Statement regarding the processing of personal data pursuant to art. 13 of Regulation (EU) 2016/679

Pursuant to art. 13 of Regulation (EU) 2016/679 governing the protection of personal data, this statement sets out the necessary information concerning the processing of personal data provided by users (hereinafter “Users”) of www.twinset.com (hereinafter the “Website”).

This statement shall not apply to other websites that it may be possible to reach via links provided on this Website. Twinset accepts no responsibility for data processing undertaken by websites attributable to third parties.

This statement is also given pursuant to Recommendation 2/2001, which the European personal data protection authorities, meeting within the framework of the Working Party established by art. 29 of Directive 95/46/EC, adopted on 17 May 2001. In particular, efforts have been made to identify certain minimum requirements for the collection of personal data online, such as, for example, the procedures, time periods and nature of the information that data controllers must give Users when they visit web pages, regardless of the purpose of their visit.

Data controller, place of and procedures for data processing

Pursuant to Regulation (EU) 679/2016, the Data Controller is Twinset S.p.A., a single-member company with registered office at Via del Commercio 32, 41012 Carpi (MO), (hereinafter “Twinset”).

The data will be processed at the headquarters of Twinset, both manually and automatically, using procedures and instruments designed to ensure the highest level of security and confidentiality, by the parties appointed for the purpose (including parties which process data on behalf of Twinset on an occasional basis in relation to maintenance activities), in accordance with articles 32 et seq of the European Regulation. The data will be kept for a period not exceeding the time necessary to achieve the purposes for which they are collected and processed.

The data deriving from the web service may be communicated to the technological and instrumental partners used by Twinset to provide the services requested by Users.

The personal data provided by Users who submit requests for the transmission or dispatch of information (requests for information, answers to questions, etc.) or who make purchases online (orders) are used for the sole purpose of providing the service requested, and are communicated to third parties only where necessary (provision of requested services via technological and instrumental partners).

Types of data processed

Personal/identification data

"Personal data" shall mean all information relating to natural persons, who have been or can be identified, either directly or indirectly, by reference to any other information, including a personal identification number. "Identification data" shall mean personal data by which the data subject can be directly identified (e.g. name, surname, date of birth, residence or domicile, email address, telephone numbers, etc.).

Browsing data

In the course of normal operation, the IT systems and software used to run the Website acquire certain personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified Users, but by its nature, it could enable such Users to be identified, by means of processing and association with data held by third parties. This category of data includes the IP addresses or domain names of computers used by Users, the URI addresses (Uniform Resource Identifier) of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (done, error, etc.) and other parameters relating to the User's operating system and IT environment. The data could be used to ascertain responsibility in the event of hypothetical cyber crimes against the Website.

Data provided voluntarily by the User

The optional and voluntary sending of emails to the addresses indicated on the Website, and/or the filling out of data collection forms, entails the subsequent acquisition of the address of the sender, insofar as it is a pre-requisite for responding to requests, in addition to any other personal data entered. Specific statements will be progressively included or displayed on the pages of the Website set up for particular on-request services.

Purposes of processing, for which consent is given where required by the European Regulation

The personal data made available to Twinset by the User will be used for legal purposes, to manage and fulfill the User's orders or purchase proposals, to provide the User with the envisaged ancillary services, and to respond to specific requests from the User.

More specifically, the personal data voluntarily provided by the User will be processed for the following purposes:

• a) browsing the Website;
• b) any contact request, with the sending of information requested by the user;
• c) general administrative and accounting operations. For the purposes of applying personal data protection requirements, any processing carried out for administrative and accounting purposes shall be connected with the performance of organizational, administrative, financial and accounting operations, irrespective of the nature of the data processed. In particular, internal organizational operations and other operations involved in the fulfillment of contractual and pre-contractual obligations shall be deemed to pursue such purposes;
• d) profiling: i.e. the compilation of User profiles by Twinset, on the basis of analyses of Users' habits and purchasing choices, with a view to improving the company's commercial offering and services. Personal data may only be processed for this purpose with the express consent of the User;
• e) subscription to mailing lists, if applicable;
• f) marketing and market research: for the purpose of receiving information by automated means, email, SMS, telephone, traditional mail or other means of communication; for determining the degree of customer satisfaction; for undertaking promotional, commercial and/or advertising activities relating to the company's products and services, programs and competitions involving the award of prizes, and events held by Twinset.

Legal basis for processing

The legal basis for data processing for the purposes established in points a), b) and c) of the previous paragraph lies in the specific contractual relationship entered into with Users, with the performance of operations strictly connected with and instrumental to the management of relations with said Users, and the fulfillment of the legal obligations to which the Data Controller is subject.

