Privacy Policy
The company TPMD S.r.l. Unipersonale (“The Private Markdown”) provides you with the following information on the processing of your personal data collected from the beginning of your relationship with The Private Markdown.
1. Data collection and purpose of processing
Your personal data provided to The Private Markdown by visiting our website or by filling in our online forms are processed for the following purposes: a) managing the sale of our products, sale and post-sale services, performance of any request you make through our website forms, e.g. administrative activities, accounting, returns, warranties, fraud prevention,; b) compliance with obligations imposed by laws, regulations or European legislation (including anti-money laundering laws) and to establish or defend a legal claim; c) research, market analysis, customer relationship management periodic sending of promotional materials and newsletter on products, services and promotion of the The Private Markdown world, including events organised by The Private Markdown or to which The Private Markdown participates as well as invitations to said events, also customized performed through traditional (mail and calls from operators) or automated (email, fax, text/SMS and MMS messaging) contact means as well as customised treatment in every The Private Markdown Boutique in Italy and abroad d) creation of group and individual profiles - analysis of your interests, preferences and purchase history, also based on the detailed purchases made in The Private Markdown Boutiques in Italy and abroad.
2. Provision of personal data
Providing your personal data for the purposes under letters 1. a) and b) above is necessary; refusal thereof would make it impossible for us to provide you with the requested products and services. For the purposes under letters 1. c) and d) above, providing of your data is optional; refusal thereof would have no consequences on the possibility to shop at our website, but we would not be able to inform you on the marketing initiatives and events above described or provide a service in line with your interests. If you provide us with personal information of third parties (e.g., your family members, your friends, other customer or prospects of The Private Markdown), you should make sure that said third parties are informed and authorized the use of their data as described in this privacy policy.
3. Processing methods
Your personal data are processed with and without the assistance of electronic means, in line with the applicable laws, including the data security aspects, and with logics and procedures based coherently upon the aforementioned purposes. Your data, in particular, will be processed through the CRM system managed by Temera S.r.l. on behalf of The Private Markdown, whose servers are located in Italy. Temera S.r.l. processes your data in its quality of Data Processor. Our online boutique uses industry-standard Secure Sockets Layer (SSL) encryption where your payment details are collected. This protects the confidentiality of your credit card information while it is transmitted over the internet. Our site features state-of-the-art security systems, offered by Ayden by the Tokenization feature, to encrypt and protect your payment details. Encryption makes your data illegible to The Private Markdown and to any third party, guaranteeing the total security of all transactions and of any card data you may wish to save in your account for future purchases.
4. Data entry into the CRM system
Your data entry into the CRM system is optional and occurred only if you provide your personal data for the purposes under letters 1. c) or d). Once inserted into the CRM system, your data may be read, amended and updated by the employees of the The Private Markdown in Italy and abroad, and by employees of TPMD s.r.l. unipersonale, expressly appointed as persons in charge of processing.
5. Data storage period
Your personal data processed for the purposes under letters 1. a) and b) will be stored for the time necessary to the execution of the contract and for the time required by applicable laws (e.g. tax, accounting, administrative laws). Your personal data processed for the purposes under letters 1. c) and d) will be stored for the time necessary to achieve the purpose for which they were collected and in line with the indication of the Italian Data Protection Authority and for no longer than, respectively, 24 and 12 months from the last purchase. You can withdraw your consent at any time, without prejudice of the processing carried out before your withdrawal. When the data storage time is expired that said data will be erased or made anonymous.
6. Data processing, communication and dissemination
Your personal data may be accessed by our employees and collaborators appointed as persons in charge of the processing. Your personal data may be also processed by the following third parties acting as data processors:
a) third parties that we use to provide technical and organizational services functional to the purposes above described, e.g. website managers, delivery companies, market analysis and research services, customer care services, information system management, etc.;
b) companies affiliated to The Private Markdown or under common control for all the purposes under point 1. c) above;
Your personal data may be communicated to the following parties which act as data controllers:
a) public entities and authorities for their institutional activities and as laws require us to do;
b) third parties in case of extraordinary operations (mergers, acquisitions, transfer of assets);
c) companies providing payments management;
d) professionals and associations offering for example legal, taxation or auditing services.
