PRIVACY POLICY

Welcome to the website www.colmar.it (hereinafter the “Website”), operated by Manifattura Mario Colombo & C. S.p.A. and Digital Boite S.r.l.

Through this Privacy Policy, Manifattura Mario Colombo & C. S.p.A. and Digital Boite S.r.l. provide information on the processing of personal data collected automatically or provided by users when accessing and browsing the Website and using the services available on it (hereinafter the “Services”).

Manifattura Mario Colombo & C. S.p.A. and Digital Boite S.r.l. therefore invite users to exercise care when signing up for services offered by third parties and to read the privacy notices provided by those parties, over which Manifattura Mario Colombo & C. S.p.A. and Digital Boite S.r.l. have no control and for which they cannot be held responsible.

1. DATA CONTROLLERS

The data controllers for the activities falling within their respective remits are:

  • Manifattura Mario Colombo & C. S.p.A. (hereinafter “Manifattura”):

  • Digital Boite S.r.l. (hereinafter “Digital Boite”):

(hereinafter jointly the “Controllers”).

In particular, Manifattura acts as an independent controller of the personal data processed for the following purposes:

  • Website Browsing;

  • Marketing;

  • Profiling;

  • Loyalty Program;

  • Personalised Assistance;

  • Anti-Fraud Activities;

  • Recruitment;

  • Defence;

  • Performance Measurement;

  • Deliverability;

  • Campaign Optimisation;

as further defined below.

Digital Boite acts as an independent controller of the personal data processed for the purpose of:

  • Product Purchases;

also further defined below.

Lastly, Manifattura and Digital Boite act as joint controllers of the personal data processed for the following purposes:

  • Customer Care;

  • Soft Spam;

  • Multichannel;

  • Defence;

as further defined below. In this regard, Manifattura and Digital Boite have entered into a specific joint controllership arrangement pursuant to Article 26 of Regulation (EU) 2016/679 (hereinafter the “Regulation”). Users may request further information on the essence of this arrangement by contacting the respective Controllers at infoedatabreach@mmcol.it and privacy@digitalboite.com.

2. DATA PROTECTION OFFICER

Manifattura and Digital Boite have each appointed a Data Protection Officer (hereinafter “DPO”). The DPO appointed by:

3. TYPES OF PERSONAL DATA PROCESSED

Personal data means any information concerning and relating to the user. Specifically, processing may involve:

  • Personal data relating to browsing

When users access and browse the Website, Manifattura and Digital Boite generally collect browsing data through cookies or other tracking technologies, each within its respective remit. During their normal operation, the IT systems and software procedures used to operate the Website automatically acquire certain personal browsing data, the transmission of which is inherent in the use of Internet communication protocols. These are electronic traffic data which, by their nature, are not collected to be immediately associated with identified users, but which could enable users to be identified through processing or combination with data held by third parties. This category includes, for example, the IP addresses or domain names of the computers used to connect to the Website, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file returned in response, the numerical code indicating the status of the response provided by the server (successful, error, etc.), and other parameters relating to the user’s operating system and IT environment.

These data make it possible to check that the Website operates correctly and enable users to use the Services available on it, provide users with a better browsing experience, obtain anonymous, aggregated information on visits and compile statistical analyses, and, lastly, create profiles enabling advertising aligned with users’ expressed preferences to be sent, as well as identify anomalies and/or misuse. For further information on the processing of these data through cookies or other tracking systems, users are invited to consult section 5) on cookies below.

  • Personal data processed through tracking pixels

Tracking pixels are images, often transparent and very small, which are not contained directly in the e-mails received by users but are hosted on remote servers. They enable the sender to obtain information on whether a message has been opened and therefore viewed by a particular user or in a specific context, potentially including further information that may be derived from the recipient’s IP address, information on the type of device used, the time spent viewing the message and the number of subsequent openings of the same message.

Manifattura uses tracking pixels in its communications (e-mails relating to the loyalty programme, e-mails with informational, commercial and promotional content, and e-mails aligned with users’ interests). When tracking pixels are activated, Manifattura processes the following personal data: the e-mail opening event (date and time), the IP address of the e-mail recipient’s device (from which geographical information may be inferred indirectly), the user agent (type of e-mail client, operating system and device), browser information, the subscriber’s internal identifier and the number of times the same message is opened, in order to measure campaign performance (open rate and engagement), optimise deliverability (ensuring successful receipt), and assess and improve promotional campaigns by adapting the content of communications according to whether they have been opened.

