Trudi S.p.a. with registered offices at Vincenzo Gioberti 1, 20123, Milano and administrative headquarters at Via Angeli A., 150, 33017 Tarcento (UD) (“Trudi”) is committed to protecting the online privacy of the users of this website (“Website”). As such, this Privacy Policy has been written in order to allow you to understand Trudi’s policy regarding your privacy, as well as how your personal information will be handled when using the Website. This Privacy Policy will also provide you with information so that you are able to consent to the processing of your personal data in an explicit and informed manner, where appropriate.
In general, any information and personal data which you provide to Trudi over the Website, or which is otherwise gathered via the Website by Trudi, in the context of the use of Trudi’s services (“Services”) as better defined in Section 3 below, will be processed by Trudi in a lawful, fair and transparent manner. To this end, and as further described below, Trudi takes into consideration internationally recognised principles governing the processing of personal data, such as purpose limitation, storage limitation, data minimisation, data quality and confidentiality.


CONTENTS
1. Data controller 
2. Personal Data processed 
    a. Name, contact details and other Personal Data
    b. Special categories of Personal Data and Data of minors
    c. Other persons’ Personal Data
    d. Browsing data
    e. Cookies
3. Purposes of processing
4. Grounds for processing and mandatory or discretionary nature of processing
5. Recipients of Personal Data
6. Transfer of Personal Data
7. Retention of Personal Data
8. Data subjects’ rights
9. Amendments

1. Data controller
Trudi, as identified at the top of this Privacy Policy, is the data controller regarding all personal data processing carried out through the Website.

2. Personal Data processed
When you use the Website, you may provide to us or we may collect – depending on how you decide to use the Services – some of your Personal Data such as your first name, last name, tax code, province of residence, phone number, e-mail address, an identification number as the customer code, an online ID or one or more characteristic elements of your physical, physiological, mental, economic, cultural or social identity which allows you to be identified either by itself, or together with other information which has been collected.(“Personal Data”).
Your “Personal Data” can be collected both when you choose to provide them (e.g., when you create an account in order to receive the Services offered by Trudi) or simply by analysing your behaviour on the Website.
Personal Data which can be processed through the Website are the following:

a. Name, contact details and other Personal Data
In various sections of the Website – including, in particular, if you decide to create an account on the Website, in the section “Contact us” or when you purchase a product in the on-line store – you will be asked to submit information about yourself, such as your first and last name, tax code or VAT number, phone / mobile numbers, e-mail address, shipping address of your purchases, the details of your credit card in case you select this payment method for your purchases, etc…
In addition, whenever you participate in surveys and other promotions which may be available on the Website, as well as whenever you communicate with Trudi through the contact details provided in the Website or with Customer Service, Trudi may collect additional information which you choose to provide.

b. Special categories of Personal Data
Certain areas of the Website may include free text fields, where you can write messages to Trudi, or otherwise allow you to post various types of content on the Website, which may contain Personal Data.
Where these fields are completely free, you may use them to disclose (inadvertently or not) more sensitive categories of Personal Data, such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The content you upload in these fields may also (inadvertently or not) include other types of sensitive information relating to you, such as your genetic data, biometric data or data concerning your health, sex life or sexual orientation.
Trudi asks that you do not disclose any sensitive Personal Data on the Website, unless you consider this to be strictly necessary. As it is totally optional to provide this information, if you nonetheless choose to do so, please mind that Trudi requires your explicit consent to process this sort of Personal Data.

c. Other persons’ Personal Data and Data of minors
As mentioned in the previous section, certain areas of the Website (particularly, in the “Contact Us” section) allow you to post various types of content on the Website which may include Personal Data related to other persons.
In any situation where you decide to share Personal Data related to other persons, you will be considered as an independent data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify Trudi against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, brought by the third parties whose information you provide through the Website. As Trudi does not collect this information directly from these third parties (but rather collects them, indirectly, from you), you must make sure that you have these third parties’ consent before providing any information regarding them to Trudi; if not, then you must make sure there is some other appropriate grounds on which you can rely to lawfully give Trudi this information.
Trudi reminds you that the use of the Website is reserved for people who have reached the 18th year of age. If you are not of legal age, Trudi invites you to visit the Website in the company of a parent.
In any of the case mentioned above, when you communicate to Trudi Personal Data relating to a minor, you guarantee from now on – assuming any related liability – that this particular processing hypothesis is based on the consent of the parental authority and/or the legal representative of the minor.

d. Browsing data
The Website’s operation, as is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While Trudi does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information must also be considered Personal Data.
This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on.
These data are used to compile statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website. Save for this last purpose, these data are not kept for more than 7 business days.

e. Cookies

3. Purposes of processing
Trudi intends to use your Personal Data, collected through the Website, for the following purposes:

  • To verify your identity and assist you, in case you lose or forget your login / password details for any of Trudi’s registration services, to allow you to consult your wishlist and shopping cart; finalize your purchase order and deliver you the products you can buy on the Site or to provide any other Services which you may request (“Service Provision”);
  • For future marketing, promotional and publicity purposes, including to carry out direct marketing, market research and surveys, via e-mail, SMS, MMS, APP, bot, traditional mail, over the phone through Trudi’s official social media pages, as well as for marketing activities in the broad sense, including prize events, games and competitions, products and/or services related to the company and/or to third-party products and/or services (“Marketing”);
  • For sending you direct e-mail marketing communication regarding products and services which are identical or similar to those you have previously purchased via the Website (“Soft opt-in”);
  • For compliance with laws which impose upon Trudi the collection and/or further processing of certain kinds of Personal Data (“Compliance”);
  • To prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website (“Misuse/Fraud”).

