LAST UPDATED: March 2020
Outlet Military di ALGI SRL “Owner”-, with registered office in Via Franco Vannetti Donnini 53/29 - 53/30, 59100 Prato (PO), Italy, constantly strives to protect the online privacy of users of their https site : //www.outletmilitary.com/ (the "Site"). This document (the "Policy") has been drawn up in order to allow you to understand how your Personal Data, as defined below, will be treated when using the Site. The Information is aimed at providing you with information necessary so that you can express explicit and informed consent to the processing carried out through the Site, if you deem it appropriate.
In general, any information or Personal Data that you will provide to the Owner through the Site, or that is collected in another way through the Site, as part of the use of the services offered by Outlet Military (the "Services"), as better defined in the Subsequent Paragraph 3, will be treated according to the principles, internationally recognized, of lawfulness, correctness, transparency, purpose limitation and conservation, data minimization, accuracy, integrity and confidentiality.
a. Name, contact details and other Personal Data
c. Location data
d. Special categories of personal data
e. Data voluntarily provided by the interested party
f. Navigation data
3. Purpose of the treatment
4. Legal basis and mandatory or optional nature of the treatment
5. Recipients of personal data
6. Transfers of personal data
7. Retention of personal data
8. Rights of the interested party
1. DATA CONTROLLER AND DATA PROTECTION OFFICER
Outlet Military, as identified at the beginning of the Information, is the Data Controller for all Personal Data that are processed through the Site.
You can contact the Outlet Military Data Protection Officer ("DPO") at the following address: firstname.lastname@example.org
2. PERSONAL DATA SUBJECT TO PROCESSING
Following navigation of the Site, we inform you that the Data Controller will process your Personal Data, which may be constituted - also depending on your decisions on how to use the Services - by an identification such as the name, an identification number, an online identification or one or more characteristic elements of your physical, physiological, psychic, economic, cultural or social identity suitable for making you identified or identifiable (hereinafter only "Personal Data").
Your Personal Data may be collected either because you voluntarily provide it (e.g. when you sign up for the Newsletter or when you create your personal account in order to receive the Services offered by the Owner) or simply by analyzing your behavior on the Site.
The Personal Data processed through the Site are as follows:
a. Name, contact details and other Personal Data
In different sections of the Site, in particular that relating to the creation of a personal account, you will be asked to enter information such as your name, telephone number, email address, date of birth, country of residence, the address, etc.
While using the Services, you may also be asked to enter information relating to your payment methods, such as for example. Paypal or credit card.
Furthermore, if you participate in surveys or any promotions that are made available through the Site, as well as when you communicate with the Owner through the contacts you find on the Site or with Customer Care, the Owner will be able to collect the additional information that you decide to provide.
c. Location data
To provide you with ever more precise and useful Services, the Owner may ask you to manually enter a physical address, postcode or simply the State to find the closest Military Outlet Store.
Alternatively, and subject to your prior and explicit consent, your Internet browsing program (so-called "Browser") could share with the Site an approximation of your geographical position through information on the wireless access points in your vicinity and on the IP address of your device.
In both cases, this is a treatment for the use of a completely optional but extremely useful personal data for the Owner for the provision of increasingly useful Services. If you believe that access to your approximate location through sharing via Browser is too invasive, you can always withdraw your consent from the Browser settings (or from your operating system settings). For more information, please consult the specific privacy information of your browser.
d. Special categories of personal data
Some sections of the Site (eg Work with us) include free fields where you can provide the Owner with some information, which may contain Personal Data.
Since these fields are free, you could use them to communicate (voluntarily or not) some sensitive categories of Personal Data, such as data suitable to reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, genetic data, biometric data intended to uniquely identify a natural person, data relating to the health or sexual life or sexual orientation of the person.
the Data Controller invites you not to send such Personal Data unless strictly necessary. Indeed, these special categories of Personal Data can be processed only with your explicit consent (manifested by the flag on the Application screen) and in compliance with the pro tempore legislation in force. the Data Controller therefore stress the importance of expressing your explicit consent to the processing of special categories of Personal Data, if you decide to share this information.
e. Data voluntarily provided by the interested party
As already mentioned above, in some parts of the Site (the insertion of an e-mail address for subscribing to the newsletter or when, by purchasing a product on the Site, you want to insert a message eg "greetings" attached to the sending of the product) it is allowed to insert text messages or information, visible to the Owner, which could contain other people's Personal Data.