  • Personal data voluntarily provided by users

The Controllers also process personal data voluntarily provided by users when interacting with the Services available on the Website. Specific privacy notices pursuant to Article 13 of the Regulation are published in certain sections of the Website where user data are collected (such as Careers, Newsletter and Loyalty Program); in all other cases, please refer to this document. The data voluntarily provided by users are:

  • first name, surname, nationality, residential address, shipping address, telephone number, e-mail address, information on the product selected and purchased, and information on the payment method selected (such as credit/debit card type, card number, expiry date, etc.) to purchase the selected product, comply with the related legal and contractual obligations and use the Omnichannel services. In the latter case, the order number and details of the user’s and/or an authorised representative’s valid identity document are also processed solely to verify their identity and hand over the purchased product;

  • first name, surname, e-mail address, telephone number, order number and any additional data provided when completing the request form or by telephone to request assistance or use customer care;

  • first name, surname, e-mail address and information on products previously purchased, for sending “soft spam” communications;

  • e-mail address, date of birth and information on biological sex, to enable newsletter subscription and the sending of communications with informational and promotional content;

  • first name, surname, date of birth, information on biological sex, telephone numbers, e-mail address, password and any further data provided when completing the profile to create a personal account;

  • first name, surname, e-mail address, date of birth and any further data provided when completing the personal profile (such as residential address, telephone number, favourite sport, number of household members and sex), cumulative overall spending, and information on purchases made (such as the product category, colour and size), for enrolment in the “Colmar Club Alta Quota” programme and the provision of personalised assistance and profiling;

  • first name, surname, place and date of birth, residence, citizenship, telephone numbers, e-mail address and any further data included in the curriculum vitae (such as education, professional experience, personal interests and photograph), cover letter and/or application form, including data revealing racial or ethnic origin and data concerning health, to submit a job application;

  • information collected through tracking pixels, such as the e-mail opening event (date and time), the IP address of the e-mail recipient’s device (from which geographical information may be inferred indirectly), the user agent (type of e-mail client, operating system and device), browser information, the subscriber’s internal identifier and the number of times the same message is opened, to measure campaign performance (open rate and engagement), optimise deliverability (ensuring successful receipt), provide anti-spam protection and security (identifying unusual activity), and assess and improve promotional campaigns by adapting the content of communications according to whether they have been opened;

  • information collected from clicks (i.e. interactions recorded when a user clicks a hyperlink in an e-mail), such as the subscriber’s internal identifier and the mailing identifier, the link clicked (URL and/or name assigned to the link), the date/time of the click, the device’s IP address and user agent, and total clicks and unique clicks, to measure the effectiveness of informational and promotional campaigns, including anonymously, and improve the services offered.

Hereinafter collectively the “Data”.

4. PURPOSES AND LEGAL BASES OF PROCESSING AND NATURE OF DATA PROVISION

The Data are processed for the following purposes:

  1. to enable browsing of the Website, monitor its proper operation and establish liability in the event of computer crimes, as well as improve the browsing experience, compile statistical analyses of Website visits and create profiles enabling advertising aligned with users’ expressed preferences to be sent (hereinafter “Website Browsing”). Processing by Manifattura is based on performance of a contract (Article 6(1)(b) of the Regulation), its legitimate interests (Article 6(1)(f) of the Regulation) and, with regard to improving the browsing experience, compiling statistical analyses and creating profiles, the user’s consent (Article 6(1)(a) of the Regulation);

  2. to process purchase orders for selected products, perform the contract entered into and comply with all related legal and contractual obligations, including administrative, accounting and tax obligations (hereinafter “Product Purchases”). Processing by Digital Boite is based on performance of a contract (Article 6(1)(b) of the Regulation) and compliance with related obligations (Article 6(1)(c) of the Regulation);

  3. to provide customer care, including handling any requests and/or complaints and returns (hereinafter “Customer Care”). Processing by the Controllers is based on taking steps at the user’s request prior to entering into a contract and performing a contract (Article 6(1)(b) of the Regulation);

