PRIVACY POLICY

Welcome to the Trap Milano srl website, present at the URL www.trapmilano.it (the “Website”).

Please read carefully this Privacy Policy which applies to each access to the Site, even independently of the booking of the services sold there. We also ask you to read, if you have not already done so, the General Conditions of Use. We remind you that this Privacy Policy is governed by Italian law and in particular by the Code regarding the protection of personal data (Legislative Decree 30 June 2003 No. 196, the “Code”) and by European Regulation no. 2016/679 (the “Regulations”). The Code and the Regulations guarantee that the processing of personal data will be carried out respecting the fundamental rights and freedoms, as well as the dignity of the interested party, with particular reference to privacy, personal identity and the right to protection of personal data.

1. Owner of personal data
TRAP MILANO s.r.l., with registered office in Via Adeodato Ressi 23, 20125 Milan, Italy (hereafter, TRAP MILANO) is the independent holder of the personal data processing of users browsing the Website, including navigation data, marketing and profiling data as well as data related to and related to the booking of the services provided by TRAP MILANO and to the relative pre and post sales support activities.

The appointed manager is the holder MARCO POZZI.

We remind you that you can always contact the person responsible for the protection of personal data and exercise your rights (including the request for the complete list of appointed managers), by writing to the following email address: privacy@trapmilano.it or by sending a request to TRAP MILANO (to the attention of the person in charge of personal data protection) to the physical address of TRAP MILANO, indicated above.

2. Responsible for the protection of personal data
TRAP MILANO has appointed the person responsible for the protection of personal data, who can be contacted at the following email address privacy@trapmilano.it for any information regarding the processing of your personal data and for exercise the rights illustrated below.

3. Type and purpose of the processing carried out on the Website – Legal basis of the Treatment
Through the Website different types of personal data are collected and processed, for different purposes and with different methods. More specifically: (a) personal data relating to navigation, processed both for the purpose of allowing the Site to function properly, and for marketing purposes. In this regard, we invite you to read the “Cookie Policy” present in the Legal Area of the Site;
(b) personal data provided voluntarily by the user (such as, for example, the e-mail address, name and telephone number, or otherwise lawfully acquired during the user’s visit to the site, to find the requests of the user and offer the services, assistance and information required about the services of TRAP MILANO.
(d) with the express consent of the user, TRAP MILANO may process the personal data of the latter for marketing purposes, ie to send to the user (through traditional tools and via telematic tools such as, newsletters, email, sms, mms and smart messages) information and updates on the services promoted by TRAP MILANO;
(e) with the express consent of the user, TRAP MILANO may also process the personal data of the latter for purposes of studying habits and consumption choices in order to make products and initiatives more responsive to tastes and need of its customers.

Except for navigation data, governed by the Cookie Policy, the processing of personal data is based on the consent implicitly provided by the user for the purposes referred to in point b) and the legitimate interest of TRAP MILANO to provide its services through the online booking, both of the user himself to navigate correctly on the Website and / or the legitimate interest of TRAP MILANO to respond to any customer requests, the legal basis of the treatment lies in the fulfillment of the contract and in the obligation to fulfill the obligations pre and post contractual. It should be noted that, based on the principle of legitimate interest, TRAP MILANO may contact you in order to offer you services and products similar to those you previously purchased. It should also be noted that, based on current legislation, this type of contact (so-called “soft spam”) does not require the granting of consent.
The user may however, at any time, request the interruption of the treatment as specified above and TRAP MILANO will arrange without delay.

4. Source of personal data Personal
data collected by TRAP MILANO are provided directly by the user (by registering on the Website or within the sales process).

5. Study of users’ consumption habits and choices
As indicated in paragraph 2 (e) above and with the express consent of the user, TRAP MILANO may process the personal data of the user for purposes of studying the habits and user consumption choices in order to make TRAP MILANO products and initiatives more responsive to the tastes and needs of its customers.

With the aid of automated tools, TRAP MILANO will process data on the value and frequency of purchases (even if these were made during the sales period) as well as the type of products purchased. This study has the sole objective of offering customers and users products, services and initiatives that are more responsive to their tastes and needs. It should be noted in this regard that the study of the behavior of users and customers will take place using non-invasive methods of the personal sphere.

As indicated in the previous point 2 (a) and with the express consent of the user, TRAP MILANO may process the personal data of the same user, using automated tools, to study the cookies in order to verify the navigation on the Site and to propose products and services in line with the navigation activity.

