INFORMATION PURSUANT TO ARTICLE 13 OF EU REGULATION NO. 2016/679 (“GDPR”)
This privacy notice describes which of your personal data are collected by TRISTATE INTERNATIONAL SA and by Zerogrey S.r.l. (referred to in this notice as “we”), for which purposes and how they are processed. Below you will also find the necessary information to enforce your rights provided for by GDPR.
Generally, we collect your personal data when you create an account on our online store https://www.cpcompany.com, (hereinafter “Store”), when you purchase products available for the sale on the Store, when you email or call us for assistance. We hereby inform you that the personal data collected during such procedures will be processed in order to reply to your requests, to allow you to benefit from the services offered on the Store through reserved areas (for instance to process your orders and carry out the related activities, including those required to fulfil tax and administrative obligations, and, whenever requested by you, to send newsletters and information material) as well as to provide better services, marketing and support services for you and for the other customers, as specified below.
1. Who processes your data: Data Controllers
Zerogrey S.r.l. a socio unico Via L. Colli, 15 10128 Torino VAT number 08003340018 (hereinafter “Zerogrey”) and Tristate International SA, Riva Albertolli 1, Lugano, CHE 147076577 are joint Data Controllers of the processing of your personal data.
According to art. 26 of GDPR, we inform you that Zerogrey is the Data Controller of your personal data and shall process them for: manage and process your purchase orders, send to you the products you bought, provide you with the necessary post-sales assistance, process all return of products, to fulfill with all obligations arising out from tax law and, upon your consent, for marketing purposes, according to the terms indicated below.
According to art. 26 of GDPR, we inform you that Tristate International SA is the Data Controller of your personal data and shall process them for: managing all Store’s accounts in order to consent possible transfer to a new service provider or to internalize all services provided by Zerogrey, to help Zerogrey to manage our position in relation to all warranties provided for by law or by agreement, including return policy, for the Store maintenance and, upon your consent, for marketing purposes.
2. Which data we process - Type of processed data
Your contact and purchase data. We will retain the contact details you provide us (for instance, your first name, surname, address, telephone number, email, country of residence) when you first create an account on our Store, when you purchase a product and/or when you take part in our competitions or promotions.
Your payment and invoicing data. We will retain the payment and invoicing data that you provide to us (for instance, your credit card number, post code and address) when you purchase a product, in order to process your order and ship the products. Upon your request, we can also retain the payment and invoicing details in order to facilitate future purchases.
Information on the use of the website and on your activities on the Store. Your use of our website implies the processing of the browsing data and the device that you are using and your IP address (this is the number that identifies a specific device connected to the internet and is required in order for your device to communicate with the websites). We may analyse the site you came from, what you did and what you did not do on our website. In order to send you commercial information about our products and to submit proposals tailored to your tastes, we may use your email address and your name, as well as browsing data and website behavioural information to better understand which products you prefer, provided you have previously authorized such processing.
3.Where do we get your data - Data collection methods:
Directly from you. For instance, if you register to make a purchase on the Store, if you create an account, if you take part to a competition, if you ask us a question or contact our call centres.
If you do not provide us with your personal data, you will not be able to register with our Store and you will therefore not be able to purchase any of the products up for sale.
4. Why and for how long we process your data - Purpose and legal basis for data processing; data retention period
To provide you with the products and services you purchased and to give you information about your orders and payments. For instance, we will use your data to process your order, to confirm your purchase and to manage any related services such as the shipping of your purchased products. Without your data, we cannot manage and process your order.
The legal basis of this processing is the performance of the purchase agreement, of which you are a party from the moment you accept the Store’s terms and conditions of sale.
The data retention period of your data is equal to the period required to process the order.
Should you have created an account on the Store, the period shall be equal to the period of validity of your account, which shall be in any case deactivated after 24 months from your last access or from last action taken by you in your account.
To provide you with the necessary after-sales assistance in compliance with the applicable legislation relating to the product liability. For instance, we will use your data to provide you with support, to manage the return and/or repair of the products that you purchased from our Store in accordance with applicable law and the Store’s terms and conditions of sale.
The legal basis of this processing is the compliance with legal obligations and the data retention period is equal to that required by law (specifically by the Italian Consumer Code).
To correctly manage your administrative status. We process your data for accounting, administrative and tax purposes, directly connected to the Data Controller’s business activities as required by the applicable legislation.
The legal basis of this processing is the compliance with the legal obligations and the retention period is equal to that required by law (specifically tax, anti-money laundering, banking and public security law).
