LAST REVISED: May 24th 2018
This policy will allow you to discover, before accessing the various sections of the Website, how Agenzia D’Herin processes your personal data, including both data you provide directly (such as your first name, surname, postal and e-mail address, age, date of birth, gender, etc.) and the data which Agenzia D’Herincollects in the manner described in the section “The personal data we collect and how we collect it” (hereinafter, collectively, the “Personal Data”). Please view the policy before providing your Personal Data.
Identity and contact details of the Controller:
The controller is AGENZIA D’HERIN– Viale Buridani, 6 – 10078 Venaria Reale (To) – Italy Mail address: firstname.lastname@example.org
Agenzia D’Herin will process your Personal Data in accordance with Regulation EU no. 2016/679 and national personal data protection regulations (hereinafter the “Privacy Regulation”).
The Personal Data we collect and how we collect it
Any requests for information or services you submit could lead to collection and subsequent processing of your Personal Data (such as first name, surname, e-mail address etc.).
In particular, your Personal Data may be collected:
- when you fill out on-line forms; and
- through your publication of Contributions (as defined below), the content of which could include Personal Data which you have provided directly on social networks managed independently by third parties, including, but not limited to, Facebook, Twitter, etc. (hereinafter “Social Networks”). By “Contributions”, we mean images, comments, catchphrases associated with the subject of the Website, contents and any other information you have conceived and published on the pages of Social Networks dedicated to the products of the various Agenzia D’Herin group brands, including any image you provide.
If you choose to send a request through the “Contact” section of the Website, you have to provide certain Personal Data to allow Agenzia D’Herin to satisfy your needs, so the relative boxes of the registration form are marked with an asterisk or otherwise indicated as obligatory. Providing Personal Data which is not marked with an asterisk or otherwise indicated as obligatory is entirely optional and there will be no consequences if this Personal Data is not provided, or is incomplete or imprecise. However, if you do not provide the Personal Data marked with an asterisk or otherwise indicated as obligatory, or said data is incomplete or imprecise, the service you request cannot be supplied. If you fail to provide any of the obligatory Personal Data, an error message will appear listing the missing obligatory Personal Data.
The purposes of processing your Personal Data and the legal basis for processing
Based on the needs you indicate each time on accessing the various sections of the Website (and excluding individual initiatives which require specific Personal Data to be provided, for which specific information will be published each time on the Website), the purposes of processing your Personal Data and the legal basis for processing are indicated below.
Your Personal Data will be processed for the following purposes only with your consent to processing, which may be withdrawn at any moment, by sending a request to the Controller via the “Contact” section of the Website:
- Management of your requests and response to them
You may decide to consent to processing of your Personal Data to allow Agenzia D’Herin to manage and respond to your requests relating to products and the various initiatives relating to the various If you decide not to consent to processing of your Personal Data for said purposes, you will be unable to send the request.
Furthermore, even without your consent, Agenzia D’Herin may process your Personal Data for the following purposes:
- management of activities linked to your use of the Website, including publication of your Contributions on the pages of Social Networks dedicated to the products of the various Agenzia D’Herin Artists (since processing is necessary for execution of a contract or pre-contractual measures);
- management and fulfilment of legal obligations (accounting, administrative, tax obligations, etc.);
- management of complaints and any disputes (as this is a legitimate interest of the Controller).
How we process your Personal Data
Processing of your Personal Data may include any type of operation, such as collection, recording, organisation, storage, consultation, processing, rectification, selection, extraction, comparison, use, interconnection, blocking, disclosure, erasure and destruction.
Your Personal Data will be processed mainly with automated tools, but also on paper, adopting logic strictly linked to the related purposes, through the use of databases and electronic platforms managed by dherin.com or by third parties appointed as external processors for this purpose and/or through the integrated IT systems of dherin.com and of said third parties and/or websites owned or used by dherin.com
The Controller has assessed the level of security to be sufficient, taking account of the risks which could derive from loss, destruction, rectification, unauthorised disclosure, accidental or illegal access, abuse or alteration of your Personal Data. In particular:
- it has adopted security measures appropriate to the risks;
- it stores your Personal Data on servers located within Europe, which have an advanced and daily back-up system.
Where we process your Personal Data
Your Personal Data will be processed primarily at the Controller’s offices and in places where the processors are located. For further information, contact the Controller at the addresses indicated in the section “Identity and contact details of the Controller”.
