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1. Definitions

  • 1.1 General Conditions: General conditions that govern the Product Purchasing Service that Nava offers on the Website.
  • 1.2 Cookies: Text files (letters and/or numbers) that contain small packages of information that are stored on the User’s computer or mobile device whenever the User visits a website from his or her browser. Each time the User visits the website after the cookies are stored, the User’s browser sends the cookies to the website that created them. The cookies can remain stored on the User’s computer only while the User is accessing a given website (i.e. session cookies) or for a longer period of time after the browser session has ended (i.e. persistent cookies).
  • 1.3 Personal Data: Any information relating to an identified or identifiable natural person, directly or indirectly, by reference to the name, identification number, location data, online identifier or to factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.
  • 1.4 Policy: The present document.
  • 1.5 Information Newsletters: Weekly communications that Nava sends by e-mail to Unregistered Users who have expressed their consent, and that contain general information not specifically customised to the Unregistered User, concerning Nava, its Products and the initiatives that Nava promotes.
  • 1.6 Dedicated Newsletters: Weekly communications that Nava sends by e-mail to Registered Users who have expressed their consent, and that contain commercial and promotional information specifically customised to and selected by the Registered User via Profiling, as well as information relating to the initiatives that Nava promotes
  • 1.7 Products: Backpacks, bags, briefcases, notebooks, timepieces, diaries, small leather goods such as, for example, key holders, wallets, document holders and similar products, in addition to travel accessories, that Nava sells on its Website.
  • 1.8 Profiling: The mode of Personal Data Processing that is completed by the use of procedures that are automated in whole or in part, and that is designed to evaluate any personal aspects of Registered Users to allow them to receive Dedicated Newsletters. Companies of the GUY Group may also use Profiling, but only if the Registered User has provided his or her consent to receive informational and commercial communications therefrom..
  • 1.9 Registration: Creation of a personal profile on the Website by filling out the online form that Nava provides for the collection of any Personal Data that may be suitable for the User to take advantage of the Product Purchasing Service (and thus lead to a possible order for the purchase of Products) and to receive Dedicated Newsletters, in cases where the Registered User has provided his or her consent.
  • 1.10 Regulation: Regulation (EU) 2016/679 of 27 April 2016.
  • 1.11 Product Purchasing Service: On the Website, Nava offers its Users the possibility of purchasing the Products directly via the online platform. The Product Purchasing Service is governed by the General Conditions that the Registered User accepts during Registration.
    • Website: The present website.
  • 1.12 Website: The present website.
  • 1.13 Companies of the GUT Group: Companies that are part of the group of companies to which NAVA belongs and of which GUT Edizioni S.p.A. is the holding company. The Companies of the GUT Group to which Personal Data may be sent for marketing purposes, subject to the prior consent of the data subject, are Gut Distribution S.r.l., C’Art Group S.r.l. and Gut Edizioni S.p.A.
  • 1.14 Processing: Any operation or set of operations of which Personal Data is the subject, such as, for example, the collection, organisation, structuring, storage, alteration, retrieval, consultation, use, disclosure, combination, restriction, erasure and destruction of Personal Data.
  • 1.15 Users: All Registered Users and Unregistered Users.
  • 1.17 Registered Users: Persons of full age who are Users of the Website and who complete Registration in order to, either immediately or in the future, take advantage of the Product Purchasing Service and/or receive Dedicated Newsletters.

2. Controller

  • 2.1 Nava Design S.r.l.: The controller for the purpose of the present Policy is Nava Design S.r.l., with its registered address at Viale Ortles no 52/54, Milan, Italy, VAT no 09301670965, registered at the Registro Imprese di Milano (Milan Companies’ Register) under no 2081946 (‘Nava’).
    Any request by the User relating to Nava’s Processing of the User’s Personal Data (including the exercise of rights set out under Paragraph 9 below) must be addressed to Nava by post at its registered office, or by e-mail at the following address: shop@navadesign.com

3. Purpose and Legal Basis of Processing

Nava collects and uses the Personal Data of Users for the following purposes:

  • a) browsing the Website: Consent;
    To allow Users to browse the Website, mainly through the use of Cookies.
    The collection of Personal Data for the purpose set out under Sub-paragraph (a) is governed by the Cookie Policy, available for consultation at the following link http://www.navadesign.com/it/cookie-policy-cookiepolicy
  • b) registration on the Website: Consent;
    To allow Users to complete Registration by creating a personal account.
    - The collection of Personal Data for the purpose set out under Sub-paragraph (b) is optional and is intended for the creation of a personal profile that the Registered User can use to manage his or her Product preferences (for example, to add Products to their wish list that they are interested in purchasing), store their Personal Data to purchase Products in the future more quickly or receive Dedicated Newsletters.
    - If the User refuses to enter his or her Personal Data, he or she is prevented from creating a personal profile on the Website and from receiving Dedicated Newsletters.
    - Such Processing is based on the User’s consent being freely given, specific, informed and unequivocal, expressed by a statement or positive action (e.g. checking a box) to this effect on the Website.
    - Users may withdraw their consent at any time, pursuant to Paragraph 9 (a) of the present Policy. Note that any withdrawal by the User is without prejudice to the lawfulness of the Processing completed prior to said withdrawal.
  • c) Product Purchasing Service: General Conditions;
    To allow Users to purchase Products and to take advantage of the Product Purchasing Service
    - The collection of Personal Data for the User to take advantage of the Product Purchasing Service can take place at the moment of Registration, as described under Sub-paragraph (b) of the present Paragraph 3 of the Policy.
    - Any refusal by the User prevents him or her from purchasing Products and from taking advantage of the Product Purchasing Service
    - For the User to purchase Products and take advantage of the Product Purchasing Service, it is necessary for Nava to collect Personal Data for the purpose set out under the present Sub-paragraph (c).
    - Such Processing is based on the General Conditions that the Registered User signs at the moment of Registration
  • d) Information Newsletters sent to Unregistered Users: Consent;
    To allow Unregistered Users to receive Information Newsletters.
    - The collection of Personal Data for the purpose set out under the present Sub-paragraph (d) is optional and any refusal by the User to such collection prevents him or her from receiving weekly communications that contain general information on Nava, its Products and the initiatives that Nava promotes.
    - Such Processing is based on the User’s consent being freely given, specific, informed and unequivocal, expressed by a statement or positive action (e.g. checking a box) to this effect on the Website.
    - Users can withdraw their consent at any time, pursuant to Paragraph 9 (a) of the present Policy. Note that any withdrawal by the User is without prejudice to the lawfulness of the Processing completed prior to said withdrawal.
  • e) fruizione delle Newsletter Personalizzate in favore degli Utenti Registrati, effettuato anche mediante Profilazione: consenso
    To allow Registered Users to receive Dedicated Newsletters
    - The collection of Personal Data for the purpose set out under the present Sub-paragraph (e) is optional, and any refusal by the User to such collection prevents him or her from receiving weekly communications that contain commercial and promotion information concerning the Products and events that Nava promotes, which the Registered User has specifically selected through Profiling.
    - Processing for the purpose set out under the present Sub-paragraph (e) is completed through Profiling of the Personal Data of the Registered User in order to personalise as much as possible the content of the Dedicated Newsletter in relation to the characteristics and preferences that the Registered User has expressed during Registration or while browsing the Website. Such Processing completed through Profiling is directed at excluding all information from the Dedicated Newsletter that is not of interest to the Registered User, to submit selected news that could instead be more similar to his or her tastes.
    - Such Processing is based on the Registered User’s consent being freely given, specific, informed and unequivocal, expressed by a statement or positive action (e.g. checking a box) to this effect on the Website.
    - Any refusal by the Registered User to consent to such Processing prevents him or her from receiving the Dedicated Newsletters but does not preclude him or her from taking advantage of the Product Purchasing Service.
    - Users can withdraw their consent at any time, pursuant to Paragraph 9 (a) of the present Policy. Note that any withdrawal by the User is without prejudice to the lawfulness of the Processing completed prior to said withdrawal.
  • f) E-mails from the Companies of the GUT Group: Consent;
    To allow Users to receive commercial and informational communications from the Companies of the GUT Group.
    - The collection of Personal Data for the purpose set out under the present Sub-paragraph (f) is optional, and any refusal by the User to such collection prevents him or her from receiving informational and commercial information from the Companies of the GUT Group
    - Such Processing set out under the present Sub-paragraph (f) is completed through the Profiling of Personal Data only in the case of Personal Data of a Registered User, in order to personalise as much as possible the content of the commercial and informational communications that the Companies of the Group sends with respect to the characteristics and preferences that the Registered User has expressed during Registration or while browsing the Website. Such Processing completed through Profiling is directed at excluding all information from the Dedicated Newsletter that is not of interest to the Registered User, to submit selected news that could instead be more similar to his or her tastes.
    - Such Processing is based on the Registered User’s consent being freely given, specific, informed and unequivocal, expressed by a statement or positive action (e.g. checking a box) to this effect on the Website.
    - Any refusal by Registered Users and Unregistered Users to such Processing prevents them from receiving informational and commercial communications from Companies of the GUT Group.
    - Users may withdraw their consent to Processing at all times, pursuant to Paragraph 9 (a) of the present Policy. Note that any withdrawal by the User is without prejudice to the lawfulness of the Processing completed prior to said withdrawal.
  • g) Improvement of the Website and of the Product Purchasing Service: Legitimate Interest
    To perform statistical analysis and market research to improve the presentation of Products, the provision of the Product Purchasing Service and the use of the Website.
    - The Processing referred to in the present Sub-paragraph (g) is based on Nava’s legitimate interest in improving the functioning of its Website and the Product Purchasing Service. Indeed, it is in Nava’s legitimate interest to improve its business and to offer Products and Product Purchasing Services that are better tailored to the preferences that its users express while browsing the Website. Moreover, all users can benefit from the improvement of the Website’s operation and of the Product Purchasing Service, thus confirming Nava’s legitimate interest in improving these functions with respect to privacy.
    - To achieve the present purpose, Nava confirms that, in each case and where possible, it uses anonymous or unidentifiable Personal Data that neither identifies its Users nor renders them identifiable.
    - In the event that Personal Data is not used anonymously, the User has the right to oppose the present Processing at all times, following the instructions set out under Paragraph 9 (f) of the Present Policy.
    Confirm the Age of Users: Legitimate Interest.
    - The Processing set out under the present Paragraph (h) of the present Paragraph 3 of the Policy is based on Nava’s legitimate interest in confirming the age of Users, to ensure that only persons of full age take advantage of the services offered on the Website.
    - This legitimate interest prevails with respect to the Users’ right to privacy, taking account of the fact that it is also in their interest that Nava undertake to guarantee a Processing of Personal Data that respects persons (minors) who may be less aware of the risks and consequences of any Processing of their Personal Data that may occur.
    - Any refusal by the User to such Processing prevents him or her from completing Registration on the Website and/or to from taking advantage of the Product Purchasing Services, Information Newsletters and Dedicated Newsletters.

