Cleto Munari Design Associati srl (hereinafter “Cleto Munari”) aims to inform you and all users of the website www.cletomunari.com (hereinafter “site”) of the policy adopted for the processing of Personal Data through the site, and to highlight our commitment and attention to safeguarding your privacy.
This statement is also provided pursuant to the General Data Protection Regulation (GDPR) (EU2016/679) and the Italian Privacy Code (DL 196/2003).
In accordance with the provisions of the GDPR, the processing operations will comply with the principles of lawfulness, fairness, transparency, purpose and retention limitation, data minimization, accuracy, integrity and confidentiality.
1. Data Owner and Controller
2. Types of Data collected and purposes of processing
According to the GDPR, Personal Data means any information relating to users that identifies them personally, either alone or in combination with other information.
When you visit this site, Cleto Munari only collects and stores Personal Data if you actively communicate it via multiple sources, email and other means.
Notwithstanding the above basic conditions, however, the server of the host automatically registers information about accesses to this site (Browsing or Usage Data).
Cleto Munari does not require, or collect, any sensitive personal information, that is, according to the provisions of the GDPR (Art. 9), Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, data concerning health or sexual orientation.
2.1. Browsing Data
This site collects non-sensitive Browsing Data by automatic means in order to enable and improve user navigation (e.g., IP address, date/time of the visit and its length, any referring URL, the pages visited on the site, the device used and other information). The processing of such information allows you to access the site and fully enjoy its features and services. Furthermore, Browsing Data may be used to verify that the site is functioning properly.
Browsing Data are stored only temporarily in compliance with the applicable law. In particular your IP address will be processed during the connection process so that Cleto Munari can make this site available. It is based on Art. 6 para. 1 lit. f) GDPR. The legitimate interest is in the stated purpose. Browsing Data could be also used to ascertain responsibility in case of hypothetical crimes against the site.
2.2. Data provided voluntarily
You have no contractual or legal obligation to provide Cleto Munari with Personal Data. So, apart from what is specified for Browsing Data, you are free to provide personal information according to the mentioned purposes.
The optional, explicit and voluntary submission of Personal Data through this site involves the subsequent acquisition of your provided data, necessary for the provision of the requested service. However, failure to provide them may make it impossible to complete the request.
You have the possibility to contact Cleto Munari at the email address provided on the site. To do this, you must provide Cleto Munari at least with your email address and any other information you may add in your message.
In order to be able to process and respond to your request, Cleto Munari must process this data. The legal basis is Art. 6 para. 1 lit. f) GDPR. Cleto Munari’s legitimate interest lies in the purpose just mentioned.
When you register for Cleto Munari’s newsletter, your email address and your permission is saved and is used exclusively for information purposes until you request to stop receiving the newsletter.
Cleto Munari uses Mailchimp for newsletter campaigns, the world’s biggest marketing automation platform, GDPR compliant. You can unsubscribe at any time contacting Cleto Munari,or using the link included in each newsletter email.
For further information, see Mailchimp Terms of Service and Privacy.
2.5. Online orders
When you place an order in Cleto Munari’s online shop, the site asks to provide personal information for the essential purpose of fulfilling purchase orders and comply with contractual obligations (e.g., name and surname, e-mail address, delivery address, etc.).
Such personal information is also essential for the Customer Service to assist you on enquiries and for any related necessity, before or after the sale (for instance, with respect to the order delivery status or on product returns).
2.6. Site registration
When you opt to register a customer account on this site, you are asked to submit personal information (e.g., name and surname or e-mail address) along with an access password. This information is mandatory to set up and log in to your account.
You may cancel your account on this site at any time by logging in and clicking delete link on the side menu, or sending a request to Cleto Munari’s email address. However access to reserved area will no longer be possible unless a new registration is submitted.
2.7. Payment methods
To complete the purchase of the products it is possible to pay online via Paypal. In this case, the Data you provide are processed directly by Paypal, the payment gateway that allows and handles the transaction.