To let you to interact with customer care operators. We may use your email and phone number, as well as your name and/or address to assist you in the event you require support using the products purchased from the Store.
The legal basis of this processing is the performance of the sale and purchase agreement that you executed with Tristate when you accepted the Store’s terms and conditions of sale and the compliance with the obligations provided for by applicable law in terms of warranties and customer care. The retention period is equal to the time necessary to manage your request (being understood that in case other process activities are applicable retention period shall be equal to one indicated in this notice)
To send you commercial communications and to offer you products aligned with your tastes. With your consent, we analyse your personal data and the data concerning your use, preferences and consumption of our products in order to improve our approach towards you and our customers in general, through automated processing activities, including profiling activities. We do this in order to make better decisions related to services, advertising, products and contents, based on a greater awareness of how our customers use our services and to ensure you a more customized user experience. For such purpose, we may also collect your mobile device’s ID for advertising (IDFA - Identifier for Advertising - for iOS devices and AAID - Google Advertising ID - for Android devices) so that we can always provide you with targeted, relevant adverts based on your preferences and interests.
The legal basis of this processing is your explicit consent.
The retention period of your data is 12 months from the collection of your data.
To prevent or assess unlawful conducts, to protect and enforce our rights. For instance, we may use your data to prevent or prosecute the breach of our intellectual property rights (for example, counterfeiting of our brands and/or of our partners' brands) or theft (including credit card cloning and theft that we may believe occurred during a competition, contest or event) or other offences, as allowed by applicable law
The legal basis of this processing is the legitimate interest of the Data Controllers.
The retention period of your data is equal to the time that is reasonably necessary to enforce our rights from the moment we became aware of the offence or of its potential commission.
For marketing purposes. With your prior consent, you may be contacted by email, or by other means of telecommunication with information or offers concerning our products or services.
The legal basis of this processing is your explicit consent.
The retention period of your data is 24 months from the collection of your data.
Other purposes permitted by law. In certain circumstances, we may process your data if Tristate International SA and/or Zerogrey S.r.l. has a legitimate interest, in accordance with Article 6, paragraph 1 (f) of the GDPR, in compliance with your rights and with the restrictions required by law.
For the above-mentioned purposes, personal data are processed using manual, digital and online tools with a software that is closely connected to the said purposes and, in any case, such data are processed so as to ensure the safety and confidentiality of the said data in accordance with the applicable legislation.
5. Cookies and similar technology
What are cookies. Cookies are small text files that from the websites visited by users send to their terminals, where they are stored before being re-transmitted to the same websites during subsequent visits.
The first time that you visit the website, you will be asked to accept (or not accept) the cookies through a banner. You may refuse to accept all or some of the cookies, or you may modify your computer settings, also in the future, in order to know when you receive cookies or to disable the function of automatic acceptance of the cookies.
The Store uses the following types of cookies:
• Technical (or browsing) cookies, which contribute to the functioning of the Store’s site, for instance to enable the browse between pages and access to the reserved area of the site; the legal basis for processing using these cookies is the Data Controllers’ legitimate interest in providing efficient and well-functioning services to their customers; the retention period of these cookies starts from the date on which the site was first accessed until they are disabled.
• Functional cookies, which allow to activate certain features of the Store and to store your preferences (such as language) in order to improve your browsing experience; the legal basis of the processing underlying the use of these cookies is the Data Controllers' interest in providing efficient, well-functioning services to their customers; the retention period of these cookies starts from the date on which they are enabled on the site until they are disabled. The user can accept and disable these cookies – at their convenience – using the cookie management tool.
• Analytical cookies, which enable the acquisition of aggregated, anonymous statistical information concerning browsing habits; the legal basis of the processing underlying the use of these cookies is the Data Controllers' interest in providing efficient, well-functioning services to their customers; the retention period of these cookies starts from the date on which they are enabled on the website until they are disabled. The user can accept and disable these cookies – at their convenience – using the cookie management tool.
• Profiling (third-party) cookies, which allow us to customize advertising messages based on your interests and preferences, so that we only send you the adverts that you might find relevant or interesting. These cookies are not managed directly by us, but are installed throughout the Store by third-party companies who handle online profiling. The legal basis of the processing underlying the use of these cookies is the consent of the data subject; the retention period of these cookies starts from the date on which they are enabled on the site until they are disabled and, in any case, for no longer than 12 months. The user can accept and disable these cookies – at their convenience – using the cookie management tool.