How long we keep your Personal Data
In order to ensure compliance with the principles of necessity and proportionality of processing, the Controller keeps the Personal Data for different periods, depending on the individual purposes being pursued:
- in order to manage and respond to your requests relating to Artists or initiatives related to Agenzia D’Herin, advertising or the Website (“Contact” section of the Website), your Personal Data will be kept for the time strictly necessary to fulfill your request;
- for management of activities linked to your use of the Website, including publication of your Contributions on the pages of Social Networks dedicated to the Artists or Shows of Agenzia D’Herin, your Personal Data will be kept for the time strictly necessary to supply the service you have requested;
- for management and fulfilment of legal obligations (accounting, administrative, tax obligations, etc.), your Personal Data will be kept for the time strictly necessary for said purpose;
- for management of any complaints and disputes, the Personal Data will be kept for the period strictly necessary for this purpose and, in any case, not beyond the applicable time limits.
The recipients of your Personal Data
Your Personal Data may be communicated to and processed by:
- legal or natural persons who act as external processors, performing activity in outsourcing, appointed by dherin.com or by the external processors of Agenzia D’Herin (including parties assigned to perform assistance, communication, marketing, advertising, promotion and sale activities relating to products and/or services and also advertisers, advertising agencies, suppliers of IT services, the Website operators, electronic platform operators, partners, credit institutions, professional consultancy firms);
- employees and/or collaborators of the Controller (including system administrators), who operate under its direct authority, who will be authorised to process your Personal Data; and
- employees and/or collaborators of the external processors (including system administrators), who operate under the direct authority of the external processors and will be authorised to process your Personal Data.
Your Personal Data will not be communicated to third parties, except when communicated by Agenzia D’Herin to consultants in order to protect its rights, nor disclosed.Minors
Minors under 16 years of age must not provide information or Personal Data to Agenzia D’Herin without parental consent. If this consent is not provided, minors cannot send requests via the Website. Agenzia D’Herin invites anyone with parental responsibility on minors to inform them on secure and responsible use of the Internet and the Web.
Identity and contact details of the processors
A complete list of the Personal Data processors may be consulted by contacting the Controller at the address indicated in the section “Identity and contact details of the Controller”.
Your rights in relation to processing of your Personal Data
As the data subject, you are granted numerous rights by the Privacy Regulation. In detail, you are entitled to:
- obtain from the Controller confirmation of whether or not your Personal Data exists, even if not registered, and its disclosure in intelligible form, and also access to your Personal Data (by obtaining a copy) and the related information (including the purposes of processing, the categories and origin of the Personal Data, the categories of recipients to whom it has been or could be disclosed, the retention period (when possible), the rights which may be exercised);
- obtain from the Controller the rectification of your Personal Data and supplementing of any incomplete Personal Data;
- obtain from the Controller the erasure of your Personal Data without undue delay, including when the Personal Data is no longer necessary for the purposes for which it has been processed or the legal basis for processing no longer exists;
- obtain from the Controller the conversion into anonymous form or blocking of your Personal Data if it is processed illegally, including data which it is not necessary to store, in relation to the purposes for which the Personal Data was collected or subsequently processed;
- obtain from the Controller the limitation of processing of your Personal Data, also when you dispute its accuracy or object to processing, for the period necessary for the respective checks to be performed;
- receive your Personal Data in a structured, commonly used, machine-readable format, and also transmit or, if technically feasible, obtain transmission of your Personal Data to another controller without impediments, in cases in which processing is carried out by automated means and is based on your consent or when necessary for execution of a contract to which you are a party;
- withdraw consent to processing of your Personal Data for any of the purposes for which it has been provided.
You may exercise your rights with Agenzia D’Herin by accessing the “Contact” section of the Website or by sending a letter by ordinary mail to the address indicated in the section “Identity and contact details of the Controller”.
Furthermore, if you believe that processing of your Personal Data breaches the Privacy Regulation, you may lodge a complaint with the Data Protection Supervisory Authority in the State in which you reside, where your workplace is located or in which the presumed breach has occurred, or contact said Authority to request information on exercising of your rights under the Privacy Regulation.
The right to object to processing of your Personal Data
At any moment and for reasons linked to your own specific situation, you are entitled to object to processing of your Personal Data which is based on a legitimate interest pursued by the Controller or by third parties. In this case, the Controller abstains from further processing of your Personal Data unless it demonstrates the existence of legitimate and binding reasons which prevail over your interests, rights or freedoms or processing is necessary to ascertain, exercise or protect a legal right.
