This policy is provided by Womo S.r.l., with its registered office in Bergamo, Italy at via Giorgio e Guido Paglia n. 1/D, in its capacity as Data Controller (hereinafter referred to as “Womo”), and describes the methods of collecting and using the user’s personal data pursuant to the relevant legislation governing the processing of personal data as may be amended, replaced or re-enacted from time to time, including the Italian Privacy Code (Legislative Decree n. 196/2003) (“Data Protection Legislation”).
The processing of personal data will be carried out based on the principles of necessity, correctness, lawfulness, proportionality and transparency. Where necessary, in relation to any specific use or processing of Personal Data, the user’s prior consent will be requested.
This policy which, together with the General Conditions of sale (available here) applies to the website store.womostore.com (the “Website”), sets out the basis on which any personal data Womo collects from the user, or that the user provides to Womo will be processed by Womo. Please read the following carefully to understand Womo’s views and practices regarding individual’s personal data and how Womo will treat it.
a) Types of Personal Data Processed
In general, the visit and consultation of the Website does not imply collection and processing of your personal data. The processing of users’ personal data when visiting and consulting the Website is limited to the so-named surfing data, namely the data whose transmission to the Website is implicit in the functioning of the systems in charge of the managing of the Website and in the communications protocols peculiar to the Internet. Surfing data are, for example, the IP addresses of the devices used to connect to the Website and other parameters relating to the user’s device and operating system.
Personal data voluntarily provided by the user
Womo will collect and process data voluntarily provided by the user upon interaction with the Website’s functionalities, for example when a user opens an account, subscribes to the newsletter, purchases products through the Website, participates to promotions and other initiatives carried out by Womo, requests information and/or sends feedback to Womo, etc.
Personal data that Womo collects and processes include name, and contact details such as street address, telephone number, e-mail address and further possible information of an optional nature provided by the user.
(b) Purposes and methods of processing
The user’s personal data will be processed for purposes related to providing requested services and fulfilling related contractual obligations including:
1. the purchase of online products; management of sales activities, after-sales services, return and guarantee management, the management of customer care activities, as well as of checking and examining suggestions, claims and disputes; the carrying out of activities prior to agreements; the fulfilment of contractual obligations; as well as the completion of administrative/accounting tasks. The legal basis for processing user’s personal data for those reasons is that it is necessary for the performance of a contract.
Womo will process the user’s personal data, after receiving the user’s specific consent, for the following purposes:
2. advertising, promotional and marketing activities, including the sending of newsletters and advertising material on products and services offered by Womo via e-mail, SMS, MMS, social network and, where Womo has the specific consent of the user to do so, the other companies in the Odissea Srl group or third parties);
3. profiling activities regarding your purchasing habits, in order to send offers that are in line with your interests, upon your consent.
The user will always have the opportunity to object, at any time and for free, to the processing of its personal data for the sending of promotional information and material; in each communication there will be a specific section in which are specified the conditions (easy to perform and free of charge) of revoking the consent.
Information and data that are required in order to proceed with the requested services are marked with an asterisk. If the user does not provide the information and data referred to above, WOMO will not be able to carry out the request.
Customer care service will be conducted by the Data Controller, who may even use the help of an outside company specifically appointed as responsible for the processing of personal data, as set out below.
Processing may be done manually or electronically.
c) Nature of the provision of data and consequences of any refusal to respond
The user’s provision of his/her personal data for the purposes outlined in point b.1) is strictly necessary in order for Womo to comply with its contractual obligation or to comply with applicable legislation. In the event of refusal to provide the required personal data, the above-mentioned activities may not be carried out.
The user’s provision of his/her personal data for the purposes outlined in point b.2) and b.3) is voluntary and denial of providing personal data in said circumstances will have no consequences on compliance by Womo with its contractual obligations and on the provision of the services, products or information requested as above specified.
d) Areas of communication of personal data
The user’s personal data may be communicated to responsible individuals appointed as Data Processors, of which the complete list is available at the registered office of the Data Controller, and/or to persons responsible for processing. After obtaining the user’s express consent, personal data may also be communicated, for marketing purposes, to other companies controlled by or affiliated with the Odissea S.r.l. Group (in its capacity as the holding company of Womo S.r.l.), a complete list of which can be requested from the Data Controller.
Womo will disclose user’s personal information to third parties:
• In the event that Womo sell or buy any business or assets, in which case Womo will disclose user’s personal data to the prospective seller or buyer of such business or assets.
• If Womo are under a duty to disclose or share the user’s personal data in order to comply with any legal or regulatory obligation or request.
o in order to enforce or apply the contract relating to any purchase by the user of Womo’s products and other agreements or to investigate potential breaches; or
o protect Womo’s rights, property or safety or of Womo’s customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Cookies are small text files sent to your device by the Website. Cookies are uploaded onto your device, thus allowing the Website to recognize you and store certain information concerning you, in order to permit or improve the service offered. The Website uses different types of cookies.
The use of session cookies (which are not persistently stored on the computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (made up of random numbers generated by the server), which are necessary in order to browse the website and its applications securely and efficiently.The session cookies used on the Website prevent the need to use other data-processing technologies that could potentially weaken the privacy of the user’s browsing, and they do not permit the acquisition of the user’s personal identifying information.
By using this Website, the user consents to the processing of his/her data by Google in the above-mentioned manners and for the above-mentioned purposes.