The cookies currently used are
|Lucky Orange||Analysis (Tracker)|
|Google Tag Manager||Technical essential|
|Google AD Words||Advertising|
|Facebook Custom Audience||Advertising|
|Facebook Connect||Social Media|
Below you will find links explaining how to disable cookies on the most common browsers (for any other browser you may be using, we suggest that you search for this option in the software's help section, which you can normally access by pressing the F1 key):
Internet Explorer: Click on the Settings button, then on Internet Options. Click on the Privacy tab and, in the Settings, move the bar to the very top to block all the cookies.
Google Chrome: Click on the menu on the browser toolbar. Select Settings. Click on “Show advanced settings”. In the "Privacy” section, click on the Content Settings button. Select “Prevent sites from saving data”.
Mozilla Firefox: Click on the menu button and select Options. Select the Privacy tab. In the History settings: select “use personal settings”. To enable cookies, tick Accept cookies from websites, and to disable them remove such mark.
Safari: Click on the menu toolbar on “Safari”, then on “Preferences”. Next, click on “Privacy”, then on “Details” to select the website, and click “Remove”.
Alternatively, it is possible to disable only the Google Analytics cookies, by using the opt-out extension provided by Google for the main browsers https://tools.google.com/dlpage/gaoptout?hl=it
6. Where your data are processed – Transfer of data
The Data are processed and stored at the offices of Tristate International SA and at the offices of Zerogrey S.r.l.
For administrative purposes we can communicate your personal data to Zerogrey’s group companies, based in the EU.
Your personal data could be communicated, also to allow you to interact with the customer care service, to third-party service providers - duly appointed as data processors pursuant to art. 28 GDPR. Such providers may have their legal office outside EU (for example in the USA) and, therefore, they may not have the same laws on data protection as the ones implemented in your country, and/or the level of personal data protection arising by such laws may be deemed not adequate, on the basis of your country standards.
Such transfers shall be authorized either upon:
· An adequate decision referred to the Extra-EU country to which personal data are transferred issued by the European Commission according to art. 45 of GDPR (for instance: Privacy Shield); or
· Appropriate guarantees provided for by articles 46, 47 and 49 of GDPR (as the standard contractual clauses approved by the European Commission, the binding corporate rules, the contractual guarantees provided for by the involved data controllers, or as the exceptions to the prohibition on the transfer, which are applicable under certain circumstances) and upon the right to ask to the Data Controllers all the contacts of the data subjects to whom personal data are communicated, from whom you can receive information about how to obtain a copy of the processed data or about the place where data are available.
7. With whom we share your data – recipients of personal data
Being understood that, where required by law, we will obtain your prior consent and complete any formalities required by said law, we may share your data with the following third parties (acting as data processors):
Our service providers We may share your data with third parties in order for them to provide us with services (for instance, IT service providers for the management of the Store, companies providing us with profiling services and compliance automation, couriers, and companies managing call centres and warehouses and providing logistics services) but in such cases, we will enter into an agreement with them pursuant to Article 28 of the GDPR in order to protect your data. These parties will only be in possession of the data required to perform their functions and shall only use it for the purpose of providing services on our behalf or complying with the law. You can find out the details of these processors pursuant to Article 28 of the GDPR by sending an email to firstname.lastname@example.org or to email@example.com. In the event any of these providers operates outside the EU, before transferring any data to such providers we will secure compliance with the relevant conditions under art. 45-47 of GDPR.
Where we deem it necessary in order to comply with our legal obligations or to legally protect ourselves or third parties. Where permitted or required by the law, we may also share the data requested by an administrative authority or by another authorised third party or organisation, in order to protect or enforce our rights or those of third parties, or to limit or prevent fraud (including credit card fraud or other fraud, that we believe may have occurred during a raffle, promotion or event) and other offences.
Our Store is not intended for minors under the age of 16, but rather for adults. If you are a parent or guardian and you believe your child may have sent us their personal data, please feel free to contact us.
9. Security Measures
We adopt the security measures required by law.
We adopt security measures to protect your data. The standard security measures we use depend on the type of data that we process, and meet the requirements provided for by law and by the standards of European governmental agencies.
10. Your rights
You can contact Tristate International SA and/or Zerogrey to request the access to, the rectification or erasure of your personal data, or the restriction of the processing, or to object to the processing and to request the portability of your data; you can also withdraw your consent at any time (this shall not affect the lawfulness of processing based on consent granted before its withdrawal).
When you exercise your right of access, you have the right to know whether your data is being processed, as well as the purpose of the processing, the categories of data being processed, the recipients or categories of recipients to whom your data have been disclosed (and, if they reside in a third country, the guarantees in place), the retention period for your data (or the criteria for determining the retention period), whether automated processing is being carried out (for instance through profiling), the reason for the processing, and the source of the data (when not initially collected by us).
