Privacy Policy
Privacy Notice for Users and for any third parties depicted in the Content
Triboo Digitale S.r.l., with registered office at Viale Sarca 336, building 16, 20126 Milan, Italy, VAT/tax code and registration number with the Milan Register of Companies IT02387250307, and Bburago Italia S.r.l., with registered office at Via Giovanni Battista Mauri no. 9, Monza, Italy, VAT/tax code and registration number with the Milan Monza Brianza Register of Companies 13149880968, as joint controllers of the processing ("Joint Controllers"), inform you, pursuant to Articles 13 and 14 of EU Regulation 679/2016 ("GDPR"), that they will process your personal data, collected through the website www.bburago.com (the "Website"), as described in this notice.
The Joint Controllers have designated Triboo Digitale as point of contact pursuant to Article 26 GDPR ("Point of Contact"). Therefore, to exercise your rights or request information about the processing of personal data, you may contact the Point of Contact at privacy@triboo.it.
The personal data processed are the data provided when you interact with the Website and with the services offered by the Joint Controllers, such as when you register, purchase products, upload or share content, grant any consents, or contact customer care.
1. Purposes and legal bases of processing
Your personal data will be processed for the following purposes.
1. To allow registration on the Website and use of the Website services, including the creation and management of your reserved area, the management of your account, access to MYarea and the use of services connected with My Garage, such as uploading, managing and sharing photos, videos, images, profile photos, biographies, product collections and other content made available by you.
2. To conclude and perform purchase agreements for products offered on the Website, including order management, payments, delivery, returns, refunds, warranty, after-sales assistance and all activities connected with the purchase.
3. To respond to your requests, provide customer care, manage reports and complaints, and provide the information requested through the contact channels available on the Website.
4. To comply with legal, accounting, tax, administrative and regulatory obligations, and to fulfil requests from competent authorities.
5. Subject to your consent, to send marketing communications, newsletters, commercial offers, promotions and information relating to the products and services of the Joint Controllers or their partners, through automated and traditional contact methods.
6. Subject to your consent, to analyse your preferences, interests and purchasing habits, including through profiling activities, in order to personalise offers, communications, services and content.
7. Subject to your specific consent, to use images, photographs, videos, audio, voice, statements, interviews, testimonials or other content uploaded by you or created with your participation, including through publication on the Website, social networks, newsletters, advertising materials or other online and offline communication channels, for promotional, editorial or commercial purposes connected with the Website, products or brand.
8. To ascertain, exercise or defend a right in court or before competent authorities.
The legal bases for processing are, depending on the case, performance of a contract or pre-contractual measures, compliance with legal obligations, the consent of the data subject, and the legitimate interest of the Joint Controllers in protecting their rights and ensuring the security and proper functioning of the Website.
2. Categories of personal data processed
The Joint Controllers may process the following categories of personal data:
If the Content uploaded by the user contains personal data of third parties, including images or other information relating to people depicted in the Content, those data are collected from the user who uploaded or shared the Content. The user represents and warrants that he or she has informed such third parties and has obtained, where required, the necessary consents or other appropriate legal basis.
3. Methods of processing
Processing will be carried out using IT and digital tools and, where necessary, paper-based tools, according to principles of lawfulness, fairness, transparency, data minimisation, confidentiality and security. The Joint Controllers adopt technical and organisational measures suitable to protect personal data against unauthorised access, loss, destruction, alteration or unlawful disclosure.
4. Provision of data
Providing data for the purposes connected with registration, purchasing, use of services, customer care and compliance with legal obligations is necessary. Failure to provide such data may make it impossible to use the Website services, complete purchases or receive the requested assistance.
Providing data for marketing, profiling and promotional use of content, images, voice, interviews or testimonials is optional. Failure to provide consent does not affect registration on the Website or the purchase of products.
4-bis. Interviews, image rights and promotional content
Where the user gives specific and express consent, the Joint Controllers may contact the user to take part in interviews, collect testimonials, photos, videos, audio or other content, and use such materials on the official channels of the Joint Controllers or their partners, such as websites and social network pages, for promotional purposes.
In that case, the processing may also concern image, voice, statements and other personal data provided directly by the user or acquired during the interview or creation of the content.
Consent may be withdrawn at any time, without affecting the lawfulness of processing carried out before withdrawal. Withdrawal may limit or prevent further use of the promotional content, without prejudice to uses already made and to any technical time needed to remove or replace published materials.
