BV – SITE POLICY

Browsing Data
In the course of their normal operations, the IT systems and softwareprocedures for the functioning of this Site acquire some personal data, the transmission of which is implicit in the use of internet communication protocols. 
This information is not collected in order to be associated with identified data subjects, but given the nature of such data, may be used to identify Users if processed and combined with data held by third parties. 
This data category includes the IP addresses or domain names of computers of Users who visit the Site, 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 in reply, the numerical code indicating the status of the response from the server (successful, error, etc.) and other parameters relating to the operating system and the computer environment of the User. By monitoring User browsing habits on our Site, combined with the use of cookies, Bottega Verde can collect specific information: This is explained in the “COOKIE” section. 

Data Supplied Voluntarily by the User
The explicit and voluntary transmission of Users’ personal data on this Site entails its subsequent acquisition by Bottega Verde, which is required in order to respond to User requests. In this way, Bottega Verde becomes the Data Controller of the information provided. Personal data will be processed for commercial, direct selling, marketing and commercial, promotional and statistical information purposes, as well for analysing customer preferences, via both electronic and paper processing methods and for any communications to third parties for direct marketing purposes.

Users of www.bottegaverde.eu must provide their data, such as name, surname and email address, to register on the Site and to access the reserved "MyBV" area of the Site and receive sales support from Bottega Verde, for example assistance to verify/overcome any difficulties, including technical problems, that Users may have. With Users’ consent, the aforementioned data will also allow Bottega Verde to send their newsletters.

The provision of the personal data of the Data Subject (name, surname and full postal address) is required:

1. in order to allow Bottega Verde to meet its contractual obligations, in the event of a purchase order being made;
2. for post-sales support;
3. for participation in the Carta Fedeltà loyalty card programme, which is also found in Stores. After the related regulation is accepted, Bottega Verde s.r.l. issues the Data Subject with their personal loyalty card that can be used to get the prizes linked to this initiative via the points accrued.

Other data requested is optional (such as home telephone number, mobile number, etc.), yet if they are given they allow for the Data Subject to be contacted with service communications regarding their orders, for their satisfaction with the product to be surveyed, or, with their consent, for offers to be presented, which may also be based on their personal consumption preferences, product sales information and new arrivals from Bottega Verde, as well as promotions, also by way of automated marketing, carried out via ordinary post, SMS/MMS, calls to the home phone and/or mobile and also using the email address provided.

Following on from specific initiatives (for example, prize contests), Bottega Verde may request authorisation to publish the personal information and/or image of the Data Subject across various mediums for publicity. In these cases, specific authorisation and consent for the processing of the data provided is requested. 

The data of third parties
Users are given the option of sending purchased products to third parties within the area of the Site dedicated to purchasing Bottega Verde products. In this instance, Users are asked to provide the personal details and complete postal address of the recipient to whom the chosen products are to be sent. 
Bottega Verde uses this data solely to carry out the User’s request to send the package, without using it for any other means. 

Publicly available information
This Site offers chat rooms, virtual notice boards and newsgroups, etc. and therefore we would like to remind you that the information revealed will be collected. This information will be used in compliance with this Privacy Policy. Bottega Verde is not responsible for the use that third parties may make of the information revealed on our sites via the chat rooms, virtual notice boards and newsgroups, etc.
In regard to the use of our chat rooms or virtual notice boards, we advise against providing sensitive data that concerns the User or other subjects, including information on race, political, religious or philosophical opinions, membership to any political party, trade union and/or philosophical, political or trade association, including personal data that could reveal health status or sexual activities or preferences. In the event that sensitive data is provided, it will be deleted and/or made anonymous. 
Data storage and access
Personal data is also processed via the creation of a centralised database using IT and online tools. 
The database containing the personal data of Data Subjects can only be accessed by authorised persons. People specifically appointed, such as employees or other collaborators, may gain knowledge of the processed data required for or connected to sending advertising material and completing the order and it may also be seen by third-party suppliers of services strictly required for meeting contractual obligations, such as:

1. data entry, customisation and mailing companies;
2. call centres;
3. parcel delivery carriers;
4. companies that provide payment services;
5. operational centres of security service providers.

Each Appointee is given specific guidelines on data processing, instructions that the appointees are required to comply with in order to avoid disciplinary sanctions and/or legal proceedings. 
Bottega Verde s.r.l. confirms that no personal data communicated by the Data Subject is used for purposes other than those indicated in herein. 