4. Methods for Data Collection

Nava collects Personal Data according to the following methods:

  • a) Personal Data that Users Enter on the Website;: Personal Data that the User provides, including, without limitation, during Registration, at the moment of purchasing Products or to take advantage of the Newsletter service.
  • b) Personal Data Disclosed by Offline Users; Personal Data that Users provide, including, without limitation, during events or fairs that are organised by Nava or in which it participates.
  • c) Personal Data Automatically Collected on the Website: Personal Data automatically collected on the Website, including, without information, through the use of Cookies (for further information, consult the Cookie Policy available at the following link http://www.navadesign.com/it/cookie-policy-cookiepolicy).

5. Categories of Possible Recipients of Personal Data

Personal Data are processed by Nava and/or by third parties, selected for their reliability and competence, and to whom Personal Data may be disclosed as necessary or appropriate, provided that said third parties are located within the European Union. In particular, Nava informs Users that Personal Data may be processed by and/or disclosed to:

  • a) Employees and/or collaborators of Nava or the GUT Group, solely for administrative purposes
  • b) Third-party providers of services necessary to guarantee the functioning of the Website (by way of example: companies that provide hosting services);
  • c) Third-party providers of services necessary to guarantee the sale of Products and the provision of the Product Purchasing Service. These subjects include but are not limited to the company that manages the Website and, in particular, Nava’s e-commerce (and thus the administrative management of purchase orders), and that completes logistics operations for the order and shipping of Products.
  • d) Third-party providers of advisory and support services (e.g. tax consultant);
  • e) Companies of the GUT Group, if the User has provided his or her express consent.

6. Storage Period of Personal Data and Criteria for Determination

Personal Data are stored by Nava for the period of time strictly necessary for Nava to achieve the purposes for which they were collected, as indicated under Paragraph 3 of the Policy.
In particular, with the exception of the exercise by the User of his or her right of withdrawal of consent set out under Paragraph 9 (a) below, or his or her exercise of the right of opposition to Processing set out under Paragraph 9 (f), Nava stores the Personal Data of the User for the following periods:

  • a) Cookies: for the purpose(s) set out under Paragraph 3 (b), consult the Cookie Policy available at the following link http://www.navadesign.com/it/cookie-policy-cookiepolicy;
  • b) For Users to purchase Products and take advantage of the Product Purchasing Service (purpose set out under Paragraph 3 (c)): Nava stores the User’s Personal Data for the period of time set out in the General Conditions and for a further 24-month period.
  • c) Personal Data for the Newsletter service (purpose set out under Paragraph 3 (d)): Nava stores the User’s Personal Data for a 24-month period beginning from the User’s last interaction with Nava. For this purpose, ‘the User’s last interaction’ means any positive action by the User that serves to communicate to Nava an interest in the Products or in receiving the Newsletter service, for example, by providing consent, opening the newsletter, accessing the personal profile on the Website during Registration, purchasing Products or participating in initiatives that Nava promotes on the Website.
    If the User does not interact with Nava for a period of 24 consecutive months, Nava must consider his or her profile to be inactive and automatically erase the Personal Data collected or render it irreversibly anonymous.

In all cases, Nava is authorised to store, in whole or in part, Personal Data for a maximum period of 10 years from its collection, said storage being limited to the information necessary for Nava to meet its legal obligations or to permit it to exercise or defend a legal claim.

Once the terms indicated in the present section of the Policy have expired, Nava will proceed to complete the automatic erasure of the Personal Data collected or to render it irreversibly anonymous, such that these data can no longer be associated with the User.

7. Profiling

Automated Processing with Evaluation of Personal Data of Registered Users to Receive Dedicated Newsletters.

The Profiling of Personal Data of Registered Users for the sending of Dedicated Newsletters has the following characteristics:

  • a) Context: In addition to offering Users a Product Purchasing Service, Nava also uses its Website to allow Users who have completed Registration the possibility of taking advantage of a Dedicated Newsletters service.
  • b) Object: Profiling is limited to the Personal Data that the Registered Users have entered in the Website at the moment of Registration and that serve to disclose the preferences of the Registered Users concerning the purchase of Products and/or the events of particular interest (for example, the opening of a new point of sale located in proximity to the Registered User)..
  • c) Purposes: To improve the effectiveness of marketing campaigns and communications concerning the Products, to provide Registered Users with a personalised service with the possibility of sending of birthday or greeting cards on holidays, and to exclude from said communications any information that may not be relevant or of interest to the Registered User.
  • d) Logic: Nava observes and evaluates the purchase of Products and interactions on the Website, as well as the Personal Data that Registered Users have provided at the moment of Registration.
  • d) Legal basis: The Registered Users’ consent, which shall be freely given, specific, informed and unequivocal, expressed by a positive action on the Website (i.e. the Registered Users check a box that was not pre-selected). The Registered Users retain their right to withdraw, at any time, their consent to receive the Dedicated Newsletter within the meaning of Paragraph 9 (a) of the present Policy.
  • e) Effects on Users: The weekly receipt of informational and commercial communications that are better tailored to their own interests and to their geographical location.
  • Note also that:
    - The Personal Data used during Profiling for the Newsletter service are adequate and strictly limited to the purposes set out under Paragraph 3 of the Policy;;
    - Profiling is not used to determine any exclusion and/or discrimination with respect to the Users’ ability to take advantage of the Product Purchasing Service;
    - Personal Data used during Profiling do not allow for the revelation or presumption of any aspect of ‘vulnerability’ of Users to promote the purchase of Products

8. Possible Transfer of Personal Data to Countries Outside the EU

The Personal Data collected by Nava for the purposes set out under Paragraph 3 of the present Policy are transferred, within the meaning of Article 45 of the Regulation, to the U.S. organisations listed below that belong to the ‘Privacy List’, which is a list that indicates which U.S. organisations guarantee adequate levels of data protection and comply with the European principles concerning Personal Data Processing, published and updated on the basis of European Commission decision no 2016/1250 on the adequacy of protection, adopted pursuant to Article 25 of Directive 95/46/EC, which shall remain in effect until repealed, amended or suspended within the meaning of Article 45 of the Regulation.
- Google LLC, compresiva di You Tube;
- MailChimp;
- Facebook, Inc;
- Oracle America, Inc (AddThis).
Furthermore, for the purpose set out under paragraph 3 (c) of the present Policy, within the meaning of Article 49(1)(b) of the Regulation, Nava transfers Personal Data to organisations outside the EU only in cases in which the User, during the purchase of Products, has indicated that the delivery of the Products shall be made to an address located in a country outside the EU.
In this case, the transfer of Personal Data is necessary for Nava to fulfil the contract of sale governed by the General Conditions and directed exclusively to allowing the User to take advantage of the Product Purchasing Service.
Note that the Personal Data that are transferred are used and stored by the organisation outside the EU only for the time necessary to manage the delivery of the Products.

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