INFORMATION ON THE PROCESSING OF PERSONAL DATA OF USERS CONSULTING THE SHOP TRAWELL CO WEBSITE, PURSUANT TO ARTICLE 13 OF EU REGULATION 2016/679

1.     WHY THIS INFORMATION

Pursuant to EU Regulation 2016/679, this page describes the methods for processing the personal data of users who consult the TraWell Co website, which can be accessed electronically at the address: shop.trawellco.com. 

This information does not concern other sites, pages or online services that can be reached via hypertext links that may be published on the site but which refer to resources outside the TraWell Co domain.

2.     CONTACT DETAILS

Personal Data Controller

TraWell Co S.p.A., with registered office at Via Olona n. 183G, Cap. 21013, in Gallarate (VA) Italy, mail  privacy@trawellco.com, Tel +0331777154. 

Data Protection Officer

Dott.ssa Virginia G. Basiricò, Via Olona, 183/G – 21013 Gallarate (VA), mail  privacy@trawellco.com, Tel 0331777154.

3.     TYPE OF DATA PROCESSED

Navigation data

The computer systems and software procedures used to operate this site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This category of data includes IP addresses, the URI/URL (Uniform Resource Identifier/Locator) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment.

Data communicated by the user

The optional, explicit and voluntary sending of messages to the company’s contact addresses, private messages sent by users to the company’s profiles/pages on social media (where this is possible), as well as the completion and submission of contact forms on the site, entail the acquisition of the sender’s contact data necessary to respond, as well as all the personal data included in the communications.

When the user decides to purchase one or more of the services available, the data required to purchase and pay for the service is also requested.

Redirecting to external sites

The website may use social plug-ins. Social plug-ins are special tools that make it possible to incorporate social network functions directly into the website (e.g. the Facebook “like” function). All social plug-ins on the website are marked with the respective logo of the social network platform (e.g. Facebook, Google, Twitter, Linkedin). When you visit a page on our website and interact with the plug-in (e.g. by clicking the “Like” button) or leave a comment, the corresponding information is transmitted from your browser directly to the social networking platform and stored there.

For information on the purposes, type and manner of collection, processing, use and storage of personal data by the social network platform, as well as on how to exercise your rights, please consult the privacy policy adopted by the individual social network.

4.     PURPOSE AND LEGAL BASIS OF PROCESSING

Personal data are processed without the express consent of the data subject pursuant to Article 6 point b of EU Reg. no. 2016/679 (“Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the request of the data subject”) and Article 6 point f of EU Reg. no. 2016/679 (“Processing is necessary for the purposes of pursuing the legitimate interests of the Data Controller or of Third Parties”), for the following purposes:

(a) to allow users to contact Trawell and obtain information on the services offered.

b) to allow users to create their own account and purchase the services offered

c) to obtain statistical information on the use of the services in aggregate and anonymous form (most visited pages, number of visitors per time slot or per day, geographical areas of origin, etc.)

d) check the correct functioning of the services offered.

On the other hand, the data are processed exclusively with the express consent of the user pursuant to art. 1 point a of EU Reg. no. 2016/679 for the following purposes:

(e) to subscribe to the newsletter and receive promotional communications with marketing purposes.

5.     MANDATORY OR OPTIONAL NATURE OF PROCESSING

The provision of data is necessary in order to pursue the purposes indicated in point 4, letters a-d of this information notice. Any refusal to answer, at the time of collecting the information, may make it objectively impossible for the Data Controller to fulfil the purposes indicated in the aforementioned point. 

With regard to the purposes set forth in point 4, letter e, the provision of data is made only with the prior consent of the data subject, and failure to provide such information does not affect in any way the navigation of the site and the use of the services offered.

6.     RECIPIENTS

Personal data will not be “disclosed”, i.e. they will not be made known to unspecified persons; on the other hand, such data will be “communicated”, i.e. they will be made known to one or more specific persons, as explained below. In particular, they may be made accessible to

·       to employees and collaborators of the Data Controller, in their capacity as appointees and/or system administrators;

·       to third party companies such as: companies entrusted with the customer care service and management of social channels, IT companies for maintenance of the IT system, in their capacity as external data processors.

7.     DATA RETENTION

We inform you that the data you provide will be processed for the time necessary to fulfil the purposes set out in point 4 and further stored only for the period required to comply with legal obligations, provided that it is not necessary to store it further to defend or enforce a right or to comply with any further legal obligations or orders of the Authorities.

