1. Data Controller and contact details
MULTI-DESIGN S.R.L., headquarter at Via A. Locatelli 31, 24121 Bergamo (BG), Italy (hereinafter also referred to simply as “MULTI-DESIGN”) will collect and process your personal data in connection with the services offered by MULTI-DESIGN and the sale of Ciclotte’s branded products through its traditional channels or via the websites www.multi-design.it and/or www.ciclotte.com (hereinafter also referred to simply as the “Websites”).
You can contact our data protection officer at firstname.lastname@example.org or write to us by post, sending a letter marked for the attention of the Data Protection Officer at MULTI-DESIGN S.R.L., Via A. Locatelli 31, 24121 Bergamo (BG), Italy.
To know your rights, please visit the section “Rights of the Data Subject” below.
2. When does this policy statement apply?
If you visit www.multi-design.it and/or www.ciclotte.com or if you have bought a Ciclotte branded product or made contact with our company in any other way (e.g. by telephone or at one of our event, to find out more about our Ciclotte’s products or company), you will find below full details about how we process your personal data.
3. Purposes and legal basis of the data processing
We will process your personal data:
- in order to fulfil our contractual obligations and, specifically, to allow you to browse and use the services offered on the Websites, regardless of whether or not you are a registered user; provide a response to your replies, which may be automated; calculate estimates if requested; fulfil contracts for this sale or purchase of products or the provision of services; provide you with the necessary assistance in relation to products and services you have bought;
- for marketing and market research purposes, with your consent, or to involve you in other commercial or promotional campaigns in addition to the sending of newsletters (you can always opt out of these campaigns) relating to other products or services offered by MULTI-DESIGN and/or Ciclotte, possibly in partnership with third parties who will never have access to your data without your specific consent. Any promotional communications we send out may include content related to market research. They may be sent by email, social networks or telephone calls;
- in accordance with the legitimate interests of MULTI-DESIGN and/or Ciclotte, to analyse and improve the quality of our products and services (e.g. product liability, product recall campaigns, maintenance, quality and originality guarantees etc); to manage insurance risk; to guarantee the quality of customer services; to manage relations with MULTI-DESIGN and/or Ciclotte distributors; to manage the loss and/or destruction of data and unauthorised access; to manage and internally control our activities; to publish on MULTI-DESIGN and/or Ciclotte channels any images or videos made during public events (promotional events or trade fairs); to carry out statistical analysis on the use of the services and, if necessary, to exercise our right to take legal action. In accordance with our legitimate interests we may also send you promotional communications about similar products or services to those you have bought in the past and/or based on profile information you have supplied us with. You may object to the sending of promotional material, at any time;
- to comply with any other obligations deriving from the applicable laws or orders made by the authorities, including accounting and tax obligations, and product warranties.
The provision of personal data is always optional, but if it is not provided it may be impossible for us to proceed with certain operations, such as those required for the fulfilment of the contract or to provide services you have requested.
4. The data we process
In the context of your use of the Websites and/or your written or telephone communications with us, MULTI-DESIGN will process the following data:
- Data you provide us with
We will process some of your personal details, including your name, surname, the contact details you have supplied us with or used to communicate with us, such as your email address, postal address or telephone number, and any other personal information you may have supplied us with (profile information given during registration on the Website). In certain cases the bank with which we cooperate may process your credit card details, but only for the time strictly necessary to complete a payment.
- Browsing data
During their ordinary course of operation, the IT systems and software procedures required to run these Websites will acquire certain personal data, the transmission of which is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects. However, by its very nature, it might allow to identify users through the processing and matching of data held by third parties. This category of data includes the computer IP addresses and domain names of the computers used by users who connect to the Websites, as well as the URI addresses (Uniform Resource Identifier) of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in reply, the numerical code indicating the status of the reply from the server (successful, error, etc.) and other parameters relating to the user’s operating system and IT system. This data is processed for the purposes of receiving statistical information about the use of the Websites and check that it is working correctly. Browsing data may be used to establish liability in the event of any potential computer crimes against the Websites.
We may also process data related to your training goals and objectives, as indicated at the time of registration or subsequently.
5. Recipients of your personal data
Your personal data may be known and processed by:
- suppliers of MULTI-DESIGN, such as the providers of technology services or financial intermediaries, banks, credit institutions, lenders, operators of centralised information systems (risk registers, anti-fraud centres etc.), insurance companies, consultants and freelancers assisting MULTI-DESIGN with debt recovery or dispute management, individuals providing packaging, shipping and delivery services or managing the sending of post and commercial communications, in the capacity of data processors;
- the personnel of the above-mentioned providers, for the sole purpose of completing the activities for which your data was collected, in the capacity of data processor.
6. International transfers
When we transfer your data to third parties based outside the EU or in countries that cannot guarantee an adequate level of data protection, we will do so after stipulating appropriate contractual guarantees with the third party provider, based on the Standard Contractual Clauses approved by the European Commission
7. Period of retention of data
Your personal data will be stored only for the time needed to complete the purpose for which it was collected, and in any case for no more than 10 (ten) years from the date of termination of the contract or from the last date on which you made contact with MULTI-DESIGN and/or Ciclotte (for example the last time you communicated with us or accessed your reserved area), unless it is essential to keep the data for a longer period of time, in accordance with the applicable laws.
8. Rights of the data subject
You have the right to know which personal data is being processed. In particular, you have the right of access, rectification and erasure and the right to portability of data, the right to limit the processing and the right to object to the processing, where the conditions are met. If the data is processed for marketing purposes, or is based on our legitimate interests, you may object to it at any time. For more information about the processing of your personal data, or to exercise your right, you can contact the email address email@example.com or write to us by ordinary post, sending a letter marked for the attention of the Data Protection Officer at MULTI-DESIGN S.R.L., Via A. Locatelli 31, 24121 Bergamo (BG), Italy.
Below is a brief illustration of your rights in relation to the processing of your personal data.
- The right of access enables you to obtain confirmation of whether or not MULTI-DESIGN is processing your personal data and if necessary access that data and the related information;
- the right of rectification allows you to obtain the modification of inaccurate personal details without unjustified delay and, taking into account the purposes of the data processing, to obtain the integration of incomplete data;
- the right to erasure enables you to obtain the erasure of your data without unjustified delay (e.g. when your personal data is no longer required for the purpose for which it was collected), subject to the exceptions provided for by the applicable laws (e.g. when the retention of your data is necessary in order to comply with legal obligations applicable to the data controller);
- the right to data portability allows you to receive your personal data, as supplied to MULTI-DESIGN, in certain circumstances provided for by the applicable laws, in a structured, commonly used, legible format from an automated device. You may send this data to another data controller provided that this right is permitted under the applicable laws, and except in the case where this could harm the rights and freedoms of others;
- the right to limit the data processing allows you to limit the processing of your personal data in certain circumstances as provided for by the applicable laws. In such cases MULTI-DESIGN may continue to process your data, but only in certain cases, for example in order to exercise its right of defence and to protect the rights of another natural or legal person;
- the right to object to data processing allows you, in certain circumstances provided for by the applicable laws, to object to the processing of your personal data unless there are prevailing legitimate reasons, rights or freedoms that would allow MULTI-DESIGN to continue to process the data; if there are reasons connected to your specific situation, you may object to the processing of your personal data at any time if it is based on a legitimate interest of MULTI-DESIGN or of a third party. In such cases, MULTI-DESIGN will no longer process the data unless there are other legitimate reasons to proceed with the processing.
At any time you may complain to the Data Protection Authority if you consider that you have not obtained a satisfactory response from MULTI-DESIGN in relation to your rights or if you consider that they have been violated.