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Privacy Policy

The following Privacy Policy is written by Panini S.p.A. - Single Member (hereinafter referred to as Panini), the data controller for the processing of personal data (hereinafter "Personal Data") we collect in our websites and applications for smartphones and tablets (hereinafter website and its application are collectively referred to as "Application” and/or "Applications") provided directly by you, or however that we received or generated by us as a result of processing your registration to sections of our Application.

Panini considers your privacy essential. We therefore ask you to read this information carefully in order to make an informed choice when filling in the fields to be completed at the time of registration in the sections of the Application for their use or to buy our goods and/or services.

Data collected

Panini does not require Personal Data for the purposes of browsing the main sections of its Applications. However, some of our Applications contain special and privileged sections for registered users.

The data collected by Panini can be of two types:

  • Personal data
  • Anonymous information

Personal Data processed consists of information requested from you during registration on our Applications and/or with every purchase of our goods and/or services, your participation in contests or events of any kind conducted by us, or sent spontaneously by you and in the information successively generated by the management of every relationship.

Anonymous information are those relating to the use of the Application, browsing habits and data traffic in general. Information collected remains anonymous and does not allow identification of users.

For more information please read our Cookie Policy

Purposes and methods of Personal Data processing

The purposes for Personal Data processing are as follows:

  1. enables the carrying out of operations that are closely related and instrumental to the management of relationships with users and customers, such as - by way of example - answering questions submitted through the contact form, enabling restricted Applications sections, supplying the service required and the execution of contracts for the sale of goods and/or services and checking the performance of relationships;
  2. allows for the proper performance of the contractual obligations taken on by us in respect to users and customers and vice versa, as well as accounting and tax requirements;
  3. allows the fulfillment of obligations imposed by laws, regulations and legislation, or rather to provisions issued by authorities empowered by law and by surveillance and control bodies;
  4. perform information operations regarding our products and/or services, as well as promotional, sales and marketing operations.
  5. set up groups of users by processing the data provided by our customers so that Panini does not forward generalized sales and promotional information to the users in an indistinct way. This enables us to segment the users, creating different groups according to the ranges of interest, for instance on the basis of the country of origin, the language, the gender, the previous purchases, etc ... This allows us to send you sales communications which are the most relevant and least invasive as possible. Finally, we remind you that the consent given for the forwarding of sales and promotional communications extends not only over the communications sent via the use of automated systems without the operator’s intervention (for instance, the email), but also over the traditional modalities of contact, as the postal service. You can always withdraw the consent to the treatment of your data with this purpose, even in a disjointed way, for example deciding to receive advertisement only via postal service and not through automated systems;
  6. carry out activities that identify the degree of customer satisfaction.

Processing will occur through computer or paper, both possibly organized as databases or storage and will involve where necessary the use of postal communication, telephone and computer systems. Panini will carry out processing also through segmentation techniques of users and customers on the basis of aggregation of personal data collected in order to limit the forwarding of communication and offers.

If you are using a service on a Panini Application or you are making or have made a purchase of a Panini good or service, you will receive commercial information from us regarding the same type of product and/or service. Please note that you can however, cancel the receipt of this marketing information at any time by sending us notification to the address set out in the last paragraph or in the event of notification via computer, following the procedure indicated at the bottom of this notification.

Without prejudice to the exceptions listed below, Personal Data is generally not intended for publication, communication, or distribution.

Personal Data will be made known to Panini staff and to other Panini Group companies members in charge of the Application development and management . All the Panini Group staff who as appointed controllers and/or in charge of processing according to the current corporate structure, is in charge of their processing in order to achieve the aforementioned purposes. Furthermore, Personal Data will be made known to third party companies, appointed controllers for the processing, who are responsible for their processing through outsourcing (for example, a company responsible for the management and completion of sales orders).

Personal Data may be disclosed to third parties with whom Panini has ongoing contractual relationships involving services for that activity (for example, accounting firms, auditors etc...).

Personal Data may be shared, used and transferred within the companies belonging to the Panini group in relation to the purposes for which the information was collected.

Finally, Personal data will be disclosed where required by competent tax offices, or rather to other Public Bodies, in accordance with the provisions of applicable laws.

Personal data from children under the age of 13 years

When a child under the age of 13 years (or older, in accordance with local laws) registers on our Applications for use of the sections reserved for registered users, Panini requires the child's email address and also that of his/her parent or guardian.

Users that won’t declare any age will be considered and treated as under 13 years old and therefore Panini will require also his/her parent or guardian email address.

