Contact
PRIVACY POLICY
Ragione sociale: Mollebaule
Nome: Thomas
Cognome: De Gobbi
Indirizzo: Via Volontari della Liberta' 58,
Mira, VE, Italy 30034
Numero di telefono: +39 3714653904
Partita IVA: IT 04652930274
e-mail: mollebaule@gmail.com
Privacy Policy
This policy explains how we process your personal data when you use our online services.
1. General
1.1. Responsible party
Company name: Mollebaule
First name: Thomas
Surname: De Gobbi
Address: Via Volontari della Liberta' 58,
Mira, VE, Italy 30034
Phone number: +39 3714653904
VAT number: IT 04652930274
e-mail: mollebaule@gmail.com
1.2. Purpose and legal basis of processing
In the course of our business activities, we process personal data of various parties (e.g. website users, interested parties and customers). We will inform you of the purposes and legal basis of the processing, as well as further details regarding the different processing situations, at the bottom of this privacy policy.
1.3. Recipients
Depending on the situation, your personal data may be processed not only by the controller, but also by third parties. Possible recipients include, in particular, order processors (e.g. web hosting, software providers and other technical service providers), shipping service providers and third-party providers of online services and content. Disclosure may also be made in connection with official investigations, court orders and legal proceedings, if it is necessary for legal action or law enforcement. For details, please refer to the notes on the respective processing, if applicable.
1.4. Transfer to third countries
We use services whose providers are partly located or process personal data in so-called third countries (outside the European Union or the European Economic Area), i.e. countries in which the level of data protection does not correspond to that of the European Union. Where this is the case and where the European Commission has not issued an adequacy decision (Article 45 of the GDPR) for these countries, our company has taken appropriate precautions to ensure an adequate level of protection for any data transfer operations. These measures include, among others, the European Union's standard contractual clauses. Where this is not possible, we will base the data transfer on the exceptions set out in Art. 49 GDPR, in particular on your express consent or on the necessity of the transfer for the performance of the contract or for the implementation of pre-contractual measures.
1.5. Storage period
Personal data will be stored for as long as is necessary for the purpose for which they were collected, for the period of time established by law, or for the time necessary to fulfill other legal obligations.
1.6. Rights of data subjects
You have the right to obtain information about the data stored concerning you, including any recipients and the planned storage period, pursuant to Art. 15 GDPR. If the data processed is not (or is no longer) correct, you have the right to rectification (Art. 16 GDPR). If the necessary legal requirements are met, you can request the deletion (Art. 17 GDPR) or the restriction (Art. 18 GDPR) of the processing, as well as object to the processing (Art. 21 GDPR). If you believe that the processing of your personal data violates data protection law, you have the right to lodge a complaint with a data protection supervisory authority of your choice (Art. 77 GDPR).
1.7. Right to object
You have the right to object, for reasons arising from your particular situation, at any time to the processing of your personal data which is carried out on the basis of Art. 6 (1) sentence 1 lit. f GDPR. In this case, we will not process the aforementioned personal data further unless there are compelling legitimate grounds for the processing that outweigh your interest in protection, or the processing serves to assert, exercise or defend legal claims. You may object at any time, without giving any reason, to the processing of your data for direct marketing purposes and to the profiling that may be associated with it.
2. Processing situations
2.1. Use of the website
Our Internet offers serve to provide information about our company and our services, to conclude or enter into contractual relationships and to communicate and interact with our customers and interested parties.
We also process personal data for the purposes mentioned above. The scope and legal basis of data processing depend on the services requested by the user, the browser configuration and the scope of any consent given.
Web technologies (cookies and similar technologies)
To improve communication and interaction with our customers and to optimize the user experience, we use various software solutions and web technologies, including third-party web analysis and marketing tools, as well as services for integrating third-party content, such as fonts, maps or videos.
These functions include storing and displaying recently entered search terms (autofill).
This function allows us to automatically suggest previous search queries entered by the user on our website, thus making the search function more convenient and efficient. You can delete your search history at any time, and the standard deletion occurs automatically after 30 days.
Analysis tools are used to collect, measure and analyze data such as the number of visitors, traffic sources, pages visited, time spent on the website or scroll depth. Marketing tools allow you to precisely control and evaluate marketing activities (advertising campaigns, affiliate advertising, multi-channel analysis).
For ePrivacy and data protection reasons, the use of such tools often requires the consent of the respective users. We use a so-called consent management tool to obtain and manage the necessary consents in accordance with Art. 6 (1) sentence 1 lit. a GDPR and, if applicable, Section 25 (1) TTDSG (see the following section).