Session cookies are not used for the transmission of personal information, nor are other persistent cookies of any kind or user tracking systems used. In any case, it is possible to set an Internet browser so that it does not accept cookies by activating anonymous browsing, in which case no data shall be processed through these systems.
Functional cookies remain on the device, even after the user has exited the website, until the user deletes them or until they expire. The Website creates this type of cookie and stores them on the user’s device so that it can read them when the user visits the website again. This allows it, for example, to find the preferences the user may have set on the website also for future visits (e.g. wish lists).
Promotional cookies are used to collect information on the user’s browsing habits in order to display advertising messages that are most relevant to his/her interests. This means that Womo also use them to limit the number of times a user sees a specific advertisement: for Womo it means communicating in a more effective manner, for the user it means seeing less invasive advertisements and more of those that are closer to his/her preferences. While a user browses the Website, promotional cookies allow Womo to confirm that he/she is viewing Womo’s advertising messages and to show him/her promotional content that Womo thinks may be of interest to him/her, based on what he/she has already visited previously. While the user browses other websites, these cookies also allow for content he/she has recently viewed on the Womo website to be displayed for promotional purposes. This is in the legitimate interests of the user as it allows the user to view content on our Website which is of interest to that particular user. The Website exclusively use promotional cookies anonymously: Womo offers targeted advertisements, but Womo does not know who the user is. The promotional cookies Womo uses are persistent, even though they remain on the user’s device for a limited time. To learn how to delete or refuse promotional cookies, please view the last section of this page.
Refuse and block cookies
Most Internet browsers are initially set to accept cookies automatically. This means that the user has the option, at any time, to set his/her browser to accept all cookies, only some cookies, or to refuse them, preventing websites from using them. In addition, the user can usually set his/her browser preferences so that he/she is notified every time a cookie is stored on his/her computer. At the end of each browsing session, the user can also delete the stored cookies from his/her device’s hard drive. If a user wants to delete the cookies stored in the cookies folder of the browser, it should be noted that each browser has different procedures for managing settings.
By clicking the links below, the user can obtain specific instructions for some of the leading browsers.
Microsoft Windows Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
Google Chrome: https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies
Mozilla Firefox: http://support.mozilla.org/en-US/kb/Enabling%20and%20disabling%20cookies
Apple Safari: http://docs.info.apple.com/article.html?path=Safari/5.0/en/9277.html
If the user does not wish to receive cookies from Google Analytics, he/she can do so by visiting https://tools.google.com/dlpage/gaoptout/
If the user would like to learn more about cookies in general, he/she can visit www.allaboutcookies.org
If the user would like to learn more about behavioural advertising and online privacy, he/she can visit http://www.youronlinechoices.com
If the user would like to learn more about Google Analytics’ cookies, he/she can visit http://www.google.com/intl/it/analytics/privacyoverview.htm l
If the user would like to learn more about the Criteo cookies used by our websites, he/she can visit http://www.criteo.com/en/privacy-policy
Womo also uses other cookies, either owned by Womo itself or by third parties (Promotional cookies), to improve the user’s overall experience on its websites and to ensure that the information on its websites is relevant to the individual user. These cookies are managed by third-party companies such as TagMan, DoubleClick and AddThis. The user can always disable cookies on his/her browser by following the instructions provided above.
f) Individual’s Rights (Article 7 of the Italian Privacy Code)
Individual users have a number of rights under the Data Protection Legislation.
Users can exercise these rights at any time by contacting Womo at the address or e-mail indicated in point j) below. Where processing of user’s personal data is based on consent, the user can withdraw that consent at any time.
Users have the right, inter alia,:
• to ask Womo not to process user’s personal data for marketing purposes. Womo will inform the user (before collecting the user’s data) if Womo intends to use the user’s data for such purposes or if Womo intends to disclose Womo’s information to any third party for such purposes;
• to request from Womo access to personal information held about him/ her; to ask for the information Womo hold about him/ her to be rectified if it is inaccurate or incomplete;
• to ask Womo not to process his/ her personal data where it is processed on the basis of legitimate interests provided that there are no compelling reasons for that processing;
• to ask for data to be erased provided that the personal data is no longer necessary for the purposes for which it was collected, the user withdraws consent (if the legal basis for processing is consent), the user exercises his/ her right to object to certain types of processing, set out in this policy, and there are no overriding legitimate ground for processing, the data is unlawfully processed, the data needs to be erased to comply with a legal obligation or the data is children’s data and was collected in relation to an offer of information society services;
In order to guarantee the security and privacy of the personal data processed, users shall be required to prove their identity in order to exercise their right to access, modify, delete or oppose to their personal data.
g) Third Party Links
Womo’s Website may, from time to time, contain links to and from the websites of its partner networks, advertisers and affiliates. If a user follows a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that Womo does not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. User’s should check these policies before submitting any personal data to these websites or use these services.
Our Website may also, from time to time, contain links to other websites operated by Womo or its affiliates. Those websites may have their own privacy policies and the user is responsible for checking those privacy policies before accessing those websites and providing Womo or its affiliates with information via those websites.
h) Data Controller and Processors
The Data Controller is Womo S.r.l, with registered office in Via Giorgio e Guido Paglia 1/, 24122 Bergamo, e-mail: email@example.com. The Data Processor is ContactLab with registered office in via Natale Battaglia n. 12, Milan. A complete list of data processors can be found at Womo S.r.l,’s registered office.