You have the right to submit a complaint to the Italian Data Protection Authority and to request to the Data Controller, at any time, information about the processors and the parties that are authorised to process your data.
You can exercise your rights by contacting Tristate International SA or Zerogrey S.r.l. (at the address mentioned above or by sending an email to: firstname.lastname@example.org or to email@example.com).
In any case, you can amend or withdraw your consent through the Store's settings.
You can withdraw your consent to receive marketing communications including newsletters. To stop receiving marketing communications, you can access your account and change your settings or follow the instructions in the promotional message that you’ve received. Alternatively, you can withdraw your consent by emailing one of the addresses mentioned above.
You can amend your preferences regarding marketing emails and data processing through profiling in the privacy settings of your account or by writing to one of the email addresses mentioned above.
11.What happens if we amend this Policy
Cookies are small text files that contain information about your visit to our website and are stored on your computer or any other device able to browse the internet, for example a smartphone or tablet. We use these cookies to make browsing our site easier, to show you content that is relevant to your needs and interests and to help us speed up your future visits and activities on our website. The cookies assist and simplify the interaction between the user and the site and allow the site to remember your preferences and individual activity, thus saving time and contributing to easier and more efficient browsing. Cookies memorise information about your visit online (for example; language, number of visits and dimensions of text) and aid the implementation of various services (user registration, contents of your shopping cart, subscription to newsletters or updates on products, etc.). Cookies are also employed to create anonymous group statistics that let us analyse how visitors use our site, allowing us to improve the structure, content and services of this site. Any services present that do not offer complete anonymity will be found in the third-party cookies list and you may deny them consent, safeguarding your privacy. This site makes use of three different types of cookies:1. Essential cookies
These cookies ensure that the site works in a correct and fluid manner: they allow you to navigate between pages, share content, they memorise your sign-in credentials making access to the site faster and they keep your preferences and credentials active during browsing and purchasing. Without these cookies we would be unable to provide the services which motivate the user to access this site.
2. Statistical cookies
These cookies help us understand how our users browse the site and navigate the online store so that we may assess and improve its performance and create content that best matches our visitors' preferences. For example, these cookies show us which are the most and least visited pages, how many people access the site, how long is spent on the site by most users and how they find us online. With this information we can find out which are the best features and which could be improved, while ensuring that site content is uploaded quickly and displayed appropriately. The information these cookies collect is anonymous and not associated with any of the user's personal data. These functions on our site are managed by third-party service providers who render the data anonymous and untraceable to any single individual.3. Third-party profiling cookies
These cookies are distributed by third parties and not directly controlled or under the control of Zerogrey. Zerogrey does not therefore accept liability regarding the use of any information collected by the owners of these third-party cookies. The cookies provided by such third parties can offer advanced features as well as more information and personalisation. These include the ability to share content across social network platforms and to maintain a personalised online site experience on the basis of any preferences expressed on pages previously visited. These services are for the most part offered by external operators. If you browse using an account or if you use third-party services on other websites, these may be able to track a user who has visited our site. The use of the data collected by these external operators through cookies must adhere to the respective privacy policies that you will find on the link copied below. Third-party profiling cookies are identified by the names of their respective operators in the list indicated below which also contains the tools for managing or disabling them.Managing your cookies
You can change the settings for downloaded cookies on your computer or mobile device through the appropriate feature on your browser. You may also block the installation of third-party cookies and remove previously installed cookies, including those that define your cookie preferences that you may have may have set here. To check or adjust the settings on your browser you need to consult the instruction manual or your browser's help window.
The instructions regarding cookies for the most widely-used browsers are available here
Chrome : https://support.google.com/chrome/answer/95647?hl=en&p=cpn_cookies
Internet Explorer: http://windows.microsoft.com/it-it/windows-vista/block-or-allow-cookies
Alternatively, to disable some or all cookies you can use the following tools. Disabling our cookies may affect your browsing experience, diminish efficiency in accessing certain parts of the site and erase preferences for future visits to the site. Remember to set the browser on your devices in a coherent manner so that each one may be adjusted to reflect your cookie preferences. Further detailed information on cookie features and how to enable or disable them on most browsers is available online at www.aboutcookies.org or http://www.allaboutcookies.org/privacy-policy.htm. For in-depth information and assistance with cookies used for advertising purposes visit http://www.youronlinechoices.com/it/