Tortuga Brill

The protection of personal data is important to Ma-Fra S.p.A. This information notice provides detailed information on the protection of your personal data. We are responsible in our capacity as Data Controllers for the collection and the processing of your personal data in connection to our activities. The purpose of this document is to provide you with information, in particular, on what data we process, the purposes for which we process and share them, for how long we store them, on your rights and how to exercise them.

We would like to ask you to carefully read our Privacy Policy which applies to your every visit to the website and whenever you decide to navigate the website and use its services, regardless of whether you buy products or not. We would also like to ask you to read and to check the Privacy Policy regularly, for any amendments or revisions that may be necessary.

We process your data to manage the orders that are placed on our e-commerce site and for advertising and marketing purposes; we manage the information via e-mail.

We appreciate our customers’ loyalty; when they grant us access to their personal data, the Protection of the Data is our priority. We recommend that you read this “Privacy Policy notice” thoroughly.

Information notice pursuant to article 13 of European Regulation 679/2016

          
Data controller

The data controller for the data collected through this website is MA-FRA S.p.A. Vat no. 02916980960, with registered office in Baranzate (MI), at 44/46, Via Aquileia (hereinafter, "MA-FRA"): it decides independently on the processing purposes and methods, as well as on the security procedures to be applied so that the confidentiality, integrity and availability of the data are guaranteed.

Optional or mandatory nature of the provision of data

Providing MA-FRA with your personal data that may be requested on the various occasions of collection may be mandatory for the purposes identified in this information notice, or optional.

The optional or mandatory nature of the provision of data is specified each time - with reference to the individual information requested - during the individual collection of data, by marking mandatory information with a special character (*). Your possible refusal to provide MA-FRA with some of your data that are marked as mandatory shall make it impossible to achieve the main purpose of the specific collection: such refusal could, for example, make it impossible for MA-FRA to fulfil the contract of the purchase of products on the website or to provide other services that are available on the website.

Providing MA-FRA with further data, different from those marked as essential, is optional and shall have no impact on achieving the main purpose of the collection (e.g. depending on the case, the use of the website and of its services and the purchase of products).

The data that we process

We collect the following data:

- Surname, name

- E-mail address

- Date of birth

- IP address

- Connection and navigation data

The optional or mandatory character of the data shall be marked with a special character at the time of data collection.

Some data are collected automatically when you enter the website.

Specifically, the personal data collected are the e-mail address, the postcode and the options you have selected for receiving sales information.

We ask for your date of birth to make sure you are an adult.

Ways in which we collect data:

• Form for registration on the e-commerce website
• Registration for the newsletter
• Landing pages
• Surveys performed by e-email and on the web
• Cookies

The information that we may receive automatically includes confirmation that you have opened our e-mails and your purchase behaviours.

We may receive automatic information of additional data, such as: the IP address, the searches that users make on the Website, or the interaction with advertisements when you contact us via social network websites or third-party advertisers.

In the event where we collect data via cookies, you will be duly informed through the Cookies Policy.: 

We will never ask you for personal data regarding your racial or ethnic origins, your political opinions, your religious or philosophical convictions, your membership with trade unions, genetic data or data that concern your sexual orientation, unless it is to fulfil a legal obligation.

It is understood that, if we process such data in other cases as well, we will inform you specifically and we will acquire your explicit consent.

Purposes of the data processing

The data provided to Mafra shall be processed only for specific, explicit and legitimate purposes. MAFRA will process your personal data mainly with manual and electronic tools, will make them available to its employees and associates who are specifically entrusted with the processing, and to the companies of the MAFRA group; your personal data will be communicated to persons who perform commercial services for MAFRA (e.g. data entry, transport and assembly, companies that provide IT services, including hosting services), duly appointed as data processors.

