Safe Riding is a website dedicated to electronic commerce (e-commerce), managed by the Tenuta Monte Magno Horses s.r.l. Company, Internal Revenue Code 09272480964, with Registered Office at 41 Corso Monforte, Milan.
The processing of Personal Data of the website’s users will be carried out in Italy and conducted in compliance with the applicable European regulations (in particular, with Regulation UE 2016/679 concerning the protection of natural persons as regards the processing of Personal Data and the free circulation of said data) and with Legislative Decree No. 196, dated June 2003, Code on the subject of Personal Data Protection (the “Privacy Code”).
1. THE POLICY
Tenuta Monte Magno Horses s.r.l., in qualità di Titolare e Gestore del Sito, si impegna a rispettare un principio di stretta necessità nel trattamento dei dati personali che possono identificare, anche indirettamente, l’utente. Per tale motivo, il Sito è configurato affinché l'uso dei dati personali sia ridotto al minimo necessario e in modo da escludere il trattamento quando le finalità perseguite nei singoli casi possono essere realizzate mediante l'uso di dati anonimi o mediante altre modalità, che consentono di identificare l'interessato solo in caso di necessità o su richiesta della pubblica autorità o delle forze di polizia.
2. WHO PROCESSES THE DATA, FOR WHAT PURPOSES AND WITH WHAT MODALITIES
Tenuta Monte Magno Horses s.r.l. is the Personal Data processing Controller for the Safe Riding site’s users, regarding management, conclusion and performance of the commercial transactions concerning the purchase of products through the same site.
Any further purposes for which Personal Data may be required and processed are specifically illustrated, each time, in the information text submitted to the user in the Site’s page where their conferment has been requested.
The Controller decides on the purposes and modalities of the data processing as well as on the instruments to be used in carrying this out, for what concerns the security profile as well.
For merely organisational and functional requirements, several external parties Responsible for the processing can be appointed, for purposes strictly connected with and relevant to the provision of services on the Site, including the sale of the products themselves.
In any case these Responsible parties are selected on the basis of their capacity, experience and reliability requisites, and on their being able to suitably guarantee full compliance with the ruling provisions on the subject of personal data processing, inclusive of the data security profile. The Responsible parties carry out the processing of the Site users’ Personal Data according to the specific instructions given by the Controller.
To obtain the complete list of the parties Responsible for the processing, also for the purposes of exercising the rights provided for by articles 7 of the Privacy Code and 15 of Reg. EU 2016/679, an e-mail should be sent to the following electronic mail address: firstname.lastname@example.org
In pursuing the aims stated above and to permit the purchasing of products on the Site, the Controller collects Personal Data (such as, for example, personal details, e-mail address, postal address, credit card and banking information, telephone number) by means of a specific order form provided on the Site.
Processing of Personal Data collected is mainly done by using IT technology and digital automated instruments, (and, in some instances, in hard-copy format as well, such as for example should this be necessary to prevent frauds on the Site), according to logics and procedures strictly correlated to the aims of the processing.
The data can also be processed without the aid of electronic equipment, i.e. manually; in any case the data are stored only for the time strictly functional to the attainment of the specific purpose pursued each time and in compliance with the regulations in force for the protection of personal data, including the security profile and the Obligations of Confidentiality.
Personal Data are processed in compliance with ruling provisions on the subject of security, in order to minimise the risk of destruction and loss, even accidental, of data, of unauthorised access, of processing that is disallowed or non-compliant with the purposes for which the information is collected, or of the illegal or incorrect use of the data themselves, with particular but not exclusive reference to Attachment B to the Privacy Code (Technical Discipline on the subject of minimum security measures). Furthermore, information systems and IT electronic programs are configured in such a way as to reduce the use of Personal and identifying Data to the minimum, using them only when necessary to the specific processing purpose pursued each time.
Personal Data are stored in a form that will allow identification of the user for the time strictly necessary to the purposes for which the information is collected and processed and, in any event, in compliance with the provisions of the applicable regulations. In order to guarantee that the Personal Data are always correct, updated, complete and pertinent, the interested parties are invited to report any modifications that might have intervened, to the following e-mail address: email@example.com
Personal Data can be provided voluntarily by the user while interacting with the Site functions and/or while requesting services offered by the Site itself.
With the consent of the user, which is free and optional, the Controller will be able to process the users’ data also for defining individual or group profiles (profiling) and for marketing purposes, i.e. to send to the user, also through newsletters, electronic mail (e-mail), sms and mms, information and updates on products, offers and/or other events and initiatives linked to the Site.