The legal basis for data processing for the purposes established in points d), e) and f) of the previous paragraph is the consent given by the data subject.

Communication and dissemination of Users' data  

The processed User data will not be disseminated, but may be communicated by Twinset to (i) companies related to and/or controlled by, or in any event belonging to the Twinset group, in accordance with and within the limits laid down in art. 44 et seq of the European regulation; (ii) any persons who provide Twinset with services that are instrumental to the purposes listed above; (iii) suppliers, banks and/or insurance companies or, in general, other persons/bodies that, on behalf of Twinset, provide the services indicated in the paragraph on the purposes of processing or activities connected therewith or instrumental thereto; (iv) consultants who assist Twinset in various capacities, on legal, fiscal, social security, accounting and organizational matters; (v) any other person/body/authority to which the data must be communicated by virtue of legal requirements.

Submission of data and consequences of refusal

Without prejudice to the points established in relation to browsing data, the submission of personal data by the User is optional.

Refusal to submit information or the submission of incorrect and/or incomplete information may make it impossible, without giving rise to any liability on the part of Twinset, to manage and/or fulfill orders or purchase proposals made by the User and, in general, to carry out the operations specified in the paragraph on the purposes of processing.

Rights of Users

Data Subjects may exercise their rights vis-a-vis the Data Controller, pursuant to articles 15 et seq of Regulation (EU) 2016/679, and may thus obtain confirmation of the existence of their personal data and request that it be communicated to them in intelligible form. They shall also be entitled to have the said data updated, corrected, supplemented or deleted or to restrict the processing thereof. Lastly, they shall be entitled to object, for legitimate reasons, to the processing of their personal data, as a whole or in part, even if relevant to the purpose for which it was collected. They shall be entitled to exercise the right of data portability and to lodge a complaint with the supervisory authority, pursuant to art. 77 of Regulation (EU) 2016/679.

A full, up-to-date list of Data Processors shall be available, on request, from the Data Controller.

Requests should be addressed to: privacy@twinset.com

Amendments to this privacy statement

Twinset reserves the right to amend, update, add or remove parts of this privacy statement at any time, at its own discretion. Users shall be under obligation to check periodically for possible amendments. In order to facilitate such checks, the statement indicates the date on which it was last updated. Using the Website after the publication of amendments to it shall constitute acceptance of the said amendments.

TWINSET COOKIE POLICY

Like many other websites, Twinset.com may store or retrieve information from the browser, especially in the form of cookies. Such information may relate to the User, their preferences or the device they use to access the Internet (computer, tablet or mobile phone) and are mainly used to align the operation of the Website with the User's expectations, by offering a customized browsing experience and storing previously made choices.

The paragraphs that follow provide further information about the various cookies used. It is possible to prevent some or all cookies being saved, should you wish to do so. This may, however, compromise your use of the Website and the services offered.

Browser cookies

Browser cookies are technical cookies that enable browsing. They include cookies that automatically recognize the language used by the User, that facilitate online purchases, etc.. If you are registered, browser cookies enable you to be recognized as a registered User of the Website when you log in.

Without these cookies, we are unable to provide the services for which Users log into the site.

Analytics cookies

These cookies show how visitors use the Website, so that its operation can be assessed and improved. For example, they indicate which pages are visited most or least. Among other metrics, they take account of the number of visitors, the time spent on the Website by Users and the way they find it. This enables us to find out what works well and what to improve, and to ensure that the pages load quickly and are displayed correctly.

All information collected by these cookies is anonymous and is not linked to Users' personal data. We use the services of Google Analytics to perform these functions.

Tracking cookies

Tracking cookies include all cookies that track and monitor User browsing, with a view to monitoring and profiling Users. Cookies of this type enable us to see which web pages Users visit, what they purchase, what they read etc.. We use these cookies to profile Users by tastes, habits and purchasing choices, and to send personalized advertising for given products.

We use these cookies to ensure that the marketing messages received from our Website or from other sites that we advertise on are aligned with visitors' preferences.

We need your prior consent to use tracking cookies.

Retargeting cookies

Retargeting cookies are necessary for the advertisement services provided via Criteo and/or Google Remarketing. Browser cookies track the products you view on our Website and then enable us to show you banners and/or advertisements for our products, based on your browsing history, when you visit other, affiliated websites. Users are assigned a technical ID, but under no circumstances will Criteo and/or Google collect personal data such as names or addresses that allow users to be identified. To find out more, please consult the privacy policy of

Criteo: http://www.criteo.com/it/privacy/ and/or

Google: http://www.google.com/intl/en/policies/technologies/ads/.

