Last update: July 2022
Moleskine S.r.l., with registered office at Via Bergognone 34, 20144 Milano, is an Italian limited liability company which processes personal data as controller pursuant to Regulation EU n. 2016/679 (General Data Protection Regulation – “GDPR”) and Legislative Decree n. 196/2003, as amended by Legislative Decree n. 101/2018 (“Privacy Code”).
This privacy notice ("Notice"), which is provided pursuant to Articles 13 and 14 GDPR, describes the processing of personal data carried out by Moleskine within the following websites (each of them the “Website”, collectively the “Websites”):
Protection and privacy of your personal data are our priority. This Notice is constantly updated. For this reason, we indicate the date of the latest update at the head of this Notice. In case you have already provided your personal data to Moleskine, you will be informed about any substantial change with the appropriate means with a view to ensuring full transparency of the processing and full and adequate protection of your rights. Otherwise, we invite you to constantly check the Notice to be informed on its updates.
This notice is composed of two parts:
1) General Part, where you can find the following information:
- Principles of processing and protection of data
- To whom Moleskine discloses your personal data
- The transfer or personal data outside EEA
- What are your rights
- The right to lodge a complaint before the competent supervisory authority
- How to exercise your rights – How to contact Moleskine
2) Special Part, in which are summarized and described all the processing activities of personal data carried out by Moleskine through the Websites. The Special Part is divided in paragraphs, each of them provides the description of a specific processing (or a set of processing activities) referred to a specific section of the Websites or to a specific activity of Moleskine. For each processing you will find a summary table of the processing operations in which are indicated the categories of data processed, the purposes and the legal basis of the processing, the source of the data and the retention period.
The processing of your personal data is carried out with computer, automated and/or manual means in compliance with the principles of lawfulness, fairness, transparency, accuracy, integrity, data minimization and purposes and storage limitation, as well as in accordance with the provisions of the GDPR and applicable legislation on the protection of personal data, Personal data are collected, elaborated, transferred and stored by using appropriate security measures (physical, logical and organisational) to protect them from possible breaches (such as destruction, loss, alteration, unauthorised disclosure or accidental or unlawful access) and to ensure that processing is carried out only for the purposes described in this Notice.
To the extent that it is necessary for the purposes of this Notice, your personal data may be disclosed to the following recipients:
Moleskine collaborates with other companies that allow it to carry out its business. Those companies provides a number of services (e.g. payment service, IT consultancy, e-commerce platform etc.) and, in same cases, may access to your personal data. Moreover, your personal data processed for marketing and profiling purposes are collected and processed in a CRM marketing platform managed by the company Jakala S.p.A. They are however not authorized to process that data for their own purposes and, in fact, Moleskine has appointed them as processors. These subjects have been selected among professionals who guarantee the implementation of appropriate technical and organizational measures, so that the processing is always carried out in compliance with applicable legislation and ensuring the protection of data subjects’ rights;
Subject to your consent, your personal data may be shared with third party partners of Moleskine ("Moleskine Partners"), which may process them as autonomous data controllers for direct marketing purposes determined by them. Depending on the specific agreements entered into with Moleskine, Moleskine Partners may process your personal data as joint controllers (art. 26 GDPR) or as autonomous controllers.
Where necessary for the exercise or protection of our rights, as well as to comply with legal obligations, your personal data may also be disclosed with third parties, such as judicial and/or administrative authorities, law enforcement agencies or auditors.
You can request further information about subjects to whom Moleskine may disclose your personal data by contacting Moleskine in the manner indicated in the "How to contact us" section of this Notice.