We shall process your personal data to perform, provide and improve the services that we offer to our customers. Said purposes include:

• The purchase and delivery of products and services: we shall use your personal data to receive and manage orders, provide products and services, process payments and communicate with you regarding your orders, the products, the services and promotional offers.
• Providing and improving our services and solving any issues related thereto: we shall use your personal data to offer functions, analyse performance, correct errors and improve the use and efficiency of our services.
• Fulfilling legal obligations: in some cases, we are obliged by the law to collect and process your personal data. For example, from third-party vendors we collect information related to their registered office and their current bank account for identification and other purposes.
• To communicate with you: we shall use your personal data to communicate with you regarding our services, products and events via various channels (e.g. on the phone, via e-mail and chat).
• Promotional communications: we shall use your personal data to send you newsletters regarding products and services that may be of interest to you, carry out statistical investigations and market surveys.
• Purposes for which we request your consent: we may also ask for your consent in order to process your personal data for specific purposes, which you will be notified about. When you consent to the processing of your personal data by us for a specific purpose, you may withdraw your consent at any time, in which case we will stop processing your data for that purpose.

Specific processing that requires your consent

In some cases, we may ask your consent or the processing of your data; e.g.:

Profiling: in order to process your personal data and identify your specific behaviours and habits, so that we can improve our products and service and make you offers according to your preferences

Information that has been acquired in that way will allow, as mentioned, MAFRA to create profiles (individual and/or aggregate) to process market analyses and statistics also to improve MAFRA products and services and adapt them to the needs of our customers; also in order to send you - always with your prior consent - targeted information and offers that, in MAFRA’s opinion, you may like and may interest you.  Should you not wish that our Company use your data for this purpose, you may at any time modify your consent to profiling, by changing the settings of your profile on the MAFRA website or by contacting the addresses mentioned in this Policy.

Marketing activities: with your consent, MA-FRA S.p.A. may carry out statistical investigations, market surveys and the promotion and sale of MAFRA products and services and those of third-party companies. These activities may be carried out using traditional methods of contact (Mailing list)

The withdrawal of consent to the processing of data by MA-FRA with automated contact methods shall be understood to extend to all contact methods, unless you specify otherwise.

Retention of data

We shall store your personal data to allow you to continue using Our Services for the time that is necessary to achieve the purposes described in this Privacy Information notice, as requested by the law, e.g. for taxation and accounting purposes, or as we may notify you otherwise. For example, we shall store the chronology of transactions, so that you may examine the purchases you have made (and repeat orders, if you so wish) and the addresses to which you instructed us to deliver your orders, as well as for the improvement of the suitability of the products and contents that we recommend.

We shall store your data if you so wish. You may at any time exercise the rights of access, rectification, erasure of and objection to your personal data being processed by sending an e-mail to the address: privacy@mafra.it

External data processors

Based on the current situation, the processors of your personal data will be the following companies related to MA-FRA, the data controller, with agreements for the management of the orders and for the operation of the system:

• TNT Global Express S.p.A.

Registered office: 268, Corso Giulio Cesare - 10154 Turin - Italy

Specifically, TNT processes the data that are necessary for the activities of dispatching, delivering and returning of products that have been purchased on our website.

• White Rabbit S.r.l.

Registered office: 12/6, Via Giuseppe Frua - 20146 Milan - Italy

We share our customer data with White Rabbit for marketing activities addressed to our consumer customers.

To get the complete list of the processors of your data, please contact MA-FRA by sending an e-mail to the following address: privacy@mafra.it. Please read this section periodically, to check any changes in the data processors listed above.

Your rights

You always have the right to obtain from MA-FRA confirmation of the processing or otherwise of the personal data that concern you, even if they have not yet been registered, and their communication in an understandable form. You also have the right to obtain from MA-FRA information on the source of your personal data; the purposes and methods of processing your personal data; the logic applied in the case of processing performed with the help of electronic tools; the details of the data controller and of the data processors; the indication of the persons or categories of persons to whom the personal data may be disclosed or who may become aware of the data, for example in their capacity as data processors. All this information is included in this Privacy Policy. You also always have the right to obtain from MA-FRA:

 a) the update, rectification, integration of your personal data;

b) the deletion and transformation into an anonymous form or the blocking of the data handled in violation of the law including data that does not require conversion in relation to the purposes for which the data were collected and processed;

c) attestation that those to whom the data was communicated or shared have been informed of the contents of the operations described in points a) and b), with the exception of cases in which this involves manifestly disproportionate means to the right protected.