It is understood that, The Private Markdown does not share with other third parties your personal data for their own marketing activities and/or analysis of your interests. Some of the above listed subjects, e.g. companies affiliated to The Private Markdown or under common control, may be established abroad, outside of European Union, in countries not providing for an adequate level of data protection as your country.
In accordance with the GDPR the data may be transferred to non EU countries or countries not belonging to the European Economic Area, provided that they grant an adequate level of protection of the personal data (according to a specific decision by the European Commission). When data are transferred in counties that do not ensure an adequate level of data protection, the Company will adopt all the necessary measures, according to the GDPR, such as the conclusion of agreements based on the Standard Contractual Clauses of the European Commission. In any case, the data processing will take place in accordance with the provisions of the current rules and regulations.
The Private Markdown transfers data abroad after adoption of the precautions set forth by applicable privacy laws.
Your personal data will not be disseminated.
7. Data Controller and Data Processor
The TPMD s.r.l. unipersonale with registered offices at Via Boccaccio 50, 50133 Florence, Italy, email admin@theprivatemarkdown.com is the data Controller.
The Data Protection Officer, domiciled at the Controller's address, can be contacted at the following email address: admin@theprivatemarkdown.com.
The data Processor is Temera S.r.l., with registered offices at Via di Pianvallico 5, 50038 Scarperia e San Piero, Italy email address: info@temera.it.
8. Data subjects' rights
You can contact the data Controller or the data Processor at the above contact details to have the updated list of data processors and of third parties that we share with your personal data and to enforce at any time your rights. If you have provided your consent regarding certain types of processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. Pursuant to applicable data protection law you may have the right to lodge a complaint with the competent data protection supervisory authority and the right to:
Request access to your personal data: you may have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data. The access information includes – inter alia – the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom the personal data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access. You may have the right to obtain a copy of the personal data undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
Request rectification of your personal data: you may have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Request erasure of your personal data: under certain circumstances, you may have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.
Request restriction of processing of your personal data: under certain circumstances, you may have the right to obtain from us restriction of processing your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes. As the Company processes and uses your personal data primarily for purposes of carrying out the contractual employment relationship with you, we will in principle have a legitimate interest for the processing which will override your restriction request, unless the restriction request relates to marketing activities.
Request data portability: under certain circumstances, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those data to another entity without hindrance from us.
Object to the processing of your personal data: under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data. This Privacy Policy takes effect on the 1 of June, 2021.
9. Complete Privacy Notice - General Data Protection Regulation - "GDPR"
The company TPMD S.r.l. Unipersonale ("The Private Markdown") as data controller informs you of the following on the processing of your personal data pursuant to art. 13 of EU Regulation 2016/679 on the protection of personal data ("GDPR").
1. Purpose of processing and consequences in case of refusal to provide your personal data
a) Purposes necessary for registration to the site and / or for the performance of a requested service The Private Markdown processes the personal data you provide to allow you to register to the website, create your own account and take advantage of all the features of the website, including request information on our products and their availability, request assistance, be contacted, make purchases through our e-commerce. For these purposes, The Private Markdown processes your data such as title, name and surname, email, data on the place of residence (city, country), date of birth. For the execution of the e-commerce service, in addition, The Private Markdown also deals with the data relating to the shipping address (street, house number, apartment, floor, postal code), telephone number, payment details. For the purposes indicated above, giving your personal data is necessary and any refusal would prevent you from creating an account on our website or from using the service requested.
b) Further objectives: marketing - profiling - sharing of data with the The Private Markdown group With your consent, which is optional, The Private Markdown uses your personal data for marketing purposes, that is to send you promotional newsletters, commercial communications or advertising on events, promotional and commercial initiatives of The Private Markdown, market research and surveys on satisfaction, as well as for statistical analysis with anonymous data, organized in an aggregated form. The marketing activities are carried out by e-mail, newsletters, telephone calls by operator, text message, MMS, chat, instant messaging, social networks and traditional mail, including sending invitations to events organized by The Private Markdown or to which The Private Markdown takes part. You can at any time indicate the preferred mode of contact between those listed above and may object to receiving promotional communications through all or only some of the communication channels mentioned above.