In order to pursue the purposes of the processing described in this Notice, Moleskine may transfer your personal data to countries outside the European Economic Area ("EEA"), which includes all Member States of European Union, Norway, Liechtenstein, and Iceland. Should such transfers be necessary, they will be carried out in compliance with the provisions of articles 44-50 GDPR. In particular, in the case of transfers to countries which do not ensure an adequate level of data protection, Moleskine will undertake to adopt one of the appropriate safeguards referred to in Art. 46 GDPR, as well as to carry out an assessment regarding its actual ability to ensure an adequate level of protection for the personal data being transferred in light of the legislation of the destination country, as established by the Court of Justice of the European Union in the Schrems II judgment (CJEU, 16 July 2020, C-311/18).
Pursuant to the applicable legislation, you can exercise the following rights:
In order to protect your rights and your personal data, anytime, you may decide to file a complaint to the competent supervisory authority.
You can also claim your right before the competent national court.
However, we invite you to contact us -in the manner indicated in the "How to contact us" section of this Notice- to ask us any information regarding the exercise of your rights. We are sure that we can find a common solution together.
In order to exercise your rights as above or to ask any question or information on how Moleskine processes your personal data in accordance with this Notice, you can send an e-mail to privacy@moleskine.com.
Moleskine has appointed a Data Protection Officer (“DPO”) to whom you can ask for any request on the processing of your personal data and exercising you right at the address dpo@moleskine.com.
In case you decide to contact Moleskine, your personal data will be processed with the sole purpose to give answer and to ensure the best management of your request.
Our Website is structured in different sections and some of them may redirect to other websites. These websites, which have their own domain name, are under the control of Moleskine, but -in some cases- they might be controlled by Moleskine Partners. In case you are redirected on a website of a Moleskine Partner, please read its privacy notice in order to understand its name and its privacy policy.
In this paragraph we will explain which information are collected by Moleskine when a normal user accesses the Website.
In general, Moleskine or its Partners collect navigation data (with your permission whenever it is mandatory by applicable law):
a. technical information including: IP address, information on the device, browser and software you use:
b. information on the navigation on the Website including: URL of pages browsed and the activities carried out on these pages, (e.g. products viewed and eventually purchased), date and time of access, duration of access and clickstream.
This information is collected to ensure the best functioning, management, and maintenance of the Website as well as the in order to ensure you a safe experience on the Website and to ascertain the liability in case of any breach or unlawful access. In addition, we analyse these information -also as aggregated data- in order to obtain statistics on the performance of the Website. Furthermore, with your permission with the acceptance of the specific cookie policy, we will process your navigation data in order to find the product you prefer and to show you pertinent advertisements or interactive function of this Website, such as social media plug-in (see social plug-in at the following paragraph).
You are completely free to provide your navigation data. However, the refusal to provide for the information necessary information may make the access and the navigation on Website as well as connected activities impossible. We will store these data as long as they are necessary for the purpose for which they are collected. Navigation data are collected with the use of cookies. Each section of the Website uses its own and different cookies. In order to understand how cookies work in particular or how to enable or disable them, please see the specific Cookie Policy of the concerned section of the Website.
The Website allows interaction with social networks through sharing buttons, which may contain social plug-in (e.g. Facebook, Twitter, Pinterest). If you access one of the areas of the Site equipped with this type of plug-in, your Internet browser will connect you directly to the servers of the social network involved. In addition, the plug-in will be shown on screen through your browser connection. With regard to privacy protection instruments and the processing of personal data collected by these social networks, please refer to the pages of the individual social networks. In addition, when you visit a Moleskine page on a social network ("Moleskine Social Page"), whether by clicking on a social network link button or browsing directly through social network pages (including advertisements), the social network operator may share certain information about you with Moleskine. In particular:
a. Your actions, such as: viewing and interacting with the Moleskine Social Page and the content posted on it (including shares, reactions, comments), clicks and private e-mail communications on the Moleskine Social Page;
b. information about those actions, the people who carry out those actions and the browsers/apps used for them: date and time of the action; country/city (estimated by IP address or user profile -if the user interacted with the Moleskine Social Page after accessing the social network); language; age/gender (from user profile only for users who logged in); website visited previously; if the action is carried out on a computer or mobile device; social network user ID (only for users who logged in first).