The user will always be entitled to oppose the processing of his Personal Data for the purpose of promotional information being sent via electronic mail; in every communication received there will be a specific section which will outline the modalities to be used in opposing the processing and to stop receiving promotional material and information.
The users’ Personal Data will in any case not be communicated to third parties for purposes not allowed by the law or without their express consent.
Personal Data may also be made available to third parties, as Responsible for or entrusted with the processing, for accessory purposes and correlated with the provision of the services requested by the user (for example, for transactions relative to purchases). For details on this aspect, please refer to what is described subsequently, in paragraph 4.
The users’ Personal Data could be communicated to the police force or to the judicial authority, where demanded, in compliance with the regulations in force.
Personal Data cannot be transferred to foreign countries, to countries that, by not belonging to the European Union, may not assure adequate levels of protection for persons. Should this be necessary for the attainment of the Controller’s purposes, we guarantee that Personal Data transfers to countries not belonging to the European Union and unable to assure adequate levels of protection, will only be done by prior stipulation of specific contracts, with suitable safeguarding clauses for the protection of user Personal Data, in compliance with the law and applicable regulations.
3. PLACE OF STORAGE OF THE PERSONAL DATA COLLECTED
Personal Data collected will be stored and processed by our employees through an electronic system managed by Weblink srl with allocated servers at IT.net, 1 Via Ortles - Milan.
4. TO WHOM PERSONAL DATA GET COMMUNICATED
The data can accessible to our in-house or external personnel entrusted with the processing inherent to the purposes specified above and to the eventual appointed person Responsible for the processing. The complete and updated list of the staff Responsible for the processing and of the individuals to whom the data are communicated, can be made available by prior request from the following electronic mail address: firstname.lastname@example.org
Personal Data can furthermore be communicated to other receivers of the data collected by Tenuta Monte Magno Horses s.r.l., who process the data autonomously, solely to fulfil the purchasing contract for products on the Site and on condition that said purpose is not incompatible with the purposes for which the data were collected and processed by the Controller and that, in any case, are in compliance with the provisions of the law in force on the matter.
The data will not be communicated, ceded or in any other way transferred to other third parties without the users having been preventively informed, and with their prior consent, when demanded by the law.
5. NON-CONFERMENT OF PERSONAL DATA AND CONSEQUENCES
Conferment of Personal Data by the user is necessary for the attainment of the purposes described above and for providing the services and functionalities required by the user himself. Some data could be indispensable to fulfil the obligations deriving from legal or regulatory provisions.
Any failure in conferring certain of the data needed, identified in the Site with character (*), could make it impossible for the products’ purchasing contract to be performed or for the legal and regulatory obligations to be correctly fulfilled. Failing to provide said data will therefore constitute, according to the various cases, a legitimate and justifiable reason to refuse performance of the purchasing contract for the products on the Site or the provision of the services through the Site.
The conferment of the data by the user for profiling and marketing purposes, instead, is free and optional; the eventual non-conferment of Personal Data by the user for profiling and marketing purposes will therefore be of no consequence.
6. SECURITY MEASURES
As far as the control and management of Tenuta Monte Magno Horses s.r.l. are concerned, we invite the users to ensure that their computers be equipped with suitable software devices for the protection of the network data transmission, both incoming and outgoing (like updated antivirus systems) and that the provider of Internet services has adopted suitable measures for the security of the data transmission on the network (as for example firewalls and anti-spamming filters).
7. RIGHT OF ACCESS TO THE DATA AND OTHER RIGHTS
At any given time, the user is entitled to exercise the rights granted to him by art. 7 of the Privacy Code and art. 15 of the Reg. (EU) 2016/679.
The user is always entitled to obtain confirmation on whether Personal Data concerning him exist or not, even if not yet recorded, and to obtain their communication in intelligible form.
The user is always entitled to obtain:
- the updating, rectification or integration of personal data;
- the cancellation, transformation in anonymous form or the blocking of Personal Data eventually processed in violation of the law, including those for which storage is unnecessary in relation to the purposes for which the data was collected or subsequently processed;
- the declaration that the operations as per the previous points were divulged, also as regards their content, to those to whom the data were communicated or disclosed, excepting in the case in which said fulfilment would prove to be impossible or would imply the deployment of means manifestly disproportionate in relation to the protected right.