With your consent, which is optional, The Private Markdown, in its boutiques and online through Internet websites or The Private Markdown's social media account, collects information related to your preferences, habits, lifestyle and details of purchases made to use them for the creation of group and individual profiles ("profiling") that are used to send you personalized communications and to conduct market research and statistical research with anonymous data, organized in aggregate form.
The personalized marketing activities are carried out by e-mail (newsletter), telephone, SMS, MMS, chat, instant messaging, social networks and traditional mail, including the invitation to events. You can at any time indicate the preferred mode of contact between those listed above and may object to receiving promotional communications through all or only some of the communication channels mentioned above.
With your consent, which is optional, The Private Markdown uses your personal data for purposes of sharing them with the companies of the The Private Markdown group, for carrying out marketing activities on their part, that is to send you promotional newsletters, commercial communications or advertising on the events, the promotional and commercial initiatives of the companies of the The Private Markdown group, market research and surveys of satisfaction, as well as for carrying out statistical analysis with anonymous data, organized in aggregate form. The marketing activities are carried out by e-mail, newsletters, telephone calls by operator, SMS, MMS, chat, instant messaging, social networks and traditional mail, including sending invitations to events organized by the companies of the The Private Markdown group or to companies of the The Private Markdown group participate. You can at any time indicate the preferred mode of contact between those listed above and may object to receiving promotional communications through all or only some of the communication channels mentioned above.
For the marketing, profiling and sharing of your data, The Private Markdown uses data such as title, name and surname, email, data relating to the place of residence (city, country), date of birth, data related to the interaction with our digital initiatives (Internet sites, social media), products searched, seen online, requested and / or purchased, participation in events organized by The Private Markdown or in which The Private Markdown takes part.
The provision of your personal data for the purposes of marketing, profiling and sharing of your data above is optional and any refusal will not have any consequence on your registration to the website.
2. Methods and legal bases of processing
The Private Markdown processes your personal data with and without the aid of electronic tools, based on the logic and procedures consistent with the purposes indicated below and in compliance with the GDPR, including the profiles of confidentiality and security. The data may be provided by you at the time of registration to our website, acquired during visits to our boutiques, provided during interaction with our digital initiatives (websites, social media), or during events organized by The Private Markdown or in which The Private Markdown takes part. In compliance with the GDPR, the personal data concerning you acquired by you or authorized third parties are used to update and correct the information previously collected.
The Private Markdown processes your personal data according to the following legal bases:
- your consent
- the legitimate interest of The Private Markdown for carrying out its business activities;
- fulfillment of obligations arising from a contract between you and The Private Markdown;
- fulfillment of legal obligations.
3. Communication of your personal data to third parties
Personal data are accessible to our staff duly authorized on the basis of need criteria and are disclosed to third parties in the following cases:
(i) when the communication is required by applicable laws and regulations with respect to third parties who are legitimate recipients of communications, such as authorities and public bodies for their respective institutional purposes;
(ii) communication to third parties in the case of extraordinary transactions (e.g. mergers, acquisitions, sale of companies, etc.).
Your personal data are also shared with our service providers, e.g. for services of a technical and organizational nature that are functional to the purposes indicated above as independent collaborators, also in an associated form - e.g. for shipments, the management of payments, companies specialized in market research and analysis of data, advertising companies, etc. We provide to these entities only the data necessary to perform the agreed services and they act as Data Processors, on the basis of the instructions received from The Private Markdown.
Finally, to provide you with the products and services you have requested (e.g. to guarantee the same benefits all over the world), other companies of the The Private Markdown Group as data controllers and on the basis of the applicable privacy law can access your personal data.