6. Methods of processing personal data carried out by TRAP MILANO
Personal data collected through the TRAP MILANO website are processed using mainly computerized and telematic methods and tools, adopting the necessary security measures in order to minimize the risk of destruction or of loss, even accidental, of the data itself, of unauthorized access or treatment not allowed or not in accordance with the collection purposes indicated in this Privacy Policy. However, these measures, due to the nature of the online transmission medium, can not limit or exclude absolutely any risk of unauthorized access or data loss. To this end, it is advised to periodically check that the computer is equipped with appropriate software devices to protect the transmission of data in the network, both incoming and outgoing (as updated antivirus systems) and that the Internet service provider has taken appropriate measures. for the security of data transmission over the network (such as firewalls and antispam filters).

7. Mandatory or optional nature of the provision of data
Except for navigation data (the transfer and collection of which are regulated by section 7 of the “Cookie Policy” of this page), the transfer to TRAP MILANO of personal data collected through the Site is to meet requests and questions of users, both for marketing purposes and study of consumption habits and preferences is free, optional and optional. Failure to provide does not limit the use of the Site, but may make it impossible for TRAP MILANO to meet requests for information and queries.

The provision of personal data, in particular of personal data, e-mail address, telephone number is necessary with regard to the conclusion of the contract for the purchase of products through the Site.
Some of these data could be, vice versa, indispensable for the provision of other services rendered on the Site and related to the sale (pre and post sales services.

Depending on the case and, where necessary, the compulsory or optional nature of the communication of the data will be indicated from time to time, by adding a special character (*) to the mandatory information or the data necessary for the provision of services and purchase of products on the Website. Failure to provide optional personal data will not entail any obligation or disadvantage.

8. Categories of recipients of personal data
TRAP MILANO communicates the personal data of users of the Site only within the limits permitted by law and in accordance with the following. In addition to what is indicated in the previous point 2 b. (ie to Social login), personal data may be known by TRAP MILANO employees and consultants who will operate as authorized parties for the internal organization of company activities; companies of the same Group as appointed controllers, in order to carry out contractual activities and services and carry out specific marketing activities (IT services and marketing services).
Personal data may also be known by police forces or judicial authorities, in accordance with the law and upon formal request by such subjects, or if there are reasonable reasons to believe that the communication of such data is reasonably necessary for (1) investigating, preventing or taking action on suspected illegal activities or assisting state control and supervisory authorities; (2) defend against any complaint or accusation from third parties, or protect the security of your website and company; or (3) exercise or protect the rights, property or safety of TRAP MILANO, the companies of the same group, its affiliates, its customers, its employees or any other person.

9. Data retention period
Personal data collected for the purpose of sale are stored for a period not exceeding 10 years, in compliance with tax and civil legislation. Furthermore, these data can be kept for a further period of time in order to respect the unlimited warranty granted to the customer. The personal data provided for marketing and profiling purposes are kept for the period necessary for the specific processing, also on the basis of the particular sector of activity (luxury products) and in consideration of the access shown by the customer to receive updates regarding products, events and fashion shows organized by TRAP MILANO.

10. Rights recognized by the privacy law to the user
The user always has the right to obtain from TRAP MILANO confirmation of the existence or not of personal data concerning him, even if not yet registered, and their communication in intelligible form. You also have the right to obtain information about the origin of personal data; the purpose and the method of treatment; the logic applied in case of treatment carried out with the aid of electronic instruments; the identification details of the data controller and data processors; the indication of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them in the quality, for example, of data processors or subjects authorized to process them.

The user also has the right to request the updating, correction or, when interested, integration of personal data, cancellation, transformation into anonymous form or blocking of personal data, processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected or subsequently processed; the attestation that the above operations have been brought to the attention, also with regard to their content, of those to whom the data have been communicated, except in the case in which such fulfillment proves impossible or involves a use of means clearly disproportionate to the protected right. The user also has the right to data portability.

The user has, however, the right to object, in whole or in part, for legitimate reasons, to the processing of personal data concerning him, even if pertinent to the purpose of collection, to the processing of personal data concerning him for purposes of sending advertising material or direct marketing or for carrying out market research or commercial communication and also has the right to request the limitation of the processing of data concerning him. The right of opposition may also be exercised specifically, with regard to one or more methods of sending marketing communications.

The user also has the right to lodge a complaint with the competent supervisory authority as well as the right to revoke the consent previously given.

The rights listed above may be exercised by contacting the Data Protection Officer by writing to privacy@trapmilano.it .