PRIVACY POLICY – ART. 13 REGULATION EU 679/2016

Last Updated May 19th, 2018

By using or accessing JOLIE COMPANY websites (“Site”), you are consenting to is use of our privacy policy as outlined below.

FOREWORD

In this page, we explain how to manage the Website in relation to the processing of personal data concerning users browsing the Website. This Privacy Notice is also provided pursuant to the Article 13 of the EU Regulation 679/2016 (hereafter referred to as “GDPR”) to those who interact with the web services of the Company Jolie Concierge (hereinafter also referred to as “Company”), accessible by telecommunication from the following addresses: www.joliecompany.com, www.jolieconcierge.it, www.jolietravel.com , www.jolieevent.com, (hereinafter “Jolie Websites”), corresponding to the respective initial pages of the official Websites of the Company. The information is provided only for the aforementioned websites of the Company and not for any other websites that may be consulted by the user via links.

DATA CONTROLLER

Consultation of this website may lead to the processing of data relating to identified or identifiable person. The Data Controller of the processing of data is JOLIE CONCIERGE DI FLAVIA VALENTINI(hereinafter referred to as “JOLIE CONCIERGE”) based in Rome, (Italy), tax code, VAT No, 14664031003, REA n.1536913.

The Company recognize the importance of protecting the personal data of our customers (e.g. identification data, financial information such as, for instance, credit card numbers) and the information of the users of our Website(s). For this reason Jolie Concierge adopts specific policies and security measures to comply with applicable data protection laws and to protect your personal data.

THE NATURE OF PERSONAL DATA

Here we have provided you with a detailed description of the nature and type of personal data asked of you.

The data processed by Jolie Concierge come within the following types:

Common Personal Data

General personal details (such as, by way of example, name, surname, date of birth, residential address and telephone number);

Browsing data

During their normal operation, the computer systems and software procedures used to operate this website collect some personal data, the transmission of which is an integral part of Internet communications protocols.
This information is not collected in order to be associated with identified data subjects but, it might allow users to be identified by processing and associating it with data held by third parties.
This category of data includes the IP address or domain of the computer used by visitors connecting to the website, the URI (Uniform Resource Identifier) of requested resources, the time of the request, the method used to submit the request to the server, the size of the file received as a reply, the numeric code indicating the status of the reply given by the server (successful, error, etc.) and other parameters regarding the user’s operating system and computer environment.
This data is used exclusively to obtain anonymous statistics on website use and to check its proper functioning, and is deleted immediately after processing. The data might also be used to ascertain any liability in cases of alleged computer crimes against the website.

Data freely provided by the user

Personal data, such as tax data and contact details, including the e-mail address, and any other personal data given to the Data Controller are processed

  1. during the request of activation of a Jolie service, such as the Newsletter Service
  2. during the sending communications to the same Company through the appropriate section of the Web Sites;
  3. as the information acquired on your consumption habits and on your consumption preferences manifested while browsing the Website, including through cookies, and during the purchase procedures of the Company’s products are processed.

Your personal data will be processed by the Company in accordance with the Regulations and national regulations, including any provisions issued by the Supervisory Authority (Guarantor for the protection of personal data), where applicable.

Jolie Concierge declines any liability with regard to the possible management of personal data by third party sites and in relation to the management of the authentication credentials provided by third parties.

Cookies

Our web site uses  cookies which can be checked by clicking on the Cookie Policy

Minimum age

The protection of underage safety and privacy is very important for us. By registering on the Jolie Websites in the appropriate section, as well as when filling out any forms for collecting data on these sites or when requesting supply / registration to the Newsletter service, the client confirms that he / she has turned 16 of age or in any case of not being under the age indicated by the legislation of the country of residence which foresees other age limits.