In any case, the User is entitled to totally or partially oppose:
- for legitimate reasons, the processing of Personal Data concerning him, even though pertinent to the purpose of the collection;
- the processing of Personal Data that concern him for the purpose of sending advertising or direct marketing material or for conducting market or commercial communication research.
Tenuta Monte Magno Horses s.r.l. reminds its users that they can freely and at any given time exercise their rights, as long as within the legally permitted limits, with specific request made to electronic mailing address: email@example.com, to which due response will be given.
8. LINKS TO OTHER WEB SITES
Safe Riding contains hypertext connections (the “links”) to other third party websites, supplies links to other websites solely to make it easier for its users to carry out research and navigation and to facilitate Internet hypertext connections. Activation of the links does not imply any recommendation or notification by the Provider for access to and navigation on these websites, nor any guarantee concerning their contents, the services and/or goods provided by these and sold to Internet users.
The Controller of the processing and Site Operator neither checks nor carries out verification and/or monitoring operations on the websites of third parties whose links might appear on Safe Riding’s site.
We urge you therefore, to pay attention when access gets gained to these websites through the links present on Safe Riding, and to carefully read their conditions of use and the relevant regulations on privacy.
Should the user require further information on how Tenuta Monte Magno Horses s.r.l., as the Controller, processes his Personal Data, the user is invited to send a relevant e-mail at the following electronic mail address: firstname.lastname@example.org
In order to become acquainted with your rights and to be constantly updated on the standards concerning the protection of individuals in relation to the processing of personal data, we suggest visiting the website of the Guarantor for the protection of Personal Data at address www.garanteprivacy.it
10. APPLICABLE LAW
The legislation in force guarantees that the processing of Personal Data gets carried out in observance of fundamental rights and freedom, as well as of the dignity
When required by the applicable regulation, the Controller will obtain the user’s consent to the modifications applied.
INFORMATION NOTE FOR THE PROCESSING OF PERSONAL DATA FOR NEWSLETTER PURPOSES
This information note is provided pursuant to art. 13 of Leg. Dec. No. 196/2003 - Code on the subject of personal data protection, as well as articles 13 and 14 of the (EU) Regulations 2016/679 concerning the protection of natural persons as regards the processing of personal data and the free circulation thereof.
The newsletter is sent via electronic mail to those that expressly request it, by filling-in the form provided on this page, thus authorising Tenuta Monte Magno Horses s.r.l., in its position as the Controller, to the processing of their personal data.
Purpose of the processing
Personal data provided by users shall be used only for the purpose of sending newsletters and will never be revealed to third parties.
Procedures for data processing
Data collected are mainly processed through information technology tools.
The Data Controller adopts suitable security measures in order to prevent data loss, unlawful or incorrect uses and unauthorised accesses.
Compulsory / optional nature of the conferment of data
Conferment of the data is optional; refusing to provide the relevant data implies the impossibility of obtaining the newsletter service.
Data processing controller
The Processing Controller of the data collected is Tenuta Monte Magno Horses s.r.l., Internal Revenue Code 09272480964, with registered office at 41 Corso Monforte, Milan.
Processing of the data connected with the newsletter service is carried out by the Controller through the use of servers located at IT.net, 1 Via Ortles - Milan, and this is done by personnel specifically appointed to perform the processing.
Appointed staff to, and Controller Responsible for the processing
Should this be required for activities connected with maintenance of the website’s technological aspect, the data connected with the newsletter service must be processed by specifically appointed individuals and/or preventively appointed persons Responsible for the processing in compliance with article 29 of the Code on the subject of personal data protection, and art. 28 of Reg. (EU) 2016/679.
Rights of the data subjects (art. 7 of the Privacy Code; art. 15 of Reg. EU 2016/679)
The data subjects to which the personal data collected refer are entitled, at any time, to obtain confirmation of whether data concerning them exist or not, and to be made aware of their content and origin, verifying their correctness or demanding their integration and updating, or their rectification.
In compliance with the same article, furthermore they are entitled the demand that the data be deleted, transformed in an anonymous format, or that data processed in violation of the law be blocked, as well as to oppose in any case, for legitimate reasons, their processing.
Requests must be addressed to:
- via e-mail, to address: email@example.com;
- via fax: 0039 0331323282
Cancellation of the service
In order to not receive newsletters any longer, click on field "Unsubscribe from the Newsletter" provided in the footnote of every e-mail received from Safe Riding.