Movimoda Privacy and Cookies Statement
1.1 Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person (e.g. Cookies, Usage Data, first name, last name, phone number, address, state, county, email address, ZIP/Postal code, city, ID card number, country and date of birth).
1.2 Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
1.3 User (or You)
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
1.4 Data Subject
The natural person to whom the Personal Data refers.
1.5 Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this Privacy and Cookie Statement. This may include: EBE GROUP S.r.l., with its address at Caserta (CE) Corso Trieste 126, Italy and TLG COMMERCE LTD, with its address at Room 48, Internal 401, Block 1, Floor 4, No.6, Chaoyangmenwai Street, Chaoyang District, Beijing.
1.6 Data Controller (or Owner, or We)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application, Movimoda (Shanghai) Trading Co. Ltd., with its address at 290 Lianda Road, Pujiang Town, Minhang District, Shanghai.
1.7 This Application
The means by which the Personal Data of the User is collected and processed, including, but not limited to, the website www.renatobalestra.cn (the “Website”).
The service provided by this Application as described in the relevant Terms and Conditions and on this website/application.
Small sets of data stored in the User's device.
2. Minimum Age
Protecting the safety and privacy of children is very important to us. We do not accept registrations or orders submitted by, and will not knowingly collect or use personal data from anyone under the age of sixteen (16) years, or any other age limit sets out by the law of the People’s Republic of China or his/her country of residence. By registering or making any purchase on the Website, you confirm that you have reached the age of majority in the People’s Republic of China and in your country of residence.
3. Privacy and Cookie Statement
Every time You use this Application You will be bound by the then current Privacy and Cookie Statement and You should review this text every time You use the Application to verify that You agree with it.
4. Data Collection
4.1 This Application, by itself or through third parties, collects some Personal Data from its Users. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
4.2 You are hereby notified that the Personal Data You have provided or will provide (including, but not limited to, through the form available on the website in the contact section, through customer service phone numbers, etc.) will be treated confidentially and will now become part of a database file being the property of the Owner. This Data will be used and processed by the Owner and/or by the Data Processor exclusively for the following purposes:
4.2.1. the full performance and enforcement of the purchase and sale contract over the products You have purchased, or of any other contract between us;
4.2.2. attending to Your requests;
4.2.3. providing You with information about the products of Renato Balestra, including, as regards the above referred products, sending commercial communications by e-mail or by any other equivalent electronic communication means (such as SMS) as well as phone calls; an
4.2.4. other purposes set out in Parts II and III.
5.2 By accepting this Privacy and Cookie Statement you consent to the use of the Cookies used in this Application, which are described below.
6. Mandatory and Non-Mandatory Data
6.1 Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that certain Data are not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
6.2 Users who are uncertain about which Personal Data are mandatory are welcome to contact the Owner.
7. Exercise of User’s Rights
7.1 Movimoda, being the data controller in charge of the file, undertakes to maintain your personal information confidential and to ensure the exercise of your access, rectification, cancellation and objection rights by sending a letter to the above referred addresses, as provided in the paragraph below, to the attention of Grazia Lovato. You can also exercise your rights by sending an e-mail to email@example.com. In both cases identity accreditation by any valid mean is necessary. In the event that You decide to exercise the aforementioned rights and You have provided to us an E-mail address as part of said personal data, we will appreciate if you could also express that circumstance by indicating the relevant e-mail address in respect of which the rights of access, rectification, cancellation and objection are exercised. 7.2 Movimoda will ensure that you are able to exercise your right of account cancellation by means of sending a letter to the above referred addresses, to the attention of Grazia Lovato. You can also exercise your right by sending an email to firstname.lastname@example.org. In the event of account cancellation, Movimoda will delete your information, except for information that may be kept pursuant to laws, administrative regulations, the T&C or the Privacy and Cookies Statement (please see Part II, Point 4).
8. Disclosure, Sharing, Assignment, Transfer of Data
8.1 To fulfil the purposes indicated in sections 3 and 4 above, we could be required to assign or to disclose the information that You have provided to us to other companies belonging to the same group as EBE, TLG and/or Movimoda. This assignment or disclosure may involve the transfer of the information that You have provided to us to other countries (in particular, those countries where EBE, TLG and Movimoda have business operations, such as Italy and France). We will transfer Your information outside the People’s Republic of China (whereby, for the purposes of this Privacy and Cookie Statement, “People’s Republic of China” does not include: Hong Kong Special Administrative Region, Macau Special Administrative Region, and Taiwan) only if we believe that in these countries or districts there are complete protection and security measures for the protection of Your personal data as well as compliance with the applicable laws regarding privacy and data protection. We understand that by providing information in this Website or otherwise to us, You expressly authorize us to share and/or to assign your information to any of the aforementioned companies whether in the People’s Republic of China (as defined above) or outside the People’s Republic of China (as defined above).
