PRIVACY POLICY
VERSION 4/2018 - DRAWN UP IN ACCORDANCE WITH ARTICLES 13 AND 14 GDPR 2016/679 EXTRACT. THE DETAILED TEXT CAN BE REQUESTED USING THE REFERENCES CONTAINED IN THIS DOCUMENT
The purpose of the Legal Notices and Privacy Policy is to ensure that Users can fully transparently verify the processing of their data online. This also highlights the importance of having contacted a company that is committed to protecting User rights and is accustomed to ensuring proper compliance with legal provisions. Please note that the text below complies with the recent provisions of GDPR 2016/679, as well as the privacy regulations in force in the countries in which Bros Manifatture srl, Bros USA Corporation, and Bros Asia Limited (hereinafter "Bros Group") offer their website services. The Bros Group hereby declares that Bros Manifatture Srl is the data controller and owner of the domains and websites. BROS MANIFATTURE Srl, as the data controller and owner of the domain and website, provides users who connect to www.rosato.it with the rules for the correct and authorized use of the photos, images, text, and any other documents published here. These Legal Notices are divided into different sections identifying the current regulatory areas defined by this company. Furthermore, the term "Company Data" in this context refers to: - any type of information that is processed, acquired, known, elaborated, communicated, and extracted from the pages of the www.rosato.it website; - information from links to other sites is not included. The Bros Group recognizes the importance of protecting its customers' personal data (such as identification data and financial data, including credit card numbers) and the data of users of its website(s). For this reason, the Bros Group adopts specific security policies and measures to comply with current data protection regulations and protect your personal data. It is important to note that the following information may be subject to review and addition by this company whenever necessary; to this end, and for transparency purposes, the current version number (currently version 1.0) is shown on the front cover. The Legal Notes also describe the user's browsing rights.
TRADEMARK AND INTELLECTUAL PROPERTY RIGHTS PROTECTION
BROS MANIFATTURE Srl represents not only the Owner's name, but also its trademark. Legal protection is hereby extended to the domain, based on the recognition granted by the legislator with the new Industrial Property Code (Legislative Decree 30/2005). Indeed, the new legislation allows for the defense of the domain name against acts of counterfeiting and usurpation by third parties, providing for both ordinary proceedings and precautionary measures. Specifically, Article 133 of the Italian Code of Civil Procedure allows the judicial authority to order an injunction against the use of an illegitimately registered domain, or its provisional transfer, if applicable, subject to the provision of an appropriate security by the beneficiary of the measure. In light of the above, the site and its contents are the exclusive property of the owner company, which reserves the right to grant any rights to use it to third parties. Any copying, downloading, or reproduction, in whole or in part, of the content published on this website is prohibited unless the possibility of such actions is expressly indicated. Therefore, the user is only authorized to view the site and perform all temporary reproductions, devoid of any economic significance, which are considered transitory or incidental, an integral and essential part of viewing www.rosato.it and its contents, and all other browsing operations performed solely for legitimate purposes. Copyright protection applies exclusively to this website. Regarding the regulation of links, it should be noted that the www.rosato.it website currently contains no links to other websites. Should external links be created in the future, BROS MANIFATTURE Srl does not control or monitor such websites and their content and cannot therefore be held responsible for the content of these sites and the rules they adopt, including with regard to your privacy and the processing of your personal data while browsing. The undersigned considers "surface linking," the classic link that leads the visitor to the home page of another site, to be legitimate; however, "deep linking" and "framing" are not authorized and may lead to liability for copyright infringement and unfair competition, respectively. TRANSPARENCY AND COMPLETENESS BROS MANIFATTURE Srl guarantees transparency, completeness, and accurate communication to all those with whom it interacts. The information complies with the standards of clarity and truthfulness dictated by the transparency regulations towards the Customer and in full compliance with the principles of consumer protection. The site is currently available in Italian. CONFIDENTIALITY OF INFORMATION BROS MANIFATTURE Srl places great importance on data confidentiality and security through the development of specific internal control programs and well-defined policies. Security measures are implemented for both paper and electronic management.
PRIVACY POLICY
This page describes the website's management procedures regarding the processing of users' personal data. This information applies only to the website www.rosato.it and not to other websites that may be accessed via links.