With respect to these hypotheses, you place yourself as an independent data controller, assuming all legal obligations and responsibilities. In this sense, you confer on the point the widest indemnity with respect to any dispute, claim, request for compensation for damage from treatment, etc. that it should come to the Data Controller from third parties whose Personal Data have been processed through your use of the functions of the Site in violation of the rules on the protection of personal data applicable. In any case, if you provide or otherwise process Personal Data of third parties in the use of the Site, you guarantee from now - assuming any related responsibility - that this particular hypothesis of treatment is based on the consent of that interested third party or on another suitable legal basis that legitimizes the processing of the information in question.
f. Navigation data
During their normal operation, the IT systems and software procedures used to operate the Site acquire some Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user's IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, to identify anomalies and / or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site or third parties: except for this eventuality, at present the data on web contacts do not persist for more than 50 days.
Definitions, characteristics and application of the legislation
Cookies are small text files that the sites visited by the user send and record on his computer or mobile device, to then be retransmitted to the same sites on the next visit. Thanks to cookies, a site remembers the user's actions and preferences (such as, for example, login data, the chosen language, font sizes, other display settings, etc.) so that they do not have to be indicated again when the user returns to visit this site or browse from one page to another. Cookies, therefore, are used to perform computer authentication, session monitoring and storage of information regarding the activities of users who access a site and may also contain a unique identification code that allows you to keep track of the user's navigation within of the site itself for statistical or advertising purposes. While browsing a site, the user can also receive cookies from sites or web servers other than the one he is visiting on his computer (so-called "third party" cookies).
There are various types of cookies, depending on their characteristics and functions, and these can remain on the user's computer for different periods of time: so-called session cookie, which is automatically deleted when the browser is closed; CD. persistent cookies, which remain on the user's equipment until a set deadline.
For "profiling cookies", on the other hand, ie those aimed at creating user profiles and used in order to send advertising messages in line with the preferences expressed by the same in the context of surfing the net, a prior consent is usually required of the user, although it depends on the applicable legislation.
Types of cookies used by the Site and possibility of (de-) selection
The Site uses the following cookies which can be de-selected, except for third-party cookies for which you will have to refer directly to the relative selection and de-selection methods of the respective cookies, indicated by means of links:
•Technical navigation or session cookies, strictly necessary for the operation of the Site or to allow you to take advantage of the content and services requested.
•Analytical cookies, which allow you to understand how the site is used. With these cookies, no information about your identity is collected, nor any Personal Data. The information is processed in an aggregate and anonymous form.
•Functionality cookies, i.e. used to activate specific Site features and a series of selected criteria (for example, the language) in order to improve the service rendered.
•Profiling cookies used in order to send advertising messages in line with the preferences expressed by you in the context of surfing the net.
the Owner also uses third-party cookies, i.e. cookies from sites or web servers other than that of Outlet Military, used for the purposes of said third parties, including also profiling cookies. It should be noted that these third parties, listed below with the related links to privacy policies, are typically autonomous Data Controller of the data collected through the cookies they serve, or act as Data Processors for the Owner (i.e. they process Personal Data on behalf of the Owner).
As for third parties that send cookies through the Site, below are the links to the respective privacy policies:
•DoubleClick – Google: https://policies.google.com/privacy?hl=en
Cookies on the Site:
In detail, the cookies sent by Outlet Military through the Site are indicated below:
Tipo di cookie e proprietario
Nome tecnico dei cookies
Funzionamento e finalità
Tempo di persistenza
Questi cookies sono essenziali per il funzionamento del Sito.
Al termine della sessione
Questo cookie salva la durata della sessione e altri dati connessi
Al termine della sessione
Questi cookies serve alla profilazione anonima
You can block or delete (in whole or in part) technical and functional cookies through the specific functions of your browser. However, we inform you that not authorizing technical cookies could make it impossible to use the Site, view its contents and take advantage of the related services. Inhibiting functionality cookies may result in some services or certain functions of the Site being unavailable or not functioning properly and you may be forced to modify or manually enter some information or preferences each time you visit the Site.
The choices made with reference to the cookies of the Site will in turn be recorded in a special cookie. This cookie may, however, in some circumstances not work properly: in such cases, we recommend that you delete unwanted cookies and inhibit their use also through the functionality of your browsers.
