Privacy Policy

Please read this Privacy Policy carefully, which contains important information about users' personal data, which is collected by visiting the website www.manbrnm.com (the "Site"), as a registered or unregistered user, and also regardless of purchase of products on the Site, and describes how such data is used.

AGB COMPANY SpA recognizes the importance of protecting the personal data of users of its Site and, for this reason, adopts specific security policies and measures to comply with current regulations on the protection of personal data and protect your personal data.

We remind you that this Privacy Policy is governed by Italian law and in particular by the Code regarding the protection of personal data (legislative decree 30 June 2003 n. 196, the "Code"), as well as by the European Regulation 2016/679 (the " Regulation") in force since 25 May 2018. The Code and the Regulation guarantee that the processing of personal data is carried out in compliance with fundamental rights and freedoms, with particular reference to confidentiality, personal identity and the right to data protection personal.

1. Owner of personal data and data controller

AGB COMPANY SpA with headquarters in Via Melitiello 5 - 80025 Casandrino - NA (hereinafter AGB) is the owner and responsible for the processing of personal data of users who browse the Site, including navigation data, marketing and profiling data as well as of data connected and correlated to sales made online.

For any questions about this Privacy Policy, to have the complete list of the appointed data processors and to submit requests relating to the exercise of rights related to the processing of personal data, you can contact the Data Controller by writing to the following email address: agb @agbcompany.com

2. Personal data collected

a) Subscription to the newsletter or creation of an account

By subscribing to the newsletter or creating an account on the Site, the user provides the following personal data: name, surname, email. These data are mandatory, therefore, in the absence of such data it will not be possible to proceed with the subscription to the newsletter or the creation of the account. It is also possible to enter further optional data (such as date of birth and gender, history of online orders): failure to enter such data will not allow the provision of some services (such as for example the sending of promotions on the birthday).

The user can also provide their personal data to create an account by logging in from their social profile (for example, Facebook). In such cases, the user is invited to read the privacy policies of the relevant social network.

b) Online purchase

The User can proceed with the online purchase, even if he is not a registered User with an account, by providing the following data: name, surname, email, country, address, city, postal code, telephone. These data are mandatory, therefore, in the absence of their provision it will not be possible to proceed with the online purchase. It is also possible to enter further optional data (such as VAT number, province, date of birth and sex): failure to enter such data will not allow the provision of some services (such as for example the sending of invoices or the sending of promotions on the birthday).

Furthermore, when purchasing online, some data relating to the sale are acquired such as, for example: products purchased, product codes, amount, size.

c) Assistance/information request

To obtain assistance or request information, the user can send an email to the email address customercare@manbrnm.com , indicated on the Site, or using the "Contact us" section, and must provide personal data such as: name, email. These data are mandatory, therefore, in their absence it will not be possible for AGB to provide the requested assistance. It is also possible to provide further optional data (such as telephone): failure to enter such data could prevent AGB from providing adequate assistance to the User's requests.

d) Data relating to navigation

When the User navigates the Site, some data is automatically acquired, also through third-party applications, including: IP addresses or domain names of the computers used by the User, addresses in URI (Uniform Resource Identifier) notation ), the time of the request, the method used to forward 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, the country of origin, the characteristics of the browser and the system operational used by the visitor, the various temporal connotations of the visit (for example 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 system operational and IT environment of the User, geographical location. Unique device identifiers for advertising are also used (such as Google Advertiser ID or IDFA identifier).

e) Cookies

Regarding the use of cookies, please refer to the Cookie Policy published on the Site.

If you provide personal data of third parties (for example, family members, other customers or potential customers), you must ensure that such third parties are informed and have authorized the use of their data as described in this Privacy Policy. The user will remain solely responsible for the communication of information and data relating to third parties without their having expressed their consent or for their possible incorrect use contrary to the law.

3. Purpose of processing, legal basis and data retention period.

3.1 Subscription to the newsletter, creation of an account and assistance/request for information

The personal data provided by the user or collected when the user subscribes to the newsletter, creates an account on the Site or requests assistance/information, will be used to:

a) provide the requested services (for example, carry out the account registration processes, manage authentication on the Website and the user's accounts, assist the user and manage any complaints and respond to a question or contact request possibly forwarded by the the user, also through the customer assistance service);

b) manage subscription to the newsletter where the user is not registered.

It is necessary to provide personal data for the aforementioned purposes and refusal would make it impossible to complete the request.

The processing of data for the purposes indicated is carried out to follow up on the request to send the newsletter, to create/manage the account and to the request for information/assistance.

The personal data processed for subscription to the newsletter will be kept until the user requests cancellation from the newsletter or, in any case, until the user is an active user (the user is considered inactive if he does not open any email for a period exceeding 12 months).

The personal data processed for the management of an account on the Site will be retained until the user closes their account or, in any case, until the user is an active user (the user is considered inactive if not log in to your account for a period exceeding 12 months).

The personal data processed for assistance/information requests will be kept for the time necessary to manage the request.

