Privacy policy

Dear user,
First of all, thank you for visiting us.
We appreciate your trust, and we would like to share with you on this page the purposes and methods of processing personal data that we collect during your navigation and the use of the services we offer, as detailed below.
The processing of your personal data is always based on principles of lawfulness and fairness in compliance with all applicable regulations. Below you will find all the details regarding the processing of your personal data.
We are available to answer your questions. You can find all the ways to contact us at this link: http://www.harpogroup.it/contatti.
Last updated: 23/05/2018

PRIVACY POLICY NOTE

Identity and Contact Details of the Data Controller

The data controller is Harpo S.p.A. (hereinafter referred to as ‘Harpo’ or ‘Data Controller’), with registered office in Trieste, Via Torino, 34 – 34123, with the following contact details: http://www.harpogroup.it/contatti or by writing to the following email address: customer.service@harpo-group.com.

Harpo will process your Personal Data in accordance with EU Regulation No. 2016/679 and national legislation on the protection of personal data (hereinafter the ‘Privacy Policy’).

What Personal Data We Process and How We Collect It

Your navigation on the Site may involve the collection and further processing of your Personal Data by Harpo. In fact, when you connect to the Site, the computer systems and software procedures used to operate it automatically and/or indirectly collect and/or acquire certain information (such as, but not limited to, the so-called ‘cookies’, as specified in the ‘Privacy Policy – Cookies’ section at the end of this statement, ‘IP’ addresses, domain names of the computers used by users who connect to the Site, the ‘URL’ of the requested resources, the time of the request to the server).

Your registration on the Site and/or any request for information or services may also involve the collection and further processing of your Personal Data (such as your name, surname, postal and email address, password, age, date of birth, sex, image, profession, marital status, etc.).
In particular, the collection of your Personal Data may take place:

  • Through your completion of online forms;
  • Through your registration via social log-in;
  • Through the publication by you of Contributions (as defined below), the content of which may include your Personal Data provided directly by you, on social networks managed independently by third parties, such as, but not limited to, Facebook, Twitter, etc. (hereinafter ‘Social Networks’). By ‘Contributions’ we mean images, comments, catchphrases associated with the subject matter of the Site, the content, and any other information conceived by you and published on the pages of Social Networks dedicated to products of various brands of the Harpo group, including the image that you may contribute. The publication of the Contributions may also occur through a pseudonym (‘nickname’) chosen by you when registering on the Site, and possibly the image that you have associated with your nickname. When choosing the nickname and any image associated with it, you are solely responsible for any harm that the use of the nickname or image may cause to third parties.

In the event that you choose to register on the Site or send a request through the ‘Contact Us’ section, providing certain Personal Information is necessary for Harpo to meet your needs within the functionality of the Site. Therefore, the relevant fields of the registration form are marked with an asterisk or are otherwise marked as mandatory. The provision of Personal Data not marked with an asterisk or otherwise marked as mandatory is purely optional, and failure to provide such data will have no consequences. On the other hand, failure to provide Personal Data marked as mandatory will prevent us from providing the requested service. If you fail to provide one or more mandatory Personal Data, Harpo will display an error message with a list of the missing mandatory Personal Data.

What Are the Purposes of the Processing of Your Personal Data and Its Legal Bases

According to the needs you express from time to time by accessing the various sections of the Site, the purposes of processing your Personal Data and its legal bases are listed below.

Your Personal Data will be processed for the following purposes, exclusively subject to your consent to processing, which can be revoked at any time by accessing your profile page (where you may uncheck the relevant box), deleting your profile, or using the link at the bottom of each promotional email (regarding marketing activities and the newsletter) or according to the procedures indicated by the Data Controller when collecting consent:

(a) Managing and responding to your requests

You may decide to consent to the processing of your Personal Data for managing and responding to your requests regarding products and initiatives of the various Harpo group brands, advertising, or the Site (‘Contact Us’ section of the Site). Consent is required at the time of sending your request. If you decide not to consent to the processing of your Personal Data for this purpose, we will not be able to proceed with your request.

(b) Marketing activities

You may choose to consent to the processing of your Personal Data for marketing purposes, such as receiving commercial communications, including via email, regarding the sending of promotional and advertising materials related to any Harpo Group brand or performing market research. Consent is required when you register for the newsletter.

