Privacy policy - myMoleskine Community

Last update: 17 January 2020

PRIVACY NOTICE

Protection and privacy of your personal data are our priority.

When you visit one of the websites managed directly by Moleskine as data controller (hereinafter collectively referred to as the “Website” – moleskine.com, mymoleskine.moleskine.com, foldmagazine.com) and each time you interact with Moleskine S.r.l. (“Moleskine”, the “Company” “we”, “us”, “our”), we collect certain information about you (“Personal Data”).

This privacy notice (“Notice”), which is provided pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 General Personal Data Protection (“GDPR”), describes the processing of personal data carried out by Moleskine as data controller.

Controller

For the purposes of this Notice and of the processing activities, the Controller (art. 4, n. 7, GDPR) is the company Moleskine S.r.l., with registered office in Via Bergognone 34, 20144 Milan (Italy).

How we process your personal data

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 to such personal data) and to ensure that processing is carried out only for the purposes described in this Notice.

To whom we disclose your personal data

To the extent that it is necessary for the purposes of this Notice, your personal data may be disclosed to the following recipients:

Data Processors

In order to ensure that your personal data are processed as accurately as possible, Moleskine has appointed a number of data processors to whom personal data may be disclosed. 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;
Moleskine Partners

If you give us 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’s Partners may process your personal data as joint controllers (art. 26 GDPR) or as autonomous controllers.
Legal obligations

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 us in the manner indicated in the “How to contact us” section of this Notice.

Transfer or personal data outside EEA

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. Moleskine ensure that all possible transfers outside the EEA will be made in such a way as to guarantee the full protection of your rights and freedoms. With regard to the third country to which the data is transferred, if no adequacy decision has been taken by the European Commission, the data transfers will be regulated by the application of standard contractual clauses issued by the European Commission, or, in the event of transfer to the United States, by the Privacy Shield mechanism whenever it is applicable.

What are your rights?

Pursuant to GDPR, you can exercise the following rights on your personal data which are processed in accordance with this Notice:

Access: you can obtain information about the processing of your personal data and a copy of those personal data (Article 15 of GDPR);
Rectification: if you believe that your personal data are inaccurate or incomplete, you may request such data to be corrected or modified by following your instructions (Article 16 of GDPR);
Erasure (so-called “right to be forgotten”): except in cases provided for by applicable law, you have the right to request the erasure of your personal data, when: (i) the data are no longer necessary for the purposes for which they were collected and processed; (ii) you decide to withdraw your consent where consent is the legal basis of the processing; (iii) you object to the processing carried out to achieve other purposes and there are no overriding legitimate grounds to continue with the processing; (iv) personal data are processed unlawfully; (v) the erasure is required by law; (vi) the personal data refer to child and have been collected in relation to the offer of information society (Article 17 of GDPR);
Limitation: you may request the limitation of the processing of their personal data (Article 18 of GDPR);
Objection: you have the right to object to the processing of your personal data at any time in relation to your particular situation. Upon receipt of the objection, Moleskine will continue with the processing only if there are legitimate and compelling reasons that can be demonstrated to prevail over rights, interests and freedoms of the data subjects. Right to object to the processing of personal data for direct marketing purposes is absolute and can be exercised at any time (Article 21 of GDPR);
Withdrawal of consent: if the processing of your personal data is based on consent, you have the right to withdraw your consent at any time (Article 7 of GDPR);
Data portability: where the processing is based on consent, you have the right to receive in a structured format, commonly used and readable by automatic device the personal data you provided us and, where technically feasible, to the secure transmission of your personal data to another data controller (Article of 20 GDPR);

How to exercise your rights

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.

Right to complain to the competent supervisory authority

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.

Changes to this Notice

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, you will be informed about any substantial change with the appropriate means in order to inform you with transparency on how Moleskine processes your data and to allow you to exercise your rights.

The Structure of this notice

This Notice summarizes and describes comprehensively all data processing controlled by Moleskine through the Website. This Notice is divided in paragraphs, each one describing how data are processed in the specific section of the Website indicated or a specific activity controlled by Moleskine. These data processing activities are indicated in the following list and tables.

