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Information on the processing of personal data.

(Articles 13 and 14 EUROPEAN REGULATION No. 679/2016)


The following information is intended for all persons visiting and interacting with this e-commerce website of the company THE CLUB S.R.L., where it is possible to purchase products online

Dear Navigator,

THE CLUB S.R.L., with registered office in Via del Seminario 113, 00186 Rome (RM), Tax Code and VAT number 02901600904, in its capacity as “Data Controller” hereby informs you, pursuant to articles 13 and 14 of the European Regulation no. 679/2016 (hereinafter “EU Regulation”), that your data will be processed in accordance with the following:

1. Purpose of the Processing

The Data Controller hereby informs you that the personal, identifying data (e.g. name, surname, company name, address, telephone number, e-mail, bank and/or payment references, etc.), hereinafter referred to as “personal data” or also simply “data”, relating to you, acquired even verbally directly or through third parties in the past, as well as those that will be collected in the future, may be processed in full compliance with the EU Regulation. The Data Controller shall carry out the processing in a lawful manner specifically for the performance of a contract to which you are a party or for the performance of pre-contractual measures (e.g. preparation of an offer, etc.) requested by you (Art. No. 6 of the EU Regulation).

Data processing means any operation or set of operations concerning the collection, recording, organisation, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, destruction of data.

2. Legal basis and Purpose of processing

Legal basis: EU Regulation No. 679/2016

A) without your express consent (Art. 6 lett. b), c), e) of the EU Regulation), for the following Purposes:

– in order to manage access to the services of the e-shop and to facilitate the purchase of products online as well as to allow your registration to the e-shop and the possible conclusion of the purchase contract through the e-shop;

– fulfil pre-contractual, contractual and fiscal obligations arising from existing relations with you

– allow you to access the e-shop, even as a non-logged-in user, and to browse the e-shop

– allow you to register on the Site, by creating an account, and to take advantage of the services reserved for registered users, including, in particular, the possibility of purchasing through the e-shop

– allow you to access and browse the e-shop as a logged-in user;

– maintaining and managing your account;

– store data and information in your account, such as, but not limited to, your personal details, your order history and any returns, your preferred delivery and/or billing addresses

– to enable you to put products in your shopping cart and to conclude the purchase contract via the e-shop.

– to execute the obligations arising from the purchase contract concluded through the e-shop, such as, for example, the delivery of the products sold;

– to allow you to fulfil your obligations arising from the purchase contract concluded through the e-shop, such as, for example, the payment, also online, of the products purchased;

– for general assistance and customer care activities and therefore to respond to requests for information from users or to respond to complaints, reports and disputes

– to comply with obligations provided for by law, regulation, Community legislation or a order of the Authority (such as anti-money laundering);

– to exercise the rights of the data controller, such as the right of defence in court;

– for general accounting purposes

– for management purposes (invoicing, possible document management, etc.);

– for credit management;

– for statistical analysis and quality control;

– for insurance management;

– for technical assistance.

In particular, your data will be processed for purposes connected with the implementation of the following fulfilments, relating to legislative or contractual obligations:

– Technical and Functional access to the Site no data is kept after closing the Browser;

– Evolved browsing purposes or customised content management;

– Statistical Purposes and Analysis of navigation and users.

B) Only with your specific and distinct consent (art. 7 of the EU Regulation), for the following commercial and/or marketing and/or profiling purposes

– sending via e-mail, mail and/or sms and/or telephone contacts of newsletters, commercial communications and/or advertising material on products or services offered by the Data Controller and/or detection of the degree of satisfaction on the quality of what has been carried out on your request

– sending via e-mail, post and/or sms and/or telephone contacts of commercial and/or promotional communications of third parties (e.g. business partners).

3. Modalities of processing

The processing of your personal data is carried out by means of the operations indicated in Article 4 no. 2) of the EU Regulation, namely: collection, recording, organisation, structuring, storage, adaptation or alteration, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, restriction, erasure or destruction, blocking. Your personal data are subject to both paper and electronic and/or automated processing (in any case suitable to guarantee the security and confidentiality of the data).