(c) Receipt of the newsletter

You may choose to subscribe and consent to receive the Harpo Group’s brand-specific newsletter service. Consent is required when subscribing to the newsletter service.

How We Process Your Personal Data

The processing of your Personal Data may include any type of operation, including collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion, and destruction.

Your Personal Data will primarily be processed in an automated manner, but also in paper form, with methods strictly related to the relevant purposes, through databases, electronic platforms managed by Harpo or by third parties appointed for this purpose as external data processors, and/or integrated IT systems of Harpo and the aforementioned third parties, and/or websites and/or apps owned or used by Harpo.

The Data Controller has assessed the security level as adequate, taking into account the risks that could arise from loss, destruction, modification, unauthorized disclosure, accidental or illegal access, abuse, or alteration of your Personal Data. Specifically:

  • Appropriate security measures have been adopted to mitigate these risks.
  • Your Personal Data is stored on servers primarily located within the European territory. (To learn about how Personal Data is transferred outside the European Economic Area, see the section “Transfer of Your Personal Data Outside the European Economic Area” below). In any case, the servers are subject to an advanced and daily backup system.

Where We Process Your Personal Data

Your Personal Data is processed primarily at the Data Controller’s premises and in places where the data processors are located. For further information, please contact the Data Controller using the contact details provided in the section “Identity and Contact Information of the Data Controller”.

How Long We Retain Your Personal Data

In order to ensure compliance with the principles of necessity and proportionality of processing, the Data Controller has established different retention periods for Personal Data based on the specific purposes pursued:

  • For managing and responding to your requests regarding products and initiatives from the various brands of the Harpo group, advertising, or the Site (the “Contact Us” section), your Personal Data will be kept for the time strictly necessary to fulfill your request;
  • For marketing activities, such as commercial communications, including by email, concerning the sending of promotional and advertising material related to any Harpo group brand or conducting market research, your Personal Data (excluding contact information) will be stored for a maximum period of 36 months;
  • For the purpose of sending newsletters, your Personal Data (excluding contact information) will be stored for a maximum period of 36 months;
  • For managing your potential participation in prize promotions as well as for related legal, administrative, and accounting obligations, your Personal Data will be stored for the duration of each prize promotion and for the time strictly necessary to complete related activities;
  • For managing and fulfilling legal obligations (such as accounting, administrative, tax obligations, etc.), your Personal Data will be retained for the time strictly necessary for these purposes;
  • For managing disputes and potential litigation, your Personal Data will be stored for the time strictly necessary for this purpose and, in any case, no longer than the applicable statute of limitations.

Who Are the Recipients of Your Personal Data

Your Personal Data may be communicated to and processed by:

  • Legal entities or individuals acting as external data processors, performing outsourcing activities, appointed by Harpo or by Harpo’s external data processors (including those responsible for customer service, communication, IT service providers, website managers, electronic platform managers, partners, banks, professional firms);
  • Employees and/or collaborators of the Data Controller (including system administrators), who, operating under the direct authority of the Data Controller, are authorized to process your Personal Data;
  • Employees and/or collaborators of external data processors (including system administrators), who, operating under the direct authority of the external data processors, are authorized to process your Personal Data. Your Personal Data will not be disclosed to third parties, except where Harpo needs to disclose your Personal Data to consultants for the purpose of protecting its rights, nor will it be disseminated. However, if you have entered Personal Data in your nickname and/or associated an image with it, such Personal Data may be disseminated via the Site or Social Networks.

Transfer of Your Personal Data Outside the European Economic Area

Your Personal Data may be transferred outside the European Economic Area, meaning outside the European Union, and Iceland, Norway, and Liechtenstein (specifically to the United States of America). The transfer is carried out by Harpo, upon entering into Standard Contractual Clauses with the providers of the servers and/or services, or verifying the registration of the external data processor in the “Privacy Shield” system.

Minors

Minors under the age of 16 should not provide information or Personal Data to Harpo without the consent of their parents or legal guardians. Without such consent, registration of the minor on the Site will not be possible. Harpo encourages all those with parental responsibility over minors to inform them about the safe and responsible use of the Internet and the Web, and to follow the procedures indicated during registration for minors under the age of 16 on the Site.