When you access the Website

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):

technical information including: IP address, information on the device, browser and software you use:
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.

Social plug-in and relations with social networks and other third parties

The Website allows interaction with social networks through sharing buttons, which may contain social plug-in (e.g. Facebook, Twitter, YouTube). 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:

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;
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. Therefore, in consideration of the above, two streams of data transfers may occur: one from Moleskine to the social network each time involved, and an equivalent one in reverse. In both cases, your click on a specific plug-in button -or a button that allows the connection between Moleskine and the social network- will be considered clear affirmative action, which will be considered as equivalent to your written consent to the transfer of your data in the manner described. 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.

When you purchase our products

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). Both ways of purchase are described in the following tables. When you make a purchase on our Website, payment transactions may be handled directly by Moleskine’s 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 data 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
Personal information (name, surname, date of birth; Contact details (e-mail address, phone number, address; Delivery address; Invoice data.	Management of your purchase and related activities Legal basis: Execution of contractual obligations of related pre-contractual measures for the proper management of your purchase. Sending of promotional communications relating to Moleskine products and services; Legal basis: Consent for the sending of promotional communications relating to products and services relating to products not similar to those you purchased (Moleskine will take note of your eventual refusal to provide your consent in order to not carry out that kind of processes). Legitimate interest for the sending of communications relating to products and services similar to those you purchased. Aggregate analysis of user preferences for Moleskine products and services Legal basis: Consent to sending promotional communications in line with your preferences and interests. Legal and accounting obligations. Legal basis: Compliance with legal obligations Exercise and defence of our rights before a judicial, administrative or other authority Legal basis: Need to defend our rights before a judicial, administrative or other kind of authority	Provision necessary for the conclusion of purchases. In case of failure, Moleskine will not be able to deal with your request. Optional provision for processing for marketing purposes and for the cross-referencing of your data with those on the Website. Failing this, Moleskine will not be able to send you promotional communications regarding its products.	Data directly provided by the data subject.	Ten (10) years for data related to your purchase. Twenty-Four (24) months for data processed for marketing purposes Twelve (12) months for data processed for profiling purposes. 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.

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

Personal information (name, surname, date of birth;
Contact details (e-mail address, phone number, address;
Delivery address;
Invoice data.

Management of your purchase and related activities

Legal basis:
- Execution of contractual obligations of related pre-contractual measures for the proper management of your purchase.
Sending of promotional communications relating to Moleskine products and services;

Legal basis:
- Consent for the sending of promotional communications relating to products and services relating to products not similar to those you purchased (Moleskine will take note of your eventual refusal to provide your consent in order to not carry out that kind of processes).
- Legitimate interest for the sending of communications relating to products and services similar to those you purchased.
Aggregate analysis of user preferences for Moleskine products and services

Legal basis:
- Consent to sending promotional communications in line with your preferences and interests.
Legal and accounting obligations.

Legal basis:
- Compliance with legal obligations
Exercise and defence of our rights before a judicial, administrative or other authority

Legal basis:
- Need to defend our rights before a judicial, administrative or other kind of authority

Provision necessary for the conclusion of purchases. In case of failure, Moleskine will not be able to deal with your request.
Optional provision for processing for marketing purposes and for the cross-referencing of your data with those on the Website. Failing this, Moleskine will not be able to send you promotional communications regarding its products.

Data directly provided by the data subject.

Ten (10) years for data related to your purchase.
Twenty-Four (24) months for data processed for marketing purposes
Twelve (12) months for data processed for profiling purposes.

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.

Cookie Policy

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	Maximum storage period
Personal information (name, surname, date of birth); Contact details (e-mail address, phone number, address); Delivery address; Invoice data.	Management of your purchase and connected activities Legal basis: execution of contractual obligations of related pre-contractual measures for the proper management of your purchase. Legal and accounting obligations. Legal basis: Compliance with legal obligations Exercise and defence of our rights before a judicial, administrative or other kind of authority Legal basis: Need to defend our rights before a judicial, administrative or other kind of authority	Provision necessary for the conclusion of purchases. In case of failure, Moleskine will not be able to deal with your request.	Data directly provided by the data subject.	Ten (10) years for data related to your purchase. 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.