Detailed information on the subject and scope of the relevant consents and the data processing based on these consents will be provided to you directly via the consent management tool.
Insofar as consent is not required, the processing of personal data takes place on the basis of Art. 6 (1) sentence 1 lit. f GDPR for the purposes described, which at the same time represent the interests pursued by us or our partners ("necessary services"). The collection of data for the provision of the website and the storage of log files are absolutely necessary for the operation of the website.
Consent Management Tool
For the purposes of consent management, we use a consent management tool ("CMT"). You can access the CMT at any time here or by clicking on the "Cookie Settings" link in the footer of the website. When a user accesses our website, a CMT cookie is set, which is used to store the consent given for the individual services and to control the corresponding activation or deactivation of the respective functionalities.
The CMT is used to obtain the necessary consents and to document them in accordance with our obligation to demonstrate them. The legal basis for this is Art. 6 para. 1 p. 1 lit. c GDPR.
The collected data is stored until the cookie is deleted. Details on data processing by the CMT can be found in the user interface of the tool.
Google Tag Manager
Our website may use the Google Tag Manager of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Tag Manager is used to manage tracking tools and other services, so-called website tags. Google Tag Manager does not require the use of cookies.
The legal basis is Art. 6 para. 1 p. 1 lit. f GDPR, based on our legitimate interest in easily integrating and managing multiple tags on our website.
Criteo
Within the framework of shared responsibility pursuant to Article 26 GDPR, we may use the services provided by Criteo SA, 32 Rue Blanche, 75009 Paris, France ("Criteo") to collect information about user behavior (e.g. products viewed, added to cart or purchased) in a purely anonymous form, in order to improve our advertising offering. As part of the contract with Criteo, we determine the scope of the respective advertising campaign. The implementation of this advertising campaign, including the decision on which ads to use and where to deliver them, is then Criteo's responsibility.
In the context of our joint responsibility for the above processing, you may exercise your rights under the GDPR against both us and Criteo. We have entered into a shared responsibility agreement with Criteo, the main terms of which will be made available to you upon request.
YouTube
On this website we have integrated videos that are stored on YouTube and can be played from our website. We have activated YouTube's extended data protection mode. This means that Google does not receive any information about your use and does not set any cookies until you actively click the play button. After you click, the video starts playing and Google sets its own cookies to improve its services and to display personalized advertising on the Google advertising network.
We also use the YouTube API to display videos and playlists, as well as to record and display the number of video views.
No further processing of user data by the YouTube API client is planned.
The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
For more information, please see the privacy policy applicable to YouTube.
2.2. Customer management, direct marketing
For the central management of sales-relevant contacts and marketing information within MOLLEBAULE, we use a so-called customer relationship management system ("CRM"). The data managed in the CRM includes both existing customer contacts and registered users of the website, including newsletter subscribers and other marketing contacts.
Customer/user profiles
The CRM allows us to collect and analyze marketing information from multiple sources to optimize our marketing strategy and send targeted mailings. This may include creating and analyzing customer or user profiles to determine which products and services are most popular, thus tailoring marketing campaigns to individual interests.
In addition to existing operational customer data, data generated via our online offerings (e.g. landing pages, contact forms) is also processed in the CRM. In addition, data from email and social media marketing may be present (e.g. open rates, referral paths, etc.).
Our goal is to make sales and marketing efforts efficient and targeted and to coordinate them across the various divisions. To this end, we process (also with the help of service providers) the relevant CRM data in accordance with Art. 6 (1) sentence 1 lit. f GDPR on the basis of a balancing of interests.
Consent management (email advertising)
Another component of our CRM is consent management. In accordance with Section 7 (2) No. 1 and 2 UWG, certain direct advertising measures, in particular e-mail or telephone advertising directed at consumers, are only permitted on the basis of prior express consent.
If and to the extent that you give us advertising consent within the scope of our Internet offerings (e.g. when registering for the newsletter), we document and store the information required to prove this (Art. 7 para. 1 GDPR and, if applicable, § 7a UWG) on the basis of Art. 6 para. 1 p. 1 lit. c GDPR.
If you withdraw your consent, we will retain the evidence for documentation purposes in accordance with Art. 6 (1) S. 1 lit. f GDPR until the expiry of the statutory limitation periods. This is done in our interest for a possible legal defense. The same applies to the documentation of advertising objections, which we also store in an email delivery blacklist to ensure that no advertising is sent to recipients who do not expressly wish to receive it.
Direct (personalized) posting and newsletter
If consent has been given (e.g. for shopping cart reminders or opinion and satisfaction surveys), the data processing for the purposes covered by the consent is carried out on the basis of Art. 6 para. 1 lit. a GDPR.