The Private Markdown does not communicate your data to third parties so that they can use it for their marketing or profiling purposes.
4. Transfers of personal data outside the European Union
Some of the aforementioned subjects may also be established outside the European Union, in countries that do not guarantee an adequate level of protection to personal data according to the standards established by the GDPR. The Private Markdown adopts the necessary precautions for a legitimate data transfer (e.g. through the implementation of the Standard Contractual Clauses approved by the European Commission). You can request information on the transfer of your personal data abroad at any time by contacting The Private Markdown or the Data Protection Officer of The Private Markdown at the addresses indicated below.
5. Retention of personal data
Personal data processed for registration purposes on our website and to reply to a specific request is processed for the time necessary to perform the requested service. Personal data processed in the context of e-commerce activities are kept for the time necessary to pursue the purpose for which they are collected and, in any case, in compliance with the applicable financial and commercial law requirements. For the purposes of marketing, profiling and sharing data with the companies of the The Private Markdown Group, the data is kept for the time strictly necessary for the fulfillment of said purposes, within the limits permitted by the GDPR. You can at any time request the deletion of data for these purposes and object to the processing of data for marketing purposes.
6. Data Controller and Data Protection Officer
The Data Controller is TPMD S.r.l. Unipersonale, with offices in Via Boccaccio 50, 50133 Firenze (FI). The Data Protection Officer is domiciled at the registered office of the Data Controller and available at the following email address: admin@theprivatemarkdown.com.
7. Your rights
You can contact The Private Markdown as Data Controller or the Data Protection Officer at the above addresses to get an updated list of our data processors (i.e. our service providers), of the subjects to whom your data are communicated and to exercise at any time the following rights as per art. 15 ss. of the GDPR; obtain confirmation of the existence or otherwise of your data, verify its content, origin, accuracy, request integration, updating, rectification, erasure, anonymity, request data portability, limitation of processing, opposition to processing for legitimate reasons, es. opposition to marketing activities, submit an application to the Supervisory Authority (the Italian Data Protection Authority).
1. Data collection and purpose of processing
Your personal data provided to The Private Markdown by visiting our website or by filling in our online forms are processed for the following purposes: a) managing the sale of our products, sale and post-sale services, performance of any request you make through our website forms, e.g. administrative activities, accounting, returns, warranties, fraud prevention,; b) compliance with obligations imposed by laws, regulations or European legislation (including anti-money laundering laws) and to establish or defend a legal claim; c) research, market analysis, customer relationship management periodic sending of promotional materials and newsletter on products, services and promotion of the The Private Markdown world, including events organised by The Private Markdown or to which The Private Markdown participates as well as invitations to said events, also customized performed through traditional (mail and calls from operators) or automated (email, fax, text/SMS and MMS messaging) contact means as well as customised treatment in every The Private Markdown Boutique in Italy and abroad d) creation of group and individual profiles - analysis of your interests, preferences and purchase history, also based on the detailed purchases made in The Private Markdown Boutiques in Italy and abroad.
2. Provision of personal data
Providing your personal data for the purposes under letters 1. a) and b) above is necessary; refusal thereof would make it impossible for us to provide you with the requested products and services. For the purposes under letters 1. c) and d) above, providing of your data is optional; refusal thereof would have no consequences on the possibility to shop at our website, but we would not be able to inform you on the marketing initiatives and events above described or provide a service in line with your interests. If you provide us with personal information of third parties (e.g., your family members, your friends, other customer or prospects of The Private Markdown), you should make sure that said third parties are informed and authorized the use of their data as described in this privacy policy.