4. Grounds for processing and mandatory / discretionary nature of processing
Trudi’s legal bases to process your Personal Data, according to the purposes identified in Section 3, are as follows:

  • Service Provision: processing for these purposes is necessary to provide the Services and, therefore, is necessary for the performance of a contract with you. It is not mandatory for you to give Trudi your Personal Data for these purposes; however, if you do not, Trudi will not be able to provide any Services to you.
  • Marketing: processing for these purposes is based on your consent. It is not mandatory for you to give consent to Trudi for use of your Personal Data for these purposes, and you will suffer no consequence if you choose not to give it (aside from not being able to receive further marketing communications from Trudi). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
  • Soft Opt-in: processing for these purposes is based on Trudi’s interest in sending you direct e-mail marketing communication regarding products and services which are identical or similar to those you have previously purchased through the Website. You can block these communications, and you will suffer no consequence if you do so (aside from not being able to receive further communications from Trudi), by objecting through the link provided at the bottom of all such communications.
  • Compliance: processing for this purpose is necessary for Trudi to comply with its legal obligations. When you provide any Personal Data to Trudi, Trudi must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
  • Misuse/Fraud: Information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potentially criminal purposes).

5. Recipients of Personal Data
Your Personal Data may be shared with the following list of persons / entities (“Recipients”):

  • subjects who typically act as Data Processors such as: i) persons, companies or professional firms providing Trudi with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services ii) entities engaged in order to provide the Services (e.g., hosting providers or e-mail Website providers) iii) subjects authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
  • Persons authorised by Trudi to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of Trudi);
  • Other companies within the Trudi Group for internal administrative purposes;
  • Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;

6. Transfers of Personal Data
Trudi does not transfer your Personal Data outside the European Economic Area.

7. Retention of Personal Data
Personal Data processed for Service Provision will be kept by Trudi for the period deemed strictly necessary to fulfil such purposes (e.g. for the management of the contract with Trudi) – in any case, as these Personal Data are processed for the provision of the Services, Trudi may continue to store this Personal Data for a longer period, as may be necessary to protect Trudi’s interests related to potential liability related to the provision of the Services.
Personal Data processed for Marketing will be kept by Trudi from the moment you give consent until it is withdrawn. Once consent is withdrawn (or not given, following a renewal), Personal Data will no longer be used for these purposes, although it may still be kept by Trudi, in particular as may be necessary to protect Trudi’s interests related to potential liability related to this processing.
Personal Data processed for Soft Opt-in will be kept by Trudi until you object to this processing through the link provided at the bottom of each Soft Opt-in’s emails. 
Personal Data processed for Compliance will be kept by Trudi for the period required by the specific legal obligation or by the applicable law.
Personal Data processed for preventing Misuse/Fraud will be kept by Trudi for as long as deemed strictly necessary to fulfil the purposes for which it was collected.

8. Data subjects’ rights
As a data subject, are entitled to exercise the following rights before Trudi, at any time:

  • Access your Personal Data being processed by Trudi (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
  • Correct or update your Personal Data processed by Trudi, where it may be inaccurate or incomplete;
  • Request erasure of your Personal Data being processed by Trudi;
  • Request the restriction of the processing of your Personal Data;
  • Exercise your right to obtain a copy of your Personal Data provided to Trudi, in a structured, commonly used and machine-readable format;
  • Object to the processing of your Personal Data by Trudi (e.g. Soft Opt-in);
  • Withdraw your consent to processing for Marketing.

When requesting Services via the Website you may have selected one or more means of communication via which Personal Data processing for Marketing purposes may be carried out (e.g. e-mail, SMS, MMS, APP, bot, traditional mail, over the phone through Trudi’s official social media pages). 
You may withdraw your consent for Marketing for each of the selected means of communication, in the manners indicated below.
You can also withdraw consent for Marketing (for communications received via e-mail) or object to Soft Opt-in by selecting the appropriate link included at the bottom of every e-mail message received. The same applies to the Trudi newsletter which you may have subscribed to and receive as a Service.
Aside from the above means, you can always exercise your rights described above by sending a written request to Trudi at the following address: privacy@trudi.it.
In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through the Website is unlawful.

9. Amendments
This Privacy Policy entered into force on Trudi from 28/10/2020.
Trudi reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. Trudi will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website. Trudi therefore invites you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how Trudi collects and uses Personal Data.