Your preferences regarding cookies will have to be reset if you use different devices or browsers to access the site.
How to view and modify cookies through the browser
You can also manage your choices regarding third-party cookies using online platforms such as AdChoice.
ATTENTION: disabling technical and / or functional cookies the Site may not be available or some services or certain functions of the Site may be unavailable or not work properly and you may be forced to modify or manually enter some information or preferences each time you visit the site.
3. PURPOSE OF THE TREATMENT
the Data Controller will use your Personal Data, collected through the Site, for the following purposes:
•provide the Services such as: verifying your identity and helping you, in case you lose or forget the login / password details of your personal account on the Site; purchase a registered Card; allow you to consult your purchase history; send you the Outlet Military newsletter that you requested as a Service by registering and which contains only informative and non-commercial material; finalize your purchase order and deliver the products you can buy on the Site; allow you to save your favorite items, find the Military Outlet Store closest to you and provide you with any other Service you request ("Service Provision");
•send you marketing communications, promotions and advertisements, market research and surveys, by e-mail, SMS, push notifications, by phone, by banner, instant messaging, by an operator, through the official social media pages of the Owner, relating to products and / or services referable to Outlet Military and / or to third parties ("Marketing");
•send you email marketing communications regarding products and services similar to those you purchased through the Site ("Soft Spam");
•to create your profile through the use of profiling cookies, where accepted, therefore collecting and analyzing information on the selections and choices you make on the Site; as well as your general activities on the Site when you are a registered user, therefore collecting information on your ongoing purchases, whishlists and browsing. This profile will be used to provide you with information on other products and / or services that the Data Controller deems to be of interest to you and to show you advertisements that may be relevant to your tastes. All the algorithms involved in this automated or semi-automated process are regularly tested to ensure that you are not offered products that do not interest you ("Profiling");
•fulfill legal obligations that require the Data Controller to collect and / or further process certain types of Personal Data ("Compliance");
•prevent or detect any abuse in the use of the Site, or any fraudulent activity and therefore allow the Data Controller to protect himself in court ("Abuse / Fraud").
4. LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF THE PROCESSING
The legal bases used by the Data Controller to process your Data, according to the purposes indicated in the previous Paragraph 3, are as follows:
•Service supply: processing for this purpose is necessary in order to provide you with the Services and, therefore, for the execution of the contract with you. It is not mandatory to provide the Owner with your Personal Data for this purpose, but otherwise it will not be possible to provide you with any Service. The same applies to the newsletter service that arises from your specific request by entering an e-mail address and which you can revoke at any time by following the instructions in Paragraph 8 of this Policy.
•Marketing: the processing for this purpose is based on your consent. It is not mandatory to give your consent to the Data Controller for this purpose and you are free to withdraw it at any time without any consequence (except for the fact that you will no longer receive marketing communications from the Data Controller). You can revoke your consent previously given by following the indications in Paragraph 8 of this Policy.
•Soft Spam: the processing for this purpose is based on the interest of the Owner to send you marketing communications via email regarding products and services similar to those you have already purchased through the Site. You can stop receiving these communications, without any consequence for you (beyond the fact that you will no longer receive further communications of this kind from the Owner) using the link at the bottom of each of these emails;
•Profiling: the processing for this purpose is based on your consent. It is not mandatory to give your consent to the Owner for this purpose and you are free to revoke it at any time without any consequence (except the inability to benefit from the personalization of the commercial offers that you will receive from the Owner). You can revoke your consent previously given by following the indications in Paragraph 8 of this Policy.
•Compliance: processing for this purpose is necessary for the Data Controller in order to fulfill any legal obligations. When you provide Personal Data to the Data Controller, they must be processed according to the applicable legislation, which could result in their conservation and communication to the Authorities for accounting, tax or other obligations.
•Abuse/Fraud: the information collected for this purpose will be used exclusively to prevent and / or identify any fraudulent activity or abuse in the use of the Site and therefore allows the Data Controller to protect himself in court.