In case you install a service that involves interaction with social networks in any way, it is possible that, even if you are not using the service, those social networks may collect traffic data from the pages on which the service is installed.
Depending on the case, Moleskine may act as an autonomous data controller or joint controller of the data processing.
For more information on how Moleskine processes personal data that it becomes aware of through the transfer of the same by social networks, please refer to the paragraphs of this Notice.
With regard to the processing carried out by social networks, please refer for more details to the individual information of each social network to which the Moleskine Social Page each time refers.
This section of the Notice describes how Moleskine processes your personal data when you purchase a Moleskine product both on the Website and in one of our retail stores.
PURCHASES ON THE WEBSITE
With regard to purchases on the Website, Moleskine distinguishes between purchases made after your registration on the Website and purchases that you make as a “guest” (i.e. without registration to the Website).
When you make a purchase on our Website, payment transactions may be handled directly by Moleskine partners who will process the personal data you provide on that occasion as data processors or, in the case of payment service providers (such as PayPal), also as autonomous controllers.
PURCHASES WITH PREVIOUS REGISTRATION
When you register an account in order to purchase something on our Website, this account is processed in a different manner from any other account that you eventually registered in any other section of the Website.
| Categories of data | Purpose and legal basis of the processing | Possible consequences of failure to provide us the requested data | Source of data | Maximum storage period |
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1) Management of your purchase and related activities Legal basis:
2) Legal and accounting obligations. Legal basis:
3) Exercise and defence of Moleskine rights before a judicial, administrative or other authority Legal basis:
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This period could be extended where this is necessary to comply with a legal obligation or to defend a Moleskine right before a judicial, administrative or other kind of authority. |
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4) Sending of promotional communications relating to Moleskine products and services; Legal basis:
5) Profiling activities based on your purchases made through the e-commerce platform or at Moleskine stores, aimed at creating targeted marketing campaigns, exclusively related to Moleskine products, based on your purchasing preferences. Legal basis:
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These periods could be extended where this is necessary to comply with a legal obligation or to defend a Moleskine right before a judicial, administrative or other kind of authority. |
3.1.2 PURCHASES IN “GUEST-MODE” WITHOUT PREVIOUS REGISTRATION TO THE WEBSITE
| Categories of data | Purpose and legal basis of the processing | Possible consequences of failure to provide us the requested data | Source of data | Storage period |
|---|---|---|---|---|
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1) Management of your purchase and connected activities Legal basis:
2) Legal and accounting obligations. Legal basis:
3) Exercise and defence of our rights before a judicial, administrative or other kind of authority Legal basis:
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This period could be extended where this is necessary to comply with a legal obligation or to defend a Moleskine right before a judicial, administrative or other kind of authority. |
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4) Sending of promotional communications relating to Moleskine products and services; Legal basis:
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This period could be extended where this is necessary to comply with a legal obligation or to defend a Moleskine right before a judicial, administrative or other kind of authority. |
IN OUR RETAIL STORES
When you make a purchase at one of Moleskine stores, we may ask you to provide us with your personal data in order to include it into our databases and process it in the manner described in the following table. This data is entered via a platform called “Retail Managment Platforms” provided by the company Oracle, which acts as processor.
| Categories of data | Purpose and legal basis of the processing | Possible consequences of failure to provide us the requested data | Source of data | Maximum storage period |
|---|---|---|---|---|
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1) Manage the purchase requested by you and related activities Legal basis:
2) Legal and accounting obligations. Legal basis:
3) Exercise and defence of Moleskine rights before a judicial, administrative or other authority Legal basis:
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This period could be extended where this is necessary to comply with a legal obligation or to defend a Moleskine right before a judicial, administrative or other kind of authority. |
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4) Sending of promotional communications relating to Moleskine products and services; Legal basis:
5) Profiling activities based on your purchases made through the e-commerce platform or at Moleskine stores, aimed at creating targeted marketing campaigns, exclusively related to Moleskine products, based on your purchasing preferences. Legal basis:
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Those periods could be extended where this is necessary to comply with a legal obligation or to defend a Moleskine right before a judicial, administrative or other kind of authority. |
Through the Website you can contact Moleskine through the "Contact Us" section of the Website.
