Privacy Policy

 

This privacy policy is to provide all the information on the processing of personal data carried out by T-Direct S.r.l. when the user browses through the Website and uses its services (as better indicated below).

 

 

Disclaimer: Change in Ownership and Data Management

We would like to inform you that, following a business unit transfer operation, the management of this website has been entrusted, by the previous owner, the company Join The Triboo Ltd., to the italian company T-Direct S.r.l.

Consequently, T-Direct S.r.l. now assumes all responsibilities previously held by the former owner in all user-related matters, including the handling of personal data.

 

This change in ownership will not impact your user experience on the site, and all services and functionalities will continue as usual with the exception of the marketing activities described in par. 4 of this privacy policy, which will not be carried out unless the user expresses a new consent. T-Direct S.r.l. is committed to maintaining the privacy and security of your personal information.

 

If you have any concerns or questions regarding this transition or the processing of your personal data, please do not hesitate to contact us at privacy.trd@triboo.it.

 

1.      INTRODUCTION – WHO WE ARE?

T-Direct S.r.l., with registered office in Viale Sarca 336 Ed.16 - 20126 Milan (Italy), VAT No. and Fiscal Code IT09290830968 (hereinafter, “Data Controller”), manager of this internet website (hereinafter, the “Website”), in its capacity as data controller in relation to personal data pertaining to the users using the Website (hereinafter, the “Users”) hereby provides the privacy policy pursuant to art. 13 and 14 of the Regulation EU 2016/679 of the Council of 27 April 2016 and UK General Data Protection Regulation (hereinafter, “Regulation” or “Applicable Law”).

 

2.     HOW TO CONTACT US?

The Data Controller takes the utmost account of Users’ right to privacy and protection of personal data. For any information related to this privacy policy, Users may contact the Data Controller at any time, using the following methods:

 

·       registered letter with return receipt to the following address: Viale Sarca 336 Ed.16 - 20126 Milan (Italy);

·       by e-mail (to the following address privacy.trd@triboo.it.

 

The Users may also contact the Data Protection Officer (DPO) appointed by the Controller. The contact details of the DPO are: lapo.curinigalletti@triboo.it.


We have appointed GRCI Law Limited to act as our UK Representative. If you wish to exercise your rights under the UK General Data Protection Regulation (GDPR), or have any queries in relation to your rights or privacy matters generally please email our Representative at ukrep@grcilaw.com or post your request or query to:

 

UK Representative, GRCI Law Limited, Unit 3, Clive Court, Bartholomew’s Walk, Cambridgeshire Business Park, Ely, Cambridgeshire, CB7 4EA, UK

 

When contacting our Representative please ensure you include our company name in any correspondence.

 

3.     WHAT DO WE DO? - PROCESSING PURPOSES

By browsing the Website the user would be able to freely search for job opportunities and by registering on the Website the user requests to receive a periodic newsletter containing the main job vacancies available on the Website (hereinafter, “Service”).

 

This Website and the services eventually offered through the Website are reserved to subjects over the age of 18 years old. Hereby, the Data Controller does not collect personal data pertaining to subjects under the age of 18 years old. At request of the Users, the Data Controller will promptly delete all the personal data, involuntary collected, pertaining to subjects under the age of 18 years old.

 

Particularly, the personal data of the Users will be lawfully processed for the following purposes:

 

a)     provision of Service: the personal data of the Users are collected and processed by the Data Controller for the provision of Service. The User’s data collected by the Data Controller for this purpose include (es: name, surname, data of birth, e-mail address, telephone number) and all other User data that may be voluntarily communicated by the User. Unless the User gives the Data Controller a specific and optional consent to the processing of his/her data for the further purposes provided for in the following paragraphs, the User's personal data will be used by the Data Controller for the sole purpose of ascertaining the identity of the User, possibly requesting confirmation and/or specification, thus avoiding possible fraud or abuse, and contact for service reasons only and to verify that the Service has been successful also by means of short surveys. Notwithstanding the provisions elsewhere in this privacy policy, under no circumstances will the Data Controller make Users’ personal data accessible to other Users and/or third parties.