4. Data retention periods and other information.

The Data Controller shall process personal data for the time necessary to fulfil the purposes set out above and in any case for no longer than the legal terms from the termination of the relationship for the Purposes set out in the existing relationship (e.g.: the data necessary for the execution of the purchase contract until the delivery of the product or, in case of non-delivery, until the termination of the contract).

With reference to personal data subject to Processing for Marketing Purposes or Processing for Profiling Purposes, the same shall be retained in compliance with the principle of proportionality and, in any case, until the Purposes of the processing have been pursued or until the data subject withdraws his/her specific consent.

Specifically, the Data Controller will process the data for no longer than 2 years from the collection of the data for Marketing Purposes and one year for data collected for Profiling Purposes.

The personal data you provide will be processed “lawfully, fairly and transparently”, protecting your confidentiality and your rights.

A periodical check will be carried out once a year on the data processed and on the possibility of their deletion if they are no longer necessary for the intended purposes.

5. Access to data

Your data may be made accessible for the purposes referred to in points 2.A) and 2.B) above

– to partners, employees and collaborators of the Data Controller in Italy and abroad, in their capacity as persons in charge and/or internal processors and/or system administrators

– to third party companies or other entities that perform outsourcing activities on behalf of the Data Controller, in their capacity as external data processors (by way of example: law firms, lawyers, data processing companies, certifying bodies, accounting/fiscal consultants and in general to all the bodies responsible for audits and controls regarding the proper fulfilment of the purposes indicated above, credit institutions, professional firms, consultants, insurance companies for the provision of insurance services, financial offices, Municipal Authorities and/or Municipal Offices, to consultants and service and safety companies, who may in turn disclose the data, or grant access to them, to their own members, users and their assignees for specific market research purposes. The data collected and processed may also be disclosed, in Italy and abroad, to subcontractors, suppliers, for the management of information systems, to carriers, forwarding agents and customs agents).

For the sake of brevity, a detailed list of these figures is available at our offices and is at your disposal.

6. Communication of data

Without the need for your express consent (Art. 6 letters b) and c) of the EU Regulation), the Data Controller may disclose your data for the purposes set out in point 2.A) above to supervisory bodies, judicial authorities, insurance companies for the provision of insurance services, as well as to those subjects to whom disclosure is required by law for the fulfilment of the above-mentioned purposes.

These subjects will process the data in their capacity as autonomous data controllers.

During and after navigation your data may be communicated to third parties, in particular to:

– Google: Advertising service, Advertising targeting, Analytics/Measurement, Content customisation, Optimisation;

– Google AdWords: Advertising service, Advertising targeting, Analytics/Measurement, Content customisation, Optimisation;

– Google Analytics: Advertising targeting, Analytics/Measurement, Optimisation.

Your data will not be disclosed.

7. Data transfer

Personal data are stored on devices located at the Data Controller’s premises or at providers within the European Union. It is in any case understood that the Data Controller, should it become necessary, will have the right to move the data to countries outside the EU. In this case, the Data Controller assures as of now that the transfer of data outside the EU will take place in compliance with the applicable legal provisions, subject to the stipulation of contractual clauses and standard checks provided for by the European Commission.

Both with regard to the data present on its own devices and to any data present at providers, the Data Controller has put in place adequate technical and organisational measures to ensure an appropriate level of security, in full compliance with Article 32 of the EU Regulation.

Browsing: Your browsing data may also be transferred, limited to the above-mentioned purposes, to the following states – EU countries, – United States.

Managing cookies: If you have any doubts or concerns about the use of cookies, you can always take action to prevent cookies from being set and read, e.g. by changing the privacy settings in your browser to block certain types of cookies.