Once the aforementioned retention periods have expired, the personal data will be permanently deleted or anonymized. Without prejudice to the above, the user's personal data will be retained only for any legal and regulatory obligations (such as, for example, accounting and tax obligations).

3.2 Online sales

The personal data provided by the user or collected at the time of purchase, made as a registered user or as an unregistered user, will be used for the management of orders, for the related administrative activities as well as to comply with any legal obligations.

The processing of data for the purposes indicated is carried out as necessary to execute the order.

The personal data processed for online purchases made by users not registered on the Site will be kept for the duration of the commercial relationship, including any return procedures or credit recovery procedures.

The personal data processed for online purchases made by users registered on the Site will be kept until the account is closed or, in any case, until the user is an active user (the user is considered inactive if you do not log in to your account for a period exceeding 12 months).

3.3 Specific purposes

The personal data collected on the Site, after obtaining consent, will be used to:

a) offer promotions, discounts and other personalized services and send newsletters, other marketing and commercial communications on AGB products, surveys and research, market analyses, promotions and other initiatives to registered users or customers ("marketing"). The Data Controller may use traditional means of contact (ordinary mail and telephone) and/or digital and automated means (e-mail, SMS,) and may send the user such communications based on his profile, if he has given his consent to profiling (see point 3.3b below);

b) analyze user behavior on the Site, interests, preferences and purchasing habits, and create individual or aggregate profiles based on them, understand how to provide a better service, also to offer a better sales experience (" profiling”). Personal data may also be used to create groups and carry out statistical and market analyzes aimed at identifying products and/or services of interest to the user and improving their services.

The use of data for the above purposes is optional and free (being based on the consent that the user can choose to give) and can only take place where personal data is provided for both the marketing and profiling purposes referred to in the points 3.3 a) and b) or only for one of the two. The user can unsubscribe from the newsletter or revoke their consent at any time. In any case, the refusal to provide personal data for one or both of the purposes referred to in points 3.3. a) and b) does not prevent the user from using the Site's services or making purchases, but the user will not be informed of the marketing initiatives promoted by the Owner and will not be able to enjoy a more personalized shopping experience.

The personal data processed for profiling purposes will be stored, in accordance with the provisions of the Personal Data Protection Authority (Guarantor), for a period not exceeding 12 months, unless the User renews his/her consent and without prejudice to any further provisions of the Guarantor.

4. Communication of personal data

The user's personal data will be processed by authorized personnel of the Owner and Manager.

Personal data may also be processed by third parties who carry out, for example, shipping services, communications sending services by e-mail or SMS, IT system maintenance services, payment management services, hosting and infrastructure services. backend. The data used for payment are not subject to processing by the Data Controller, but are acquired directly by the manager of the requested payment service, which operates as an independent data controller, in order to provide the user with online sales services.

The aforementioned subjects will only process the personal data necessary for the performance of the relevant services and will not be authorized to process them for different purposes.

5. Protection of minors' privacy

The processing of personal data of minors is lawful if the minor is at least 16 years old. Where the minor is under the age of 16, such processing is lawful only if and to the extent that such consent is given or authorized by the holder of parental responsibility.

The Data Controller will endeavor, in every reasonable way and in consideration of available technologies, to verify that consent is given or authorized by the holder of parental responsibility for the minor.

If the Data Controller or Manager becomes aware that data from a minor has been collected, they will immediately delete it.

If the user is not of the required age, please do not register or proceed with the online purchase and ask an adult (i.e. your parents or guardian) to carry out the necessary procedures.

6. Treatment methods

The personal data collected through the Site are processed using mainly IT and telematic methods and tools, adopting the necessary security measures in order to minimize the risks of destruction or loss, even accidental, of the data themselves, of unauthorized access or of processing that is not permitted or does not comply with the collection purposes indicated in this information.

However, these measures, due to the nature of the online transmission medium, cannot absolutely limit and exclude any risk of unauthorized access or dispersion of data. To this end, we recommend: periodically checking that the computer is equipped with adequate devices and software for the protection of data transmission over the network, both incoming and outgoing (such as updated antivirus systems); verify that the internet service provider has adopted suitable measures for the security of data transmission over the network (such as firewalls and anti-spamming filters); keep the username and password to access the account confidential and not communicate to anyone; change your password periodically.

In the event that the Data Controller believes that the security of the user's personal data in its possession or under its control has been or may have been compromised, it will inform the user of the incident in the manner required by current law, using the methods prescribed by it (by providing the Owner with your email address, the user consents to receive such communications in electronic format through such email address).

The user's personal data may be processed for profiling purposes, subject to the user's consent, with the aid of automated tools, in order to analyze the habits and consumption choices of users to make the products and promotional initiatives of the Owner more responsive to user preferences.

7. Transfers to third countries or international organizations

If the Data Controller must transfer personal data to third countries or international organizations, in order to pursue the purposes set out in this Information, it will adopt measures to ensure that such communications take place in compliance with European data protection standards (for example the use of standard contractual clauses or Privacy Shield).