In any case, you have the right to object in whole or in part:

• a) for legitimate reasons, to the processing of the personal data that concern you even if they are pertinent to the purpose of the data collection;
• b) to the processing of the personal data that concern you for sending advertising or direct marketing material or for market research or commercial communication.

You may exercise your rights freely and at any time, with a written request addressed to MA-FRA via post or to the e-mail address privacy@mafra.it; we will promptly reply to your request. To guarantee that your personal data are always exact, updated, pertinent and complete, please notify us of any changes at the address privacy@mafra.it.

This is the minimum amount of information that MA-FRA is obliged to provide you with: for any further information regarding the processing of your personal data by MA-FRA, please thoroughly read the Privacy Policy on the website http://www.garanteprivacy.it/

How we guarantee the security of the personal data

The security of your personal data is of great importance to MAFRA

We make use of the latest technologies. Our website is stored on secure servers which are protected from the most common types of attacks. However, we would like to remind you that all technology is vulnerable technology. That is why you must use the means at your disposal to maintain the security level of your data. We especially recommend that you use strong passwords for access to your account. We also recommend that you change the password with a certain regularity (at least once a year) and that, if you suspect that a third party may know your password, you change it immediately.

Summary of our Privacy Policy

Our privacy policy is based on the following principles:

• 1. we process data exclusively for the purposes and in accordance with the methods mentioned in the information notice presented at the time of their collection;
• 2. we use the data for purposes other than the ones for which they were specifically released only if we have the express consent from the user;
• 3. we make the data available to third-party companies only for purposes that are fundamental to the provision of the service requested and in the context of the appointment of a data processor; we do not disclose the data, give them or transfer them to third parties for processing without first informing the users and having acquired their consent;
• 4. we reply to all requests for erasure, modification, integration of the data provided, to the objection to the processing of the data for sending commercial and advertising information;
• 5. we ensure the correct and lawful management of the data, safeguarding the privacy of users; we also apply appropriate security measures for the protection, integrity and availability of the data provided.

How and why we process your personal data

Processing on personal data is performed mainly through electronic and telematic methods by MA-FRA and other persons who, selected especially for their reliability and competence, carry out operations that are instrumental to achieving the purposes strictly connected to the use of the website, of its services and to the purchase of products via the website (see below, paragraph “Persons who may process your personal data”).

The specific purposes of the processing of the data are summarised, each time, in the information notice of article 13 of European Regulation 679/2016, which is presented to the user when he/she provides personal data.

In general, the data are processed for the provision of the following services that are available by accessing our website:

• 1. registration to the website, to avail of the related services;
• 2. registration to specific additional services;
• 3. fulfilment of orders and related activities;
• 4. management of your requests: technical, commercial, on the status of your orders and requests for information in a broader sense;
• 5. for contact with the representatives of our services.

During the processing that may, directly or indirectly, identify you, we try to respect the principle of strict necessity. For this reason, we have configured the website in such a way as to reduce the use of your personal data to a minimum: therefore, your data shall not be processed when the purposes in individual cases may be achieved by the use of anonymous data (e.g. market surveys aimed at the improvement of services) or with other methods that allow the identification of the data subject only in case of need or on the request of the authorities and the police (e.g. for data related to traffic and to the duration of your stay on the website or your IP address).

Your data will be transmitted to third parties only with your explicit consent, except in cases where disclosure is mandatory by the law or necessary for purposes envisaged by the law for which the consent of the data subject is not sought; in such cases, the data may be made available to third parties that will process them independently and solely for the aforementioned purposes (e.g. in case of a request by the police or the judicial authorities or other competent bodies, or in order to fulfil obligations arising from the contract stipulated with you).