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

Personal information (name, surname, date of birth);
Contact details (e-mail address, phone number, address);
Delivery address;
Invoice data.

Management of your purchase and connected activities

Legal basis:
- execution of contractual obligations of related pre-contractual measures for the proper management of your purchase.
Legal and accounting obligations.

Legal basis:
- Compliance with legal obligations
Exercise and defence of our rights before a judicial, administrative or other kind of authority

Legal basis:
- Need to defend our rights before a judicial, administrative or other kind of authority

Provision necessary for the conclusion of purchases. In case of failure, Moleskine will not be able to deal with your request.

Data directly provided by the data subject.

Ten (10) years for data related to your purchase.

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.

Cookie Policy

In our retail stores

When you make a purchase at one of Moleskine’s 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. The inclusion of this personal data in Moleskine’s databases will not result in Moleskine’s use of it in a different manner from that described below.

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
Personal information (name, surname, date of birth); Contact details (e-mail address, telephone number, postal address);	Manage the purchase requested by you and related activities (including any repairs of defective products to be purchased) Legal basis: Execution of contractual obligations of related pre-contractual measures for the proper management of your purchase. Sending of promotional communications relating to Moleskine products and services; Legal basis: Consent to the sending of promotional communications relating to products and services relating to products not similar to those you purchased (Moleskine will take note of your possible refusal to provide your consent in order to not carry out that kind of processes). Legitimate interest in the sending of communications relating to products and services similar to those you purchased. Cross-reference of personal data provided by you in the store with those already present on our Website Legal basis: Consent (Moleskine will take note of your possible refusal to provide your consent in order to not carry out that kind of processes). Aggregate analysis of user preferences for Moleskine products and services Legal basis: Consent to sending promotional communications in line with your preferences and interests. Legal and accounting obligations. Legal basis: Compliance with legal obligations Exercise and defence of our rights before a judicial, administrative or other authority Legal basis: Need to defend our rights before a judicial, administrative or other kind of authority	Provision necessary for the conclusion of purchases. In case of failure, Moleskine will not be able to deal with your request. Optional provision for processing for marketing purposes and for the cross-referencing of your data with those on the Website. Failing this, Moleskine will not be able to send you promotional communications related to its products.	Data directly provided by the data subject.	Ten (10) years for data related to your purchase. Twenty-Four (24) months for data processed for marketing purposes Twelve (12) months for data processed for profiling purposes. 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.

When you contact us

Through the Website you can contact Moleskine through the “Contact Us” section of the Website. This section describes the processing of your personal data that Moleskine carries out when you decide to contact us through the section mentioned above.

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
Personal information (name, surname, date of birth); Contact details (e-mail address, telephone number, postal address); Order number in relation to which you are contacting Moleskine; Any other personal data or information that you choose to share with us and that it is contained in your message or in the attachments.	Provide a feedback to your request; Legal basis: Consent (Moleskine will take note of your possible refusal to provide your consent in order to not carry out that kind of processes). Compliance with possible legal obligations. Legal basis: Need to comply with a legal obligation Exercise and defence of our rights before a judicial, administrative or other authority Legal basis: Need to defend our rights before a judicial, administrative or other kind of authority	Consent and provision of the necessary data to be able to respond to your request.	Data directly provided by the data subject.	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.

Cookie Policy

When you sign in our newsletter

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 data	Maximum storage period
E-mail address	Sending of promotional communications relating to Moleskine products and services; Legal basis: Consent (Moleskine will take note of your possible refusal to provide your consent in order to not carry out that kind of processes). Legal and accounting obligations. Legal basis: Compliance with legal obligations Exercise and defence of our rights before a judicial, administrative or other authority Legal basis: Need to defend our rights before a judicial, administrative or other kind of authority	If you do not provide your data, you will not be able to subscribe to the Moleskine newsletter.	Data directly provided by the data subject.	Twenty-Four (24) months for data processed for marketing purposes, unless it is necessary to extend such period in order to comply with a legal obligation or to defend a Moleskine right before a judicial, administrative or other kind of authority.