PURPOSE OF PROCESSING

The personal data requested via Jolie Websites are collected and processed for the following purposes:

a) To pursue your requests, including registration on the Website and / or finalization of purchase orders for products, and manage the relation you wish to establish with our Company or the one already existing between you and the Company;

b) For administrative purposes in any way connected with the fulfillment of the relevant contractual obligations or the fulfillment of law requirements (e.g. accounting, tax), or for pursuing the requests of judicial authorities;

c) In case of consent, to check the level of customer satisfaction and to propose (by mail, email, phone, fax, sms, mms, social media, social chat) products similar to those already supplied, by regularly sending newsletters, catalogues, brochures, invitations to events or, in general, commercial communications and advertising material, and by carrying out market surveys; 

d) In case of consent, the Company, based on your purchasing data and preferences, will also carry out client profiling and analysis activities, in order to perform an analysis on your purchase habits and on your consumption choices for sending (by mail, email, phone, fax, sms, mms, social media, social chat) of advertising communications expressly dedicated to you.

The profiling activity consists in an analysis of your consumption habits and choices, and in the creation of your profile using the personal data provided to the Company in combination with the information and preferences expressed during the purchase of Jolie products and use of the Customer Card in order to send personalized commercial communications.

The profiling activity will not produce legal effects on you nor affect you, except for the formulation and reporting of personalized promotional offers.

The Company informs you that you may object to the marketing purpose at any time, including profiling, by sending an e-mail to privacy@jolieconcierge.it and unsubscribing from the newsletter service by the newsletter format on the home page or sending a message to privacy@jolieconcierge.it or clicking on link that you will find at the bottom of the promotional e-mails you will receive in case of registration to the aforementioned service.

NATURE OF SUBMISSION OF DATA

The provision data for the purposes referred to in point a) and b) is necessary and any refusal to do so will make it impossible for the Company to pursue its contractual and legal commitments. With regard to the purposes referred to in points c) and d), instead, the provision of personal data is optional, and their use is subject to your explicit consent. Any refusal to provide consent will not have any effect other than the inability to analyze your consumer habits and duly inform you of any corporate initiatives that may be of interest to you.

METHODS OF PROCESSING

 

Personal data shall be processed, by the Company and its Authorized Persons, using both computerized and no-computerized systems. Personal data will be processed fairly, lawfully and transparently, in accordance with the Regulation, also ensuring the confidentiality of the Data Subject information and its rights through the adoption of suitable technical and organizational security measures information to guarantee an appropriate level of security. Specific security measures are adopted to prevent data loss, illicit or incorrect use and unauthorized access.

DATA RETENTION

With reference to the purposes referred to in points a) and b) of the art. 4 (Purpose of processing), personal data will be processed for the entire duration of the relationship and necessary to achieve the aforementioned purposes. The personal data necessary for the fulfillment of any legal obligations will be retained also subsequently, in compliance with these obligations and in compliance with the retention times established by the applicable regulations.

For the data provided for the purposes referred to in points c) (marketing) and d) (profiling) of art. 4 (Purpose of processing), in consideration of the fact that the personal data that the Company intends to preserve pertain to purchases of products of ‘Upmarket’ and that the average annual frequency of purchase, for each client, is spaced over time, the personal data you provide will be kept for a maximum period of 7 years, considering this time frame adequate and proportionate both to the purposes intended and to the type of personal data being processed. Upon expiry of this deadline, the data will be deleted or made anonymous and in any case you can always give new consent to the processing of your data by the Company for the same purposes.

COMMUNICATION AND TRANSFER OF DATA

Your data will be processed by the smallest possible number of people who have been specifically authorised to such end by 
Jolie Concierge.

Your personal data may be transmitted within the following areas in the performance of the above-described  purposes:

Your data may be used by staff of the Jolie Concierge, who have been assigned the specific duty of processing staff, who have been adequately trained and who are bound by confidentiality obligations.

Your personal data will only be made accessible to those who need to have access to them within Jolie Concierge, as a result of their duties or position in the hierarchy.

The above staff will be appropriately trained in order to avoid losses of, destruction of, unauthorised access to, or processing to which consent has not been given, of the data concerned.

Personal data may be made accessible, communicated and transferred to Public Authority in order to give effect to investigation requests or where expressly authorized by legal obligation.