  4. to send commercial and promotional e-mails concerning Colmar-branded products and services similar to those purchased, known as soft spam (hereinafter “Soft Spam”). Processing by the Controllers is based on the exemption provided for in Article 130(4) of Legislative Decree No. 196/2003 (hereinafter the “Privacy Code”);

  5. to enable newsletter subscription and send informational, commercial and promotional e-mails concerning Colmar-branded products, services and events (hereinafter “Marketing”). Processing by Manifattura is based on the user’s consent (Article 6(1)(a) of the Regulation);

  6. to analyse users’ interests, purchasing habits and tastes in order to personalise the products and services offered and send further communications aligned with their interests (hereinafter “Profiling”). Processing by Manifattura is based on the user’s consent (Article 6(1)(a) of the Regulation);

  7. to create a personal “My Account” profile and provide access to services reserved for registered users (hereinafter “Personal Area”). Processing by Manifattura is based on taking steps at the user’s request prior to entering into a contract and performing a contract (Article 6(1)(b) of the Regulation);

  8. to enrol and participate in the “Colmar Club Alta Quota” programme, create the relevant profile, manage closely related activities (such as granting discounts, benefits, experiences and dedicated special initiatives) and comply with all further legal and contractual obligations (hereinafter “Loyalty Program”), provided that the user resides and/or is domiciled in one of the territories specified in the programme rules. Processing by Manifattura is based on performance of a contract (Article 6(1)(b) of the Regulation) and compliance with related obligations to which it is subject (Article 6(1)(c) of the Regulation);

  9. to provide personalised assistance and advice when purchasing products at stores participating in the “Colmar Club Alta Quota” programme (hereinafter “Personalised Assistance”). Processing by Manifattura is based on its legitimate interests (Article 6(1)(f) of the Regulation);

  10. to use Omnichannel services (such as the “Delivery to Store” service, which enables users to purchase products online and collect them at their chosen store) (hereinafter “Multichannel”). Processing by the Controllers is based on taking steps at the user’s request prior to entering into a contract and performing a contract (Article 6(1)(b) of the Regulation);

  11. to verify that the purchaser is the holder of the selected payment method (hereinafter “Anti-Fraud Activities”). Processing by Manifattura is based on its legitimate interests (Article 6(1)(f) of the Regulation);

  12. to assess professional profiles and conduct any recruitment process aimed at establishing an employment or professional relationship (hereinafter “Recruitment”). Processing by Manifattura is based on taking steps prior to entering into a contract (Article 6(1)(b) of the Regulation and Article 111-bis of Legislative Decree No. 196/2003) and, for any special categories of data provided, the need to fulfil obligations and exercise specific rights of the user or Manifattura in the field of employment and social security and social protection law (Article 9(2)(b) of the Regulation);

  13. to exercise and defend the Controllers’ rights in any forum, including judicial and administrative proceedings, arbitration and/or mediation and conciliation procedures (hereinafter “Defence”). Processing by the Controllers is based on their legitimate interests (Article 6(1)(f) of the Regulation);

  14. to measure campaign performance, including through tracking pixels (hereinafter “Performance Measurement”). Processing by Manifattura is based on consent (Article 6(1)(a) of the Regulation and Article 122 of Legislative Decree No. 196/2003), together with the purpose referred to in point e) above;

  15. to optimise deliverability through tracking pixels (hereinafter “Deliverability”). Processing by Manifattura is based on consent (Article 6(1)(a) of the Regulation and Article 122 of Legislative Decree No. 196/2003), together with the purpose referred to in point e) above;

  16. to assess and improve a promotional campaign through tracking pixels in order to adapt communications based on which e-mails have been opened (“Campaign Optimisation”). Processing by Manifattura is based on consent (Article 6(1)(a) of the Regulation and Article 122 of Legislative Decree No. 196/2003), together with the purpose referred to in point e) above.