DATA CONTROLLER
In accordance with the principles of transparency and fairness established by the Privacy Code, data processing is directly owned by BROS MANIFATTURE Srl, whose complete details are listed on the home page. The domain is owned by the same owner and is registered in their name. The email address for communications is: privacy@brosmanifatture.it
Bros Manifatture srl
Via Guido Rossa, 1 63025 Montegiorgio (FM)
Bros USA Corporation
169 East Flager Street, Suite 1022 Miami, FL 33131
Bros Manifatture Asia Limited
Suite 2301, 23rd Floor, Chinachem Hollywood Centre, 1-13 Hollywood Road Central, Hong Kong SAR
DATA CONTROLLER
Pursuant to Article 28 of GDPR 2016/679, please send any information or requests to the Data Controller: resp.trattamento@brosmanifatture.it. A complete and updated list of Data Controllers can also be requested by writing to the address on this website.
INTERNATIONAL TRANSFERS OF PERSONAL DATA
If the customer has chosen to register in the Bros Group customer database, the Bros Group collects the customer's personal data in their country, such as data relating to their visits to our stores, and then transfers and stores it, in accordance with applicable law, in another country where our group companies' servers are located. The data will be transferred for the purposes described in this Policy (for example, to provide the requested services or to offer personalized services in all our stores worldwide). The privacy and data protection laws in these countries may not be equivalent to those in the customer's country of residence. Bros Group companies will take measures to ensure that customer data is processed securely, in accordance with the principles of fairness, necessity, and proportionality, and in accordance with this Policy, regardless of the country to which it may be transferred. Where permitted in the customer's country, by using the above-mentioned websites or providing us with data for the purposes set out in this Policy, the customer fully understands and clearly consents to the transfer of personal data abroad as part of the normal business operations of the Group's companies, including the collection, storage, and processing of such data in the United States and Asia. These policies represent the rules of conduct regarding the processing of personal data for all Bros Group companies and therefore regulate and permit the transfer of data between the same companies located in different geographical areas, in compliance with the guarantees established by privacy legislation (the Binding Corporate Rules principle).
PLACE AND METHODS OF DATA PROCESSING
The term "processing methods" in this context describes the technical and organizational methods implemented by Bros Manifatture srl to ensure appropriate and secure data management and storage. The data is processed electronically and on paper, is accessible to authorized personnel, and is not disclosed. Electronic storage occurs on the server located at the registered office at Via Guido Rossa no. 1 – 63833 Montegiorgio (FM) and on the server units of the provider hosting the domain; while paper-based storage occurs in the archive located at our headquarters. For the sake of transparency, please note that the domain is hosted by an external provider who is responsible for its operation and security and, in the event of violations, is subject to the responsibilities set forth by specific industry regulations. The provider is located in an EU country. The processing related to the web services of the website www.rosato.it takes place and is handled by the owner and any third-party companies acting as data processors pursuant to art. 28 GDPR 2016/679.
DATA TYPES
The term "processing methods" in this context describes the technical and organizational methods implemented by Bros Manifatture srl to ensure appropriate and secure data management and storage. The data is processed electronically and on paper, is accessible to authorized personnel, and is not disclosed. Electronic storage occurs on the server located at the registered office at Via Guido Rossa no. 1 – 63833 Montegiorgio (FM) and on the server units of the provider hosting the domain; while paper-based storage occurs in the archive located at our headquarters. For the sake of transparency, please note that the domain is hosted by an external provider who is responsible for its operation and security and, in the event of violations, is subject to the responsibilities set forth by specific industry regulations. The provider is located in an EU country. The processing related to the web services of the website www.rosato.it takes place and is handled by the owner and any third-party companies acting as data processors pursuant to art. 28 GDPR 2016/679. BROWSING DATA The computer systems and software procedures used to operate this website acquire, during normal operation, some personal data whose transmission is implicit in the use of internet communication protocols. This category includes IP addresses or domain names of computers used by users connecting to the site, URI (Uniform Resource Identifier) addresses of requested resources, the numerical code indicating the status of the response given by the server (e.g. successful, error), and other parameters relating to the user's operating system and IT environment. This data could be used to ascertain responsibility in the event of hypothetical computer crimes against the site. DATA PROVIDED VOLUNTARILY BY THE USER The optional, explicit, and voluntary sending of emails to the addresses indicated on this site entails the subsequent acquisition of the sender's address, necessary to respond to requests, as well as any other personal data included in the message. The processing of this data is exclusively for the purpose of responding to the information provided by users. Please note that with regard to data retention, the data is retained only for the time necessary to fulfill this purpose and is subsequently deleted. The information provided is acquired and managed exclusively by this firm in compliance with the principles of data integrity and confidentiality. Please note that the Personal Data collected by these websites, independently or through third parties, includes: First and last name – Phone number – Email address – Address – City – Province – Country – Company name – Profession – Website – Cookies – Usage data – IP address – Location. Unless otherwise specified, all Data requested by these sites is mandatory to allow the Data Controller to respond to your requests; therefore, if the User refuses to provide such data, it may be impossible to provide the service.
