users of the website (the “Site”) with the following information regarding the use of personal data.

a) Type and source of data processed

The personal data processed by ROBY & ROBY is gathered directly from the Site users when they sign up for the services offered (for example subscription to the newsletter or online shopping services). Simply browsing the Site, without signing up for any online services, may imply the acquisition of completely anonymous data. The Site does in fact use tracking systems and cookies to gather information about the way its web pages are used by the visitors. The tracking systems collect information (such as the type of browser used, whether visitors click on the ROBY & ROBY banner, the pages viewed, the nationality of the server used by the computer) in order to make browsing more efficient.
For further information on the cookies used by the ROBY & ROBY website, click here.

b) Data controller

The Data controller is ROBY & ROBY snc di Mascia Raffaela, Mascia Carmela e Fasolato Roberto with headquarters in Via Sant'Anna 1 - 10017 Montanaro TO

c) Purpose of processing

The personal data collected in the registration forms for services on the Site and/or any data collected while browsing the website, including any sensitive data of which ROBY & ROBY may come into possession through the client’s own initiative, related to specific operations or services requested by the client (for example to subscribe to the Newsletter), will be processed for the following purposes:
(i) fulfilling obligations required by laws, regulations, European standards, and the provision of the authorities and monitoring organizations;
(ii) managing and fulfilling pre-contractual and/or contractual relations with customers/users in Italy, in the European Union and beyond, by entering the data supplied into ROBY & ROBY’s electronic systems and those of its controlled/associated companies (hereafter, collectively “ROBY & ROBY”);
(iii) sending information and commercial promotions, also on the basis of the consumer choices and preferences expressed, by telephone, SMS, MMS and e-mail, regarding ROBY & ROBY’s range of products and services, as well as for market research, surveys and customized or statistical analyses. To this end, the information obtained from browsing on the ROBY & ROBY website and from the other services offered may be used and processed electronically.
In accordance with articles 24.1.b) and 43.1.b), of the Code, no specific consent is required for processing related to points (i) – (ii). Other than this, the interested party should mark the specific box on the registration form to express their consent to data processing (with the exception of sensitive data) for the purposes stated in point (iii).

d) Processing methods

With reference to the purposes stated in point c), the data processing, including the operations stated in the definition of “processing” laid down in article 4 of the Code (such as collection, recording, processing, extraction, comparison, communication and deletion), will take place using manual and automated instruments, for which ROBY & ROBY has taken suitable security measures in order to ensure the integrity and confidentiality of the data.

e) Compulsory/optional nature of data entry

Data is provided at the user’s discretion. However, failure to provide the data indicated in the registration form, or other personal data that may be required in order to initiate any contractual relations and provide the service requested, may make it impossible for ROBY & ROBY to initiate and/or continue the contractual relations, fully or in part, i.e., fulfil the request for the provision of the services.

f) Categories of parties to whom the data may be disclosed, or who may have access to it

Personal data may be disclosed to:
(i) other companies in the ROBY & ROBY (following entry of the data into the corporate IT system);
(ii) external companies that ROBY & ROBY may appoint for the management of contractual relations with clients, i.e., for its own organizational and business requirements, including those specializing in: (a) banking, financial and insurance services, including parties operating in the management of payment systems; (b) services for the acquisition, recording and processing of data; (c) activities of printing, conveyance, enveloping, transport and sorting of communications; (d) archiving services for documentation regarding contractual relations; (e) debt collection services; (f) IT services and management services for the ROBY & ROBY IT system and for the telecommunications networks (including e-mail); (g) firms or companies providing assistance and consultancy; (h) parties performing control, auditing and certification of ROBY & ROBY’s activities; (i) call centre services and agencies and/or agents appointed to promote the goods and services offered by ROBY & ROBY; (l) market analyses and communication services for the proposal of standard and personalized commercial offers. These parties will process the clients’ personal data as autonomous data controllers, i.e., they can have access to the data as external data processors where specifically nominated, in line with article 29 of the Code. Your personal data will also be accessible to employees and collaborators, including external collaborators, specifically appointed to process it (with selected access according to their function), belonging to services and central offices and/or to the sales network of ROBY & ROBY, who perform technical, support and control roles for the company. The list of external data processing companies, i.e., the specification of those operating in complete autonomy as separate data controllers, will be kept up to date by the ROBY & ROBY Privacy Office, and will be made available at the ROBY & ROBY registered offices.

g) Rights in accordance with Art. 7 of the Code

With reference to the processing of personal data, in accordance with article 7 of the Code, persons whose personal data is held have the right at any time to enquire as to the existence of this data, to be informed of its content and origin, to verify that it is correct or to request that it be updated, integrated or corrected.
In accordance with the same article, they also have the right to request that it be deleted or rendered anonymous, or that data processed in violation of the law be blocked, and in any case to oppose its processing for legitimate reasons.
Requests pursuant to article 7 of the Code should be addressed to ROBY & ROBY snc di Mascia Raffaela, Mascia Carmela e Fasolato Roberto – Data Privacy Office – Via Cesare Battisti 21 - 10017 Montanaro TO