With the exception of browsing data (collected automatically), provision of the Data is:

  • mandatory for the purposes referred to in points a), b), c), d), g), h), i), j), k), l) and m). If users do not provide the Data marked with (*), Manifattura and/or Digital Boite will therefore be unable to fulfil their requests (for example, browse the Website, process product purchase orders and comply with legal and contractual obligations, handle requests and/or complaints, use the “Delivery to Store” service, or initiate the recruitment process). Failure to provide Data not marked with (*) does not prevent Manifattura and/or Digital Boite from fulfilling requests for the above purposes;

  • optional for the purposes referred to in point a), specifically compiling statistical analyses of Website visits, improving the user’s browsing experience and creating profiles enabling advertising aligned with expressed preferences to be sent. Failure to provide the Data therefore makes it objectively impossible for Manifattura to fulfil the relevant request, without affecting the remaining purposes in point a) above or those in points b), c), d), g), h), i), j), k), l) and m) above;

  • optional for the purposes referred to in points e) and f). Failure to provide the Data therefore makes it objectively impossible for Manifattura to send newsletters and informational, commercial and promotional communications or carry out profiling, without affecting the purposes in points a), b), c), d), g), h), i), j), k), l) and m) above;

  • optional for the purposes referred to in points n), o) and p). Failure to provide the Data therefore makes it objectively impossible for Manifattura to measure campaign performance, optimise deliverability, or assess and improve campaigns, without affecting the sending of loyalty programme e-mails, informational, commercial and promotional e-mails, and e-mails aligned with users’ interests.

5. COOKIES

The Website uses technical, functional, analytics and profiling cookies, including third-party cookies, to enable normal browsing and use of the Website, improve the browsing experience, compile statistical analyses and create profiles enabling advertising aligned with users’ expressed preferences to be sent. Further information on the characteristics of the cookies used on the Website is available in the Cookie Policy.

6. PROCESSING METHODS

For the purposes set out in section 4) above, the Data will be processed primarily by electronic and automated means, as well as on paper, in compliance with personal data protection legislation and using appropriate security measures.

The Data are processed by internal personnel of Manifattura and Digital Boite (employees, system administrators and any collaborators) who are specifically authorised, trained and instructed to ensure adequate security and confidentiality and prevent risks of loss and/or destruction and access by unauthorised parties.

7. DISCLOSURE OF DATA

The Data will not be publicly disseminated. Within the limits strictly relevant to the purposes set out in section 4) above, the Data may be disclosed to:

  • parties external to the Controllers which, as independent controllers or processors pursuant to Article 28 of the Regulation, are involved in processing the Data, including, for example, credit institutions, Internet providers, transport companies, marketing companies, companies responsible for IT infrastructure and its management and maintenance, the company responsible for system security and anti-fraud checks, the company managing the Website, tax advisers, the company managing the call centre and companies operating physical stores;

  • parties authorised by law or regulation, including, without limitation, public authorities and judicial authorities.

An updated list of processors may be requested from the Controllers by e-mail at infoedatabreach@mmcol.it and privacy@digitalboite.com.

8. DATA RETENTION PERIOD

The Controllers retain the Data for the time strictly necessary to achieve the respective purposes for which they were collected. Specifically, Data processed for the purpose of:

  • Website Browsing: will be retained for no more than 7 (seven) days from collection and, specifically for Data processed through cookies or other tracking systems, for the period expressly indicated in the Cookie Policy;

  • Product Purchases: will be retained throughout the relationship and, in any event, until the limitation periods for rights arising from that relationship have expired;

  • Customer Care: will be retained for the time strictly necessary to achieve the purpose;

  • Soft Spam: will be retained until the user exercises the right to object;

  • Marketing: will be retained for 24 (twenty-four) months from collection;

  • Profiling: will be retained for a maximum of 12 (twelve) months from collection;

  • Personal Area: will be retained until the user requests closure of the profile, which may be done at any time;

  • Loyalty Program and Personalised Assistance: will be retained throughout the user’s participation in the “Colmar Club Alta Quota” programme and, in any event, until the limitation periods for rights arising from that relationship have expired;

  • Multichannel: will be retained for the time strictly necessary to complete all activities connected with providing the service requested by the user;

  • Recruitment: will be retained for one year from collection;

  • Defence: will be retained throughout the dispute and until the time limits for any appeal and/or the limitation period for the relevant action have expired;

  • Performance Measurement: will be retained for a maximum of 6 (six) months from collection;

  • Deliverability: will be retained for a maximum of 6 (six) months from collection;

  • Campaign Optimisation: will be retained for a maximum of 6 (six) months from collection.