 

b)     administrative and accounting purposes, i.e., to carry out activities of an organisational, administrative, financial and accounting nature, such as internal organisational activities and activities functional to the fulfilment of contractual and pre-contractual obligations;

 

c)     legal obligations, i.e., to comply with obligations imposed by law, an authority, a regulation or legislation.

 

The provision of personal data for the above-mentioned processing purposes is optional but necessary, since failure to provide such data will make it impossible for the Data Controller to provide the Service.

 

  1. OTHER PROCESSING PURPOSES

4.1        Third parties Marketing (sending of advertising material, direct sales and commercial communication)

 

With the User’s free and optional consent, User’s personal contact information may also be processed by the Data Controller for third parties marketing purposes (as for example, sending of advertising material, direct sales, commercial communication), or in order for the Data Controller to contact the User through electronic mail, phone (with automated calling or call-communication systems with and/or without operator intervention), messaging App and/or SMS to propose to the User the purchase of products and/or services offered by the by third parties, belonging to the following categories:

 

  • Clothing, fashion, accessories, footwear, optics, costume jewelry, jewelry, watches;
  • Lenses and eye care products;
  • Underwear costumes and accessories;
  • Tourism, airports, flights, ticket discounts, conventions, travel, hotels, itineraries, restaurants, resorts, agritourism, bus lines, bed&breakfasts, hostels;
  • Leather goods bags and suitcases;
  • Event planning, weddings, parties, concerts;
  • Children and early childhood, goods and services, toys, items and services for pregnant women and new mothers;
  • Education, culture;
  • Real estate listings, buying and selling, renting, mortgages;
  • Home services, renovations, decorating, furniture, doors, windows and doors, security, intrusion and safes, private guards and security;
  • Personal services (investigations, dating and socializing, hangouts, health and wellness, herbalist and perfumery, assisted hotel services, legal and accounting advice;
  • Culture and training courses, specialty courses, master's degrees, school remediation, college preparation assistance, cultural exchanges;
  • Financial products, banking, social security, loans and debt consolidation, investments, home banking, investment platforms;
  • Personal aids: mattresses, armchairs, elevators and elevators, ergonomic tubs, various devices including electronic devices;
  • Business services (credit recovery, business information, advertising and marketing, translations, interpreters, removals);
  • Personnel search and selection, job offers, internships, apprenticeships;
  • Prevention and safety devices;
  • Food products, organic, KM zero farming;
  • Beverages and soft drinks, wines and spirits;
  • Energy drinks and dietary supplements (proper nutrition and fitness);
  • Body care products, hair stylist, make-up, nail-art, beauty center and aesthetics, treatments, color therapy, solarium, gym, spa treatments, sporting goods;
  • Specialist medical services, dentists, teeth whitening, hair thickening, skin treatment and the like;
  • Tattoos, piercings and microdermis;
  • Sanitization products, pollutant monitoring, filters and purifiers;
  • Air conditioning and living environment management;
  • Vegetable garden and gardening, floriculture and green thumb;
  • Bricolage and do-it-yourself;
  • Temporary warehousing, storage and the like;
  • Pet services, food, care, pet care, accommodation and treatment;
  • Electrical, burglar alarm, telephone, data, satellite, digital and similar installations;
  • Entertainment and recreation, video games, consoles, hand-held consoles and computing;
  • Multimedia entertainment;
  • Subscriptions to pay-per-view, pay TV, on-demand, etc. channels;
  • Theme channels for children or interest categories; Multimedia content, CDs, DVDs, Bluray, Streaming and downloads;
  • Thematic channels for music, hobbies, cooking, technical, cultural, etc.;;
  • Cinemas and theaters, cabaret and live shows, concerts, rehearsal rooms, recording, recording, various equipment, post-production, mixing editing;
  • Sports, dedicated channels, specialized magazines, subscriptions, discounts, clothing, accessories, gyms, sports centers, events and competitions;
  • Technology, computers, tablets, cameras, telephony, TV and HiFi;
  • Home appliances, home furnishings, linens, artistic decor;
  • Interior planning, furniture and interior design;
  • Utilities and commodities: energy rates and utilities;
  • Home, auto, personal, travel insurance, discount rates, discounts and promotions;
  • Driving schools, point recovery, car practices, special licenses, license renewal;
  • Automotive, tuning, car practices, buying and selling, rental, parts, maintenance and services for the world of cars and motorcycles;
  • Rallies, races, sporting events of the motor world;
  • Cycling, equipment, events, services, spare parts and the like;
  • Sea, lake and river: products and services for boating, fishing, tourism and leisure, water sports;
  • Prank pastimes based on horoscopes, magic games, astrology and statistics;
  • Contests and lotteries, sweepstakes and prize operations;
  • Market research and analysis.