3. Processing methods
Your personal data are processed with and without the assistance of electronic means, in line with the applicable laws, including the data security aspects, and with logics and procedures based coherently upon the aforementioned purposes. Your data, in particular, will be processed through the CRM system managed by Temera S.r.l. on behalf of The Private Markdown, whose servers are located in Italy. Temera S.r.l. processes your data in its quality of Data Processor. Our online boutique uses industry-standard Secure Sockets Layer (SSL) encryption where your payment details are collected. This protects the confidentiality of your credit card information while it is transmitted over the internet. Our site features state-of-the-art security systems, offered by Ayden by the Tokenization feature, to encrypt and protect your payment details. Encryption makes your data illegible to The Private Markdown and to any third party, guaranteeing the total security of all transactions and of any card data you may wish to save in your account for future purchases.
4. Data entry into the CRM system
Your data entry into the CRM system is optional and occurred only if you provide your personal data for the purposes under letters 1. c) or d). Once inserted into the CRM system, your data may be read, amended and updated by the employees of the The Private Markdown in Italy and abroad, and by employees of TPMD s.r.l. unipersonale, expressly appointed as persons in charge of processing.
5. Data storage period
Your personal data processed for the purposes under letters 1. a) and b) will be stored for the time necessary to the execution of the contract and for the time required by applicable laws (e.g. tax, accounting, administrative laws). Your personal data processed for the purposes under letters 1. c) and d) will be stored for the time necessary to achieve the purpose for which they were collected and in line with the indication of the Italian Data Protection Authority and for no longer than, respectively, 24 and 12 months from the last purchase. You can withdraw your consent at any time, without prejudice of the processing carried out before your withdrawal. When the data storage time is expired that said data will be erased or made anonymous.
6. Data processing, communication and dissemination
Your personal data may be accessed by our employees and collaborators appointed as persons in charge of the processing. Your personal data may be also processed by the following third parties acting as data processors:
a) third parties that we use to provide technical and organizational services functional to the purposes above described, e.g. website managers, delivery companies, market analysis and research services, customer care services, information system management, etc.;
b) companies affiliated to The Private Markdown or under common control for all the purposes under point 1. c) above;
Your personal data may be communicated to the following parties which act as data controllers:
a) public entities and authorities for their institutional activities and as laws require us to do;
b) third parties in case of extraordinary operations (mergers, acquisitions, transfer of assets);
c) companies providing payments management;
d) professionals and associations offering for example legal, taxation or auditing services.
It is understood that, The Private Markdown does not share with other third parties your personal data for their own marketing activities and/or analysis of your interests. Some of the above listed subjects, e.g. companies affiliated to The Private Markdown or under common control, may be established abroad, outside of European Union, in countries not providing for an adequate level of data protection as your country.
In accordance with the GDPR the data may be transferred to non EU countries or countries not belonging to the European Economic Area, provided that they grant an adequate level of protection of the personal data (according to a specific decision by the European Commission). When data are transferred in counties that do not ensure an adequate level of data protection, the Company will adopt all the necessary measures, according to the GDPR, such as the conclusion of agreements based on the Standard Contractual Clauses of the European Commission. In any case, the data processing will take place in accordance with the provisions of the current rules and regulations.
The Private Markdown transfers data abroad after adoption of the precautions set forth by applicable privacy laws.
Your personal data will not be disseminated.
7. Data Controller and Data Processor
The TPMD s.r.l. unipersonale with registered offices at Via Boccaccio 50, 50133 Florence, Italy, email admin@theprivatemarkdown.com is the data Controller.
The Data Protection Officer, domiciled at the Controller's address, can be contacted at the following email address: admin@theprivatemarkdown.com.
The data Processor is Temera S.r.l., with registered offices at Via di Pianvallico 5, 50038 Scarperia e San Piero, Italy email address: info@temera.it.
8. Data subjects' rights
You can contact the data Controller or the data Processor at the above contact details to have the updated list of data processors and of third parties that we share with your personal data and to enforce at any time your rights. If you have provided your consent regarding certain types of processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. Pursuant to applicable data protection law you may have the right to lodge a complaint with the competent data protection supervisory authority and the right to:
Request access to your personal data: you may have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data. The access information includes – inter alia – the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom the personal data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access. You may have the right to obtain a copy of the personal data undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
Request rectification of your personal data: you may have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Request erasure of your personal data: under certain circumstances, you may have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.