This is without prejudice to the right to withdraw consent for processing based on consent, the right to object to processing and compliance with specific statutory retention obligations.

9. DATA SUBJECT RIGHTS

With regard to the Data, users have the right to request the following from Manifattura and Digital Boite, in accordance with the Regulation and subject to the provisions and limitations of the Privacy Code (Part I - Title I - Chapter III):

  • access, where applicable (Article 15 of the Regulation);

  • rectification of inaccurate data and completion of incomplete data (Article 16 of the Regulation);

  • erasure of data, where applicable (Article 17 of the Regulation), for example when they are no longer necessary for the purposes indicated above or are not processed in compliance with the Regulation;

  • restriction of processing in the circumstances provided for (Article 18 of the Regulation), such as where the accuracy of the data is contested and needs to be verified;

  • portability, namely the right, where applicable (Article 20 of the Regulation), to receive the data in a structured, commonly used and machine-readable format and transmit those data to another controller;

  • objection to processing, where applicable (Article 21 of the Regulation).

Users also have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, unless they have given prior explicit consent (Article 22 of the Regulation). By way of non-exhaustive example, this category includes any form of automated processing of personal data aimed at analysing or predicting aspects relating to consumption and purchasing choices, economic situation, interests, reliability and behaviour.

Where processing is based on consent, users also have the right to withdraw it at any time, through simple, free and granular means, without affecting the lawfulness of processing carried out before withdrawal.

All the rights listed above may be exercised by sending:

  • Manifattura an e-mail at infoedatabreach@mmcol.it or a registered letter to its address: Via Olimpia, 3 - 20900 - Monza (MB);

  • Digital Boite an e-mail at privacy@digitalboite.com or a registered letter to its address: Via Cusani, 5 - 20121 - Milano (MI).

In both cases, users must specify their first name, surname, any purchase code, details of the request and contact details.

Furthermore, to stop receiving newsletters and commercial and promotional communications and/or disable tracking pixels, simply click the “Unsubscribe” button at the bottom of each communication.

10. COMPLAINTS

If users consider that the processing infringes the Regulation, they have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) pursuant to Article 77 of the Regulation.

11. TRANSFERS OF DATA TO THIRD COUNTRIES

To provide the Services, the Data may be transferred to third countries. In such cases, the Controllers undertake to ensure that transfers to those countries comply with the Regulation and, specifically, are subject to appropriate safeguards (adequacy decisions, standard contractual clauses approved by the European Commission, etc.). Further information may be requested from the Controllers at infoedatabreach@mmcol.it and privacy@digitalboite.com.

Last updated: October 2026

NEWSLETTER

Policy regarding the processing of personal data, in accordance with Article 13 of European Regulation no. 2016/679

Pursuant to Art. 13 of European Regulation no. 2016/679 (hereinafter "Regulation"), we are providing the following information relating to the processing of personal data that you provide us with for the purposes of sending communications containing information and promotional and/or advertising content about our products, services and events.

1. Data Controller

The Data Controller is Manifattura Mario Colombo & C. S.p.A. (Tax code. 00763670155 and VAT no. 00691110969), with registered office in Monza, Via Olimpia no. 3; email address: infoedatabreach@mmcol.it; PEC email address: amministrazionemmc@legalmail.it (hereinafter referred to as the "Company").

2. Data Protection Officer

The Data Protection Officer appointed by the Company can be contacted by sending an email to dpo@mmcol.it (hereinafter referred to as "DPO").

3. Personal Data

Personal data is any information about you that can be traced back to you. Specifically, the processing will involve the following data: name, surname, email address, DOB, country and biological sex (hereinafter “Data”).

4. Processing Purpose

Your data will only be used for the purposes of sending communications containing information and promotional and/or advertising content about our products, services and events.

5. Legal Basis of Processing

The legal basis for the processing of your data for the purposes indicated in paragraph 4) lies in the express consent you have provided, pursuant to Article 6.1, let. a) of the Regulation, by actively selecting the “Subscribe/Send” button.