 

(hereinafter, the “Categories”)

 

In case of lack of consent, the possibility to browse and register on the Website will not be affected in any way.

 

In case of consent, the User may at any time withdraw the same, making a request to the Data Controller in the manner indicated in paragraph 8 below.

 

The User can also easily oppose further sending of promotional communications via e-mail by clicking on the appropriate link for the revocation of consent, which is present in each promotional email. If the User wishes to revoke his or her consent to the sending of promotional communications by telephone, while continuing to receive promotional communications by e-mail, or vice versa, please send a request to the Data Controller in the manner indicated in paragraph 8 below.

 

The Data Controller informs that, following the exercise of the right of opposition to the sending of promotional communications via email, it is possible that the User continues to receive further promotional messages due to technical and operational reasons (e.g. formation of contact lists already completed shortly before the Data Controller’s receiving of the opposition request). Should the User continue to receive promotional messages after 24 hours from the exercise of the right of opposition, please report the problem to the Data Controller, using the contacts indicated in paragraph 8 below.

 

4.2        Communication of data to the Data Controller's Partners

The User’s personal and contact data will be disclosed by the Controller to third party companies belonging to the Categories (hereinafter, jointly, the “Data Controller’s Partners”).

 

The Partners already identified by the Data Controller at the time of publication of this policy, the indication of which is also accompanied by the link to the privacy policy of each Partner, can be found in the list at the bottom of this page.

 

In this case, the Data Controller’s Partners, as autonomous data controllers, will process the User’s personal data for their own marketing purposes (direct sales, sending of advertising material and commercial communication), and may contact the User via e-mail, telephone (with automated call or call communication systems with and/or without the intervention of an operator) messaging App and/or SMS to propose to the User the purchase of products and/or services offered by the same Categories of third companies and present the User with offers, promotions and commercial opportunities. Once the disclosure has taken place, it will be the responsibility of the Data Controller’s Partner to provide Users with all the information provided for the applicable law.

 

5.     LEGAL BASIS FOR PROCESSING

Provision of Service (as described in the previous paragraph 3, letter a)): the legal basis consists of art. 6, paragraph 1, lett. b) of the Regulation, or the processing is necessary for the performance of a contract to which the User is party or in order to take steps at the request of the data subject prior to entering into a contract.

 

Administrative and accounting purposes (as described in the previous paragraph 3, letter b)): the legal basis consists of art. 6, paragraph 1, lett. b) of the Regulation, as the processing is necessary for performance of a contract to which the User is party or in order to take steps at the request of the data subject prior to entering into a contract.

 

Legal obligations (as described in the previous paragraph 3, letter c)): the legal basis consists of art. 6, paragraph 1, lett. c) of the Regulation, as the processing is necessary for compliance with a legal obligation to which the Data Controller is subject.

 

Other processing purposes (as described in paragraph 4 above) for the processing relating to third parties marketing activities and to communication of data to the Data Controller's Partners, the legal basis is Article 6, paragraph 1, letter a) of the Regulation, i.e., the provision by the data subject of consent to the processing of his/her personal data for one or more specific purposes. For this reason, the Data Controller asks the User to provide a specific free and optional consent, in order to pursue such processing purposes.

 

6.     PROCESSING METHODS AND DATA RETENTION PERIOD

The Data Controller will process the personal data of Users using manual and IT tools, with logic strictly related to the purposes themselves and, in any case, in order to guarantee the security and confidentiality of the data.

 

The personal data of Users will be retained for the time strictly necessary to carry out the main purposes explained in paragraph 3 above or, in any case, as necessary for the protection in civil law of the interests of both the Users and the Data Controller.