Identity and Contact Details of the Data Processors

The full list of the Data Processors for your Personal Data can be consulted by contacting the Data Controller using the contact details provided in the section “Identity and Contact Details of the Data Controller.”

Your Rights Regarding the Processing of Your Personal Data

The Privacy Legislation grants you, as the data subject, numerous rights. In particular, you have the right to:

  • Obtain confirmation from the Data Controller as to whether or not your Personal Data exists, even if not yet registered, and receive it in an intelligible form, as well as access to your Personal Data (obtaining a copy) and related information (including the purposes of processing, the categories and origin of the Personal Data, the categories of recipients to whom the data have been or may be disclosed, the retention period (if possible), and the rights you can exercise);
  • Obtain from the Data Controller the rectification of your Personal Data and the completion of any incomplete Personal Data;
  • Delete your profile on the Site and, in any case, obtain the deletion of your Personal Data without unjustified delay, including when the Personal Data are no longer necessary for the purposes for which they were processed or there is no longer a legal basis for processing them;
  • Obtain from the Data Controller the transformation into anonymous form or the blocking of your Personal Data processed in violation of the law, including those that no longer need to be stored in relation to the purposes for which the data were collected or subsequently processed;
  • Obtain from the Data Controller the restriction of the processing of your Personal Data, for example, when you contest its accuracy or oppose its processing, for the time necessary to carry out the respective verifications;
  • Receive your Personal Data in a structured, commonly used, and machine-readable format, and transmit or, if technically feasible, request the direct transmission of your Personal Data to another data controller without hindrance, in cases where the processing is carried out by automated means and is based on your consent or is necessary for the performance of a contract to which you are a party;
  • Withdraw your consent to the processing of your Personal Data for any of the purposes for which it was granted.

You can exercise your rights towards Harpo by accessing the “Contact Us” section of the Site, writing to the following email address: customer.service@harpo-group.com, or sending a letter to Harpo via regular mail at the address indicated in the section “Identity and Contact Details of the Data Controller.”

Additionally, if you believe that the processing of your Personal Data violates the Privacy Legislation, you may file a complaint with the Data Protection Authority of the country where you reside, where your workplace is located, or where the alleged violation occurred, or contact the same Authority to request information regarding the exercise of your rights under the Privacy Legislation.

The Right to Object to the Processing of Your Personal Data

At any time, and for reasons related to your particular situation, you have the right to object to the processing of your Personal Data if it is necessary for the pursuit of the legitimate interests of the Data Controller or third parties. In this case, the Data Controller will refrain from further processing your Personal Data, unless it demonstrates the existence of legitimate overriding grounds for processing, which prevail over your interests, rights, or freedoms, or the processing is necessary for the establishment, exercise, or defense of a legal claim.

Without prejudice to your right to withdraw consent for processing for marketing and profiling purposes, you have the right to object to the processing of your Personal Data for direct marketing purposes, including profiling, to the extent that it is related to such direct marketing. You can do this by accessing the “Contact Us” section of the Site or by sending an email to the following address: customer.service@harpo-group.com. If you object to the processing of your Personal Data for direct marketing purposes, the Data Controller will no longer process your data for such purposes.

PRIVACY NOTICE – COOKIES

Cookies are text lines that act as digital markers sent from a server (in this case, the Site’s server) to a user’s device (usually to the Internet browser) when they access a particular page on a website. Cookies, which can also be set by websites other than the one the user is visiting (“third-party cookies”), are automatically stored by the user’s browser and sent back to the server that generated them each time the user accesses the same webpage. In this way, for example, cookies allow and/or facilitate access to certain webpages to improve the user’s browsing experience (e.g., they allow the storage of visited pages and other specific information, such as frequently viewed pages, connection errors, etc.), or enable profiling activities. Therefore, for a smoother and more complete use of a website, it would be advisable for the user to configure their browser to accept the receipt of such cookies.

Browsers are often set to automatically accept cookies. However, users can modify the default settings to disable or delete cookies (either one by one or once and for all). However, doing so may restrict optimal access to some areas of the website. It is also possible to check the types and categories of cookies stored on your browser by modifying the cookie settings in your browser.