Regardless of any consent requirement, we process personal data from our CRM and, if necessary, from other sources (including service providers) for the purposes of targeted and, where possible, personalized delivery and design of direct mail. The legal basis for processing for the pursuit of our advertising interests is Art. 6 para. 1 p. 1 lit. f GDPR.
On our website there is the possibility to subscribe to a free and regular newsletter, which contains, among other things, personalized information for users, news about our products and current special offers.
If consent has been given (e.g. for shopping cart reminders or for opinion and satisfaction surveys), the data processing for the purposes covered by the consent is carried out on the basis of Art. 6 para. 1 lit. a GDPR.
Regardless of any consent requirement, we process personal data from our CRM and, where necessary, from other sources (including service providers) for the purposes of targeted and, where possible, personalized delivery and direct mail design. The legal basis for the processing for the pursuit of our advertising interests is Art. 6 para. 1 p. 1 lit. f GDPR.
On our website, there is the possibility to subscribe to a free and regular newsletter, which contains, among other things, personalized information for users, news about our products and current special offers.
For registration to our newsletter, we use the double opt-in process, which means that we will only send you the newsletter by email if you click on a link in our notification email to confirm that you are the owner of the email address provided. If you confirm your email address, we will store your email address, the time of registration and the IP address used for registration until you unsubscribe from the newsletter. The data is stored exclusively for the purpose of sending the newsletter and verifying your registration. You can unsubscribe from the newsletter at any time. There is an unsubscribe link in every newsletter. Notification to the contact details above or in the newsletter (e.g. by email or letter) is also sufficient.
The legal basis for the processing is your consent in accordance with Art. 6 para. 1 p. 1 lit. a GDPR. The recording of the registration process is based on our legitimate interests in accordance with Art. 6 para. 1 p. 1 lit. f GDPR for the purpose of demonstrating consent.
In order to determine when our emails are opened and how they are used, we record and analyze interactions with the newsletter and access data (e.g. opening rate or click rate) using industry-standard technologies. For this purpose, our emails include web beacons. These are small image files loaded from our website that allow us to determine when an email has been opened by the recipient. We also learn which links in the email the recipient clicks on. The use of the aforementioned access data allows us to continuously improve our services, content, customer communication and is useful for statistical purposes. We also use this information to better understand which content and products are of interest to you, so that we can provide you with the most relevant content in the future.
As part of your registration to receive our promotional emails, we also ask for your consent to personalize our emails according to your needs and interests, based on the data we store about you across devices, such as your login data, any account information, and any purchase history (orders, returns, uncompleted orders). The legal basis for this is your consent in accordance with Art. 6 para. 1 p. 1 lit. a GDPR.
Access data (open and click data) are only stored anonymously. A separate revocation is not possible with regard to the described analysis of your access data and the creation of a personalized usage profile. However, you can configure your email program to display emails in text format instead of HTML. This prevents the display of image and graphic files, making tracking impossible. In this case, the newsletter will not be displayed in full and you may not be able to use all of its features. If you do not want us to analyze your access data or create a personalized usage profile for you, you can withdraw your consent to receive personalized advertising emails at any time, as described above.
Advertising for existing customers
Please note that consent for sending and tracking is not required for postal advertising and advertising sent by email to existing customers, under the conditions of Article 7 (3) UWG. Data processing on the basis of a legitimate interest pursuant to Art. 6 (1) p. 1 lit. f GDPR can therefore also take place in connection with email marketing and postal advertising, if you have not given your consent to advertising or if you have revoked the consent given to us.
Please note that consent for sending and tracking is not required for postal advertising and advertising sent by e-mail to existing customers, under the conditions of Article 7 (3) UWG. Data processing on the basis of a legitimate interest pursuant to Art. 6 (1) p. 1 lit. f GDPR can therefore also take place in connection with e-mail marketing and postal advertising, if you have not given your consent to advertising or if you have revoked the consent given to us.
You can object to the use of your data for advertising purposes based on our legitimate interest at any time by using the corresponding link in the e-mails or by letting us know at the contact details given above (e.g. by e-mail or letter), without incurring any costs other than the transmission costs according to the basic rates.
Contact by SMS and telephone
If you have given your consent and have entered your mobile number and/or telephone number in your customer account, we will contact you by telephone or SMS for satisfaction surveys, special offers and promotions, to inform you about products and for statistical purposes. You can revoke your consent at any time with effect for the future by notifying us at the contact details above (e.g. by email or letter).
