Welcome to our website www.recarlo.com (the Site).

This Privacy Policy illustrates the purpose and processing methods used by the Data Controller to process personal data. It applies every time a user browses the pages of the website www.recarlo.com (the “Site”), regardless of whether the same decides to take advantage of the services proposed by the same. This document shall be regarded as an integral part of the Site's General User Conditions as they provide information on privacy and the security systems adopted by the Site.

The processing of Personal Data of Site users will be performed in Italy and conducted in accordance with applicable European legislation and Legislative Decree 30 June 2003, No. 196 providing the Personal Data Protection Code, (the "Code").

Triboo Digitale S.r.l., with registered office in Milan (Italy), viale Sarca 336, edificio 16, Post Code 20126, tax code, VAT number and Milan Business Register number 02912880966 ("Triboo Digitale"), provides e-commerce services and the sale of products via the Site, in its capacity as joint Data Controller together with Recarlo  S.p.A., strada per Solero 3/A, 15048 Valenza (AL), Italia.

1. THE POLICY

All Data subjects are entitled to the protection of their Personal Data. Triboo Digitale respects the rights of its users to be informed on the collection and subsequent processing operations concerning their Personal Data. TD always tries to respect a strictly necessary principle when processing data that can identify the user, even indirectly. For this reason, the Site has been configured so that the use of personal data is kept to the minimum necessary and exclude the processing of personal data when the purpose of the specific activity can be achieved using anonymous data or other means, identifying the person only when needed or at the request of the authorities and police forces. This Privacy Policy will provide all useful information to understand how we collect and use the information that identifies users on the Site . 

2. WHO PROCESSES YOUR PERSONAL DATA, HOW AND FOR WHAT PURPOSES

TD is the joint Data Controller in charge of processing the personal data of Site users. TD decides the scope and processing methods to be implemented and the tools to be used as far as security measures are concerned. For purely organisational and functional requirements, we have appointed some Chief Data Processors to manage user Personal Data, for purposes strictly linked and related to the provision of services on the Site, including the sale of products. Such Chief Data Processors have been selected on account of their experience, capabilities and reliability, thorough compliance with the provisions in force applying to the processing of personal data, as also related to security matters. Chief Data Processors process the Personal Data of Site users following the instructions provided by Triboo Digitale.

Please contact the Customer Care service for a complete list of the Chief Processors assigned to processing the personal data of Site users, or send an e-mail to: privacy@triboo.it.

Personal Data are mainly processed in electronic format and in certain cases also in paper format, such as for instance, when the processing of personal data is necessary to prevent fraud on the Site.

Personal Data shall be retained in the form that allows users to be identified for the time strictly necessary for the purpose for which the data were collected and subsequently processed and, in any case within the limits foreseen by the laws in force. To ensure that Personal Data is always accurate and updated, pertinent and complete, Users are asked to kindly notify us of any changes to the same sending us an e-mail to: privacy@triboo.it.

Further to what already provided for above, the personal data of Users shall not be disclosed to third parties for purposes not permitted by law or without their express consent.

Personal data may be made available to third parties, for ancillary purposes related to the provision of services required by the user. For further details on this aspect, please consult paragraph 4 below. Users can at any time obtain an updated list of Chief Data Processors by sending a request to the following e-mail address: privacy@triboo.it.

User personal data can be disclosed to Police forces or Judicial authorities, for instance pursuant to Site anti-fraud services, in accordance with the laws in force and whenever requested. Personal data will not be transferred abroad to Countries other than those belonging to the European Union, which do not guarantee a sufficient level of privacy protection. If the above should be necessary to achieve the purposes posed by Triboo Digitale, we will ensure that the transfer of Personal Data to Countries which do not belong to the European Union and do not guarantee adequate levels of protection, will only be implemented after such parties and Triboo Digitale have all signed specific contracts containing clauses for the protection of Personal Data, in accordance with applicable law and regulations.

The purposes for which Personal Data are requests and processed shall be specifically disclosed each time in the Information Note text provided on the page where the same are requested to confer their Personal Data.

There may be cases where Triboo Digitale processes third-party personal data communicated directly by Triboo Digitale users, e.g. when the user intends to tell a friend about a service at the Site, or when the user purchases a product to be sent to a friend or when the subject paying for the purchase is different to the subject to whom it will be delivered.

In the above cases, Triboo Digitale, to the extent required by law, shall fulfil its disclosure obligations to the indicated user and, where necessary, request relative consent, upon registration of the relevant data in its Personal Data archives.

3. DENYING CONFERRAL OF PERSONAL DATA AND RELATIVE CONSEQUENCES

Conferral of Personal Data to Triboo Digitale and, in particular, personal data, email address, mailing address, credit card/debit card and bank details and phone number, is required in order to fulfil the aforementioned purposes.

Some of the aforementioned data may be indispensable so as to fulfil the obligations imposed by the law or other regulations, or to provide other services you may have requested as provided on the Site.

Refusal to disclose certain essential Personal Data, identified on the Site by an asterisk (*), may make it impossible to complete all purchase contract phases, and/or fulfil all obligations required by the laws and regulations in force. Failure to disclose certain Data can therefore, according to individual circumstances, constitute a legitimate and justified reason preventing the execution of the supply of services via the same.

4. TO WHOM PERSONAL DATA IS DISCLOSED

No Personal Data shall be disclosed, assigned or otherwise transferred to third parties without informing users and obtaining their consent in advance, when required by law.

