PRIVACY POLICY
Policy in accordance with article 13 of Regulation (UE) number 679/2016 (“GDPR”)
In accordance with the Regulation of the European Union number 679/2016 (hereinafter referred to as “GDPR”) and particularly with article 13, hereunder we provide You with the information required by law with regards to processing of your personal data.
What data we process (article 13, 1° paragraph letter a, article 15, letter b, GDPR)
MIRIADE S.p.a., with headquarters in Nola (NA) Interporto Lotto C, A19 – A20 – A2, operates as Holder of the data processing and collects and/or receives information about you, which are:
- Data included in forms of adhesion to the Fidelity card (through online form or directly in one of our Stores) such as: name, surname, tax code, place and date of birth, physical address, email address, phone and/or mobile number;
- Data regarding browsing on our website, such as: website traffic data, eventual localisation, visits to the website, weblog, IP address, operating system used, browser used, cookie (for further information please visit the “Cookie” section);
- Data which you send us through correspondence/email/surveys or other contact forms;
in addition to the above-mentioned data, MIRIADE S.p.A. collects and utilizes the following further categories of data: - spending volume progressively realised correlated to the use of the Card as well as further info on date and location of purchase and the purchased product;
- Identification and contact personal data related to Your participation to events, promotions and prize contests;
- Personal data which are spontaneously communicated through enquiry or report to our customer care (e.g. contact details and eventual theft or malfunctioning of the Card);
- Data regarding payment methods: payment tools (credit card or debit card) and, if that is the case, identification number, when required for fiscal reasons or in relation to the anti-money-laundering law.
What we need your data for (article 13, 1° paragraph, letter c, d GDPR)
We use Your data to realise a number of promotional offers, fidelity programs and market research, to send you newsletter and to carry out all marketing activities aimed at satisfying demands of a growingly diversified and attentive to purchased products client base.
The above-mentioned personal data will be used on paper-based and through technology solutions, also with support of electronic and information methods, in accordance with principles of necessity, lawfulness, correctness, proportionality and transparency for purposes, and in accordance with legal conditions mentioned below:
a) Card release and adhesion to the fidelity program
In order to issue you the Miriade Fidelity Card and enable you to access all the advantages reserved to card holders (discounts, promotions, participation to prize contests, invitations to events, etc.) and to provide you with assistance if you require it through our customer care.
The legal base of such data processing is the necessity to enable you to use the Card and the correlated advantages with regards to what is established by the regulation of use of the Fidelity Card.
b) Analysis of consumer habits
To analyse you consumer habits and carry out market evaluation and research to improve our commercial offering and send you promotions and invitations suitable to your preferences.
The legal base of this data processing is Your consent (obtained at the time of request of the Card and revocable at any moment).
c) Marketing
To send You advertising and promotional material via phone, mail, or electronic communications such as email, SMS, and mms.
The legal base of this data processing is Your consent (obtained at the time of request of the Card and revocable at any moment).
d) Verification of compliance with provisions of Fidelity card Regulation and protection of rights
To manage eventual conducts violating what is established in the Regulation and to protect our rights in court of law.
The legal base of this data processing is the necessity to pursue our legitimate interests (with respect of provisions of Fidelity card Regulation and protection of our rights in court of law).
e) Compliance with legal obligations
To comply with the obligations established by laws or regulations or by orders from competent Bodies.
The legal base of this data processing is the necessity to comply with a legal obligation.
f) Use of cookies
To track in an anonymous and aggregate form the visitor’s use of the website and to recommend social media contents.
Cookies are small files registered on Your device. Cookies can be used to determine whether there already has been a connection between Your device and our webpages. Only the cookie memorized on Your device can be identified. No personal data is memorized in the “Cookies” file.
There are 2 types of cookies utilized by this website:
- Technical cookies, such as that of google analytics and the one used to keep track of acceptance of our cookies policy.
- Third party cookies. These cookies are installed in the visitor’s computer from social media incorporated in the “social” webpage of this website. For such cookies, a link to the publisher’s policy pages is subsequently indicated.
Consent to use of profiling cookies is given by the user through the following modalities: closing the cookies notice banner, by scrolling the banner page or by clicking any of its elements and this can be revoked at any moment. For further information on how to carry out this transaction you can refer to instructions from Your browser or device.
All technical cookies do not require consent; therefore, they are automatically installed after access to the website or service.