6. Processing methods

With regard to the purposes outlined in section 4) above, and in compliance with the principles of lawfulness, correctness, transparency, accuracy and relevance, and without excessive processing, your data will be processed by electronic means, in compliance with legal provisions regarding the processing of personal data, and appropriate security measures shall be adopted. The processing of your data will be carried out by specially trained and instructed personnel to ensure adequate security and confidentiality, and to avoid the risk of loss and / or destruction and access by unauthorised individuals.

7. Disclosure and Sharing of Data

Your data will not be disclosed. Within limits applied strictly to the purpose outlined in section 4) above, your data may be disclosed to specially designated persons within the Company who carry out activities linked to and instrumental to the sending of Company communications containing information and promotional and/or advertising content (for example, sales personnel, staff working in the marketing department, etc.). Where necessary to carry out activities relating to the management and maintenance of computer systems and the website, Data may be processed by the subjects/entities in charge, which have been specifically appointed as Data Processors.

8. Data Retention Period

Your Data will be stored until you revoke your consent. This includes unsubscribing in the manner referred to in section 9) below.

9. Rights of the Data Subject

With regard to your data, you have the right to ask the Company, in the ways specified by the Regulation and without prejudice to the provisions and limitations of Legislative Decree no. 196/2003 (Part I - Title I - Chapter III), to:

  • access it in cases provided for by the Regulation (Art.15);
  • have inaccurate data rectified and incomplete data supplemented (Art. 16 of the Regulation);
  • have data deleted for reasons provided for by the Regulation (Art. 17), such as when they are no longer necessary for the purposes outlined above or are not processed in accordance with the Regulation;
  • limit data processing based on scenarios provided for by the Regulation (Art. 18), such as when the accuracy of the data is contested and needs to be verified;
  • You also have the right to portability, i.e. the right to receive data, in cases provided for by the Regulation (Art. 20), in a structured, commonly used and machine-readable format, and to have said data transmitted to another Data Controller;
  • and to oppose to data being processed in cases provided for by the Regulation (Art. 21).

In relation to the purpose referred to in section 4) above, you also have the right to revoke your consent at any time without prejudice to the lawfulness of processing carried out before withdrawal of consent. You may exercise any of the rights listed above by sending an email to the Company (infoedatabreach@mmcol.it) or by registered letter to the Company's address: Monza, Via Olimpia no. 3. Also, if you no longer wish to receive communications from the Company containing information and promotional and/or advertising content, you can click on the link at the bottom of each communication, or send an e-mail to infoedatabreach@mmcol.it, with "Cancel subscription" in the subject line.

10. Complaints

If you believe that the processing of your data contravenes the provisions set out in the Regulation, you have the right to complain to the Italian Data Protection Authority, in accordance with Art. 77 of the Regulation.

11. Nature of Data Provision

The provision of your personal data is required to enable us to send communications containing information and promotional and/or advertising content about our products, services and events. Failure to provide even certain parts of your data will make it objectively impossible to send these communications.

12. Transferring Data Abroad

Your Data will not be transferred abroad and is stored at the Company's registered office and on servers located within the European Union. The Company also uses cloud services provided by third country companies recognised as adequate in terms of security by the European Commission, in accordance with Art. 45.3 of the Regulation.

Membership of and participation in the “Colmar Club Alta Quota” program in the ways described in the “Regulations of the Loyalty Program - Colmar Club Alta Quota” entails the processing of the personal data of customers by Manifattura Mario Colombo & C. S.p.A.. Pursuant to art. 13 of EU Regulation no. 2016/679, Manifattura Mario Colombo & C. S.p.A. gives the following information on the personal data provided.

1. Data Controller

The Data Controller is Manifattura Mario Colombo & C. S.p.A. (Tax number 00763670155 and VAT Reg. no. 00691110969), registered office Via Olimpia 3,Monza, e-mail infoedatabreach@mmcol.it, Certified email amministrazionemmc@legalmail.it (hereinafter “Company”).

2. Data Protection Officer

The Data Protection Officer appointed by the Company may be contacted by sending an email to the address dpo@mmcol.it (hereinafter “DPO”).

3. Personal Data

Personal data means any information that can be referred to the customer. Specifically, the processing will concern the following data:

  • - First name, surname, email address, date of birth and any further information provided through filling in the personal profile (such as, for example, address, telephone number, favourite sport, number of members of the household and gender);
  • - Total amount progressively spent, as well as the information related to the purchases made by the customer (such as, for example, the category of goods of the product purchased, the colour and the size);

4. Purposes of the processing

Your data will only be used for the purposes of sending communications containing information and promotional and/or advertising content about our products, services and events.