8.2 Likewise, only if absolutely necessary for the fulfillment of the above-mentioned purposes, as well as for the development or support of certain services or functionalities, third party suppliers will have access to your personal data, as per example suppliers of technological services, financial transaction management, logistics services, transportation, order management and customer service, and/or analysis of the transactions made through the Website in order to provide our users with sufficient guarantees in purchasing transactions, etc.. Your consent to this access/disclosure, includes those cases where for efficiency of the provision of the services, providers may be located in and/or have access to the data from countries or territories outside People´s Republic of China (as defined above), e.g. territories/countries within the European Union, will be deemed as granted by clicking the acceptance button. Please do NOT proceed if you do NOT agree on the abovementioned Data usage and transfer conditions.
We take in great consideration the protection of the information of our customers. We have adopted specific technical and organizational safety measures to protect personal information and avoid that such information be affected by any problem, or be illegally disrupted, lost, modified or being disclosed or accessed without consent. In addition, in order to protect your personal information also beyond our sphere of control, You must have your computer regularly maintained (for instance, by installing updated versions of anti-virus programs); your internet provider must adopt measures that are suitable to ensure the safe transfer of data through internet (for instance, firewall protection and spam emails filters). Although we adopted all the possible measures to protect the safety of your personal information, we still cannot guarantee that the information that you disclosed to us is 100% safe, and we cannot guarantee that leaks of your personal information will not occur. Your acceptance of carrying out commercial transactions through internet involves security risks, You will not claim EBE, TLG and/or Movimoda, and/or other parties entrusted to process your information to take responsibility for any leak of information, unless this has been cause by our negligence.
10. User’s Undertakings
The User (You) hereby guarantees that the Personal Data provided is true and accurate and undertakes to notify any change or alteration to the same. In case you provide us with third parties’ Personal Data, you guarantee to have informed the relevant third parties and obtained their consent for the purposes indicated above. Any loss or damage caused to this Application or to the person responsible for this Application or to any third person through the provision of erroneous, inexact or incomplete information on the registration forms will be the exclusive responsibility of the User.
Should you have any enquiry, suggestion, feedback or complaint, or should you need any explanation regarding the Privacy and Cookies Statement, please contact us through the Website or by email to the address email@example.com.
1. How are Data processed?
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
2. What is the legal basis of processing?
The Owner may process Personal Data if one of the following applies:
• Users have given their consent for one or more specific purposes;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
3. Where are Data processed?
The Data are processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the People’s Republic of China or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
4. For how long are Personal Data retained?
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:
• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document (please see Point 5) or by contacting the Owner.
• The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
• Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiry of the retention period.
5. For what purposes are Data processed?
5.1 Subject to the User’s consent and a “just reason” or a legal basis, the Data concerning the User are collected and processed to allow the Owner to provide its Services, as well as for the following purposes:
• Processing is necessary to perform the contract with the User or to adopt those procedures set out in the contract or requested by the User (e.g., sales contracts);
• Processing is compulsory in order to comply with statutory obligations;
• Processing is in our legitimate interests as an enterprise, and our interests do not exceed the User’s interests, basic rights or freedoms. Our legitimate interests may include our interest in using the personal information of our customers and users of this website for carrying out and developing our business activities (including general marketing activities) with current and potential customers and users of this website, as well as for establishing, exercising or defending legal claims; or
• Processing is based on the explicit prior consent of the User, such as separate and customized marketing activities.
We process the User’s personal information for the
Our processing of the User’s information is based on
the following grounds:
To process your purchase and to provide
you, through this Website, the services and the information your requested
To manage your account
To verify and implement all the financial
transactions connected with your payment
To monitor the download of data from this
To better know our customers and to
improve, according to the laws, the benefits of our services
To distinguish the visitors of this
To better know our customers and to
improve, according to the laws, the benefits of our services
To implement data analysis and market
To better know our customers and to
improve, according to the laws, the benefits of our services
To expand our information collection (for
instance: through the information collected by a third party; the information
you agree, through social networks, to share with us and / or with our affiliate
companies, including the
details of any transactions implemented through programs (applications) in public social networks
through us or through our affiliate companies and the information
reciprocally shared with us and / or with our affiliate companies through
public social networks (“public social networks” includes, but it is not
limited to, Facebook, Instagram, WeChat and any programs (applications)
affiliated with WeChat, Sina Weibo, etc.) and / or information collected by
us from public data base) in order to analyse your product preferences, your
purchase history and your interactions with this Website.