Since each browser, and often different versions of the same browser, also differ considerably from one another, if you prefer to do this yourself via your browser preferences, you can find detailed information on the necessary procedure in your browser’s help file.

8. Nature of provision of data and consequences of refusal to answer

The provision of data for the purposes set out in point 2.A) above is mandatory. In their absence, we will not be able to guarantee the Services as indicated in point 2.A) above (e.g.: failure to provide data will therefore make it impossible for the user to conclude the contract and therefore to purchase through the e-shop).

On the other hand, the provision of data for the purposes set out in point 2.B) above is optional. You may therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material and/or anything else related to the Services offered by the Data Controller.

However, you will continue to be entitled to the Services referred to in point 2.A).

9. Rights of the data subject

In your capacity as data subject, you have the rights set out in Article 15 of the EU Regulation below, namely

1. you have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning you are being processed and, if so, to obtain access to the personal data and the following information: 

a) the purposes of the processing;

b) the categories of personal data concerned

c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular if they are recipients in third countries or international organisations

d) where possible, the proposed period of retention of the personal data or, if this is not possible, the criteria used to determine that period

e) the existence of the right of the data subject to request from the controller the rectification or erasure of personal data concerning him or her or to object to the processing of personal data concerning him or her;

f) the right to lodge a complaint with a supervisory authority (the Data Protection Authority);

g) where the data are not collected from the data subject, all available information on their source;

h) the existence of an automated decision-making process, including profiling as referred to in Article 22 (1) and (4) of the EU Regulation, and, at least in such cases, meaningful information on the logic used, as well as the importance and the expected consequences of such processing for the data subject.

2. If your personal data is transferred to a third country or an international organisation, you have the right to be informed of the existence of adequate safeguards within the meaning of Article 46 of the EU Regulation relating to the transfer.

3. The Data Controller will provide you with a copy of your personal data being processed if you request it.

If you request further copies, the Data Controller may charge you a reasonable fee based on administrative costs. If you make your request by electronic means, and unless you indicate otherwise, the information will be provided to you in a commonly used electronic format.

4. The right to obtain a copy referred to in paragraph 3 must not infringe the rights and freedoms of others.

Furthermore, where applicable, you may enjoy the rights set out in Articles 16 to 22 of the EU Regulation, namely you have:

– the right to rectification of personal data;

– the right to be forgotten (right to erasure);

– the right to restriction of processing;

– the right to data portability;

– the right to object;

– the right to complain to the Supervisory Authority.

You also have the right to revoke at any time any consent already given without affecting the lawfulness of the processing based on the consent given before revocation.

10. Procedures for exercising rights

You may exercise your rights at any time by sending

– a registered letter with acknowledgement of receipt to the writer (see address on the letterhead);

– an e-mail to

11. Minors

What is offered by the Data Controller and the subject of the relationship with you in being does not provide for the intentional acquisition of personal information relating to minors. In the event that information on minors is unintentionally recorded, the Data Controller will delete it in a timely manner at the request of the data subject.

12. Personal data not obtained from the data subject

It may happen that the writer is not the data controller to whom you have given your personal data, but appears to be a co-processor or external data processor and that your data has therefore come to the writer as a result of a contract between the parties. In this case, please note that the writer will make every effort to ensure that you have been informed and have given your consent to the processing. You may at any time ask the writer about the origin of the acquisition of your data.

13. Owner and responsible persons

Below we provide you with some information that it is necessary to bring to your attention, not only to comply with legal obligations, but also because transparency and fairness towards our customers is a fundamental part of our activity.

Data Controller. The Data Controller of your personal data is THE CLUB S.R.L. p.iva 02901600904, with registered office in Via del Seminario 113 – 00186 – Rome (RM), on behalf of the legal representative, who is responsible to you for the legitimate and correct use of your personal data and whom you can contact for any information or request at the following addresses: telephone +39 06 6783699, e-mail:, pec:

Data Processors. The updated list of data processors is kept at the Data Controller’s head office.