Request restriction of processing of your personal data: under certain circumstances, you may have the right to obtain from us restriction of processing your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes. As the Company processes and uses your personal data primarily for purposes of carrying out the contractual employment relationship with you, we will in principle have a legitimate interest for the processing which will override your restriction request, unless the restriction request relates to marketing activities.
Request data portability: under certain circumstances, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those data to another entity without hindrance from us.
Object to the processing of your personal data: under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data. This Privacy Policy takes effect on the 1 of June, 2021.
9. Complete Privacy Notice - General Data Protection Regulation - "GDPR"
The company TPMD S.r.l. Unipersonale ("The Private Markdown") as data controller informs you of the following on the processing of your personal data pursuant to art. 13 of EU Regulation 2016/679 on the protection of personal data ("GDPR").
1. Purpose of processing and consequences in case of refusal to provide your personal data
a) Purposes necessary for registration to the site and / or for the performance of a requested service The Private Markdown processes the personal data you provide to allow you to register to the website, create your own account and take advantage of all the features of the website, including request information on our products and their availability, request assistance, be contacted, make purchases through our e-commerce. For these purposes, The Private Markdown processes your data such as title, name and surname, email, data on the place of residence (city, country), date of birth. For the execution of the e-commerce service, in addition, The Private Markdown also deals with the data relating to the shipping address (street, house number, apartment, floor, postal code), telephone number, payment details. For the purposes indicated above, giving your personal data is necessary and any refusal would prevent you from creating an account on our website or from using the service requested.
b) Further objectives: marketing - profiling - sharing of data with the The Private Markdown group With your consent, which is optional, The Private Markdown uses your personal data for marketing purposes, that is to send you promotional newsletters, commercial communications or advertising on events, promotional and commercial initiatives of The Private Markdown, market research and surveys on satisfaction, as well as for statistical analysis with anonymous data, organized in an aggregated form. The marketing activities are carried out by e-mail, newsletters, telephone calls by operator, text message, MMS, chat, instant messaging, social networks and traditional mail, including sending invitations to events organized by The Private Markdown or to which The Private Markdown takes part. You can at any time indicate the preferred mode of contact between those listed above and may object to receiving promotional communications through all or only some of the communication channels mentioned above.
With your consent, which is optional, The Private Markdown, in its boutiques and online through Internet websites or The Private Markdown's social media account, collects information related to your preferences, habits, lifestyle and details of purchases made to use them for the creation of group and individual profiles ("profiling") that are used to send you personalized communications and to conduct market research and statistical research with anonymous data, organized in aggregate form.
The personalized marketing activities are carried out by e-mail (newsletter), telephone, SMS, MMS, chat, instant messaging, social networks and traditional mail, including the invitation to events. You can at any time indicate the preferred mode of contact between those listed above and may object to receiving promotional communications through all or only some of the communication channels mentioned above.
With your consent, which is optional, The Private Markdown uses your personal data for purposes of sharing them with the companies of the The Private Markdown group, for carrying out marketing activities on their part, that is to send you promotional newsletters, commercial communications or advertising on the events, the promotional and commercial initiatives of the companies of the The Private Markdown group, market research and surveys of satisfaction, as well as for carrying out statistical analysis with anonymous data, organized in aggregate form. The marketing activities are carried out by e-mail, newsletters, telephone calls by operator, SMS, MMS, chat, instant messaging, social networks and traditional mail, including sending invitations to events organized by the companies of the The Private Markdown group or to companies of the The Private Markdown group participate. You can at any time indicate the preferred mode of contact between those listed above and may object to receiving promotional communications through all or only some of the communication channels mentioned above.
For the marketing, profiling and sharing of your data, The Private Markdown uses data such as title, name and surname, email, data relating to the place of residence (city, country), date of birth, data related to the interaction with our digital initiatives (Internet sites, social media), products searched, seen online, requested and / or purchased, participation in events organized by The Private Markdown or in which The Private Markdown takes part.