Cookie Policy

Careers

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.

As a preliminary point, it should be clarified that Moleskine, in carrying out its personnel selection activities, 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 data	Maximum storage period
Personal information (name, surname, date of birth; Contact details (e-mail address, telephone number, postal address); Photography/personal image (where attached to your CV); Data relating to your qualifications, training and professional career; Any other information you decide to provide us with together with your application and in the course of the possible selection procedure. Among this information, it could be special categories of personal data according to Article 9 of the GDPR, i.e. personal data concerning health, revealing political opinions, religious beliefs, or trade union membership or concerning your sex life or sexual orientation shall be prohibited (“Sensitive Data”).	Assess whether your profile can be in line with Moleskine’s professional needs and to make selections in this sense among the various candidates; Legal basis: Performance of pre-contractual measures aimed at establishing a possible employment relationship between you and Moleskine. Consent (for Sensitive Data) (Moleskine will take note of your possible refusal to provide your consent in order to not carry out that kind of processes). Compliance with a legal obligation Legal basis: Need to comply with a legal obligation Exercise and defence of our rights before a judicial, administrative or other authority Legal basis: Need to defend our rights before a judicial, administrative or other kind of authority	Provision necessary. Failing to provide your data, Moleskine will not be able to consider your application. Provision and consent optional for Sensitive Data. Failing it, Moleskine will not be able to process your Sensitive Data.	Data directly provided by the data subject; Professional social network and other publicly available sources; Moleskine’s intermediaries and partners.	No more than 2 (two) years after the conclusion of the selections. Possibility to extend the storage period, with the consent of the data subject or where this is necessary to comply with a legal obligation or for the protection of a right of Moleskine.

Cookie Policy

B2B – Corporate gifts

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’s 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
Personal information (name, surname, date of birth); Contact details (e-mail address, telephone number, postal address); Information on the professional qualifications of the data subject (name or business name of employer of the data subject, professional role held).	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; Legal basis: legitimate interest of Moleskine and the performance of a contract and related pre-contractual measures. Sending of promotional communications related to Moleskine products and services. In the case of communications relating to products and/or services similar to those covered by the relationship between Moleskine and a B2B Customer, Moleskine has a legitimate interest in promoting its business activity. In the case of communications relating to products and/or services not similar to those covered by the relationship between Moleskine and a B2B Customer, consent (Moleskine will take note of your possible refusal to give your consent in order not to carry out this kind of processing). Legal and accounting obligations. Legal basis: Compliance with legal obligations Exercise and defence of our rights before a judicial, administrative or other authority Legal basis: Need to defend our rights before a judicial, administrative or other kind of authority	Provision optional. Failing this, Moleskine will not be able to properly establish and manage the relevant client relationship with the B2B Customer for which the data subject works. Provision optional for promotional communications. Failing this, Moleskine will not be able to send promotional communications related to Moleskine’s products and services.	Data provided directly by the data subject (or by a colleague and/or employer) by filling in a form on the Website or during participation and events or fairs in which Moleskine has taken part as an exhibitor; Organisations that manage fairs and events in which Moleskine has taken part as an exhibitor, to the extent that the organisations in question have obtained consent to the disclosure of personal data to third parties for the purpose of sending promotional messages for marketing purposes; Agencies or other specialized subjects that have lawfully collected personal data of the data subjects and have obtained from the data subjects the consent to the transfer of personal data to third parties for sending promotional messages for marketing purposes; Social networks (e.g. LinkedIn) to which data subjects are subscribed, insofar as such social networks have obtained consent from data subjects to the disclosures of personal data to third parties for the purpose of sending promotional messages for marketing purposes.	In the event of successful negotiations and subsequent establishment of a customer relationship, Moleskine will not retain personal data for more than ten (10) years. Twenty-Four (24) months for data processed for marketing purposes. That periods 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.

