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  1. The Policy

In the processing of personal data that could identify you, directly or indirectly, LEATHERAW S.p.A. (“LEATHERAW”) complies with the general principles of said processing being strictly necessary and proportionate (by configuring the Website in a manner that use of Personal Data is reduced to a minimum and in a manner to exclude the processing of Personal Data when the purposes being pursued in individual cases can be achieved through the use of anonymous data or using other methods that allow the data subject to be identified only in the case of need or on request of the authorities and law enforcement, such as data related to traffic, time spent on the Website and your IP address), lawfulness, fairness and transparency, integrity and confidentiality, limitation of duration, as envisaged by Regulation (EU) no. 679/2016 (GDPR) for controllers.  

 

  1. Types of data

We could process data in four general categories: i) the user’s browsing data on this website and/or on other websites of LEATHERAW ii) data actively provided by the data subject, iii) pertinent data collected from third parties, particularly data relating to the data subject’s interactions with on-line portals monitored by LEATHERAW through the cookies of the third-party software belonging to the supplier, Hubspot Inc. (see below), iv) data on telephone calls with customers, which are recorded through the Aircall cloud-based call centre service. 

 

  1. i) Browsing data

The computer systems and software procedures used for functioning of the Website acquire certain personal data during their normal operation, the transmission of which is implicit in use of Internet communication protocols. This information is not collected in order to be associated with identified data subjects but, due to its nature and as a result of processing and association with data held by third parties, could allow users to be identified. 

This data category includes IP addresses or domain names of the computers used by users connecting to the website, URI (Uniform Resource Identifier) notation addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the digital code indicating the status of the response given by the server (successful, error, etc.), the country of origin and other parameters relating to the user’s operating system and computer environment (such as the characteristics of the browser and operating system used by the visitor, the type of device used to access the Internet, the various time aspects of the visit, such as the time spent on each page, and the relative details on the path taken on the pages of the Website, with particular reference to the sequence of pages consulted). This category also comprises the so-called system logs, which are the files that record interactions between the user and the Website.  

This data is used to manage access to the Website and the services it offers, to obtain anonymous statistical information on its use, to make functioning of the website technically possibly and to monitor correct functioning and guarantee maintenance of the relative database. In these cases, the browsing data cannot be used to identify the data subject and is erased immediately after being processed in anonymous form. The browsing data could also be used to ascertain liability in the event of crimes or other unlawful actions committed by the data subject that damage the Website itself and/or third parties through the Website. 

 

  1. ii) Data provided by the user

LEATHERAW collects the Personal Data and other information directly from Users, as part of the processes that it manages on the Website (purchase of products on the Website, for conclusion of e-commerce transactions / compilation of User registration forms on the Website for the marketing purposes of LEATHERAW) or through other means (such as a) collection on paper or electronically at stores, b) events and exhibitions, c) trade fairs, chat services on the LEATHERAW website; d) on-line forms dedicated to specific LEATHERAW initiatives).  

The data provided voluntarily by the User and collected through the Website and with other means, for business purposes, is entered into two separate general databases of LEATHERAW:  

– “B2B” (relating to dealers, distributors and agents of the company);  

– “B2C” (relating to natural persons who are final users of the company’s products and services). 

This data is: 

  • the information sent by users, on an optional and voluntary basis, to the addresses indicated on the Website (such as e-mail address, subject of the e-mail, company name, first name and surname, etc., address of the office, residence or domicile (postcode, city, province), telephone number or mobile telephone number, country, contact language, company to which they belong and position held there, etc.); the personal data provided by users in order to use the services accessible on the Website (through the order form for the purchase of goods and services on the e-commerce website, such as personal details, e-mail address, e-mail content and attachments, postal address, credit card details, bank details, details of payment tools and codes used through mobile devices, telephone number, data on purchases made by the data subject, such as type of product, data and purchase price, product model and serial number, dealer from whom the purchase was made), or to participate in initiatives promoted through the Website or with other means  
  • the personal data provided by users who send on-line or off-line requests for sending of news, informational material or newsletters
  • the personal data provided by users who submit their candidacy (“curriculum vitae”, etc.) through the “Careers” on-line form; 
  • the personal data collected through the D-Air category of products, which include a GPS (necessary for functioning of the product) that records data on its geolocation, for a limited time and only on the product microchip. LEATHERAW will only process the data in the event of delivery of the D-Air category product to LEATHERAW itself or to an authorised dealer, for reactivation of the D-Air bag or repairs, or for product research and development purposes.  

 

iii) Data collected from third parties

LEATHERAW uses HUBSPOT software to automatically associate the personal details of the B2C data subject with further information on that data subject, which said software obtains independently on this website and on other websites of LEATHERAW, and also data on the data subject’s interaction with the on-line portals monitored through the cookies of the HUBSPOT software, in order to create a basic profile of the data subject, which LEATHERAW uses for analysis and direct marketing purposes. This is mainly, but not only, personal details and contact data. 

 

  1. iv) Data collected from the Aircall service

LEATHERAW makes audio recordings of telephone calls with customers and records the metadata associated with them (such as duration of the conversation, telephone number and name of the customer, notes of the operator), through the cloud-based call centre service provided by the third-party supplier Aircall, in order to provide its employees with training on the assistance service. 

 

  1. v) Special categories of data

We will never ask you to provide “special” categories of data (data that could reveal racial or ethnic origin, religious or philosophical beliefs or other beliefs, political opinions, membership of political parties, trade unions or religious, philosophical, political or trade union associations or organisations, or personal data that could reveal state of health or sexual orientation) or “criminal” data (data on criminal records, or relating to the position as a defendant or suspect or person with a criminal conviction) through the forms available on the websites.

 

  1. Changes or updates

LEATHERAW may change or update the Privacy Policy at any time, in full or in part, also in consideration of any changes in the laws or regulations that protect your rights. The most recent version of the Privacy Policy is indicated at the end of this document and this is the one that is applied to processing of Personal Data from the date indicated. The changes and updates to the Privacy Policy of the Website will come into effect as soon as they are published on the Website, in this section. Users will receive an e-mail informing them of any change to this Privacy Policy. You are kindly asked, in any case, to access this section regularly to check whether a more recent and up-to-date version of the Privacy Policy of the Website has been published.