Any processing purpose other than the specific one for which you provided your personal data will be shown in the information notice and will be followed up by MA-FRA only with your explicit consent.

There are also instances of processing whereby the rules and regulations provide for the exclusion of consent: for example, we would like to inform you that MA-FRA may process your personal data without obtaining your consent when this is necessary for the fulfilment of a legal obligation or if it is necessary for the performance of our contractual obligations to you (if you have purchased products or have asked to use specific services through our website).

MA-FRA may on occasion processes personal data of third parties directly provided by its users: for example, if the user has purchased a product as a gift for a friend or when the person who pays the purchase price is not the same person for whom the product is destined, or when the user wants to show a service or the availability of a certain product to a friend.

In those cases, where a user has processed the personal data of third parties, said person will be solely and exclusively responsible for the disclosure of information and data related to third parties without such parties having expressed their consent, or for their incorrect or unlawful use.

We may also have to share your data to fulfil legal obligations or obey rules or regulations or if our business (or a portion of it) is sold and the buyer requires your personal information for the performance of services.

Cookies
Our website uses automatic systems for the collection of data not directly provided by the user, such as cookies. Cookies are a device transmitted to the user’s hard disk; it does not contain understandable information but allows the association of the user with the personal data he/she has provided to the website. Cookies are located on our server and no one may access the information contained therein. Only MA-FRA processes the information collected via cookies and only in anonymous and aggregated form in order to optimise its services and its website with regard to the specific user needs and preferences. For example, we use cookies with regard to browsing the catalogue and the online purchase of products.

The Internet browser allows the deletion of cookies after each session. The Internet browser contains instructions on how to delete cookies. Consult it.

Accepting the automatic data collection procedures and the use of cookies are necessary to use the website and its services, including the purchase of products. If you have activated the cookie deletion procedure, MA-FRA cannot guarantee that you will be able to view some web pages or be provided with certain services, such as the storing and viewing on the web pages of the products you have selected during your online shopping.

Links to other websites

Our website contains links to other websites that may have no connection to us. MA-FRA does not control or monitor such websites and their contents. MA-FRA shall not be liable for the contents of these websites and for the rules they adopt, also with regard to your privacy and the processing of your personal data during your browsing. Therefore, please pay attention when visiting such websites via the links on our website and read their terms of use and privacy policies. Our Privacy Policy does not apply to third-party websites. Our website provides links to those websites solely in order to facilitate the user’s search and browsing and to allow hyperlinking to other websites. The activation of the links does not constitute recommendation or endorsement by MA-FRA of the access to and navigation on those websites, nor does it constitute any guarantee regarding the contents, services or goods provided and sold to Internet users by them.

Contact
If you wish to receive more information on how MA-FRA processes your personal data, please send an e-mail to the address privacy@mafra.it. In order to know your rights and stay updated on the rules and regulations on the protection of persons with regard to the processing of their personal data, we recommend that you visit the website of the Personal data protection authority at the address http://www.garanteprivacy.it/

       
Applicable law

This Privacy Policy is governed by Italian law and, specifically, by the Code on the protection of personal data (Information notice of art. 13 of European Regulation 679/2016) which regulates the processing of personal data - also of those held abroad - performed by any resident or company with a registered office in Italy. The Code guarantees that the processing of personal data is performed in compliance with the fundamental rights and freedoms, in respect of the dignity of the data subject, with particular reference to confidentiality, personal identity and the right to the protection of personal data.
 

Amendments and updates to MA-FRA’s Privacy Policy

MA-FRA may amend or simply update, totally or partially, the website’s Privacy Policy, also in conformity to amendments to the law or regulations that govern this issue and protect your rights. We ask, therefore, that you access this section regularly to check the publication of the most recent and updated Privacy Policy.