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

Personal information (name, surname, date of birth);
Contact details (e-mail address, telephone number, postal address);
Information on the professional qualifications of the data subject (name or business name of employer of the data subject, professional role held).

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;

Legal basis:
- legitimate interest of Moleskine and the performance of a contract and related pre-contractual measures.
Sending of promotional communications related to Moleskine products and services.
- In the case of communications relating to products and/or services similar to those covered by the relationship between Moleskine and a B2B Customer, Moleskine has a legitimate interest in promoting its business activity.
- In the case of communications relating to products and/or services not similar to those covered by the relationship between Moleskine and a B2B Customer, consent (Moleskine will take note of your possible refusal to give your consent in order not to carry out this kind of processing).
Legal and accounting obligations.

Legal basis:
- Compliance with legal obligations
Exercise and defence of our rights before a judicial, administrative or other authority

Legal basis:
- Need to defend our rights before a judicial, administrative or other kind of authority

Provision optional. Failing this, Moleskine will not be able to properly establish and manage the relevant client relationship with the B2B Customer for which the data subject works.
Provision optional for promotional communications. Failing this, Moleskine will not be able to send promotional communications related to Moleskine’s products and services.

Data provided directly by the data subject (or by a colleague and/or employer) by filling in a form on the Website or during participation and events or fairs in which Moleskine has taken part as an exhibitor;
Organisations that manage fairs and events in which Moleskine has taken part as an exhibitor, to the extent that the organisations in question have obtained consent to the disclosure of personal data to third parties for the purpose of sending promotional messages for marketing purposes;
Agencies or other specialized subjects that have lawfully collected personal data of the data subjects and have obtained from the data subjects the consent to the transfer of personal data to third parties for sending promotional messages for marketing purposes;
Social networks (e.g. LinkedIn) to which data subjects are subscribed, insofar as such social networks have obtained consent from data subjects to the disclosures of personal data to third parties for the purpose of sending promotional messages for marketing purposes.

In the event of successful negotiations and subsequent establishment of a customer relationship, Moleskine will not retain personal data for more than ten (10) years.
Twenty-Four (24) months for data processed for marketing purposes.

That periods 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.

Cookie Policy

Experiences – Subscription to the retreat

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 our 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 – even though exceptional- processing of your data that Moleskine may carry out as a result of your registration and/or participation in such experiences.

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
Personal information (name, surname, date of birth; Contact details (e-mail address, phone number, address; Information on professional position of data subject (personal information, name of the employer, position)	Management of possible complaint and/or any other extraordinary situation that may occur during the retreat in which you participate Legal basis: execution of contractual obligations of related pre-contractual measures for the proper management of your purchase. Legal and accounting obligations. Legal basis: Compliance with legal obligations Exercise and defence of our rights before a judicial, administrative or other authority Legal basis: Need to defend our rights before a judicial, administrative or other kind of authority	Provision necessary to allow Moleskine to manage any extraordinary situations that may occur in the retreat in which you participate	Data directly provided by the data subject. Employer of the data subject	Ten (10) years starting from the end of the retreat in you participate.

Cookie Policy

Mymoleskine – Participation to the Community

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 data	Maximum storage period
Personal information (name, surname, date of birth); Contact details (e-mail address, phone number, address); Social network accounts; Personal data contained in the works shared with the community.	Allow the participation of the data subject to the My Moleskine community. Legal basis: Consent (Moleskine will take note of your possible refusal to give your consent in order not to carry out this kind of processing). Legal and accounting obligations. Legal basis: Compliance with legal obligations Exercise and defence of our rights before a judicial, administrative or other authority Legal basis: Need to defend our rights before a judicial, administrative or other kind of authority	Inability to register and participate in the community.	Data directly provided by the data subject	10 years after the deletion of the data subject’s profile on MyMoleskine

Cookie Policy

Fold – Magazine

Fold is Moleskine’s magazine that can be consulted from the following link. With the exception of navigation data collected in the manner described in the cookie policy and those collected through the use of social network plug-ins, Moleskine will not collect or process personal data of users who consult the pages of the magazine Fold.

Cookie Policy