With verifiable consent, Panini collects Personal Data such as name, surname, email address, sex, date of birth, country and province of residence, or other information required for a given activity (regarding competitions, quizzes or online games, etc.). We will use the child's email address only for the purpose for which it was collected and will use the parent or guardian's e-mail address only to provide notification of the child's contact. Parents and guardians of children under 13 years of age, from whom we have collected personal information, have the right to review and request deletion of such personal data.

Children under the age of 18 are not permitted to purchase goods or services from our Applications.

The procedure for child control is as follows:

  1. the child's parent or guardian receives an email with a summary of the child's personal data and can confirm or cancel the child's registration through a special link, the guardian is not registered on our Applications, but can at any time check what personal data the child provided or cancel the child's registration.
  2. parents or guardians have the option of allowing the collection and use of their child's personal information without agreeing to disclosing that information to third parties. If Panini changes to the collection, use, or disclosure practices the parent already agreed to, Panini will send the parent a new notice and get their consent.
  3. parents and guardians will be notified of any change made by the child to the personal information originally approved by them and a new consent request will be sent before collecting the new data.
  4. parents or guardians can revoke their consent and refuse the further use or collection of personal information from their child.

Panini uses a geolocation feature through which it is able to establish from which country the Applications are being accessed given that the process of child control depends on the country from where the user connects and not by the Application and not even from the Nation specified in the registration information.

Mandatory nature of personal data provision and consequences in case of non-response

The provision of Personal Data and its processing for the purposes specified in sub., a., b., and c., in the section Purposes and methods of processing of Personal Data are necessary for the execution of the contractual relationship and therefore are a necessary condition for the establishment of the relationship itself. Consequently, failure to provide Personal Data, failure to provide consent to the processing with regard to the transfer of Personal Data abroad and their communication in companies that are part of the Panini group, or rather the proven inaccuracy of the data provided, will result in Panini's inability to implement the contractual relationship and legitimises Panini to reject the execution of the contractual relationship, or to discontinue the execution of it.

The provision of Personal Data and its processing for the purposes indicated sub d., e., and f. in section Purposes and methods of processing of Personal Data are optional. Consequently, failure to provide consent to the processing will make it impossible for Panini to carry out the activities therein.

With specific reference to participation in games, competitions and events with awards, forwarding of text, drawings or photographs by you will be considered by us as consent to their publication, even if not expressly provided previously.

Rules applicable to all countries

Panini Privacy regulations comply with the current disclosure laws on the processing of personal data to ensure the protection of personal data, worldwide.

Security and Quality of Information

It is our intention to protect and manage personal data with quality. We always adopt measures and processes that are appropriate and obligatory, such as using encryption when transmitting certain sensitive information, making them secure and to ensure a high quality service.

Use of external services

Panini may use outside services to collect, use, analyse and process information. Panini asks such agencies that provide external services to manage information in a manner consistent with the Panini Privacy Policy, including the possible appointment of "data processors", if required.

Mergers and acquisitions

Circumstances may arise where, whether for strategic or business reasons Panini decides to sell, buy, merge or otherwise reorganise its company in some countries. Such transactions might involve the disclosure of personal data to buyers or potential buyers, or receiving of such information by the sellers. Panini researches the appropriate protection to use information for these types of transactions.

Connection to non Panini websites

The Panini Applications may contain links to other websites. Panini is not responsible for privacy practices or the content of such Websites.

The rights of the data subject

The Data Controller for Personal Data is Panini S.p.A. - Single Shareholder, with head office in Modena, Viale Emilio Po, 380. The Data processor of personal data is the Director New Media Giorgio Aravecchia. webprivacy@panini.it

You can exercise your rights and therefore access your data to know them, verify their use, or, in extreme cases, correct, update, edit, supplement and delete them or oppose their treatment, through the "edit data" section of our Applications or by writing to: webprivacy@panini.it

  1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him/her exist, regardless of their being already recorded, and the communication of such data in intelligible form.
  2. A data subject shall have the right to be informed regarding:
    1. the source of the personal data;
    2. the purposes and methods of the processing;
    3. the logic applied to the processing, if the latter is carried out with the help of electronic means;
    4. the identification data concerning the data controller, data processors and the representative designated as per Section 5, paragraph 2;
    5. the entities or categories of entities to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative in the State’s territory, data processor or person in charge.
  3. The data subject shall have the right to obtain
    1. updating, rectification or, where interested therein, integration of the data;
    2. erasure, anonymisation or blocking of data that have been unlawfully processed, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
    3. certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
  4. The data subject shall have the right to object, in whole or in part:
    1. on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of collection;
    2. to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.