5. Further Purposes of Processing: Use of Tracking Pixels in E-mail Communications Sent by the Controllers to the Data Subject
The Controllers use tracking pixels in e-mails sent to the Data Subject for the marketing and newsletter purposes referred to in the preceding sections, in order to:
(A) carry out an aggregate statistical count to measure the overall message open rate, improve e-mail deliverability and counter spam. The Controllers inform Data Subjects that no personalised measurements are carried out for this purpose; unique pixels are used (i.e. they are not differentiated for each Data Subject, but are the same for all recipients of the same communication), and techniques are adopted to anonymise the technical data associated with use of the pixel (IP address, client, etc.). The legal basis for this purpose is the exemption from consent set out in Article 122(1) of Legislative Decree No. 196 of 30 June 2003, as amended by Legislative Decree No. 101 of 10 August 2018 (the “Privacy Code”), since, based on the guidance provided by the Italian Data Protection Authority, the use of such tracking pixels is considered capable of falling within this statutory exemption;
(B) carry out an individual measurement and analysis of the open rate of e-mail communications sent to Data Subjects. The legal basis for this purpose is consent pursuant to Article 122(1) of the Privacy Code. Based on the guidance provided by the Italian Data Protection Authority, any specific consent given by the Data Subject for marketing purposes and newsletter purposes referred to in the preceding sections is also considered to include consent to receive the tracking pixels inserted in those communications. The Data Subject who has consented to the processing of their personal data for marketing and newsletter purposes referred to in the preceding sections (which consent also covers the use of tracking pixels for non-technical purposes inserted by the Controllers in those communications) may withdraw their choices at any time, including on a granular basis. In other words, the Data Subject may: (i) withdraw the single consent given, thereby preventing receipt of any further communications for marketing and newsletter purposes; or (ii) withdraw consent only in part, solely in relation to receiving tracking pixels within those communications (through a dedicated page accessible via a link included in those communications). Personal data collected through tracking pixels used by the Controllers in e-mails, with the Data Subject’s consent for marketing and newsletter purposes (unless the Data Subject has exercised the granular withdrawal described above), will be processed for 24 months from the date on which the Data Subject first opens the e-mails.
6. Data retention
Personal data will be retained for the time strictly necessary to achieve the purposes for which they were collected and, in any case, for the periods required by applicable law. Data connected with purchases and accounting or tax obligations will be retained for the periods required by law. Data processed on the basis of consent will be retained until consent is withdrawn or for the shorter period indicated by the Joint Controllers. Content uploaded to MYarea will be retained until deletion by the user or until account closure, unless further retention is necessary for legal obligations or to protect rights.
7. Communication and transfer of data
Personal data may be communicated to employees and collaborators authorised to process them, to companies providing technical, logistical, payment, marketing, customer care, hosting, maintenance, IT and administrative services, to consultants and professionals, to companies of the Triboo group and to public authorities, where required by law.
The parties that process personal data on behalf of the Joint Controllers are appointed as processors pursuant to Article 28 GDPR. An updated list of processors may be requested from the Point of Contact.
Personal data may be transferred outside the European Economic Area only in compliance with the safeguards provided by the GDPR, such as adequacy decisions, standard contractual clauses or other lawful transfer mechanisms.
8. Rights of the data subject
You may exercise the rights provided by Articles 15 to 22 GDPR, including the right to obtain access to your personal data, rectification, erasure, restriction of processing, portability, objection to processing, and withdrawal of consent where processing is based on consent.
Requests may be addressed to the Point of Contact at privacy@triboo.it.
You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali), www.gpdp.it, or with the supervisory authority of the Member State in which you reside, work or where the alleged infringement occurred.
Extract from the joint controllership arrangement pursuant to Article 26 GDPR
Triboo Digitale S.r.l. and Bburago Italia S.r.l. have entered into a joint controllership arrangement pursuant to Article 26 GDPR to define their respective responsibilities in relation to the processing of personal data carried out through the Website www.bburago.com and the related services.
The Joint Controllers jointly determine the purposes and essential means of the processing connected with the management of the Website, online sales, customer care, user services, MYarea, My Garage, marketing, profiling and promotional activities where consent has been obtained.
Triboo Digitale is responsible for the technical and operational management of the Website and has been designated as Point of Contact for data subjects. Bburago Italia is responsible for the brand, products, commercial initiatives and promotional activities connected with the Website and the related services.
The essential content of the joint controllership arrangement is made available to data subjects through this Privacy Policy. Data subjects may exercise their rights against each of the Joint Controllers, without prejudice to the possibility of contacting the Point of Contact at privacy@triboo.it.
Se ti iscrivi alla Newsletter, ricevi uno sconto del 10%. E se ti iscrivi al sito, hai un ulteriore sconto del 20%.* Approfittane subito!
*I due sconti non sono cumulabili, ma sono da utilizzare, tramite codice sconto, durante due acquisti separati