  • a. Membership of and participation in the “Colmar Club Alta Quota” program and creation of the personal profile;
  • b. Management of the obligations closely connected with the membership of and participation in the “Colmar Club Alta Quota” program, such as the attribution of discounts, advantages, experiences and special dedicated initiatives;
  • c. Fulfilment of the legal and contractual obligations connected with participation in the “Colmar Club Alta Quota” program, also including those of an administrative character;
  • d. Inclusion and/or updating of the names of the customers of the “Colmar Club Alta Quota” program;
  • e. Sending communications with informative content and closely connected with the “Colmar Club Alta Quota” program (such as, by way of example and not exhaustively, the welcome letter, notification of reaching and going past the levels, etc.);
  • f. Registration for the Company’s newsletter and sending communications with informative and promotional content on the products of the Colmar brand, services and events;
  • g. Analysis of the interests, of the purchasing habits and tastes of the customer to allow the Company to personalize the offer of its products and services, as well as to send further communications in line with the customer’s interests;
  • h. Assistance and personalized advice during the purchase of products in the stores belonging to the “Colmar Club Alta Quota” program;
  • i. Exercise and defence of the Company’s rights in every seat, including judicial and administrative, in arbitration and/or mediation and reconciliation procedures.

5. Lawfulness of the processing

The processing of the Data for the purposes shown in point 4) above is lawful:

  • - As for letters a), b), c) and e) in the execution of the contract (art. 6.1 b) Regulation), as well as in the compliance with obligations connected with it to which the Company is subject (art. 6.1 c) Regulation);
  • - As for letters d), h) and i) in the legitimate interest of the Company (art. 6.1 f) Regulation);
  • - As for letters f) and g) in the consent expressed by the customer (art. 6.1 a) Regulation).

6. Methods of processing

As part of the purposes shown in point 4) above, the processing of the Data will take place using electronic and automated instruments, in the respect of the legislation on the processing of personal data, adopting the appropriate safety measures. The processing of the Data will be carried out by personnel who perform activities that are connected with and instrumental to the management of the “Colmar Club Alta Quota” program (such as, for example, the sales assistants in the stores, the administrative personnel, the personnel of the marketing department and the IT department), who are specially authorized, trained and instructed, in order to guarantee the appropriate security and confidentiality, as well as in order to avoid risks of loss and/or destruction and access by unauthorized subjects.

7. Communication and diffusion of the Data

The Data will not be diffused. Within the limits strictly pertinent to the purposes shown in point 4) above, the Data may be communicated to :

  • - subjects legitimates pursuant to law or regulation, such as by way of example the competent public authorities and the judicial authority;
  • - subjects specifically appointed Data processing managers (natural persons or companies that process data on the documented instruction of the Company such as, by way of example, the subject that manages and maintains the IT systems, as well as the website and the CRM - Customer Relationship Management - system, companies which manage the points of sale where the “Colmar Club Alta Quota” program is active). The updated list of names of the Processing Managers can be requested from the Company, by sending an email to infoedatabreach@mmcol.it.

8. Period of storage of the Data

The Data will be stored for the period of time strictly necessary for the pursuit of the purposes for which the aforementioned Data have been collected. Specifically, the Data processed:

  • - For the purposes as per point 4) letters a), b), c), d), e) and i) above, will be kept for the entire duration of the participation in the “Colmar Club Alta Quota” program and, in any case, until the rights deriving from the relationship reach the limitation period. Cancellation of the “Colmar Club Alta Quota” program will allow the customer, in any case, to keep their personal profile active until its closure is explicitly requested;
  • - For the purposes as per point 4) letter f) above, the data will be kept until the revocation of consent;
  • - For the purposes as per point 4) letter g) above, they will be kept for a maximum period of 12 (twelve) months from the date on which they were collected;
  • - For the purposes as per point 4) letter h) above, they will be kept for a maximum period of 12 (twelve) months from the date on which they were collected.