General processing
Bottega Verde uses the data of its Users in compliance with the choices that the User freely made in giving their informed consent when the data was collected or afterwards.
Processing operations subject to consent, communication and dissemination of data.
Bottega Verde will only use User data with their express consent. Please note that User data is used – until otherwise indicated by the User – via remote communication techniques that permit individual communications to send advertising material, so as to carry out direct sales, market research or commercial communication. 
Similarly, and only with the express consent of the User, Bottega Verde may send the User personalised offers based on their shopping habits. 
The data may be communicated to companies in the following sectors: home and office furniture, textiles, clothing, cosmetics and wellness, floriculture, publishing, hobby products and general for marketing purposes. To this end, Bottega Verde requests specific consent from Data Subjects.
In regard to the applicability of the GDPR. The legal basis for processing consists in the obligations towards the Data Subject as part of the contractual purchase and sale agreement (“processing necessary for the fulfilment of a contract” – GDPR, Article 6, paragraph 1, lett. b)); for processing for direct marketing purposes, the legal basis consists in the legitimate interest of the company (“processing necessary to pursue a legitimate interest of the data controller” – GDPR, Article 6, paragraph 1, lett. f) and “Processing personal data may be considered legitimate interest for direct marketing purposes” considering Article 47); for all other processing that the Data Controller may conduct, the legal basis consists in the Data Subject’s consent (GDPR, Article 6, paragraph 1, lett. a)).
User data is never disseminated, with the exception of the information provided voluntarily by the User in the common areas of the Site which are publicly accessible. 
Bottega Verde ask that its Users refrain from providing special categories of personal data (e.g. sensitive data) on the Site and reserves the right to delete this data or make it anonymous, in accordance with the protection directives found in Article 9 of the GDPR 2017/679. Lastly, the data may be communicated to the public authorities in the presence of a legitimate order issued by the same and may be used to ascertain liability in the case of any cybercrimes that damage the Site.

This Site uses the possibility to send and later receive “cookies” or similar files from the internet browser used by Users. 
By accessing the homepage of the Bottega Verde Site, or other pages of the Site, Users can view the short cookie information banner and access this Privacy Policy and the Site Policy, as well as the specific Cookie Policy. By continuing to browse on our Site, Users are giving their consent to the use of cookies. Users can withdraw their consent to cookies by accessing the Cookie Policy.

1. collect anonymous statistical data on the percentage of emails delivered compared to those sent, the percentage read, the percentage of messages opened, the percentage sent to third parties and the number of clicks, etc.;
2. count the unique visitors to a web page or a service;
3. produce aggregate statistics on how our Site is functioning and on the services it contains;
4. improve the performance of the Site, also making User searches faster;
5. collect data on traffic and User interaction on the website to identify trends and assess our audience;
6. save information on User preferences and thus customise the Site depending on the specific interests of the User;
7. avoid that the same advertising messages are seen several times;
8. recognise the computer when the User returns and uses the Bottega Verde Site;
9. save the chosen products that have been previously added to the User’s cart;
10. assess satisfaction, also anonymously, of the services available on the Site, including advertising materials;
11. improve the User browsing experience by suggesting the best promotions and products based on their navigation;
12. with the consent – which can be withdrawn at any time – of Users registered in the “MyBV” section, identify and collect personal shopping preferences and subsequently record the monitored data for targeted offers and promotions.

Users can find the approach Bottega Verde s.r.l. takes to cookies in the specific Cookie Policy, to which reference should be made.

Link to Facebook’s social plug-ins. Facebook social plug-ins may be active on www.bottegaverde.eu in order to make the online shop more personal. Your browser will create a link with Facebook when you visit a page on the www.bottegaverde.eu Site. Following on from this link, information may be downloaded or sent from/to Facebook. Therefore, your visit to www.bottegaverde.eu may be traced, even if you are not actively using the aforementioned function. 

If you have a Facebook account, you can use this type of plug-in to share information with your friends. In any case, Bottega Verde has no influence on the content of the plug-ins and the transmission of information. 

Facebook provides detailed information on its website regarding the scope, type, purpose and use of your data. You will find more information on your rights and how to change the settings to protect your privacy here. 
Data policy of Facebook www.facebook.com/fbprivacy/

Bottega Verde is aware that the Site and its Services many interest a younger audience. Bottega Verde encourages parents to monitor the internet usage of their children to ensure the safe and filtered use of its content, also by using parental control tools. In addition to guaranteeing an online environment that is suitable for children, these tools can prevent the sharing of the personal data of children or teenagers who do not have their parents' consent.

Pursuant to Articles 15-22 of the GDPR, the Data Subject is entitled to:

1. access their personal data (Article 15 of the GDPR);
2. have incorrect personal data corrected (Article 16 of the GDPR);
3. have their personal data deleted without undue delay in accordance with the conditions set forth by Article 17 of the GDPR;
4. restrict processing in the presence of the conditions under Article 18 of the GDPR;
The data subject also has the right to:
5. oppose the processing of their personal data for direct marketing and profiling means at any time, insofar as it is connected to such direct marketing (Article 21 of the GDPR);
6. withdraw consent at any time – in the event that the processing has a legal basis for consent – without prejudice to the lawfulness of the processing based on the consent prior to the withdrawal;
7. the right of data portability, i.e. to receive their personal data provided by the Data Controller, in a structured, commonly used and machine-readable format, and to transfer it to another Data Controller, without impediment by the Data Controller that provided said data. In exercising their rights concerning data portability, the Data Subject is also entitled to obtain the direct transmission of personal data from one Data Controller to another, if technically feasible.

These rights can be exercised by the Data Subject at any time by writing to the Data Controller, Bottega Verde s.r.l., at its administrative offices on Via XXV Aprile 10, 13836 Cossato (Biella), Italy, for the attention of the Corporate Privacy Office, or by sending an email to ufficio.privacy@bottegaverde.com .
Pursuant to Article 77 of the GDPR, it is without prejudice to the right of the Data Subject to contact the Italian Data Protection Authority – in the manners specified – the details for which can be found on www.garanteprivacy.it