The data processed with the user’s consent will be processed for a maximum of two years and in any case until the user revokes his consent.

With regard to the retention period of cookies installed on Trawell’s website, please refer to the “Cookie Policy” paragraph of this statement.

8.     SOURCES

The data subject to processing may be acquired via the website.

9.     TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

Our customer care services are entrusted to a third party company, which acts as Data Processor. This company manages contact and call centre activities also from Moldova, on the basis of the guarantee agreements established by law. Where required, the call can be handled directly from Italy, avoiding the transfer of data to third countries.

10.  RIGHTS OF THE DATA SUBJECT

Data subjects have the right to obtain from TraWell Co, in the cases provided for, access to their personal data and the rectification or erasure of the same or the restriction of processing concerning them or to object to processing (Articles 15 et seq. of the Regulation). Requests may be sent to the addresses indicated in point 2.

Interested parties who believe that the processing of personal data relating to them carried out through this site is in breach of the provisions of the Regulation have the right to lodge a complaint with the Guarantor, as provided for by art. 77 of the Regulation itself, or to take legal action (art. 79 of the Regulation).

COOKIE POLICY

What are Cookies?

Cookies are packets of information sent by a web server (e.g. the website) to the user’s Internet browser, automatically stored on the computer and automatically sent back to the server each time the website is accessed.

By default, almost all web browsers are set to automatically accept cookies.

Typically, cookies can be installed

•       directly by the owner and/or manager of the website (so-called first-party cookies);

•       by managers outside the website visited by the user (so-called third-party cookies). Unless otherwise specified, it should be noted that these cookies fall under the direct and exclusive responsibility of the manager himself. Further information on privacy and their use can be found directly on the websites of the respective operators.

This website may use, also in combination with each other, the following types of cookies classified according to the indications of the Privacy Guarantor and the Opinions issued at European level by the Working Group ex art. 29 of the GDPR:

• Session: these are cookies that are not permanently stored on the user’s computer and are deleted when the browser is closed. They are strictly limited to the transmission of session identifiers needed to allow the safe and efficient exploration of the site, avoiding the use of other IT techniques that could potentially compromise the confidentiality of users’ browsing.
• Persistent: these are the cookies that remain stored on the computer’s hard drive until they expire or are deleted by users/visitors. Persistent cookies automatically recognise visitors accessing the site (or any other users using the same computer) each time they visit. Visitors can set their computer’s browser to accept/reject all cookies or to display a warning whenever a cookie is proposed, so that they can decide whether or not to accept it. Users may, however, change the default configuration and disable cookies (i.e. block them permanently) by setting the highest level of protection.
• Technical: these are the cookies used to authenticate, to use multimedia content such as flash players or to allow the choice of navigation language. It is therefore generally not necessary to obtain the user’s prior, informed consent. This also includes cookies used to statistically analyse access/visits to the site only if they are used exclusively for statistical purposes and by collecting information in aggregate form.
• Non-technical: these are all cookies used for profiling and marketing purposes. Their use on users’ terminals is forbidden unless they have been adequately informed beforehand and have given their valid opt-in consent. These types of cookies can, in turn, be grouped according to the functions they perform in:
• Analitycs: these are cookies used to collect and analyse statistical information on access/visits to the website. In some cases, associated with other information such as the credentials entered to access restricted areas (your email address and password), they can be used to profile the user (personal habits, sites visited, content downloaded, types of interaction carried out, etc.).
• Widgets: This category includes all those graphical components of a program’s user interface, the purpose of which is to facilitate user interaction with the program itself. For example, Facebook and Twitter cookies are widgets.
• Advertsing: This category includes cookies used to advertise on a site. Google, Tradedoubler fall into this category.
• Web beacons: This category includes code snippets that allow a website to transfer or collect information through the request for a graphic image. Websites may use them for various purposes, such as analysing the use of websites, monitoring and reporting on advertisements, and personalising advertisements and content.

What cookies are present on the Shop Trawell website?

TECHNICAL COOKIES THAT DO NOT REQUIRE CONSENT

This type of cookie is necessary to acquire statistical information in an anonymous and aggregate form relating to the user’s navigation of the Shop Trawell site pages. They are absolutely essential for the site to function properly and ensure the basic functionality and security features of the site anonymously.

ANALYTICAL COOKIES THAT DO NOT REQUIRE CONSENT

The site uses the following analytical cookies to check visitors’ interactions while guaranteeing anonymity