| Categories of data | Purpose and legal basis of the processing | Possible consequences of failure to provide us the requested data | Source of personal data | Maximum storage period |
|---|---|---|---|---|
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1) Provide a feedback to your request; Legal basis:
2) Compliance with possible legal obligations. Legal basis:
3) Exercise and defence of our rights before a judicial, administrative or other authority Legal basis:
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Provision of data necessary in order to respond to your request. Failing this, Moleskine will not be able to provide a feedback to your request. |
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Your data will be kept for the period necessary to provide a response to your request, without prejudice to the possibility of extending this period where this is necessary to comply with a legal obligation or to defend a Moleskine right before a judicial, administrative or other kind of authority. |
By browsing through the Website’s pages you can subscribe to the newsletter managed by Moleskine. The newsletter in question is the same regardless of the specific page of the Website through which you decide to subscribe. This section describes the processing of personal data carried out by Moleskine as part of the aforementioned newsletter.
| Categories of data | Purpose and legal basis of the processing | Possible consequences of failure to provide us the requested data | Source of personal data | Maximum storage period |
|---|---|---|---|---|
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1) Sending of promotional communications relating to Moleskine products and services; Legal basis:
2) Profiling activities based on your purchases made through the e-commerce platform or at Moleskine stores, aimed at creating targeted marketing campaigns, exclusively related to Moleskine products, based on your purchasing preferences. Legal basis:
3) Legal and accounting obligations. Legal basis:
4) Exercise and defence of our rights before a judicial, administrative or other authority Legal basis:
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Moleskine can extend the abovementioned periods if it is necessary to comply with a legal obligation or to defend a Moleskine right before a judicial, administrative or other kind of authority. |
When you apply for a job position in Moleskine, as well as in the relevant selection procedure, Moleskine may process your personal data in the manner described in the table below.
You can apply for job positions within Moleskine through the section “Careers” of the Website as well us through Job announcements published on Internet. It should be clarified that Moleskine uses the advice of a third-party partner who manages a platform specifically dedicated to the professional world and through which it collects the curriculum of candidates which are then shared with Moleskine. This subject, as well as Moleskine, will process your personal data as autonomous data controller.
In particular, you can apply for jobs at Moleskine either through the "Careers" section of the Website or through other job advertisements published on the Internet. When submitting your application, you will be asked to register on our partner's platform, through which you can then forward your CV to us.
In addition to the methods described above, Moleskine may, exceptionally, take into consideration unsolicited applications that may be received by Moleskine via e-mail or other channels.
| Categories of data | Purpose and legal basis of the processing | Possible consequences of failure to provide us the requested data | Source of personal data | Maximum storage period |
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1) Assess whether your profile can be in line with Moleskine professional needs and to make selections in this sense among the various candidates; Legal basis:
2) Compliance with a legal obligation Legal basis:
3) Exercise and defence of our rights before a judicial, administrative or other authority Legal basis:
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In this section are described processing activities of personal data that Moleskine carries out with regard to employees, collaborators, representatives, owners or accounts in any capacity of Moleskine B2B customers in any form organised (“B2B Customers”).
| Categories of data | Purpose and legal basis of the processing | Possible consequences of failure to provide us the requested data | Source of data | Maximum storage period |
|---|---|---|---|---|
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1) Establish and manage the relationship with the B2B Customer of which the data subject is an employee, collaborator, representative, owner or account in any capacity, for the provision of good or services; Legal basis:
2) Sending of promotional communications related to Moleskine products and services.
