INFORMATION FOR CUSTOMERS

Who are we and what do we do with your personal data?

Montefeltro Sport Srl, with registered office in Via della Stazione 50, 61029 Urbino (PU), as data controller works to ensure the confidentiality of your personal data and guarantees them the necessary protection from any event that may put them at risk of infringement.

Montefeltro Sport s.r.l. implements policies and practices regarding the collection and use of personal data and the exercise of the rights that you have under the applicable legislation. Montefeltro Sport s.r.l. updates its policies and practices for the protection of personal data whenever this becomes necessary and in any case in the event of regulatory and organizational changes that may affect the processing of your personal data.

How does Montefeltro Sport Srl collect and process your data?

Montefeltro Sport s.r.l. collects and / or receives information about you, like: name, surname, tax code, place and date of birth, physical and digital address, telephone and / or cell phone number, identity card number, passport number , bank account number, particular data relating to the state of health, images, firearms license, firearms license number, subject to express consent.

Your personal data will in no way be disseminated or disclosed to indeterminate and non-identifiable subjects even as third parties.

Your personal information will be processed:

1) For the management of the contractual relationship and consequent fulfilment, even under regulations

The processing of your personal data takes place to carry out preliminary activities related to the management of the contractual relationship established, like payment management,the handling of complaints, as well as for the fulfilment of any other obligations arising from the contractlike recording and storage of your personal data.

The obligations with which Montefeltro Sport s.r.l  must comply based on the contract and specific pertinent regulations include, among other thingskeeping accounting records.

Your personal data is also processed to prevent fraud, even contractual.

Finally, your data (like telephone number and / or cell phone number and digital address) will be processed to provide youwith assistance on the services covered by the contract.

Your personal data may also be used to send you specific communications and information relating to contractual obligations or deadlines, the methods of providing the service or any business operational needs. Without prejudice to the principles of necessity, relevance and non-excess, these notices may be made by paper, telephone (fixed or mobile number with direct, pre-registered and / or SMS) or telematic means (e-mail).

Your personal data are also collected from third parties such as, by way of example:

• lists and registers kept by public authorities or under their authority or similar bodies on the basis of specific national and / or international legislation;

• Private and public bodies operating in the industry nationally and internationally with which the Data Controller has established informative relationships.

The personal data that Montefeltro Sport s.r.l.  processes for this purpose are, among others:

• name, surname, tax code or VAT number, place and date of birth, physical and digital address, telephone number and / or cell phone number.

2) For disclosure to third parties and recipients

The processing of your personal data takes place depending on the contract and the legal and / or regulatory obligations deriving from it

Your data will not be disclosed to third parties/recipients, unless:

1. youauthorizeit;
2. it is necessary for the fulfilment of the obligations depending on the contract and by the laws that regulate it (e.g. for the defense of your rights, for the report to the supervisory authorities, etc ;
3. the communication is made to the auditing and certification firm of the financial statements; quality survey and certification company; network of collaborators/agents used by Montefeltro Sport s.r.l.; banking institutions for the management of receipts and payments; companies and law firms for the protection of contractual rights and/or dealing with credit recovery; data processing and IT services companies (e.g. web hosting, data entry, management and maintenance of IT infrastructures and services, etc.
4. the communication is made to the financial administration, and to the public supervisory and auditory bodies in relation to which Montefeltro Sport srl must fulfil specific obligations deriving from the very nature of the activity carried out;
5. we are not delegated or have no legally recognized right to receive your personal data. This is the case, for example, of family members, cohabitants or legal representatives (curators, guardians, etc.).

3) For business promotion

The processing of your personal data takes place to offer you products and services in addition to those related to your purchase, to send you advertising material. The processing of your data (like name, surname, physical and digital address, email, telephone number and / or cell phone number) can be done by:

• e-mail;
• Telephone (sms or calls);

The processing in question can be carried out:

1. If you give your consent for the use of your data also with regard to the methods of communication by which the processing takes place, whether traditional or automated;
2. If you are not in the opt-out register referred to in Italian Presidential Decree no. 178/2010, for processing carried out by a contact via telephone operator;
3. If you did not object to processing and / or if you did not specifically and separately object to the sending of communications through traditional and / or automatic methods.

4) For profiling

Your personal data may be processed for analysis of consumption habits and choices, defining individual profiles in order to send commercial and promotional information relevant to your latest purchases and preferences  in order to improve the offer of services and products offered by Montefeltro Sport srl. These treatments are carried out in an automated way.

Your personal data, processed by the Data Controller for this purpose, are name, surname, physical and digital address, telephone number and cell phone number, information related to the destination or game.

The processing in question can be carried out if:

• If you give your consent for the use of your data ;

5) For the disclosure of data to the group Beretta Holding S.p.a. for marketing activities (direct marketing, research and market surveys) autonomously carried out by them.

The disclosure of your personal data (like name, surname, physical and digital address, email, cell phone number and / or telephone number) to the Group Beretta Holding S.p.a., such as Fabbricad’Armi Pietro Beretta S.p.A. and Benelli Armi S.p.a. may take place for their own marketing purposes, only if you consent to such processing.

6) For information security purposes

The Data Controller and its suppliers (third parties and / or recipients) process your personal data, your digital data (e.g. accesses), to the extent strictly necessary to ensure the security and ability of a network or servers connected to it to withstand at a given level of security unforeseen events or illicit or malicious acts that compromise the availability, authenticity, integrity and confidentiality of stored or submitted personal data.

For these purposes, Montefeltro Sport srl provides procedures for managing the breach of personal data (data breach).

What happens if you do not provide your data?

If you do not provide your personal data, Montefeltro Sport srl will not be able to proceed with the processing activities associated with the management of the contract and the services associated with it or with the obligations that depend on them.

Montefeltro Sport srl intends to carry out certain processing based on certain legitimate interests that do not affect your right to privacy, like those that:

• allow the prevention of IT incidents and the notification of the supervisory authority or, if necessary, the communication to users of the breach of the personal data;
• allow disclosure to third parties / recipients for activities associated with the management of the contract.

What happens if you do not consent to the processing of personal data for marketing purposes (direct marketing, research and market surveys) by Montefeltro Sport srl or to disclosure to Sister Company / recipients for marketing purposes pursued by them independently or for profiling?

Your personal data will not be processed for these purposes; This will not affect the processing of your data for the main purposes or for which you have already given your consent, if required.

How and for how long is your data stored?

The processing of your data is carried out using electronic and manual means and tools made available to parties acting under the authority of Montefeltro Sport srl and specifically authorized and trained for this purpose.

The paper and especially electronic archives where your data is archived and stored are protected by effective security measures able to counter the risks of breach considered by Montefeltro Sport srl provides for periodic and constant verification of the measures implemented, especially for electronic and online tools, to guarantee the confidentiality of personal data that is thereby processed, archived and stored, especially if belonging to particular categories.

Personal data is stored for the time necessary to complete the activities related to the management of the contract with Montefeltro Sport srl and for the fulfilment of related obligations, legal or otherwise. For data intended for marketing purposes, you are always allowed to oppose the related processing and/or to revoke consent.

The Data Controller may transfer your personal data to countries outside the European Economic Area.

How

The processing of data is performed through paper supports or computerized procedures by internal, specially authorized and trained, personnel. The personnel is allowed to access your personal data in the measure and within the limits necessary for performing the processing procedures that regard you.
The Data Controller periodically verifies the tools through which your data is processed as well as the related security measures that are constantly updated; verification, also through persons authorized to process the data, that personal data not necessary for collection is not collected, processed or stored; verification that the data is stored with the guarantee of integrity and authenticity and their use for the purposes of processing actually performed.

Where

Personal data may be transferred, stored or processed on the MailChimp servers located in the U.S.A. and are protected by effective and adequate security measures to counter the risks of violation considered by the Data Controller, based on the “Privacy Shield” agreement concluded between the European Commission and the U.S.A. on 12 July 2016.

Your data may be transferred to non-EU countries – with full assurance of the guarantees provided for by European legislation and on the basis of art. 49, co. 1, letter b) of EU Regulation 679/2016, such as: Kazakhstan, Botswana, Burkina Faso, South Africa, Tanzania, Zimbabwe, Namibia, Russia, etc. 

How long

The personal data processed by Montefeltro Sport srl is kept for the time necessary to complete the activities related to the management of the contract with Montefeltro Sport srl and up to ten years after its conclusion (art. 2946 of the Italian Civil Code) or from when the rights that depend on it may be exercised (pursuant to art. 2935 of the Italian Civil Code); as well as for the fulfilment of the obligations (e.g. tax and accounting) that remain after the conclusion of the contract (art.2220 of the Italian Civil Code), for which Montefeltro Sport srl must keep only the data necessary for compliance non less than 10 years.

The personal data processed by Montefeltro Sport srl for marketing purposes (direct marketing, research and market surveys) will be kept for two years by Montefeltro Sport srl subject to withdrawal of the consent you have given and / or subject to your opposition to such processing.

The personal data processed by Montefeltro Sport srl for profiling will be kept for one year by Montefeltro Sport srl subject to withdrawal of the consent you have given and / or subject to your opposition to such processing.In any case, you retain the right to object to processing at any time based on a legitimate interest for reasons associated with your particular situation.

The personal data processed by Montefeltro Sport Srl, for the purposes of Public Security, will necessarily be kept for at least 50 years as required by the TULPS. and related regulations, without any possibility of revocation by you of the consent pursuant to Legislative Decree 26 October 2010 n. 204.

What are your rights?

Essentially, at any time and free of charge and without any particular obligations or procedures for your request, you can:

• Receive confirmation of the processing performed by Montefeltro Sport Srl;
• Access your personal data and know their origin (when the data is not obtained from you directly), the purposes of the processing, the data of the parties to whom they are disclosed, the storage period for your data or criteria useful for determining it;

• Withdraw consent at any time if consent is the basis for the processing. However, the withdrawal of consent does not prejudice the lawfulness of the processing based on the consent given before the withdrawal.
• Update or rectify your personal data so that they are always accurate;
• Erase your personal data from the databases and / or archives, including backups, of Montefeltro Sport Srl in the case, among others, where they are no longer necessary for the purposes of the processing or if processing is assumed to be illegitimate and if the conditions established by law exist, and in any case if the processing is not justified by another equally legitimate reason.
• Restrict the processing of your personal data in certain circumstances, for example where you have challenged their accuracy, for the period necessary for the Data Controller to verify their accuracy. You must be informed in a reasonable time even when the suspension period has expired or the reason for the restriction of processing no longer exists and therefore the restriction itself is revoked.
• Obtain your personal data – if received and / or otherwise processed by the Data Controller with your consent and / or if their processing is done on the basis of a contract and with automated tools – in electronic format, even in order to transmit them to another data controller.

Montefeltro Sport srl must respond without delay and, in any case, no later than one month after receiving your request.The deadline may be extended by two months if necessary, considering the complexity and the number of requests received by the Data Controller. In such cases, the Data Controller will inform you within one month of receiving your request and will inform you of the reasons for the extension.

For further information and in any case to submit any requests, please contact the Data Controller at the address privacy@montefeltro.com.

How and when can you object to the processing of your personal data?

For reasons relating to your particular situation, you can object at any time to the processing of your personal data if it is based on legitimate interest or if it concerns the processing of personal data whose conferment is subject to your consent, by sending your request to the Data Controller at ‘address privacy@montefeltro.com

You have the right to the erasure of your personal data if there is no other prevailing legitimate reason with respect to your request, and in any case if you object to processing.

Who can you submit complaints to?

Without prejudice to any other action in administrative or judicial proceedings, you can lodge a complaint with the competent supervisory authority or with the authority carrying out its duties and exercising its powers in Italy, where you have your habitual residence or work or if different in the Member State where the violation of Regulation (EU) 2016/679 took place.

Every update of this privacy policy will be communicated to you promptly and by means of a reasonable means, and you will be notified as well if the Data Controller processes your data for purposes other than those set out in this policy before proceeding and giving you time to provide your consent if necessary.

Consent provision

If you have received this information and have understood its content, Montefeltro Sport Srl asks you if you consent to the processing of your personal data:

1. a) per l’attività di promozione commerciale (quali invio di materiale pubblicitario, aggiornamenti e promozioni speciali confacenti alle tue necessità)

• Yes, I give my consent
• No, I don’t give my consent

1. b) for profilingactivities

• Yes, I give my consent
• No, I don’t give my consent

1. c) for the communication of data to companies of the Beretta Holding S.p.a. for marketing activities (direct, research and market surveys) carried out by them independently

• Yes, I give my consent
• No, I don’t give my consent