3. Connection to third-party websites or platforms
This website may contain links to other third-party websites or platforms, such as social networks like Facebook, Twitter and Pinterest, in order to share its content.
Cleto Munari cannot control the usage of Cookies or other monitoring technologies of such websites to which this Policy does not apply, so Cleto Munari cannot be held responsible for their conduct with respect to Privacy Law. You are encouraged to read their privacy policies to verify how they collect and process personal information.
4. Legal basis of processing
The legal basis of the processing of Personal Data is art. 6 of the GDPR, if one of the following applies:
— the consent has been given for one or more specific purposes;
— provision of data is necessary for the performance of an agreement and/or for any pre-contractual obligations thereof;
— processing is necessary for compliance with a legal obligation;
— processing is related to a task that is carried out in the public interest or in the exercise of official authority;
— processing is necessary for the purposes of the legitimate interests.
5. Place of processing
Personal Data are processed at Cleto Munari’s operating offices in Italy and in any other places where the parties involved in the processing are located.
6. Communication and transfer of Data
Personal Data are processed by internal staff duly authorized to do so under their respective job duties. Whenever necessary and/or instrumental to the above-mentioned purposes, they may also be processed by third parties, appointed, if necessary, as Data Processors: companies and consultants firms providing assistance and/or consulting or performing related services on behalf of Cleto Munari, e.g. hosting, maintenance of IT systems, updating of the site.
Cleto Munari will not transfer any personal information outside the European Economic Area (EEA), unless you have explicitly authorized such transfer or the transfer of personal information outside the EEA is allowed by the GDPR on another legal basis.
Personal Data shall not under any circumstances be disseminated to unknown persons.
7. Processing methods and Security measures
Personal Data are processed with IT, automated and electronic tools and, in limited cases, by using documentary means, following organizational procedures and modes strictly related to the purposes indicated.
In accordance with the GDPR, Cleto Munari applies all industry standard security measures to protect your personal information as is available to us within the hosting services, software, plugins and addons used by this website. Specific security measures have been implemented to prevent data loss, unlawful or improper use, and unauthorized access, including data encryption (SSL/TLS) and a powerful firewall against common types of attacks, with protection from known security vulnerabilities, hacks and malware.
While Cleto Munari adopts primary security measures, at the same time it cannot exclude the safety risks that are naturally involved by online transmission of Data. You accept the inherent risks of providing personal information over the Internet and will not hold Cleto Munari responsible for any breach of security, unless this breach is due to negligence or willful default.
8. Retention of Personal Data
Personal Data collected by this site will be kept – for each type of data processed – only as long as it is needed to provide you with the required services or to meet legal obligations or for the minimum period prescribed by the law.
In order to determine the appropriate retention period for personal information collected and stored by this website under your consent, Cleto Munari will take into account multiple factors to ensure that personal information is not stored for longer than the necessary or appropriate period, including:
— the purpose for which we site holds personal information;
— legal and regulatory obligations in relation to that personal information;
— any specific request in relation to the deletion of personal information;
— legitimate business interests.
Cleto Munari will promptly delete or anonymize personal information that is no longer needed or retained according to the law.
9. Affected rights
Under the GDPR you are entitled to receive confirmation as to whether Cleto Munari holds any personal information about you.
If you would like to request to review, correct, update, suppress, restrict or delete Personal Data that you have previously provided, or if you would like to request to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact Cleto Munari by writing at info@cletomunari or visiting the Personal Data Management page. Cleto Munari will respond to your request consistent with applicable law.
In your request, please make clear what Personal Data you would like to have changed, whether you would like to have your Personal Data suppressed from the database or otherwise let know what limitations you would like to put on the use of your personal information.
In any case, you will always be entitled to file a complaint with the competent supervisory authority (the Italian Data Protection Authority) at www.garanteprivacy.it, pursuant to art. 77 of the GDPR, if you believe that the processing of your Data violates applicable law.
10. Additional information about Data collection and processing
More details concerning the collection or processing of Personal Data may be requested at any time at: email@example.com.