Privacy Policy

Privacy Policy for users of the website www.lecult1944milano.myshopify.com

Why this policy?

Following consultation of this website, your personal data may be processed.
On this page, we intend to describe the management methods we adopt for your data collected during your visit to this site.
This policy is provided pursuant to personal data protection regulations (Legislative Decree 196/03 and EU Regulation 2016/679 – GDPR) to all those who interact with the web services of Le Cult 1944 Milano, accessible electronically from the address www.lecult1944milano.myshopify.com

This policy applies only to this Website and not to other sites you may consult via links.

Data Controller

Le Cult 1944 Srl

Registered office: Via Melzi D'Eril 44 20154 Milan

Tax Code/VAT Number: 11412100965

Contact: infolecult@gmail.com

Personal data collected by www.lecult1944milano.myshopify.com

We only collect Personal Data about you if we have good reasons to do so. For example, to provide you with our services, to communicate with you, or to make our services better. We do this in 3 different ways: when you choose to provide it to us, automatically through our services, and automatically through third-party services.

Among the Personal Data we may collect when you decide to provide it to us, or automatically by us or through third parties, are: Cookies, Website usage data, name, email, and phone number at our sales point.

In the following sections of this Privacy Policy, we will provide you with complete details on each type of data collected. Specific information texts are then displayed on the site before the data collection itself.

As we wish to collect Personal Data only if we have good reasons to do so, you must consider that if you refuse to communicate certain Data, it may be impossible for this Website to provide you with the Service. Where Data is indicated as optional on the Website, you are free not to provide such Data without consequences for the availability or operation of the Service.
If you have any doubts about which Data is mandatory, we encourage you to contact the Controller indicated at the beginning of this document.

The possible use of Cookies – or other tracking tools – by this Website or by the owners of the third-party services used by this Website, unless otherwise specified, is for the purpose of providing the Service requested by the User, in addition to the further purposes described in this document.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Website and guarantees to have the right to communicate or disseminate them, releasing the Controller from any liability towards third parties.

Methods and place of processing of the collected Data

Processing methods

The Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data.
The processing is carried out using IT and/or telecommunication tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Controller, in some cases, other parties involved in the organization of this Website (administrative, commercial, marketing, legal personnel, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the Data, also appointed, if necessary, as Data Processors by the Controller. The updated list of Processors can always be requested from the Data Controller.

Legal basis for processing

The Controller processes Personal Data relating to the User if one of the following conditions exists:

• the User has given consent for one or more specific purposes; Note: in some jurisdictions, the Controller may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, until the User objects ("opt-out") to such processing. However, this is not applicable if the processing of Personal Data is governed by European data protection legislation;
• processing is necessary for the performance of a contract with the User and/or for the implementation of pre-contractual measures;
• processing is necessary to comply with a legal obligation to which the Controller is subject;
• processing is necessary for the performance of a task carried out in the public interest or for the exercise of official authority vested in the Controller;
• processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party.

It is always possible to ask the Controller to clarify the concrete legal basis of each processing and, in particular, to specify whether the processing is based on law, provided for by a contract or necessary to conclude a contract.

Place

The Data is processed at the Controller's operating offices and in any other place where the parties involved in the processing are located. For more information, please contact the Controller.
The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data.

The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization of public international law or constituted by two or more countries, such as the UN, as well as regarding the security measures adopted by the Controller to protect the Data.

If one of the transfers just described takes place, the User can refer to the respective sections of this document or ask for information from the Controller by contacting them using the details provided at the beginning.

Retention period

The Data is processed and stored for the time required by the purposes for which it was collected.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Controller and the User will be retained until the performance of such contract is completed.
• Personal Data collected for purposes attributable to the legitimate interest of the Controller will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.

When processing is based on the User's consent, the Controller may retain Personal Data for a longer period until such consent is revoked. In addition, the Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, Personal Data will be deleted. Therefore, upon expiration of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purpose of the Processing of Collected Data

The User's Data is collected to allow the Controller to provide its Services, as well as for the following purposes: Statistics, Contacting the User, Interaction with social networks and external platforms, Advertising, Displaying content from external platforms, SPAM protection, Traffic optimization and distribution, Address management and sending email messages, Payment management, Content commenting, Registration and authentication, Tag management, Location-based interactions, and Remarketing and behavioral targeting.