Your prior express written consent
To liaise with you in order to address
your questions or complains
Your prior express written consent
To send you offers, promotions and news
regarding special events, information and updates, regarding our products as
services, as well as other commercial information you might be interested on
(through SMS, emails or phone calls), and based on your interests and
purchase habits (this is especially based on our customers analysis)
customize your experience. We may also use the information we collected
regarding you in order to support the advertising of our products and
services on third parties’ websites. Please check our Cookies policy to
obtain more information on this.
express written consent and our legitimate interest to obtain our customers /
potential customers’ most updated information regarding our services and
6. What are the User’s rights in relation to his/her Data?
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. For example, if the Users wish to opt-out of receiving electronic marketing communications, they can change their settings in their account on the Website, use the 'unsubscribe' link provided in the Owner’s emails or reply STOP to the Owner’s SMS, or otherwise contact the Owner directly, and the Owner will stop sending the Users communications.
• Access their Data. Users have the right to learn if Data are being processed by the Owner, obtain disclosure regarding certain aspects of the processing and in some cases, to obtain a copy of any of their personal data that the Owner may hold.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for them to be updated or corrected. The Users can see and update most of this data themselves online, or by contacting the Owner directly.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data by the Owner.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing them. The Users may restrict the processing of their Data under (but not limited to) the following circumstances:
o The Users contest the accuracy of their personal information until the Owner has taken sufficient steps to correct or verify its accuracy;
o The processing is unlawful, but the Users do not want the Owner to erase the Data;
o The Owner no longer needs the Personal Data for the purpose of the processing purposes, but the Users require such data for the establishment, exercise or defence of legal claims; or
o The Users objected to processing justified on legitimate interest grounds (see below) pending verification as to whether the Owner has overriding compelling legitimate grounds to continue processing.
o Where personal data is subject to restriction in this way, the Owner will only process it with your consent or for the establishment, exercise or defence of legal claims, in accordance with local legislation.
• Right to object to processing justified on legitimate interest grounds - where the User is relying upon legitimate interest to process personal data, then the Users have the right to object to that processing. If the Users object, the Owner must stop that processing unless the Owner can either demonstrate compelling legitimate grounds for the processing that override interests, rights and freedoms of the Users or where the Owner needs to process the data for the establishment, exercise or defence of legal claims. Where the Owner relies upon legitimate interest as a justification for processing, he believes that he can demonstrate such compelling legitimate grounds, but the Owner will consider each case on an individual basis.
• Right to object to process the personal data about the Users for the Owner’s own direct marketing purposes. Where the Owner process the Data for his own direct marketing purposes, the Users are entitled to raise any objection at any time.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below. You also have the right to lodge a complaint with us or a regulatory authority if you believe that the handling of your personal information violates the relevant laws.
• Details about the right to object to processing:
- Where Personal Data are processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
- Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
• The Users also have the right to lodge a complaint with a supervisory authority if they consider that the processing of their personal data infringes applicable law.
• For further information regarding the Users’ rights, to exercise any of the Users’ rights, or if the Users have any complaints or questions regarding the processing of their personal data please contact the Owner. Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document.
• Please note that the Owner may request proof of identity, and where permissible under applicable law, the Owner reserves the right to charge a fee where permitted by law, for instance if the request of the Users is manifestly unfounded or excessive. The Owner will endeavour to respond to their request as early as possible and always within one month, and in any case within the applicable timeframes.
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document.
7. Changes to this Policy
We may occasionally change this Policy, for example, to comply with new requirements imposed by the applicable laws or technical requirements. We will post the updated Policy on the Website. We may also notify You in case of material changes and seek your consent to those changes, where required by applicable law. You are thus encouraged to periodically review this page.
1. What is a cookie?
A cookie is a small text file that a website places in your PC, telephone or any other device, with information on your navigation in that website. Cookies are necessary to facilitate navigation and to make it friendlier and they do not damage your computer. Some of the purposes for which Cookies are installed may also require the User's consent. Where the installation of Cookies is based on consent, such consent can be freely withdrawn at any time following the instructions provided in this document.
Although in this policy the general term “Cookies” is used since it is the principal method of storing information that this website uses, the browser's "local storage" space is used for the same purposes as the cookies. In this regard, all the information and provisions regarding Cookies are also applicable to this "local storage".
2. What are Cookies used for in this Website?
The cookies are an essential part of how our website functions. The main objective of our cookies is to improve your navigational experience. For example, the cookies help us to identify you (if you are registered in our website), to remember your preferences (language, country, etc.) during the navigation and in future visits, to manage the shopping cart, to allow you to carry out on-line purchases, etc. The information collected in cookies also allows us to improve the website, by means of estimates on the numbers and patterns of use, the adaptation of the website to the users' individual interests, the improved speed of the searches, etc.