Refusing cookies

If you have any doubts about the use of cookies, you can take action to prevent their placement, for example by changing the configuration of your browser to block certain types of cookie. Bear in mind, however, that disabling browser cookies may prevent the Website from working properly and/or restrict the services available on it.

For detailed information on the necessary procedure, please consult your browser's help pages. For an overview of the most common browsers, visit
http://www.cookiepedia.co.uk/index.php?title=How_to_Manage_Cookiesor
http://www.aboutcookies.org/

Advertising companies also enable you to refuse to receive targeted advertisements if you wish. This does not prevent the placement of cookies, but it stops the use and collection of certain data by these companies. For further information and refusal options, visit http://www.youronlinechoices.eu/

To disable the display of Criteo advertisements, go to: http://www.criteo.com/it/privacy/.

To disable analytics cookies, you can download the browser add-in for disabling Google Analytics: tools.google.com/dlpage/gaoptout.

To disable Google retargeting cookies, go to http://www.google.com/settings/ads/anonymous

The cookies placed by the Website are listed below:

• a) ai
• b) AWSLEB
• c) .AspNet.ApplicationCookie
• d) userSessionId
• e) userWishListId
• f) CookieAlarm
• g) __RequestVerificationToken
• h) localeInfo

The data may be processed using IT, hard-copy, digital, electronic and magnetic media. The collected data will be stored and kept at the headquarters of Twinset S.p.A. in Carpi (MO) - 41012, Via del Commercio, 32.

The Data Controller is Twinset S.p.A. with registered office in Carpi (MO) - 41012, Via del Commercio, 32. Tel. 059.91951 - fax 059.9195101 e-mail: privacy@twinset.com.

Information to Supplier pursuant to article 13 of EU Regulation 2016/679

Pursuant to article 13 of Regulation EU 2016/679 (hereinafter referred to as the “Regulation”), Twinset S.p.A., a sole shareholder Company (hereinafter simply referred to as “Twinset” or the “Company”), in its capacity as Data Controller, hereby inform You that the personal data you provide shall be processed in a pertinent and transparent manner, and in accordance with the principles of legality and necessity, pursuant to current regulations on the subject.

Data Controller

The Data Controller is Twinset S.p.A., sole shareholder company, with registered office in Carpi (Modena) Italy, Via Del Commercio, 32, Tax identification and VAT number 07889180969, e-mail privacy@twinset.com.

Purposes of data processing

We hereby inform you that the processing of personal data shall be carried out for the following purposes:

• a) compliance with all legal obligations;
• b) execution of the operations strictly related and instrumental to establishing contract relationships, including the acquisition of preliminary information on the termination of the Contract;
• c) management of relationship with the supplier for administrative, accounting, procurement, shipping, invoicing, service activities and to manage possible disputes;
• d) any assessment of the supplier based on ISO 9001 2015 and GDPR EU 2016/679.

Processing shall be carried out in accordance with the principles of correctness, lawfulness and transparency, whilst protecting your privacy and your rights.

Your personal data will be processed during the full term of the contractual relationship, and also thereafter in order to fully comply with all legal obligations and for future commercial purposes.

Legal basis of the processing

The legal basis of data processing is represented by the specific contractual relationship established, as well as by the legal obligations to which the Data Controller is subject.

Methods of processing

The processing of data for the aforementioned purposes is done using computer methods, on electronic or magnetic supports, as well as non-electronic methods, on hard-copy supports, pursuant to the rules of confidentiality and security stipulated by law, the consequent regulations and internal rules.

Place where data are processed Personal Data are currently processed and stored at the operational premises of the Company Twinset S.p.A., with registered office in Via del Commercio 32, 41012 Carpi (MO) Italy. The data is also processed on behalf of the undersigned by professionals and/or companies appointed to carry out technical, development, management and administrative-accounting activities.

Mandatory or voluntary provision of data Certain data is indispensable to establishing the contract relationship or for its execution, whereas other data may be defined as ancillary to these purposes. The provision of data to the undersigned is mandatory only in the case of data required in terms of a regulatory or contractual obligation.

Consequences of possible refusal to provide data

In the case of the provision of data being required by a regulatory or contractual obligation, the possible refusal would place the supplier in circumstances that would not permit the execution or continuation of the contract in that this would qualify as unlawful processing. In the event that there is no legal obligation to provide data, the refusal would not have the aforementioned consequences, but would prevent the execution of ancillary operations.