What happens if you do not provide your data? (article 13, 2° paragraph, letter e, GDPR)
Provision of your data, although optional, is necessary within the terms of regulation of use of Fidelity card and the lacking, incomplete or untruthful communication will result in the impossibility to release the Card and to revoke it. Provision of spending volume data is necessary to enable You to benefit from exclusive advantages reserved for holders (e.g. reaching a certain spending level allows the holder to participate to prize contests) and lack of provision will result in impossibility to benefit from the aforementioned advantages.
Provision of personal data for marketing and consumer habits analysis purposes is always optional and eventual refusal will imply impossibility to pursue the objectives.
Subjects whom personal data can be communicated to (article 13, 1° paragraph, letter e, GDPR)
The data collected by the company shall be communicated to:
companies which carry out activities directly connected with and instrumental to the operativity – also technical – of MIRIADE S.p.a. such as, for example, providers of advertisement revision and assessment, providers of direct marketing and customer care services, companies that provide administration, filing, payment and invoicing services, governmental and juridical institutions and bodies pursuant to legal obligations.
Under no circumstances we give or sell personal data to third parties.
How long are your data stored for? (article 13, 2° paragraph, letter a, GDPR)
Collected data will be stored for a period of time not longer than the time it takes to achieve the purposes which they are processed for (“principle of minimisation” ex article 5, GDPR) or based on deadlines established by law.
In particular,
• personal biographic and contact data and preferences indicated when applying to membership to the Fidelity Card are stored for the full duration of the Card, except in case of withdrawal;
• data acquired for marketing purposes will be stored for 24 months maximum since your consent. Data collected for profiling purposes instead will be stored for 12 months maximum.
Assessment of obsolescence of data stored in relation to purposes which they are collected for is conducted periodically.
How we process your data (article 13, 2° paragraph, letter f, GDPR)
Data processing is carried out through paper-based and electronic procedures by purposely authorized and trained persons. Data processing does not involve automatized decisional processes, while profiling for activities related to website navigation can be conducted through technical instruments like cookies.
We pay high attention to implementation and maintenance of Your data security. We put into practice appropriate physical and technological guarantees to help preventing non-authorized access, to maintain security of data and to correctly use information we collect online. These protections vary depending on sensitivity of the data that we collect and store.
All MIRIADE S.p.A. staff are subject to rigorous codes of confidentiality and are obliged to protect Your personal information.
We employ accurate procedures and specific technical controls to guarantee security of our information systems, such as:
• secure network typology, which includes breach and firewall prevention systems;
• cryptographic communication;
• authentication and access control;
• external and internal verification tests, etcetera.
Despite all the measures implemented to safeguard Your information we cannot guarantee, considering technology, that non-authorized access or abuse of services by third parties can be excluded.
What are your rights? (article 13, 1° paragraph, letter b, and 2° paragraph letter b, GDPR)
As in your interest, in accordance with articles15-21 of GDPR you have the right to:
- receive confirmation that Your personal data are being processed;
- have access to Your personal data and know their source (when data are not directly collected from you), purposes and treatment objectives, data regarding persons whom they are communicated to, the period of storage of Your data or useful criteria to determine this;
- update or amend Your personal data to ensure that they are always correct and accurate;
- in cases covered by law, cancel Your personal data or ask for limitation of data processing;
- receive a copy of Your personal data.
Eventual enquiries will be processed no later than a month since received, unless there is the possibility to extend such time-limits for additional two months, if necessary, considering the complexity and high number of enquiries received by the Holder.
To obtain the full specific list of the Holder’s external Supervisors or for any further info and enquiry you can contact the Holder at the email address privacy@miriadespa.it .
Modifications to privacy policy
We reserve the right to modify the present privacy Policy at any moment. We will notify You of substantial modifications to the present privacy Policy by sending an email to the email address you indicated. Such substantial amendments will be effective seven (7) days after notification.
Who can you submit a complaint to? (article 13, 2° paragraph letter d, GDPR)
Holder of data processing is MIRIADE S.p.A, in person of the legal representative pro tempore, headquarters in Nola (NA) Interporto Lotto C, A19 – A20 – A2; PEC: miriade@pec.it ;
In case of general questions about information we collect and how we use it, we kindly ask You to send us an email at privacy@miriadespa.it or send a mail to MIRIADE SpA – Nola (NA) Interporto Lotto C, A19 – A20 – A2.
If you are not satisfied with our reply, you can contact the Guarantor Authority for data protection (Guarantor Authority for the Protection of Personal Data):
Piazza Venezia 11, 00187, Roma (E-mail: protocollo@gpdp.it, PEC*: protocollo@pec.gpdp.it, operator +39 06.696771).