You are entitled to object to processing of your Personal Data, by accessing the Contact” section of the Website.
If you object to processing of your Personal Data for this purpose, the Controller will be unable to carry out the related processing.
What is a COOKIE?
Cookies are texts strings which act as computer markers sent by a server (the Website service in this case) to the user’s device (normally an Internet browser) when the user accesses a given page of a website. Cookies, which may also be set by different websites to the one the user is visiting (“third party cookies”), are automatically stored by the browser and retransmitted to the server which generated them each time the user accesses the same web page. In this manner, for example, cookies facilitate access to several web pages in order to improve the user’s browsing (or allow storage of pages visited or other specific information, such as the most frequently consulted pages, connection errors, etc.), or allow profiling. For easy and complete use of a website, the user should therefore configure their browser to accept these cookies.
Browsers are often set to accept cookies automatically. However, users can change the pre-set configuration, to disable or delete cookies (each time or once and for all), although this could prevent optimal use of certain areas of the website. It is also possible to check the cookies modes and types stored on your browser by changing its cookie settings.
Characteristics and purposes of cookies
Our Website uses the following categories of cookies, which may belong to Agenzia D’Herin or to third parties.
Technical and functionality cookies
These cookies assist you in browsing the Website and using its functions. Technical cookies include what are called “strictly necessary” cookies, which enable functions without which the Website cannot be used in full, or “performance cookies”, which improve the Website functions.
These cookies allow the Website to remember your choices (such as the language or your geographic location) and propose them again on subsequent accesses, in order to provide better and customised services (they can be used to propose similar contents to those you have requested in the past, for instance).
Description of the methods of consenting to installation of cookies
On your first access to the Website, you will see a banner with brief information containing the link to this extended policy, where you will find further information on the cookies installed by the Controller and by third parties.
This extended policy contains more detailed information on the description and characteristics of the various types of cookies and also allows you to decide independently which cookies you want to authorise.
Your consent is not required for the use of technical and analytical cookies. However, you can disable them using the procedure described in the paragraph “How to enable and disable cookies in your browser”.
Your consent is required for the use of profiling cookies, which are used to send you adverts and services in line with your tastes, preferences and consumption choices.
The table below describes the cookies sent to your browser when you access the Website. The table is revised up to 22th May 2018; any subsequent reviews will always be published on this page.
We currently use both session, technical and persistent cookies on our sites.
- Geo Location – Stores the ISO country code of the user by geo-detection for Language detection (12 MONTHS)
- Send Message Form – Stores a user’s email address (12 MONTHS)
- Google Analytics – Helps analyse use of the Site through the collection of standard internet log information and visitor behaviour, such as new visitor numbers, interactions and paths through our website, response to our marketing campaigns and browser usage, all in an anonymous form. Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. By using any dherin.com website, you consent to the processing of data about you by Google in the manner and for the purposes set out above (utma 2 YEARS expiration / utmz cookie or “campaign” cookie has a 6 MONTHS expiration period / The utmbcookie, or “session” cookie, has a 30 MINUTES expiration period)
Third Party Cookies
Below are some of the main third party services we use:
- Facebook – Like or Share website content to the Facebook platform, and display content from Facebook : https://www.facebook.com/help/cookies
- Twitter – to display content from Twitter and allow users to connect with the artist’s Twitter accounts :https://twitter.com/privacy
- Youtube – to display video content in embedded players from YouTube : https://www.google.com/policies/privacy/
- Add This – to enable users to share website content on a variety of social and content networks : https://www.addthis.com/privacy
- Google – to enable users to be shown search or YouTube advertising relevant to the artist site they have visited and web analytics : https://www.google.com/policies/privacy/
- Adobe Flash Player – to improve the user experience and to save preferences : https://www.adobe.com/uk/privacy/policy.html
- SmartURL – we may use SmartURL to rebrand some links to our Sites properties as well as the websites of our third party partners to which our Sites link. SmartURL provides anonymised, aggregated statistics relating to use of a shortened URL, for example by telling us how many times it has been clicked on. We do not have access to the IP address of a user’s computer collected by SmartURL when a user uses its service. SmartURL does not have any access to data collected on our Sites.
Refusing Cookies on the Site