RETENTION PERIOD
The Data is processed and stored for the time required by the purposes for which it was collected. Therefore: • Personal Data collected for purposes related to the activities we carry out and for which the User has freely expressed interest will be retained until the requested services have been completed; • Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until such interest is fulfilled. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller. When the processing is based on the User's consent, the Data Controller may retain the Personal Data for a longer period until such consent is revoked. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority. At the end of the retention period, the Personal Data will be deleted. Therefore, upon expiration of this period, the right to access, erasure, rectification, and the right to data portability can no longer be exercised. The only data that, upon termination of the relationship or in the event of a request for erasure, must be retained for 10 years are the data contained in sales invoices for tax purposes, together with the data contained in commercial communications (whether by email, certified email, or paper) to comply with the provisions of the Italian Civil Code (Article 2214) regarding commercial communications (a period defined as 10 years). Bros Manifatture srl informs that the data submitted via the form on the "Contact" page are retained both electronically and in paper form at its headquarters. They are retained for a maximum period of 1 year, in the event that no projects are launched; however, by law, such data is retained by our provider, located in an EU country, for a period of 6 years in accordance with Law 167/2017 – Data Retention.
COOKIES
In accordance with the provision of the Italian Data Protection Authority of June 14, 2014, it is stated that this site uses technical cookies, i.e., navigation cookies; it does not use analytics cookies or functionality cookies. No personal user data is acquired by the site. Cookies are not used to transmit personal information, nor are persistent cookies of any kind, or user tracking systems, used. The use of session cookies (which are not stored permanently on the user's computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to enable safe and efficient navigation of the site. Cookie settings are handled by the Web Master appointed by the company, and the domain www.rosato.it is hosted on the server of an external provider (ITALY). More information regarding the cookies on this site is available at the following page: www.rosato.it/cookie_policy/
OPTIONAL NATURE OF DATA PROVISION
Aside from what is specified for browsing data, the user is free to provide personal data by filling in the appropriate form in the "CONTACTS" section of the website to request information or for other communications. For the sake of completeness, it should be noted that in certain cases, not covered by the ordinary management of this website, the Authority may request information pursuant to GDPR 2016/679 for the purposes of monitoring the processing of personal data; in these cases, responding is mandatory under penalty of an administrative fine.
RIGHT TO BE FORGOTTEN
Except as specified for browsing data, the user is free to provide personal data. The Company respects the User's right to be forgotten, or the right to obtain the deletion of data concerning him or her without undue delay.
RIGHTS OF INTERESTED PARTIES
Each data subject has the right at any time to obtain confirmation of the existence or otherwise of his or her data and to know its content and origin, verify its accuracy, or request its integration, updating, or rectification (Article 7 of the GDPR 2016/679). Each user also has the right to revoke any consent previously granted for informational or marketing purposes. Pursuant to the same article, the data subject has the right to request the deletion, anonymization, or blocking of data processed in violation of the law, as well as to object, for legitimate reasons, to its processing. The data subjects to whom the personal data refers have the right, at any time, to obtain: • Confirmation of the existence or otherwise of such data; • Know its content and origin; • Verify its accuracy; • Request its integration, updating, or rectification (Article 7 of the GDPR 2016/679); • The deletion of data or its anonymization; • Block data or object, for legitimate reasons, to its processing. Requests should be sent by email to: privacy@brosmanifatture.it. The Data Controller protects the User's digital identity through the implementation of specific policies. The User is required to provide, in the appropriate form on the website, only the information strictly necessary to achieve the purposes for which it is provided. The Data Controller and each designated person implement the security measures deemed most appropriate to ensure the security of data processing and storage.