Communication of data

Your data may be communicated in Italy and/or abroad to:

• a) Professionals and consultants, consulting companies, factoring companies, credit institutions, debt recovery agencies, credit insurance companies, business information companies and transport companies;
• b) Public and private entities, including subsequent to inspections or audits, such as for example: Financial Administration, Tax Police structures, Judicial Authorities, Italian Foreign Exchange Office, Labour Inspector, Local health Authorities (ASL), Social Welfare Entities, ENASARCO, Chamber of Commerce, etc.;
• c) Other companies of the Twinset Group, including those resident abroad;
• d) Data subjects that can access your data in terms of legislation.

Data retention period

In compliance with the principles of proportionality and necessity, your data will not be stored for longer periods than those necessary to achieve the aforementioned purposes; the data provided will then be stored in our archives according to the following parameters:

The data provided shall be retained in our archives, based on the following parameters: for administration, accounting, orders, the management of quotations and the entire production flow, assistance and maintenance, shipping, invoicing, services, managing of possible disputes: 10 years as specified by Law under Art. 2220 of the Italian Civil Code, without prejudice to extensions justified by possible delays in the payment of compensations;

Transfer of personal data abroad

Twinset may transfer personal data in a third country or to an international organization in compliance with the regulations set out in Articles. 45-49 of the GDPR.

Rights of the data subject

At any time, You can exercise your rights towards the Data Controller, pursuant to Article 15 ss. of the EU 2016/679 Regulation, that is, You may obtain confirmation of the existence of your personal data and request their communication in an intelligible form. You will also have the right to obtain the updating, rectification, integration and deletion of data or the limitation of processing, as well as the right to object, in whole or in part, for legitimate reasons, to the processing of your personal data, even if relevant to the purpose of the collection. Pursuant to art. 77 of the 2016/679 EU Regulation, moreover, will have the right to lodge a complaint with the Data Protection Authority in case they believe that the treatment violates the aforementioned Regulation. Requests should be addressed to privacy@twinset.com.

The present Information on Privacy is also available in the Privacy Section of our website www.twinset.com.

Information to the Client pursuant to article 13 of EU Regulation 2016/679

Pursuant to article 13 of Regulation EU 2016/679 (hereinafter referred to as the “Regulation”), Twinset S.p.A., a sole shareholder Company (hereinafter simply referred to as “Twinset” or the “Company”), in its capacity as Data Controller, hereby inform You that the personal data you provide shall be processed in a pertinent and transparent manner, and in accordance with the principles of legality and necessity, pursuant to current regulations on the subject.

Data Controller

The Data Controller is Twinset S.p.A., sole shareholder company, with registered office in Carpi (Modena) Italy, Via Del Commercio, 32, Tax identification and VAT number 07889180969, e-mail privacy@twinset.com.

Purposes of data processing

We hereby inform you that the processing of personal data shall be carried out for the following purposes:

• a) compliance with all legal obligations;
• b) execution of the operations strictly related and instrumental to establishing contract relationships;
• c) management of relationship with the client for administrative, accounting, procurement, shipping, invoicing, service activities and to manage possible disputes;

Legal basis of the processing.

The legal basis of data processing is represented by the specific contractual relationship established and the fulfillment of the legal obligations connected to it. The processing of data supplied by you is necessary for the execution of the cited contractual relationship of which you are a part; any failure to provide personal data will make it impossible to proceed with the execution of the contract.

Methods of processing

The processing of data for the aforementioned purposes is done using computer methods, on electronic or magnetic supports, as well as non-electronic methods, on hard-copy supports, pursuant to the rules of confidentiality and security stipulated by law, the consequent regulations and internal rules.

Retention period of personal data

In compliance with the principles of proportionality and necessity, the data will not be stored for longer periods than those necessary to achieve the purposes indicated above and, therefore, for the time necessary to execute the contract, however in limits to what is established by the relevant legal regulations.

Recipients of personal data

The data collected will be processed exclusively for the purposes mentioned above. In compliance with the appropriate security measures implemented by the Data Controller, the data may be communicated to the control authorities required by law and to other public and private entities for the fulfillment of obligations under the law on contracts and other laws also in tax, administrative and financial matters.

Transfer of personal data abroad

Twinset may transfer personal data in a third country or to an international organization in compliance with the regulations set out in Articles. 45-49 of the GDPR.

Rights of the data subject (art. 15 and sub. of the Regulation)

The subject to whom the personal data refers has the right to ask Twinset to access his data, to rectify it, to cancel it and to limit its processing. The interested party can oppose the processing of his data and exercise the right to the portability of the same as well as to propose a complaint to the Authority for the protection of personal data, pursuant to art. 77 of the Regulation. Requests should be addressed to privacy@twinset.com.

The present Information on Privacy is also available in the Privacy Section of our website www.twinset.com.