The provision of your personal data for the purposes of marketing, profiling and sharing of your data above is optional and any refusal will not have any consequence on your registration to the website.
2. Methods and legal bases of processing
The Private Markdown processes your personal data with and without the aid of electronic tools, based on the logic and procedures consistent with the purposes indicated below and in compliance with the GDPR, including the profiles of confidentiality and security. The data may be provided by you at the time of registration to our website, acquired during visits to our boutiques, provided during interaction with our digital initiatives (websites, social media), or during events organized by The Private Markdown or in which The Private Markdown takes part. In compliance with the GDPR, the personal data concerning you acquired by you or authorized third parties are used to update and correct the information previously collected.
The Private Markdown processes your personal data according to the following legal bases:
- your consent
- the legitimate interest of The Private Markdown for carrying out its business activities;
- fulfillment of obligations arising from a contract between you and The Private Markdown;
- fulfillment of legal obligations.
3. Communication of your personal data to third parties
Personal data are accessible to our staff duly authorized on the basis of need criteria and are disclosed to third parties in the following cases:
(i) when the communication is required by applicable laws and regulations with respect to third parties who are legitimate recipients of communications, such as authorities and public bodies for their respective institutional purposes;
(ii) communication to third parties in the case of extraordinary transactions (e.g. mergers, acquisitions, sale of companies, etc.).
Your personal data are also shared with our service providers, e.g. for services of a technical and organizational nature that are functional to the purposes indicated above as independent collaborators, also in an associated form - e.g. for shipments, the management of payments, companies specialized in market research and analysis of data, advertising companies, etc. We provide to these entities only the data necessary to perform the agreed services and they act as Data Processors, on the basis of the instructions received from The Private Markdown.
Finally, to provide you with the products and services you have requested (e.g. to guarantee the same benefits all over the world), other companies of the The Private Markdown Group as data controllers and on the basis of the applicable privacy law can access your personal data.
The Private Markdown does not communicate your data to third parties so that they can use it for their marketing or profiling purposes.
4. Transfers of personal data outside the European Union
Some of the aforementioned subjects may also be established outside the European Union, in countries that do not guarantee an adequate level of protection to personal data according to the standards established by the GDPR. The Private Markdown adopts the necessary precautions for a legitimate data transfer (e.g. through the implementation of the Standard Contractual Clauses approved by the European Commission). You can request information on the transfer of your personal data abroad at any time by contacting The Private Markdown or the Data Protection Officer of The Private Markdown at the addresses indicated below.
5. Retention of personal data
Personal data processed for registration purposes on our website and to reply to a specific request is processed for the time necessary to perform the requested service. Personal data processed in the context of e-commerce activities are kept for the time necessary to pursue the purpose for which they are collected and, in any case, in compliance with the applicable financial and commercial law requirements. For the purposes of marketing, profiling and sharing data with the companies of the The Private Markdown Group, the data is kept for the time strictly necessary for the fulfillment of said purposes, within the limits permitted by the GDPR. You can at any time request the deletion of data for these purposes and object to the processing of data for marketing purposes.
6. Data Controller and Data Protection Officer
The Data Controller is TPMD S.r.l. Unipersonale, with offices in Via Boccaccio 50, 50133 Firenze (FI). The Data Protection Officer is domiciled at the registered office of the Data Controller and available at the following email address: admin@theprivatemarkdown.com.
7. Your rights
You can contact The Private Markdown as Data Controller or the Data Protection Officer at the above addresses to get an updated list of our data processors (i.e. our service providers), of the subjects to whom your data are communicated and to exercise at any time the following rights as per art. 15 ss. of the GDPR; obtain confirmation of the existence or otherwise of your data, verify its content, origin, accuracy, request integration, updating, rectification, erasure, anonymity, request data portability, limitation of processing, opposition to processing for legitimate reasons, es. opposition to marketing activities, submit an application to the Supervisory Authority (the Italian Data Protection Authority).