3) Legal and accounting obligations. Legal basis:
4) Exercise and defence of our rights before a judicial, administrative or other authority Legal basis:
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That period may be extended when this is necessary to comply with a legal obligation or to defend a Moleskine right before a judicial, administrative or other kind of authority. |
When consulting the "Experiences" section of our website, if you decide to subscribe to one of the experiences promoted by Moleskine, you will be redirected to Moleskine partner's website, which manages entirely with the organization of the retreat as well as the processing of your request for participation.
In such situation, our partner is the autonomous data controller of all your personal data. For more information please consult the privacy policy on our partner's website.
In most these cases, Moleskine does not know any personal data referred to you. However, it could occur -exceptionally- that Moleskine may process some of your personal data (such as in case during the retreat something concerning you and our partner happens and you or our partner decide to communicate it to us).
In the table below, we list the possible processing of your data that Moleskine may carry out as a result of your registration and/or participation in such experiences promoted on the Website.
| Categories of data | Purpose and legal basis of the processing | Possible consequences of failure to provide us the requested data | Source of data | Storage period |
|---|---|---|---|---|
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1) Management of possible complaint and/or any other extraordinary situation that may occur during the retreat in which you participate Legal basis:
2) Legal and accounting obligations. Legal basis:
3) Exercise and defence of Moleskine rights before a judicial, administrative or other kind of authority Legal basis:
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Provision necessary to allow Moleskine to manage any extraordinary situations that may occur in the retreat in which you participate |
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This section describes the processing of personal data that Moleskine performs through the MyMoleskine community which is accessed, upon registration, through the Website. The registration to MyMoleskine, i.e. the creation of an account on MyMoleskine, is an activity completely unrelated to those that can be performed on other sections of the Website (e.g. online purchases).
| Categories of data | Purpose and legal basis of the processing | Possible consequences of failure to provide us the requested data | Source of personal data | Maximum storage period |
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1) Allow the participation of the data subject to the My Moleskine community. Legal basis:
2) Legal and accounting obligations. Legal basis:
3) Sending of promotional communications relating to Moleskine products and services; Legal basis:
4) Profiling activities based on your purchases made through the e-commerce platform or at Moleskine stores, aimed at creating targeted marketing campaigns, exclusively related to Moleskine products, based on your purchasing preferences. Legal basis:
5) Exercise and defence of Moleskine rights before a judicial, administrative or other authority Legal basis:
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Moleskine can extend the abovementioned periods if it is necessary to comply with a legal obligation or to defend a Moleskine right before a judicial, administrative or other kind of authority. |
In addition to data collected through App Notes developed by itself, Moleskine can – with prior specific consent of users – receive personal data of users of apps of third-party partners of Moleskine, that will collect and transfer data to Moleskine acting as autonomous controller. Data collected in that way will be included in Moleskine databases and processed for marketing and, where applicable, profiling purposes, as explained in the following table.
| Categories of data | Purpose and legal basis of the processing | Possible consequences of failure to provide us the requested data | Source of personal data | Maximum storage period |
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1) Marketing activities relating to Moleskine products and services. These activities include, in addition to the sending of promotional communications, the matching of personal data transferred by Moleskine partners with those already present in Moleskine databases in order to detect overlaps and extract statistical data; Legal basis:
2) Profiling activities based on your purchases made through the e-commerce platform or at Moleskine stores, aimed at creating targeted marketing campaigns, exclusively related to Moleskine products, based on your purchasing preferences. Legal basis:
3) Legal and accounting obligations. Legal basis:
4) Exercise and defence of our rights before a judicial, administrative or other authority. Legal basis:
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Moleskine partners developers of mobile apps that will transfer data to Moleskine with prior specific consent of users. Namely:
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Moleskine can extend the abovementioned periods if it is necessary to comply with a legal obligation or to defend a Moleskine right before a judicial, administrative or other kind of authority. |