Without prejudice, however, to the right of opposition to processing, the right of revocation of the consent for those types of processing which are lawful, to be exercised according to the methods better described in point 9) below, as well as compliance with specific obligations of storage according to law and the exercise of the right of defence of the Company in the event of dispute.

9. Rights of the data subject

With reference to the Data, the data subject has the right to ask the Company with the ways shown by the Regulation and without prejudice to the provisions and limitations as per Legislative Decree no. 196/2003 (Part I - Chapter I -Section III):

  • Access, in the cases foreseen (art. 15 Regulation);
  • The correction of inexact Data and the completion of incomplete Data (art. 16 Regulation
  • The cancellation of the Data for the reasons considered (art. 17 Regulation) such as for example whey they are no longer necessary with respect to the purposes shown above or are not processed in the respect of the Regulation;
  • The limitation of treatment for the hypotheses considered (art. 18 Regulation), as in the case in which the exactness of the Data is contested and their correctness has to be checked;
  • Portability, i.e. the right to receive the Data, in the cases foreseen (art. 20 Regulation), in a structured form of common use and legible by an automatic device and to transmit the aforementioned Data to another Data Controller;
  • Opposition to the processing, in the cases foreseen (art. 21 Regulation).

In relation to the purposes as per point 4) letters f) and g) above, the right is also recognized to revoke consent, at any time whatsoever and without prejudicing the lawfulness of the processing done before being revoked. All the rights listed above may be exercised by sending to the Company an email to the address infoedatabreach@mmcol.it or by registered letter to the address of the Company: Via Olimpia n. 3, Monza. In addition, in order to no longer receive communications from the Company with an informative and promotional content on products with the Colmar brand, services and events, it will be possible to cancel registration by clicking on the appropriate link at the bottom of each communication.

10. Complaint

In the case that the processing of the Data infringes the provisions in the Regulation, there is the right to file a complaint with the Supervisory Authority for the protection of personal data according to the provisions of art. 77 of the Regulation.

11. Provision of personal data

Provision of the Data is compulsory and is strictly necessary for the pursuit of the purposes shown in point 4) letters a), b), c), d), e) and i) above. Therefore, failure to provide, including only partially, the Data entails the objective impossibility of participating in the program and satisfying what is requested. The provision of the Data shown as optional in the personal profile (such as, for example, address, telephone number etc.) as well as of the Data for the pursuit of the purposes as per point 4) letters f), g) and h) above, is, on the other hand, optional. However, failure to provide, including only partially, the Data entails the objective impossibility for the Company to proceed with registration for the newsletter, with the analysis of interests, habits and tastes, as well as the activity of personalized advice and assistance, but without prejudicing the participation in the “Colmar Club Alta Quota” program.

12. Transfer of Data abroad

The Data are stored at the registered office of the Company and on servers located in the European Union. In the event that the Data have to be transferred to countries not belonging to the European Union, the Company undertakes to ensure that this transfer takes place in the respect of the adequate guarantees for the protection of the Data, according to the provisions of articles 46 and 47 of the Regulation.

In the event of a breach of personal data, Manifattura Mario Colombo & C. has set up a crisis team and provided for specific intervention procedures, in order to swiftly resolve the problem and alert the user so that he or she can adopt suitable precautions to reduce to a minimum the potential damage that may caused by the breach.


The information provided to users in the event of a breach will specifically indicate:

  • the name and contact data of the Data Protection Officer, or any other contact that can provide information;
  • the measures adopted or proposed by the Legal Representative to remedy the breach of personal data and, if appropriate, to limit the possible negative effects.

Manifattura Mario Colombo & C. will issue a public communication, or take similar measures, and will not be obliged to inform the user if adequate technical and organisational measures are implemented to protect the data affected by the breach, if measures are subsequently adopted to prevent the user’s rights being placed at high risk again, or when the communication would require a disproportionate effort. In any case, Manifattura Mario Colombo & C. will consider whether it is opportune - even if it is not strictly compulsory - to keep the user informed.

Where necessary, Manifattura Mario Colombo & C. will also inform the Data Protection Authority of the breach within 72 hours.

For this reason, if a breach comes to the attention of a Data Processor, or another processor appointed thereby, he or she must notify the violation, within 12 and 24 hours respectively of discovery.

Any breaches of personal data may be notified by writing to infoedatabreach@mmcol.it.