8. User rights

To exercise the rights indicated below, the user can send a request by contacting the Owner by sending an email to agb@agbcompany.com or a letter by ordinary mail to the Owner's address. When contacting the Owner, you must ensure that you include your name, email address, postal address and/or telephone number(s) to ensure that the Owner can correctly handle your request.

8.1 Right of access

The user has the right to obtain confirmation as to whether or not personal data concerning him is being processed, and, in this case, he has the right to obtain information regarding: the origin of the personal data; the purposes of the processing; the categories of personal data; the recipients or categories of recipients; when possible, the expected retention period of personal data or, if this is not possible, the criteria used to determine this period; the existence of the user's right to ask the data controller to rectify or delete personal data or limit the processing of personal data concerning him or to oppose their processing; the right to lodge a complaint with a supervisory authority; if the data is not collected from the user, all available information on their origin; the existence of an automated decision-making process, including profiling and, in this case, significant information on the logic used, as well as the importance and expected consequences of such processing for the user; the existence of adequate guarantees in the event of data transfer to third countries or international organisations.

The user has the right to obtain a copy of the personal data being processed.

8.2 Right of rectification

The user has the right to obtain from the Data Controller the rectification of inaccurate personal data concerning him without unjustified delay. Taking into account the purposes of the processing, the user has the right to obtain the integration of incomplete personal data, including by providing a supplementary declaration.

8.3 Right to erasure

The user has the right to obtain from the Data Controller the deletion of personal data concerning him without unjustified delay and the Data Controller has the obligation to delete the personal data without unjustified delay, if one of the following reasons exists:

a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

b) the user revokes the consent on which the processing is based;

c) the user objects to the processing and there is no overriding legitimate reason to proceed with the processing, or objects to the processing for direct marketing purposes, including profiling;

d) the personal data have been processed unlawfully;

e) the personal data must be deleted to comply with a legal obligation established by Union or Member State law to which the Data Controller is subject;

f) the personal data were collected in relation to the offer of information society services to minors.

8.4 Right to Limit

a) the user disputes the accuracy of the personal data, for the period necessary for the Data Controller to verify the accuracy of such personal data;

b) the processing is unlawful and the user opposes the deletion of the personal data and instead requests that their use be limited;

c) although the Data Controller no longer needs them for the purposes of the processing, the personal data are necessary for the user to ascertain, exercise or defend a right in court;

d) the user has objected to the processing pursuant to Article 21, paragraph 1 of the Regulation, pending verification of the possible prevalence of the legitimate reasons of the data controller with respect to those of the user.

8.5 Right to data portability

The user has the right to receive the personal data concerning him/her provided to the Data Controller in a structured, commonly used and machine-readable format and has the right to transmit such data to another data controller without impediments from of the data controller to whom he provided them if:

a) the processing is based on consent pursuant to Article 6, paragraph 1, letter a) of the Regulation, or Article 9, paragraph 2, letter a) of the Regulation, or on a contract pursuant to Article 6, paragraph 1, letter b) of the Regulation; And

b) the processing is carried out by automated means.

When exercising your rights regarding data portability pursuant to paragraph 1, you have the right to obtain direct transmission of your personal data from the Data Controller to the other, if technically feasible.

8.6 Right to object

The user has the right to object at any time, for reasons related to his particular situation, to the processing of personal data concerning him pursuant to Article 6, paragraph 1, letters e) of) of the Regulation, including profiling on basis of these provisions.

The user also has the right to object, at any time, to the processing of personal data for direct marketing purposes, including profiling to the extent that it is connected to such direct marketing.

If the user objects to the processing for direct marketing purposes, the personal data will no longer be processed for these purposes.

8.7 Additional rights

You have the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

The user has the right to revoke, at any time, the consent given for the use of their personal data, by sending a request to the Data Controller at the email address agb@agbcompany.com

The user has the right to lodge a complaint with a supervisory authority (in Italy, the Guarantor Authority for the Protection of Personal Data).

9. Updating of personal data

The user is invited to check and update their personal data regularly. To this end, in the event of changes, the user is invited to write to the email address agb@agbcompany.com or to directly modify the data online using the user account settings on the Site.

10. Updates to this information - communications

The Owner reserves the right to modify, add or delete parts of this Privacy Policy at any time, publishing the revised version on this page of the Site and updating the "Last modification" date indicated below.

It is the user's responsibility to review the Information from time to time to be aware of any changes made.

In some cases, the Owner may provide further communications relating to significant changes to this Policy by publishing a notice on the home page of this Site or, in the case of registered users, by sending a notification email or by placing a notice on their account page. Where requested, the user must again give consent to the processing of personal data.

11. Responsible for the protection of personal data (Data Protection Officer)

The Personal Data Protection Officer of AGB Company SpA is Mr. Silvio Tortora Maione, who can be contacted at the email address: silvio@itadvice.it

The Effective Date of this Privacy Policy is March 16, 2020.

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