 

In the case referred to in paragraph 4 above, Users' personal data shall be stored for the time strictly necessary to fulfil the purposes set out therein and, in any case, until Users revoke their consent or does not object to the processing.

 

7.     TRANSMISSION AND DISSEMINATION OF DATA

The User’s personal data may be transferred outside the European Union or outside the UK, and, in this case, the Data Controller will ensure that the transfer takes place in accordance with the Applicable Law and, in particular, in accordance with Articles 45 (Transfer on the basis of an adequacy decision) and 46 (Transfer subject to adequate guarantees) of the Regulation.

 

The personal data of the Users may be disclosed to the employees and/or collaborators of the Data Controller in charge of managing the Website and the Users’ requests. These subjects, who have been instructed to do so by the Data Controller pursuant to Article 29 of the Regulation, will process the User’s data exclusively for the purposes indicated in this policy and in compliance with the provisions of the Applicable Law.

 

The personal data of the Users may also be disclosed to third parties who may process personal data on behalf of the Data Controller as “Data Processors” pursuant to Article 28 of the Regulation, such as, for example, IT and logistic service providers functional to the operation of the Data Controller’s Website, suppliers of outsourcing or cloud computing services, professionals and consultants.

 

Users have the right to obtain a list of any data processors appointed by the Data Controller, making a request to the Data Controller in the manner indicated in paragraph 8 below.

 

The Data Controller may ALSO communicate the personal data of Users to third-party data controllers, to the extent necessary to fulfill contractual obligations and/or to comply with legal obligations. For the purposes of paragraph 4.2, the Controller may communicate the data to the Data Controller’s Partners.

 

 

8.     RIGHTS OF THE DATA SUBJECTS

Users may exercise their rights granted by the Applicable Law by contacting the Data Controller as follows:

 

·       registered letter with return receipt to the following address: Viale Sarca 336 Ed.16 - 20126 Milan (Italy);

·       by e-mail (to the following address privacy.trd@triboo.it.

 

The Users may also contact the Data Protection Officer (DPO) appointed by the Controller. The contact details of the DPO are: lapo.curinigalletti@triboo.it.


We have appointed GRCI Law Limited to act as our UK Representative. If you wish to exercise your rights under the UK General Data Protection Regulation (GDPR), or have any queries in relation to your rights or privacy matters generally please email our Representative at ukrep@grcilaw.com or post your request or query to:

 

UK Representative, GRCI Law Limited, Unit 3, Clive Court, Bartholomew’s Walk, Cambridgeshire Business Park, Ely, Cambridgeshire, CB7 4EA, UK

 

When contacting our Representative please ensure you include our company name in any correspondence.

 

Pursuant to the Applicable Law, Users have:

a.    the right to withdraw consent at any time, if the processing is based on their consent;

b.   the right of access to personal data;

c.    (where applicable) the right to data portability (the right to receive all personal data concerning them in a structured, commonly used and machine-readable format), the right to restriction of processing of personal data, the right to rectification and the right to erasure ("right to be forgotten");

d.   the right to object:

            i.        in whole or in part, for legitimate reasons to the processing of personal data concerning them, even if relevant to the purpose of collection;

           ii.        in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication;

e.    if they consider that the processing of their personal data is in breach of the Regulation, the right to lodge a complaint with a supervisory authority (in the Member State in which they have their habitual residence, in the Member State in which they work or in the Member State in which the alleged breach has occurred). The Italian Supervisory Authority is the Garante per la protezione dei dati personali, located in Piazza Venezia n. 11, 00187 - Rome (http://www.garanteprivacy.it/ ). The Supervisory Authority in the United Kingdom is the Information Commissioners' Office (ICO) located in Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.  Helpline number: 0303 123 1113.  https://ico.org.uk/make-a-complaint/



    9.     UPDATES TO THIS PRIVACY POLICY

We may make changes to this privacy policy from time to time. You should check this page regularly to see our most up to date policy.  This privacy policy was last updated 1st January 2024.

 

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The Data Controller is not responsible for updating all links that can be viewed in this privacy policy, therefore whenever a link is not functional and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to such link.


Identity of our Business Partners & Clients:


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