Features and Purposes of Cookies

Our Site uses the following categories of cookies, which may be either from Harpo or third parties:

Technical and Functional Cookies:

  • Technical Cookies:
    These are used to facilitate your navigation on the Site and to use its features. Among technical cookies, we highlight essential cookies, also called “strictly necessary” cookies, which enable functions without which you would not be able to fully use the Site, as well as performance cookies, or “performance cookies,” which help improve the Site’s features.
  • Functionality Cookies:
    These allow the Site to remember your choices (e.g., the language or geographical area you are in) and present them again during subsequent visits to provide better and more personalized services (e.g., they can be used to suggest content similar to what you have previously requested).

Description of Consent Methods for Cookie Installation

Upon your first visit to the Site, you will find a banner with a brief notice containing a link to this extended notice, where you will find more information about the cookies installed by the Data Controller and third parties.

In this extended notice, you will find more detailed information about the description and characteristics of the various categories of cookies and will have the option to decide independently which cookies to authorize.

For the use of technical and analytical cookies, your consent is not required. However, you can disable them by following the procedure described in the section “How to Enable or Disable Cookies on Your Browser.”

By browsing the Site, you consent to the use of cookies. In any case, you can modify your cookie preferences at any time, even denying consent to the use of any cookies (including those installed by third parties) in the table below.

The following table describes the cookies sent to your browser when accessing the Site. The table is updated as of 23/05/2018; any updates will always be published on this page.

Harpo Cookies:

  • Technical Cookies

Analytical Cookies:

  • Google Analytics

Profiling (Marketing) Cookies:

  • Facebook Cookies

Below are the links to the privacy notices and consent forms of third parties, who are independent data controllers, through which you will have the opportunity to gather more information, manage, and deactivate these cookies.

How to Enable or Disable Cookies on Your Browsers:

You can block your browser from accepting cookies. However, this action may reduce the efficiency of the website or prevent access to certain features or pages of the Site.

Below are the methods offered by major browsers to block the acceptance of cookies:

Additional Methods for Disabling Analytical and Profiling Cookies:

In addition to disabling and/or deleting cookies through your browser’s settings, you can disable and/or delete individual analytical and profiling cookies by visiting the following websites:

  • Google Analytics Cookies, which is a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files stored on the user’s computer to analyze how users use the Site. The information generated by the cookies regarding the user’s use of the Site is transmitted to a Google server where it is stored. Google will use this information to analyze the user’s use of the Site, prepare reports on Site activity, and provide additional services to the site operator related to Site usage and Internet usage. Google will not associate the IP address transmitted by the user’s browser in the scope of Google Analytics with other data held by Google. The user can prevent the storage of cookies by modifying the settings of their browser software, but doing so may make the Site’s functions less personalized according to the user’s preferences. The user can obtain information on the personal data processing activities carried out by Google Analytics at the following link: https://support.google.com/analytics/answer/6004245; they can also prevent Google from recording data generated by cookies regarding their use of the Site (including their IP address) and from processing such data by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en. By using the Site, the user consents to the processing of their data by Google in the manner and for the purposes indicated in Google’s privacy policy regarding the use of Google Analytics, which can be accessed here: https://www.google.com/intl/en/policies/privacy/partners/. To disable these cookies, visit: https://tools.google.com/dlpage/gaoptout?hl=en
  • Facebook Cookies: visit https://www.facebook.com/policies/cookies/ to delete the cookies provided by Facebook.
  • Your Online Choices, a website managed by the European Interactive Digital Advertising Alliance (EDAA), to delete other cookies for users located in the European Union.
  • About Ads for the deletion of other cookies for users residing in the United States.

Social Buttons

The Data Controller uses social buttons on the Site.
Social buttons are digital buttons or direct links to social network platforms configured in each individual “button.”
By clicking these links, you will have the ability to interact directly with the Data Controller’s accounts (social media pages).
The managers of the social networks that the buttons link to are independent data controllers. More information on the privacy policies of the social network platforms and on how to manage and deactivate their cookies can be found on the social network platforms themselves.