Your personal data will not be disseminated, but some of the subjects to whom the data are disclosed could be established in countries outside the European Union (“EU”). In some cases, the third countries are deemed appropriate based on a decision by the European Commission; in other cases, the Company ensures the existence of adequate guarantees for the transfer on the basis of contractual clauses between the Company and the recipient of personal data in the third country. The Company undertakes to guarantee adequate levels of protection according to the applicable rules, including the provision of technical and organizational security measures.

You can obtain an updated list of the external Data Processors which have been appointed by Jolie Concierge by sending the related request to the e-mail address privacy@jolieconcierge.it 

REDIRECT TO OTHER WEBSITES

Jolie Websites may use the so-called social plug-ins. Social plug-ins are special tools that allow social network features to be incorporated directly within our websites (e.g. the “Like” button on Facebook). All social plug-ins on our Websites are marked by the respective logos owned by the relevant social network.

When you visit a page of our Websites and interact with a plug-in (e.g. clicking the “Like” button) or decide to write a comment, the corresponding information is transmitted by your browser directly to the relevant social network (Facebook in this case), which stores it. For information on the purposes, types, and methods used for personal data collection, processing, use and storage by social networks, and for information on how to exercise your rights, please refer to the social network’s privacy policy.

POLICY UPDATE

Any new regulations on the subject, as well as our constant analysis and updating of user services, may result in the need to change the user’s personal data processing methods. Consequently, our privacy policy may change over time. Therefore, we invite you to visit this page on a regular basis. For this purpose, the policy document states the latest review date.

Any material changes to this Privacy Policy will be notified to registered users by email and by posting a notice on the Website.

Last Review May 19th, 2018

RIGHTS OF THE DATA SUBJECT

You have the right to request access to, rectification of, the portability of, or the erasure of, your personal data in addition to the restriction of, opposition to and the revocation of the processing

You have the right to request jOLIE CONCIERGE, in relation to the processing of your personal data:

  • For ACCESS: you can ask for confirmation whether or not data relating to you are being processed in addition to greater clarification with regard to the information set out in this policy;
  • For RECTIFICATION: you can ask to rectify or add to the data you have provided us with should they be imprecise;
  • For ERASURE: you may ask for your data to be erased in the following circumstances: they are no longer necessary for our purposes, the revocation of your consent or your opposition to the processing, in the case of unlawful processing or where there is a legal obligation to erase the data or where they refer to people under 16;
  • For RESTRICTION: you may request that your data are only processed for storage purposes – with the exclusion of other processing – for the period necessary for the rectification of your data, in the case of unlawful processing by reason of which you have opposed their erasure if you have to exercise your rights in judicial proceedings and the data stored by ourselves may be useful and, finally, in the case of opposition to the processing if an investigation is being conducted into whether our legitimate interests should prevail over yours;
  • For OPPOSITION: you may oppose the processing of your data at any time save where we have legitimate reasons to go ahead with the processing which prevail over yours for example in the exercise of our defence in legal action;
  • For PORTABILITY: you may ask to receive your data, or ask for them to be transmitted to another Data Controller indicated by you, in a structured format in common use and legible by an automated device;
  • For REVOCATION: you may revoke your consent at any time when this constitutes the basis for the processing. The revocation of consent will in any case not prejudice the lawfulness of the processing based on consent and carried out prior to such revocation.

You may send a request to Jolie Concierge asking to exercise your above rights at any time by writing to the e-mail address to privacy@jolieconcierge.it or by postal mail to the Company: (Adress will be updated soon- Rome, Italy)

and Jolie Concierge will manage your requests within the time limits laid down by the GDPR.

We would also inform you that you have the right to make a claim to the Italian Regulatory Authority: “Garante per la Protezione dei Dati Personali” (The Regulatory Authority for the Protection of Personal Data) should you consider that your rights have been breached by Jolie Concierge and/or by a third party when you do not consider the response of Jolie Concierge to your requests to be satisfactory.

DISCLAIMER

The original, legally binding version of this document is written in Italian, and it is translated into English for the courtesy of our English-speaking users. If there are any discrepancies between the Italian version and a translated version, the Italian version supersedes the translated version.