To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant for each purpose, the User can refer to the relevant sections of this document. 

Details on the processing of personal data

Personal data is collected for the following purposes and using the following services.

Interaction with social networks and external platforms

This type of service allows interaction with social networks, or with other external platforms, directly from the pages of this Website.
The interactions and information acquired by this Website are in any case subject to the User's privacy settings relating to each social network.
If a social network interaction service is installed, it is possible that, even if Users do not use the service, it collects traffic data relating to the pages on which it is installed. 

Facebook Like button and social widgets (Facebook, Inc.)

The Facebook "Like" button and social widgets are services for interacting with the Facebook social network, provided by Facebook, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy.

Instagram Like button and social widgets (Instagram, Inc.)

The Instagram "Like" button and social widgets are services for interacting with the Instagram social network, provided by Instagram, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy.

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior. 

Google Analytics (Google Inc.) 

Google Analytics is a web analytics service provided by Google Inc. ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google.
Google may use the Personal Data to contextualize and personalize the ads of its advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy – Opt Out.

Statistics collected directly (This Website) 

This Website uses an internal statistics system that does not involve third parties.

Personal Data collected: Cookies and Usage Data.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Website and to interact with them.
If a service of this type is installed, it is possible that, even if Users do not use the service, it collects traffic data relating to the pages on which it is installed.

Google Fonts (Google Inc.)

Google Fonts is a typeface visualization service managed by Google Inc. that allows this Website to integrate such content within its pages.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy.

User Rights

Users can exercise certain rights regarding the Data processed by the Controller.

In particular, the User has the right to:

• withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously expressed.
• object to the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below.
• access their Data. The User has the right to obtain information on the Data processed by the Controller, on certain aspects of the processing and to receive a copy of the processed Data.
• verify and request rectification. The User can verify the accuracy of their Data and request its update or correction.
• obtain the restriction of processing. When certain conditions apply, the User can request the restriction of the processing of their Data. In this case, the Controller will not process the Data for any purpose other than its storage.
• obtain the erasure or removal of their Personal Data. When certain conditions apply, the User can request the erasure of their Data by the Controller.
• receive their Data or have them transferred to another controller. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to obtain its transfer without hindrance to another controller. This provision is applicable when the Data is processed by automated means and the processing is based on the User's consent, on a contract to which the User is a party or on contractual measures related thereto.
• lodge a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of official authority vested in the Controller or for the legitimate interests pursued by the Controller, Users have the right to object to the processing on grounds relating to their particular situation.

Users are reminded that if their Data is processed for direct marketing purposes, they can object to the processing without providing any reason. To find out if the Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise rights

To exercise User rights, Users can address a request to the Controller's contact details indicated in this document. Requests are filed free of charge and processed by the Controller as quickly as possible, in any case within one month.

Cookie Policy

Definition and purpose

Cookies are small text files that websites visited by users send to their terminals, where they are stored and then retransmitted to the same sites on the next visit. "Third-party" cookies, on the other hand, are set by a website other than the one the user is visiting. This is because on each site there may be elements (images, maps, sounds, specific links to web pages of other domains, etc.) that reside on servers other than that of the visited site.

Cookies are used for different purposes: performing computer authentications, monitoring sessions, storing information on specific configurations regarding users who access the server, storing preferences, etc.

The provision of 8 May 2014 of the Garante per la protezione dei dati personali identifies two macro-categories of cookies: "technical" and "profiling".

"Technical" cookies 

These are cookies that serve to carry out navigation or to provide a service requested by the user. They are not used for further purposes and are normally installed directly by the website owner. Without the use of these cookies, some operations could not be carried out or would be more complex and/or less secure, such as home banking activities (viewing the account statement, transfers, bill payments, etc.), for which cookies, which allow the user to be identified and maintained within the session, are indispensable.