5. RECIPIENTS OF PERSONAL DATA
Your Personal Data may be shared with the following subjects listed below (the "Recipients"):
•subjects who typically act as data processors, namely: i) persons, companies or professional firms that provide assistance and advice to the Data Controller in accounting, administrative, legal, tax, financial and debt collection matters relating to the provision of the Services;
•subjects with whom it is necessary to interact for the provision of the Services (for example, hosting providers or suppliers of platforms for sending emails);
•subjects delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communications networks);
•persons authorized by the Data Controller to process Personal Data necessary to carry out activities strictly related to the provision of the Services, who are committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees of the Data Controller);
•Outlet Military Group companies for internal administrative purposes;
•subjects, entities or authorities to whom it is mandatory to communicate your Personal Data for Compliance, Abuse or Fraud purposes, or for orders from the authorities;
6. TRANSFERS OF PERSONAL DATA
Given the international presence of Outlet Military, some of your Personal Data are shared with Recipients that could be found outside the European Economic Area.
The Data Controller ensure that the processing of his Personal Data by these Recipients takes place in compliance with the applicable legislation. Indeed, transfers are made through adequate guarantees, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission or others. More information is available at Outlet Military by writing to the following address: email@example.com
7. STORAGE OF PERSONAL DATA
The Personal Data processed for the purpose of Providing the Services will be kept by the Data Controller for the time strictly necessary for the aforementioned purpose (e.g. for sending the purchased product). In any case, since these Personal Data are processed to provide you with the Services, the Data Controller may keep them for a longer period, in particular for what may be necessary in order to protect the Data Controller's interests from possible complaints relating to the Services.
Personal Data processed for the purpose of Recruitment will be kept by the Data Controller for the entire period in which the position for which the Application was sent or, if shorter, for one (1) year. the Data Controller reserves the right to contact the candidates before the expiry of this period to request them to extend the retention period of their Personal Data or to request an update of the Application. In case of no response, the Data Controller delete the Personal Data collected.
Personal Data processed for Marketing and Profiling purposes will be kept by the Data Controller until the moment you withdraw your consent. In any case, we will remind you of the consents you have given us every 24 months. Once consent has been withdrawn, the Data Controller will no longer use your Personal Data for these purposes, but may still retain them, in particular for what may be necessary in order to protect the interests of the Data Controller from possible complaints based on these treatments.
Personal Data processed for the purpose of Soft Spam will be kept by the Data Controller until you object to this treatment through the link at the bottom of each of the Soft Spam e-mails.
Personal Data processed for Compliance purposes will be kept by the Data Controller for the period provided for by specific legal obligations or by applicable legislation.
The Personal Data processed in order to prevent Abuse / Fraud will be kept by the Data Controller for the time strictly necessary for the aforementioned purpose and therefore until the moment in which the Data Controller will be required to keep them in order to protect themselves in court to communicate said data to the competent Authorities.
8. RIGHTS OF THE INTERESTED PARTY
You have the right to ask the Owner, at any time:
•access to your Personal Data, (or a copy of such Personal Data), as well as further information on the treatments underway on them;
•the rectification or updating of your Personal Data processed by the Owner, if they are incomplete or out of date;
•the cancellation of your Personal Data from the Data Controller databases;
•the limitation of the processing of your Personal Data by the Owner;
•to obtain the Personal Data concerning you in a structured, commonly used and machine-readable format;
as well as you can:
•object to the processing of your Personal Data by the Owner (eg Soft Spam);
•revoke your consent for Marketing and Profiling purposes.
We point out that most of the Personal Data you have provided to the Owner can be changed at any time, by accessing, where possible, your personal account created on the Site.
When requesting the Services, you may have selected which communication channels through which you want to be contacted for Marketing purposes (i.e., telephone, sms, email, mail, push notifications, social media).
You will be able to withdraw consent for Marketing relating to each of these communication channels through your personal account on the Site, by deselecting the relevant options. You can also revoke the consent to Marketing sent by e-mail and stop receiving Soft Spam using the appropriate link that you will find at the bottom of each e-mail received. The same method can be used to stop receiving the Outlet Military newsletter, if I have requested it as a Service.
The consent to profiling through cookies can be revoked through the methods indicated in the previous Paragraph 2.f.
In addition to the above, you can also exercise your rights by writing to the owner at the following address: firstname.lastname@example.org.
In any case, you always have the right to lodge a complaint with the competent Control Authority (Guarantor for the Protection of Personal Data) if you believe that the processing of your Personal Data is contrary to the legislation in force.