If you give your consent at the beginning of the call, the conversation may be recorded. We will retain the information provided during the call for the training of our customer service staff and for the quality assurance of our call center, and will normally delete it after three months, unless a longer retention period is required by law or for evidentiary purposes. We may retain the recording for up to three years for evidentiary purposes (e.g. for the conclusion of a sales contract). Your consent is the legal basis (Art. 6 para. 1 p. 1 lit. a GDPR) for recording the conversation and evaluating it.
Surveys and competitions
If you participate in one of our surveys, the data collected will be used for market and opinion research. We carry out anonymous data analysis only for internal purposes. If, in exceptional cases, surveys are not evaluated anonymously, the data will only be collected and processed with your consent (Art. 6 para. 1 p. 1 lit. a GDPR).
In the context of competitions, the data is used for the purpose of conducting the competition and notifying the prizes. More detailed information can be found in the general terms and conditions of the respective competition. The legal basis for the processing is the competition contract pursuant to Art. 6 para. 1 p. 1 lit. b GDPR.
Evaluations with comment function and star rating system
Our websites offer the possibility to provide public reviews of the products and services made available. If you participate in the star rating system, your overall score is calculated based on our feedback analysis scale. In the case of the comment function, your review may only be published on our websites with your initials or a name (pseudonym) of your choice.
The processing is carried out on the basis of Art. 6 para. 1 p. 1 lit. f GDPR with the legitimate interest in obtaining user ratings and thus creating a basis of trust for the use of the website. We also have a legitimate interest in making our sales relationships transparent for other customers and in verifying that they are based on actual purchases.
2.3. Contact
When you contact us via our contact forms or by e-mail, we regularly process your personal data (also with the help of service providers) to answer your request or to process your request on the basis of Art. 6 (1)(1)(f) GDPR, to protect the essential interests of our business, in particular our corporate communications.
Contract-related communication that is necessary for the implementation of a contractual relationship concluded with you or in the context of pre-contractual measures based on your request is also carried out on the basis of Art. 6 para. 1 p. 1 lit. b GDPR.
You can also contact our company by telephone. If you give us your consent at the beginning of the call, we will record the conversation. We will store the information provided during the call for the training of our customer service staff and for quality assurance of our call center and will usually delete it after three months, unless a longer retention period is required by law or for evidentiary purposes. We can retain the recording for up to three years for evidentiary purposes (e.g. for the conclusion of a sales contract).
Your consent is the legal basis (Art. 6 para. 1 p. 1 lit. a GDPR) for recording the conversation and its evaluation.
2.4. Customer account
Our website offers users the option of creating a customer account or registering in the login area so that they can use all the features offered by our website. Registering a user account constitutes a contract for the use of an account for MOLLEBAULE Shop. The data collected is used to grant the user access to the platforms and their services. We have highlighted the information that must be entered by marking it as mandatory. The registration information is used to process orders in our online shop and to create a customer account. Registration is not possible without this information. The legal basis for the processing is Art. 6 para. 1 p. 1 lit. b GDPR.
2.5. Ordering process
When a user places an order, we may collect additional information in addition to that provided during registration, which is necessary for processing the order.
Optional data, such as telephone and fax numbers, may be requested to enable us to contact you in case of questions or to request payment by telephone in case of non-payment after the due date and a written reminder, if all this is necessary and it is not possible to contact you by other means.
The legal basis for the processing is Art. 6 para. 1 p. 1 lit. b GDPR.
2.6. Payment service provider
You can choose between different payment service providers and payment methods to make the payment, including advance payment such as PayPal. For this purpose, data directly related to payment processing, such as billing addresses, IBAN, BIC and preferred payment method, may be transmitted to these service providers. For payment verification, for example for the release of the purchased goods, the corresponding payment information is transmitted directly to our company by the payment service providers. We also receive master data and financial information from payment service providers as part of the legally required identity check.
Unless you have given us your consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR, the legal basis for the transfer of data to payment service providers in the context of contract processing is Art. 6 para. 1 sentence 1 lit. b GDPR, as the processing is necessary for the performance of the contract and the processing of the order.
For the legal basis and further details on the data processing carried out by payment service providers under their responsibility, please refer to the data protection information of the respective payment service provider. Please note that not all payment methods are available in all countries.