In particular we use:
A. Session cookies, which only last for the duration of a browsing session. They are usually used to facilitate the access to the services on our Website, to authenticate you when you are a registered member, and to remember what a user has put in their shopping basket, and
B. Persistent cookies, which last for more than one visit. They are used to remember a user’s preferences and actions within the Website. In this case, when a user returns to our Website, or visits sites that use the same cookies, the site reads the cookies and identifies the user’s browser.
Among these cookies it is possible to refer to:
C. First party cookies, which are supplied by the website you are visiting, i.e., www.renatobalestra.cn and can be read only by such site. For example the cookies that maintain products in the shopping bag of a user who is in the meantime still surfing the site. First party cookies can be either session or permanent cookies.
D. Third party cookies, which are meant to collect data in an anonymous way, for example analytics information, including browsing statistics. Other third party cookies are meant to track our visitors’ response to our online promotional activities. This technology uses information about your visits to our website and third parties' sites on which we advertise, to deliver relevant advertisements. We also use this to learn which banner adverts bring users to our website. Also third party cookies can be either session or permanent cookies.
Categories of cookies on our Website
The types of cookie used on our Website can fall under one of the categories below.
A - Technical Cookies
Technical cookies include navigation or session cookies, cookies analytics and functionality cookies.
We do not need to obtain your consent to use these Cookies.
A.1: Navigation or Session Cookies
These cookies are strictly necessary session cookies essential to enable you to move around the website and use its essential features, such as accessing secure areas of the website. These cookies include session authentication cookies. Without these cookies, necessary services such as shopping baskets or e-billing cannot be provided.
We are able to identify you as being logged in to www.renatobalestra.cn and to ensure that you are able to access the appropriate features on our site.
If you choose to disable these cookies, you will be unable to use our site for ordering our products, but only for browsing.
These cookies are also known as performance cookies and collect information about how you use our website, so that we can improve the quality of our site and services. Some examples include which pages you visit most often, whether you get error messages from web pages, and your choices about receiving cookies or not. Performance cookies allow us to implement these choices and optimize the way our site works. All the information that these cookies collect is aggregated and therefore they do not collect personal identification information. These type of cookies may be first party or third party.
These cookies include analytics that allow us to obtain statistics about website access and browsing, monitor which website our users arrive from, help us improve the site by measuring usage information and any errors which occur during our users browsing experience, as well as the effectiveness of advertising campaigns, using aggregated information.
A.3: Functionality Cookies
Functionality cookies allow the website to remember your online settings (such as your user name, language or location) and provide enhanced, more personalized features.
These cookies can also be used to remember changes you made to text size, fonts and other parts of a web page that you can customize. They may also be used to provide services you have asked for or to prevent you from receiving services you have already refused.
These types of cookies may be first party or third party. Presently we only use first party cookies, and they can be session or permanent.
When you choose functionalities and services, you agree to our use of the related functionality cookie.
B - Profiling Cookies
Among the many types of advertising or targeting cookies, we may use Flash Cookies and Pixel Tags:
Flash Cookies: We may use local shared objects, known as Flash cookies, to store your preferences. The amount and type of information collected through Flash cookies and how they work is different from browser cookies. Please be aware that the browser's tools to manage cookies will not remove Flash cookies.
Pixel Tags: If you agreed to being tracked and/or profiled, we may use other tracking technologies (e.g., web beacons, clear gifs) in the communications we send to you. The purpose of these may be to learn about whether you have read or opened the email, whether you have interacted with any link, e.g., by clicking on it, and if so which ones. This information may be combined with other information we have gathered about you, to help us deliver more interesting communications to you, based on your browsing experience and shopping.
At any time you can manage your preferences for advertising or targeting cookies through your browser settings, or by enabling/disabling all third party cookies.
3. Information sharing
4. How to provide or withdraw consent to the installation of Cookies?
In addition to what is specified in this document, the User can manage preferences for Cookies directly from within their own browser and prevent – for example – third parties from installing Cookies.
Through browser preferences, it is also possible to delete Cookies installed in the past, including the Cookies that may have saved the initial consent for the installation of Cookies by this website.
Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses: Chrome, Firefox, Apple Safari, Microsoft Internet Explorer and Opera.
5. Notice on Third-Party Cookies
IV. ADDITIONAL INFORMATION
1. Additional information about Data collection and processing
• Legal action.
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
• Additional information about User's Personal Data
• System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
2. Information not contained in this Privacy and Cookies Statement
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
3. How are “Do Not Track” requests handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.
4. Changes to this Privacy and Cookies Statement
The Owner reserves the right to make changes to this Privacy and Cookies Statement at any time by giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
A full overview of the cookies we use on our website and their respective names and purposes can be found hereunder: