This page describes how the personal data of users (“Users”) is processed on the website https://www.coccinelle.com/en/ (the “Website”). Website Users may simply be visitors or may sign up for the newsletter service, register and create an account or make purchases through e-commerce and/or benefit from customer service.

This is the privacy policy disclosure provided pursuant to European Regulation 2016/679 (the “GDPR”) and Legislative Decree 196/2003 – the Personal Data Protection Code (the "Privacy Code”) to those who interact with the web services of Coccinelle S.p.A. (the “Disclosure”).

The Disclosure is provided solely for this Website and not for any other websites, apps and/or third party content of any type, that may be visited by the User by following links available on this Website. In these cases, the data protection provisions of those third parties could apply, which may differ from those contained in this Disclosure. We recommend consulting such provisions before communicating any data.

This Disclosure describes the methods, time frames, and nature of the information that the Data Controller (as defined herein) shall provide to Users when it processes their data.

DATA CONTROLLER

For the purposes of this Disclosure, the Data Controller is Coccinelle S.p.A., with headquarters in Via Lega dei Carrettieri 6, 43038 – Sala Baganza (PR), Italy, tax code and VAT number 00478330343 (“Coccinelle” or the “Data Controller”).

For more information on how the Data Controller processes personal data, you can always contact them using the contact information indicated in the section “Rights of Data Subjects” of this Disclosure.

DATA PROCESSED

DATA COLLECTED BY THE DATA CONTROLLER - BROWSING DATA

During their normal operation, the IT systems and software procedures which operate this Website acquire some personal data, the transmission of which is implicit in the use of Internet communications protocols.

These data are not gathered for association with identified subjects, but by their very nature, through processing or association, they might allow Users to be identified.

This category of data includes the IP addresses or domain names of the computers used by Users who log onto the Website, the addresses in URI (Uniform Resource Identifier) notation of the resources requested, the time of the request, the method used when submitting the request to the server, the size of the file obtained in reply, the numerical code indicating the server’s response status (concluded successfully, error, etc.) and other parameters relating to the User’s operating system and IT environment (“Browsing Data”).

These data are used for the sole purpose of obtaining anonymous statistical information concerning use of the Website and to check that it is operating correctly and are deleted immediately after processing. The data might be used in order to identify those responsible in the event of IT crimes against the Website; except in this case, data concerning web contacts are not currently stored for more than seven days.

COOKIES

Cookies and similar technological tools are used on the Website to collect and store data related to use, access and interaction via the Website. For further information regarding the use of cookies, reference should be made to the additional, specific FULL PRIVACY POLICY DISCLOSURE published on this Website, and prepared pursuant to Provisions of 10 June 2021 issued by the Italian Data Protection Authority, which supplements and completes this document.

DATA SUPPLIED VOLUNTARILY BY THE USER – personal details, contact data and purchasing data

On the Website, Users can:

send messages and requests to Coccinelle’s email addresses. The optional, explicit and voluntary sending of messages and requests to the addresses indicated on this website entails the subsequent acquisition of the personal data of Users necessary to respond to them, as well as all additional personal data included in the communications, if any;
sign up for the newsletter service;
create an account; and
make purchases through e-commerce.
As part of the above activities, Users shall provide Coccinelle the personal data necessary and requested using the various forms on the Website. Data marked with an asterisk (*) are mandatory and required to be able to complete the action. If such data is not provided, Users will not be able to proceed with or conclude the procedures.

Specifically, Coccinelle collects the following personal data:

name, surname, home address, country of residence, nationality and birth date (the “Personal Details”);
telephone number and email address (“Contact Data”).
data regarding purchases, such as the products purchased, the place, date, time and chronology of purchases, delivery, payment method and billing data, as well as any personal data contained in the communications between the Data Subject and the Data Controller, regarding the products purchased or of interest to the customer (“Purchasing Data”).
The Browsing Data, Personal Details, Contact Data and Purchasing Data are jointly defined as the “Data”.

PURPOSES AND LEGAL BASIS OF THE PROCESSING

ACCOUNT

The Data communicated by Users during registration on the Website (including shipping and payment data) are processed in order allow the user to sign up for an account on the Website, add products to their wish lists, complete purchases of the desired products, and manage their own reserved areas.

The Data Controller may receive the User’s identification and contact data from Facebook or Google, if the User logs in through Facebook or Google. A personal account involves the use of authentication credentials that are known solely to the User and must be stored carefully by the User under his/her full, exclusive responsibility.

Registering for the Website provides certain benefits, such as invitations to exclusive promotions, birthday discounts and a simplified check-out process for online purchases. It is not necessary to create an account in order to make online purchases, as these can be made also simply as a visitor to the Website.

The legal basis of that processing is the need to perform a contract to which the User is a party and/or precontractual measures adopted at the User’s request, and to fulfil the related legal obligations.

Any refusal by Users to provide their personal data will make it impossible to complete the account registration process.

RESPONSES TO USER REQUESTS

The Data shall be processed in order to respond to requests sent by Users based on the contact data or by completing the forms available on the Website, such as the “Contact Us” form, including the communications sent to Customer Service.

The legal basis of that processing is the need to perform a contract to which the User is a party and/or precontractual measures adopted at the User’s request, and to fulfil the related legal obligations.

It is necessary to process the above-described Data, failing which it will be impossible to respond to Users’ requests.

ONLINE PURCHASES

The Data shall be processed to manage purchase orders (including sending out information and service emails regarding order status; carrying out the related shipments and pre- and post-sales customer support activities) and in order for Coccinelle to fulfil legal obligations.

The legal basis of the processing is the need to perform a contract to which the User is a party and/or precontractual measures adopted at the User’s request, and to fulfil the related legal obligations.

Processing of the User Data is necessary in order to complete the purchase process. Users who deny their consent to such processing will not be able to complete the purchase of the products on the Website.

Customer Satisfaction Inquiries

Within 48 days after a purchase and/or 30 days after making a request to our customer service, Users will receive customer satisfaction surveys and inquiries via email, asking Users to evaluate Coccinelle products and/or their own experience with customer service.

Participation in customer satisfaction inquiries is optional, and the Data collected may be used to improve the products and services offered by Coccinelle.

The legal basis for this processing is the legitimate interest of Coccinelle in keeping their Users satisfied with the products and customer service provided. That interest is commensurate with the Users’ interests, as it is reasonable to believe that customers are interested in finding and purchasing high-quality, non-defective products and in being able to request support from qualified customer service.

Soft Marketing Messages

The Data (and, particularly, the email address provided by the User at the time of registering on the Website and of completing the purchase) will also be processed in order to send by email commercial, promotional or advertising messages exclusively concerning Coccinelle brand products equivalent to those already purchased and used by the User.

Under art. 130 (4) of the Privacy Code, the legal basis of such processing is the legitimate interest of Coccinelle to keep its customers constantly informed and up to date about its offers of such new products and services as may be available from time to time on the Coccinelle website, as well as the promotions and/or initiatives promoted by Coccinelle. That legitimate interest is commensurate and compatible with the User’s interest insofar as it may reasonably be assumed that the person who buys a Coccinelle brand product or benefits from a service via the Website may interested in and expect to receive updates on the catalogue of Coccinelle products and services.

At any time, the data subject may object to the processing carried out for purposes described above, conveniently and free of charge (by following the procedure indicated in each commercial message or by using the contact details of the Data Controllers indicated below).

Any objection to the processing by the data subject shall be without prejudice to the legitimacy of the processing performed to that point, nor shall it affect future purchase of Coccinelle brand products.

Newsletter – Marketing 

The Data shall be processed to allow Users to subscribe to and benefit from Coccinelle's newsletter service. In the event of a request to subscribe to the newsletter service, the Data shall be processed to respond to the request and send email messages containing informational, promotional, commercial and advertising materials concerning Coccinelle products and invitations to events and notices of any extraordinary store openings/closings, catalogues and invitation cards to Coccinelle events and special promotions.

It will be possible to process Data in order to send newsletters only with the explicit, free and informed consent of the User, which may be given by checking the appropriate box on the registration form (i.e. account, contact us) or filling in a specific request for subscription in the section “Subscribe to the Newsletter”. Failure to grant consent will not prevent the User from completing online purchases, browsing the Coccinelle website, sending requests for information or receiving non-targeted messages.

Users wishing to revoke their consent may object at any time to the processing described herein by writing to Coccinelle at the contact addresses indicated in the section “Rights of Data Subjects”. In any case, any objection made will be without prejudice to the lawfulness of any processing activities carried out by Coccinelle up to that time.

Profiling

Subject to consent granted in the process of completing the purchasing procedure, the Data pertaining to the products purchased, preferred and/or added to the wish list will also be processed – automatically – for the purpose of profiling, i.e. to analyse consumer choices of the User and to personalize accordingly the commercial and promotional messages sent by the Data Controller, to better assist the User in his/her purchases, whether online or at Coccinelle shops, by suggesting products that may interest them. 

Such profiling does not involve automated decision-making that has legally binding effects on the Users. 

Processing will be possible only with the explicit, free and informed consent of the User, which may be given by checking the appropriate boxes on the Website. Failure to grant consent will not prevent the User from completing online purchases, browsing the Coccinelle website, sending requests for information or receiving non-targeted messages.

Users wishing to revoke their consent may object at any time to the processing of personal data by writing to Coccinelle at the contact addresses indicated in the section “Rights of Data Subjects”. In any case, any objection made will be without prejudice to the lawfulness of processing carried out on the basis of consent given prior to revocation. 

If the preference whether or not to give consent is expressed several times (e.g. because several purchases are made or because an account is created and a purchase is made), the last choice made will prevail.

Right of defence 

Where necessary, the Data may be used to allow the Data Controller to fulfil its legal obligations, as well as to guarantee the Data Controller’s right of defence in legal or arbitration proceedings, referring to any disputes relating to the performance of the contracts concluded with the Data Controller.

The legal basis of that processing is the need to fulfil the legal obligations of the Data Controller, as well as the legitimate interest of the Data Controller of defence in legal proceedings. In balancing the interests of the parties, this legitimate interest does not violate the rights or freedoms of the User, as legal defence of a right is guaranteed by the legal system.

DATA PROCESSING METHODS

The Data shall be processed according to adequate operating instructions given by the Data Controller, exclusively by the personnel and workers of the Data Controller or of the companies expressly designated as Data Processors. These include:

- Eurostep Commerce Srl with registered office at Via Feltrina Sud 192, 31044 Montebelluna (TV), Italy, provider of commercialization services for products sold through the e-commerce platform which is used;
- PVS eServices Srl with registered office at Piazza Santa Maria Beltrade 1, 20123 Milan (MI), Italy, and affiliated companies, as provider of Customer Service and shipping.
the companies affiliated with the sales network of Coccinelle S.p.A. that manage the Coccinelle shops under a franchising arrangement. Such companies will be informed of the data of the persons who have created an account on the Website and/or who have made a purchase online, so that the companies may assist the Users who frequent Coccinelle shops, both regarding their purchases and for requests concerning customer support and warranties.
The affiliated companies, where not present in Italy, all have registered offices in States that belong to the European Union and/or that benefit from an adequacy decision by the European Commission or, failing that, have signed the standard contract clauses approved by the European Commission as an adequate measure for the transfer of personal data abroad.

Specific and adequate security measures are implemented to prevent the loss of the Data, their illegal or improper use, or unauthorised access thereto.

COMMUNICATION OF DATA

Where necessary for the pursuit of the specific purposes of the processing, the Data may be communicated to third party providers of ancillary services (e.g. communication agencies for the preparation and sending of commercial and promotional messages; shippers and carriers for the management of deliveries of products purchased with e-commerce). Such entities shall process the Data, as appropriate, as autonomous data controllers, or as data processors under a specific written assignment granted to them by the Data Controller.

TRANSFERS TO THIRD COUNTRIES

The Data may be transferred abroad only when the User requests that the products purchased with e-commerce be delivered outside Italy: in which case, the transfer will be made (if to countries that do not benefit from an adequacy decision of the European Commission and therefore fail to offer an adequate level of personal data protection) under the exemption corresponding to the need to perform a contract between the Data Controller and the User.

Data Storage Period

The Data shall be stored only for the period necessary to achieve the purposes for which the Data are processed. In particular:

to carry out such activities as are necessary to perform the contract with the User in connection with the purchase of products, the Data shall be stored for the retention period prescribed by law;
to guarantee the right to defence, the Data shall be stored for 10 years starting from the termination of the contractual relationship entered into between Coccinelle and the Data Subject;
to send out commercial and promotional messages (including personalized messages, if the User consented thereto) and the newsletter, for a maximum period of 48 months after the sign-up for the newsletter service. Such period may be extended by an equal duration whenever Users renew their consent by responding to a specific request transmitted by Coccinelle prior to the expiry of the storage period;
for soft marketing (or soft spam) activities, the Data shall be processed in a form that enables identifying the User only for such time as is strictly necessary to achieve the purposes for which the Data were collected, particularly, for a maximum period of 48 months after collection;
for customer satisfaction inquiries, the Data shall be processed and stored for a maximum period of 48 months after each individual purchase; and
for profiling, the Data shall be processed for a maximum period of 48 months after collection.
Please note that the Data may be stored for a longer period, if necessary, in order to comply with the statutory or regulatory obligations and/or for protective purposes.

RIGHTS OF DATA SUBJECTS

Users have the right, at any time, to:

obtain access to the Data;
obtain the rectification, erasure or, where appropriate, restriction of processing;
object to the processing;
revoke consent;
where applicable, receive in a commonly used, machine-readable format the Data provided to Coccinelle and transmit those data to another Data Controller without hindrance from Coccinelle; and
lodge a complaint with the Italian Data Protection Authority, or file an appeal with the judicial authorities.
Users may also request, at any time, a full list of the addressees of the Data.

The rights set out in this section, and any requests for clarifications regarding the characteristics of Data processing, may be exercised by writing to the following addresses:

by email, to: reserved@coccinelle.com;
by post, to the address: Via Lega dei Carrettieri 6, 43038 – Sala Baganza (PR), Italy.
SUPPLEMENTS

In the event of substantial modifications to this Disclosure, the Data Controller shall send out a notice by email and/or publish a notice on the Website to point out the changes and collect any requests to exercise the rights described above.

 

Information updated on October 2024