Klarna, Sveavägen 46, 111 34 Stockholm, Sweden: Privacy Policy
Sofort GmbH, a Klarna Group company, Theresienhöhe 12, 80339 Munich, Germany: Privacy Policy
PayPal (Europe) S.a r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg: Privacy Policy
Trustly Group AB, 556754-8655, Norrtullsgatan 6, 113 29 Stockholm, Sweden: Privacy Policy
Dalenys Payment SAS, 110 avenue de France 75013 Paris, France (“Dalenys”): Privacy Policy
Braintree, a PayPal company (Europe) S.a r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg: Privacy Policy
Przelewy24 by PayPro Spólka Akcyjna, ul. Kanclerska 15, 60-327 Poznań, Poland: Privacy Policy
PostFinance, PostFinance AG, Mingerstrasse 20, 3030 Bern, Switzerland: Privacy Policy
EPS Überweisung, PSA Payment Services Austria GmbH, Handelskai 92, Gate 2, 1200 Vienna Austria: Privacy Policy
Oney bank S.A, RSC Lille Métropole 546 380 197, BP6, 59895 Lille Cedex 9, France: Privacy Policy
UniCredit Bank AG, Arabellastr. 12, 81925 Munich, Germany: Privacy Policy
UniCredit Bank Austria AG, Rothschildplatz 1, 1020 Vienna, Austria: Privacy Policy
AS SEB Pank, Tornimäe 2, 15010 Tallinn, Estonia: Privacy Policy
Please note that the most effective way to enforce your privacy rights is to contact your payment service provider, who has access to the data and can take action directly.
2.7. Sanctions comparison
In order to comply with the obligations under EU anti-terrorism legislation, we carry out a cross-check with the sanctions lists maintained and published by the EU. The legal basis is Art. 6 para. 1 sentence 1 lit. c GDPR as well as our legitimate interest pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR in checking whether the business relationship violates § 134 BGB and in avoiding sanctions.
We do this by comparing your name and delivery address with the most recent sanctions lists at the time the order is placed. If the check is positive, we will carry out a manual check of the result. If the manual check does not lead to a clear negative result, we will contact you and, if necessary, ask you for further information for the purpose of the check (in particular a copy of your identity document showing your nationality, date and place of birth). We will delete copies of identity cards immediately after manual verification. Your order will be temporarily suspended while the check is being carried out. If the check result is negative, your order will continue to be processed. If the check result matches an entry on the sanctions list, we will inform you and give you the opportunity to comment. We will then decide whether or not to engage in or continue the business relationship with you.
3. Online presence on social networks
We maintain online presences in social networks to communicate with customers and interested parties, among others, and to provide information about our products and services.
User data is usually processed by the relevant social networks for market research and advertising purposes. This allows usage profiles to be created based on the interests of users. For this purpose, cookies and other identifiers are stored on users' computers. On the basis of these usage profiles, advertisements are then placed, for example, within social networks or also on third-party websites. As part of the operation of our online presence, we may have access to information such as statistics on the use of our online presence provided by social networks. These statistics are aggregated and may include, in particular, demographic information and data on interaction with our online presence and the posts and content distributed through them. Details and links to the data of the social networks to which we have access as operators of the online presence are listed below.
The legal basis for data processing is Art. 6 para. 1 p. 1 lit. f GDPR, based on our legitimate interest in informing and communicating effectively with users, or Art. 6 para. 1 p. 1 lit. b GDPR, to stay in touch and inform our customers and to carry out pre-contractual measures with future customers and interested parties.
With regard to the legal basis for data processing carried out by social networks under their responsibility, we ask you to consult the data protection information of the respective social network. The following links will also provide you with further information on the respective data processing and your options for objection.
We would like to point out that the most effective way to address privacy concerns is to contact the provider of the social network, which has access to the data and can take action directly.
Below is a list of information on the social networks on which we have an online presence:
Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland)
Operation of the Facebook fan page under joint responsibility on the basis of a Joint Processing Agreement (so-called Page Insights Supplement for the responsible party);
Information on the processed site insights and the contact option in case of data protection inquiries: https://www.facebook.com/legal/terms/information_about_page_insights_data;
Privacy Policy: https://www.facebook.com/about/privacy/;
Opt-Out: https://www.facebook.com/settings?tab=ads and https://www.youronlinechoices.com
Instagram (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland)
Privacy Policy: https://help.instagram.com/519522125107875
Google/ YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland)
Privacy Policy: https://policies.google.com/privacy;
Opt-Out: https://www.google.com/settings/ads
TikTok (TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380 Ireland)
Privacy Policy/Opt-Out: https://www.tiktok.com/legal/privacy-policy?lang=en
4. Data Protection Officer
Ragione sociale: Mollebaule
Nome: Thomas
Cognome: De Gobbi
Indirizzo: Via Volontari della Liberta' 58,
Mira, VE, Italy 30034
Numero di telefono: +39 3714653904
Partita IVA: IT 04652930274
e-mail: mollebaule@gmail.com