5. HOW WE COLLECT PERSONAL DATA ON THE SITE

Triboo Digitale collects Personal Data and other information during the online registration process. These data are processed by Triboo Digitale within the limits and purposes illustrated in the Information Note presented to users in the relative data collection section.

6. SECURITY MEASURES

Triboo Digitale has taken all suitable security measures to minimise the risk of destruction or loss, even accidental, of such Data, further to unauthorised access or processing that is not authorised or does not comply with the scope and purpose of collection indicated in this Privacy Policy.

However, as it is impossible to guarantee that such measures for the security of the Site and the transmission of data and information on the same Site limit or exclude any risk of unauthorised access or dissemination of data, we recommend users check that they have an updated antivirus protection system installed on their computer, which protect incoming and outgoing data, and that their Internet provider uses firewalls and anti-spamming filters where suitable for the security of data transmission on the web.

7. RIGHTS TO ACCESS PERSONAL DATA AND OTHER RIGHTS

Users are entitled to obtain confirmation as to whether or not personal data concerning them exists, regardless of their being already recorded, and communication of such data in an intelligible form.

They are also entitled to receive information concerning the origin of the Personal Data; the purpose and processing methods; the logic used in the case where the data is processed using electronic equipment; the personal data of the Data Controllers, information on the subjects or categories of subjects to whom the personal data may be disclosed or who may become aware of such data in their capacity, for instance, as Chief Processors or Designated Officers. Part of this information is contained in our Privacy Policy; if users wish to receive further details, simply send an e-mail to privacy@triboo.it.

Users are always entitled to obtain from Triboo Digitale:

- updating, rectification or integration of Personal Data;

- erasure, anonymisation or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;

- certification to the effect that the operations indicated above have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared to the right that is to be protected.

Users are also entitled to oppose, totally or partially:

-  on legitimate grounds, to the processing of personal data concerning them, even though they are relevant to the purpose of the collection;

- to the processing of Personal Data concerning them, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

- Users are entitled to exercise their rights at any moment in time, within the terms and conditions of the law, sending such requests by e-mail to Triboo Digitale at privacy@triboo.it; we will respond to your mail as soon as possible.

8. LINKS TO OTHER WEBSITES

Triboo Digitale does not control or monitor the operations of such websites or their content. Triboo Digitale shall not be held liable for the web content of such sites or the rules adopted by the same regarding the processing of Personal Data whilst browsing their website. We therefore recommend Users pay attention when visiting such websites and read their terms and conditions of use and privacy policy carefully. This Privacy Policy does not apply to third party websites and Triboo Digitale is under no circumstances liable for the privacy policy applied by those websites.

The Site provides links to these websites exclusively to assist users in their search and browsing activities and to facilitate links to other websites on the Internet. Posting of such links does not infer that Triboo Digitale recommends the use or browsing of these websites, nor any guarantee of their content, services or merchandise supplied and sold to Internet users.

9. COOKIES

Cookies are small units of text strings that Sites visited by the user send to the user's device; they are then stored on the device and transmitted to the site again next time the user visits it again. Whilst browsing a website, the user may also receive cookies on his device that are sent by other sites or web servers (so-called "third party cookies")

A distinction is usually made between technical cookies and profiling  cookies.

• Technical Cookies

These are used for the sole purpose of "conveying a communication to an electronic communication network or, to the extent strictly necessary to the company so as to provide a service, the information explicitly requested by the member or user to provide such service " (see art. 122, paragraph 1 of Legislative Decree  196/2003).

They are not used for any other purposes  and are normally installed directly by the website owner or manager. The can be divided into navigation or session cookies that guarantee regular browsing and use of the website ; analytic cookies, similar to technical cookies used directly by the site manager to collect information in an aggregate manner, on the number of users and how they visit the site; functional cookies that allow the user to navigate according to a series of selected options (e.g. the language, products selected etc.) so as to improve the service provided to the same.

• Profiling cookies

These are used for the sole purpose of "conveying a communication to an electronic communication network or, to the extent strictly necessary to the company so as to provide a service, the information explicitly requested by the member or user to provide such service " (see art. 122, paragraph 1 of Legislative Decree 196/2003).

Profiling cookies are used to create user profiles and are used to send advertising message in line with the preferences shown by the same during the browsing sessions.

 [NB: it is necessary to understand which types of cookies are used on the Site and amend the content of this paragraph accordingly.]

10. CONTACTS

Users wishing to receive further information on how Triboo Digitale processes Personal Data should send an e-mail to the following email address: privacy@triboo.it. To receive further information and be updated on the rights and the regulations concerning the protection of persons in relation to the processing of Personal Data, please visit the website of the Authority for the Protection of Personal Data at http://www.garanteprivacy.it

11. APPLICABLE LAW

This Privacy Policy is governed by Italian law and in particular by the Data Protection Code which regulates the processing of personal data - including those retained overseas - carried out by anyone who is resident or located in Italy or using instruments located in Italy.

The Code ensures that Personal Data are processed by respecting data subjects’ rights, fundamental freedoms and dignity, particularly with regard to confidentiality, personal identity and the right to Personal Data protection.

12. CHANGES AND UPDATES TO THE PRIVACY POLICY

Triboo Digitale may amend or simply update all or part of this Privacy Policy also when amendments are made to laws or regulations that govern protection of personal data and user rights. The changes and updates to the Privacy Policy shall be notified to the users in the Homepage of the Site as soon as they become applicable, and they will be binding once published in this section. We therefore recommend users access this section regularly in order to check the most recent and updated version of the Privacy Policy.