Technical Cookies can be further divided into:

• Navigation or session cookies, which guarantee normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access reserved areas);
• Analytics cookies, similar to technical cookies when used directly by the site manager to collect information, in aggregated form, on the number of users and how they visit the site itself;
• Functionality cookies, which allow the user to navigate according to a series of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided to the same.

"Profiling" cookies

These are cookies used to track the user's browsing on the network and create profiles on their tastes, habits, choices, etc. With these cookies, advertising messages in line with the preferences already expressed by the user during online browsing can be transmitted to the user's terminal.

Use of Cookies by this site 

This site uses technical, analytics and functionality navigation cookies.

Other types of Cookies or third-party tools that may use them

Some of the services listed below collect statistics in aggregated form and may not require the user's consent or may be managed directly by the Controller – depending on what is described – without the help of third parties.

If there are any third-party services among the tools indicated below, these could - in addition to what is specified and even without the Data Controller's knowledge - carry out user tracking activities. For detailed information, please consult the privacy policies of the listed services.

Cookie management and deletion

In addition to what is indicated in this document, the User can manage Cookie preferences directly within their browser and prevent – for example – third parties from installing them. Through browser preferences, it is also possible to delete Cookies installed in the past, including the Cookie in which consent to the installation of Cookies by this site may have been saved. It is important to note that by disabling all Cookies, the functioning of this site may be compromised. The User can find information on how to manage Cookies in their browser at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari, and Microsoft Windows Explorer.

In the case of services provided by third parties, the User can also exercise their right to object to tracking by informing themselves through the third party's privacy policy, through the opt-out link if explicitly provided, or by contacting the third party directly.

Without prejudice to the foregoing, the Data Controller informs that the User may avail themselves of Your Online Choices. Through this service, it is possible to manage the tracking preferences of most advertising tools. The Data Controller, therefore, advises Users to use this resource in addition to the information provided in this document.

Ownership of Cookie processing

Since the installation of Cookies and other tracking systems operated by third parties through the services used within this site cannot be technically controlled by the Data Controller, any specific reference to Cookies and tracking systems installed by third parties is to be considered indicative. For complete information, consult the privacy policy of any third-party services listed in this document.

Given the objective complexity linked to the identification of Cookie-based technologies and their very close integration with the functioning of the web, the User is invited to contact the Data Controller if they wish to receive any further information regarding the use of Cookies themselves and any uses thereof - for example, by third parties - carried out through this site.

Further information on processing

Legal Defense

The User's Personal Data may be used by the Data Controller in court or in the preparatory stages for its possible establishment for defense against abuses in the use of this Website or related Services by the User.
The User declares to be aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific disclaimers

Upon the User's request, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System log and maintenance

For needs related to operation and maintenance, this Website and any third-party services it uses may collect System Logs, i.e., files that record interactions and may also contain Personal Data, such as the User's IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

"Do Not Track" requests response

This Website does not support "Do Not Track" requests.
To find out if any third-party services used support them, the User is invited to consult their respective privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Website, as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details held by the Data Controller. Please, therefore, consult this page regularly, referring to the date of last modification indicated at the bottom.

Should the changes affect processing whose legal basis is consent, the Data Controller will collect the User's consent again, if necessary.

Definitions and legal references

Personal Data (or Data)

Any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable, constitutes personal data.

Usage Data

This is information collected automatically through this Website (also by third-party applications integrated into this Website), including: the IP addresses or domain names of the computers used by the User who connects with this Website, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g., the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User's IT environment.

User

The individual who uses this Website who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural person, legal entity, public administration, or any other entity that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Controller)

The natural or legal person, public authority, service, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of this Website. The Data Controller, unless otherwise specified, is the owner of this Website.

This Website (or this Application)

The hardware or software tool by which Users' Personal Data is collected and processed.

Service

The Service provided by this Website as defined in the relevant terms (if any) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is intended to extend to all current member states of the European Union and the European Economic Area.

Cookie

Small piece of data stored within the User's device.

Legal references

This privacy policy is drawn up on the basis of multiple legislative systems, including Articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy policy exclusively concerns this Website.

Last modified: May 23, 2018