PRIVACY POLICY SOCIAL NETWORK
VERSION 1/2021 - DRAWN UP IN ACCORDANCE WITH GDPR 2016/679. THE DETAILED TEXT CAN BE REQUESTED USING THE REFERENCES CONTAINED IN THIS DOCUMENT
The purpose of this Privacy Policy is to ensure that Users can fully transparently verify the processing of their data on our company's social media profiles, BROS MANIFATTURE SRL. Specifically, BROS MANIFATTURE SRL, as Data Controller, respects and protects the privacy of its users and is committed to transparency regarding the processing of personal data. This policy is intended to illustrate how BROS MANIFATTURE SRL, as Data Controller, processes personal data using various social media platforms, such as Facebook, Instagram, and YouTube. This policy may be subject to change, so we encourage users to consult it for the most up-to-date version.
CUSTOMER DATA
For the purposes of this document, the term "User Data" refers to all the information freely provided by the user in the appropriate forms on the social media pages of our company, Bros Manifatture Srl. The Personal Data processed may include, but is not limited to: – Information such as name, surname, email address, age, gender, country, professional qualifications, current or previous employer, educational background, profile picture, interests, list of friends and/or followers, and other publicly available information, provided that the user has published all such information on their social media profile. – Additional information that the user provides by posting on the social media page of our company, BROS MANIFATTURE SRL, comments and/or "Likes" on our posts, images, or by sending direct messages. If the user decides to subscribe to a newsletter, about products, related services, or if they request to be contacted for information, they may provide us with their personal data such as name, surname, email address, and telephone number. Furthermore, we inform users that various social media platforms collect personal data through the use of cookies and similar technologies, including cookies collected via social networks such as Facebook, Instagram, and YouTube. In some cases, for example, in relation to our Facebook page, we act as a "Joint Controller" with Facebook for the processing of personal data. Therefore, we recommend that users read the Facebook social media privacy policy to understand how Facebook processes personal data. Users can find the various privacy policies of the various social media platforms Facebook, Instagram, and YouTube.
USER POLICY
Users who connect to our company's social media pages, BROS MANIFATTURE SRL, are required to comply with the policies described below. ➢ Users must be particularly cautious about including, in their posts, data that could reveal, even indirectly, the identity of third parties. In such cases, they declare that they have personally requested the third parties' consent for dissemination; ➢ Users must be aware that the content of their messages and/or posts may be seen by the entire community. Therefore, BROS MANIFATTURE SRL reserves the right to remove, without notice, any posts deemed inappropriate or not compliant with this policy or applicable law; ➢ Users must be polite and courteous in their posts. The use of inappropriate language, language that is detrimental to our firm's image, or language that is discriminatory based on sexual orientation, personal or social conditions, race, language, or nationality is prohibited. ➢ The user must refrain from violating copyright, privacy, or unauthorized use of trademarks; ➢ The user is prohibited from advertising other brands or logos on our pages; ➢ The user is prohibited from posting SPAM content that could cause harm to other fans (viruses, malware, etc.) or to the legitimate owners.
WEBSITE
BROS MANIFATTURE SRL's social media pages [Facebook, Instagram, and YouTube] may contain links to websites owned by the Data Controller or to websites owned by third parties. This Privacy Policy does not apply to third-party websites, so if you would like information about their data collection methods and distribution policies, we recommend contacting them directly.
TRANSFER OF DATA ABROAD
We will not transfer your personal data outside the European Union or to countries that do not guarantee an adequate level of data protection.
RIGHTS OF INTERESTED PARTIES
Each data subject has the right at any time to obtain confirmation of the existence or otherwise of his or her data and to know its content and origin, verify its accuracy, or request its integration, updating, or rectification (Article 7 of the GDPR 2016/679). Each user also has the right to revoke any consent previously granted for informational or marketing purposes. Pursuant to the same article, the data subject has the right to request the deletion, anonymization, or blocking of data processed in violation of the law, as well as to object, for legitimate reasons, to its processing. The data subjects to whom the personal data refers have the right, at any time, to obtain: • Confirmation of the existence or otherwise of such data; • Know its content and origin; • Verify its accuracy; • Request its integration, updating, or rectification (Article 7 of the GDPR 2016/679); • The deletion of data or its anonymization; • Block data or object, for legitimate reasons, to its processing. Requests should be sent by email to privacy@brosmanifatture.it. The user has the right to submit a complaint to the Data Protection Authority.
DATA RETENTION
With regard to the storage of data on social media pages, the Data Controller is required to follow the policies established by the Service Provider.