Here at Clementoni S.p.a., we are totally committed to protecting the privacy of our users, therefore we take all steps in this sense and constantly strive to process personal details with the utmost attention and professionalism because we are all too aware that our business revolves around children and children's toys and games.
This is the reason why we have adopted personal data-processing measures that guarantee the safety and confidentiality of said details in compliance with prevailing laws.
The Data Controller is CLEMENTONI S.p.A., with registered office in Recanati, Zona Industriale Fontenoce, VAT number 00092380435, hereinafter referred to as "Clementoni" or "Controller".
Categories of processed data
You do not need to register nor to provide your personal details in order to browse our Website.
You are required to provide your data only if you want to register on the reserved areas and access specific sections of the Website.
Furthermore, data subjects may provide their personal data when they sign up for the newsletter, send in applications for the jobs advertised in the "Work for us" area and write to the Customer Support office to ask for information and help.
Bearing in mind the above, the personal data processed by Clementoni on the website www.clementoni.com are as follows:
- "Work with Us" area: personal details and contact information of candidates, photographs, information about the applicant's training, education and career, applicability of protected categories and additional data voluntarily provided by candidates in their CVs;
- Customer support: personal details, contact information; system log and any other details provided when a request for support/assistance is made;
- Newsletter: email address; system log.
Legitimacy of data provision
Kindly note that registering on the Website, accessing a registered account and, more generally, providing personal data is only allowed for users who are at least 16 years old.
Clementoni S.p.A. shall have no liability should users provide inaccurate or false data, or data about third parties (including minors) which they are not entitled and/or expressly authorised to provide and to grant consent for processing. The user takes full responsibility for such a line of conduct.
Purposes of the data processing
On the website www.clementoni.com, the following data is processed for the following purposes:
- "Work for Us" area: to manage job applications (Purpose 1).
- Customer Support: to handle customer requests and ensure that they are properly processed (Purpose 2).
- Newsletters: to send news, messages, information and promotions and/or advertising content by email (Purpose 3).
Legal basis for the processing
Purposes 1, 2 and 3: the processing is based on the User's consent (art. 6, paragraph 1, lett. A of the GDPR) to be granted separately for each single purpose by filling in the online form that appears when data is provided.
Users have the right to withdraw their consent at any given time, but this does not affect the lawfulness of processing for which consent was granted prior to revocation. For further information on how to exercise one's right to withdrawal, please see the section "Exercising of the data subject's rights".
Providing your data for the aforementioned purposes is entirely optional. Should the data subject refuse to provide their personal details, fail to give their consent or withdraw it for one or more purposes, they will not be able to use the relevant services.
Should the data subject refuse to provide their details either partially or fully, this will not only make it impossible to fulfil their request for the provision of services in whole or in part, but will also make it impossible to enter into or continue with the contractual relationship.
Provision of personal details is optional, unless it is necessary for other purposes.
The data subject is not subject to decisions based on automated processing, pursuant to article 22 of the GDPR.
Period of time for data storage
Personal data will be retained for the following periods of time.
- "Work for Us" area: the period required for candidate recruitment and a maximum of 2 years as from the time of sending the application;
- Customer support: 10 years from closing the support file;
- Newsletters: for the period of time that Clementoni keeps the service active or until the data subject withdraws their consent, whichever comes first. Each message will contain a reminder, informing the User that they have the right to unsubscribe by following the link. Furthermore, data storage will cease after 2 years of inactivity (the user has not opened an email, clicked on a link, replied, etc.).
Once this period of time has elapsed, all the data (including the user account) will be deleted.
Personal data may be disclosed to external parties duly appointed by the data processors (art. 28 of the GDPR) who are processing said data on behalf of Clementoni S.p.A.
Specifically, the data processed on our websites is disclosed to:
- Beesoft.it it S.r.l., with registered office in Via San Giovanni Scafa, 7 - 63074 San Benedetto del Tronto (AP), Italy (https://www.iubenda.com/privacy-policy/813188/cookie-policy?an=no&s_ck=false), who assists Clementoni S.p.A. with website management;
- FiloBlu S.p.A., with registered office in Santa Maria di Sala (VE), via Caltana 116/C, Italy (https://filoblu.com/it/privacy-policy/), who assists Clementoni S.p.A. with website management;
- Zendesk, Inc., with registered office in 1019 Market Street, San Francisco, CA 94103, USA, represented in Europe by Zendesk International Ltd, with registered office in 1 Grand Parade Dublin 6 D06 R9X8, Ireland (https://www.zendesk.it/company/customers-partners/privacy-policy/), who provides infrastructure for Website customer support;
- Overside srl, with registered office in Via della Repubblica 90 bis, 63822 Porto San Giorgio (FM), Italy, who provides technical support for the customer-support section on our Websites;
- ActiveCampaign, with registered office in 1 North Dearborn St, 5th Floor Chicago, IL (https://www.activecampaign.com/legal/privacy-policy), who provides infrastructure for managing and sending newsletters.
Furthermore, personal data may also be disclosed to the following categories of recipients:
- technical experts and software houses who assist the controller in developing, maintaining and managing the website;
- subsidiaries, affiliated companies or parent companies of the data Controller;
- companies providing hosting services for the data being processed;
- companies which manage customer support through the website;
- companies which manage orders of products purchased on the online shop;
- sector professionals and/or legal firms for the protection of the Company's own interests/rights.
For logistical and operational purposes relating to the hosting service, personal data may be transferred to Countries outside the EU for whom an adequacy decision has been made by the European Commission, or which provide appropriate safeguards pursuant to article 46 of the GDPR.
A full list of the data processors and those in charge of data processing may be obtained by sending a request to the following email address: email@example.com.
Personal data is subjected to both paper-based and electronic processing. To this end, all appropriate procedures will be put in place in order to protect the confidentiality, integrity and availability of the information in compliance with prevailing laws.
The rights of the data subject
Pursuant to articles 13-21 of the GDPR and under the conditions set forth therein, the data subject is entitled to exercise the following rights:
- the right to withdraw their consent for data processing (see section "Purposes of data processing and legal basis"):
- the right of access (the User has the right to receive confirmation that processing has been made, to obtain information on the processed data and to receive a copy thereof);
- right to rectification (the User may ask for their own personal data to be updated or rectified);
- the right to erasure of data (the User may ask for their personal data to be erased in the circumstances and under the conditions outlined in article 17 of the GDPR);
- the right to portability (in the circumstances and under the conditions outlined in article 20 of the GDPR, the User has the right to receive their own data in a structured, commonly used and machine-readable format and, whenever technically feasible, to obtain unhindered transfer of data to another controller);
- the restriction of processing (the User may ask for restriction of processing of their own data in the circumstances outlined under article 18 of the GDPR). In such an event, the data may be processed by the Controller not only for the purposes of storage with the consent of the data subject, but also for the protection of Clementoni's own rights or the rights of others in legal proceedings, or for reasons of public interest);
- the right to object (when personal data is processed for the sake of public interest or for the legitimate interests of the Controller, the User has the right to object to processing on grounds relating to their particular situation. In the event of processing for direct marketing purposes, there is no need for any specific reasons to make an objection);
- the right to file a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).
Exercising the rights of the data subject
In order to exercise the aforementioned rights, with the exception of the right to file a complaint with the Italian Data Protection Authority, the User may contact Clementoni S.p.a. by writing to the following address: firstname.lastname@example.org.
Data-protection officer (DPO)
Clementoni S.p.A. has appointed a Data Protection Officer (D.P.O.) pursuant to article 37 of the GDPR.
Should a data subject wish to make any enquiries or exercise their rights, they can contact the D.P.O. by writing to the following email address: email@example.com or by sending a request to the following postal address:
Data Protection Officer
Zona Ind.le Fontenoce scn
62019 Recanati (MC), Italy