Privacy Policy

At Clementoni S.p.A. we value the privacy of our users. That’s why we do all we can to safeguard it and are fully committed to using the utmost attention and discretion when processing personal data. We are also aware that children and children’s games are at the core of our business. That is why we adopt proper measures to ensure the security and confidentiality of the personal data we collect, in accordance with applicable laws. This privacy information notice explains how we process the personal data of users of our website (www.clementoni.it). It also explains our procedures and purposes for collecting such data, as well as how we use and process the information, in accordance with Articles 13 and 14 of the General Data Protection Regulation (Regulation (EU) 2016/679 – GDPR).

Data Controller

The Data Controller is Clementoni S.p.A. with registered office in Recanati, Zona industriale Fontenoce, VAT no. 00092380435, referred to below as “Clementoni” or “Controller”.

Categories of data processed

It is not necessary to register or provide personal data to visit our website.

On the other hand, those intending to access the private area “MyClem” and related sections (“MyClem” and “Competitions Area”) are required to register and provide personal data.

Data Subjects may also provide their personal data when applying for jobs in the “Job Opportunities” section or when asking our Support Service for information and assistance.

The following types of data are processed by Clementoni through our website:

registration in the “MyClem” area: the user’s contact details (first name, surname, email address, password) and system logs, cookies, IP address;
request for delivery of “Triops” (dedicated section in “MyClem” area): in addition to the data provided in point a., data concerning the delivery address for the “Triops”;
competition area (dedicated section in “MyClem” area): in addition to the data provided in point a., data concerning the delivery address for the prizes; further data necessary for the purposes of the competition, such as image data;
purchase of refills: the user’s contact details (first name, surname, email address) and system logs, cookies, IP address, data concerning the delivery address for materials, invoicing data, data concerning payment procedures;
“My Frame me up”: User’s personal and contact details (first name, surname, e-mail), image data, system log, cookies, IP address, product shipping address details, invoicing details, details of payment method;
“Job Opportunities” area: contact details of applicants, photographs, data about education, training and career paths, membership of protected categories, further data provided by applicants of their own accord in their CVs;
Customer Support: contact details.

Legitimation of the provision of data

Please note that only users aged 16 or over can register in the “MyClem” area, access a registered account and, generally, provide personal data through our website.

Personal data relating to children under the age of 16 may be provided with the consent of a parent, guardian or other authorised person , in accordance with article 8 of the GDPR.

Clementoni S.p.A. declines all responsibility for cases in which the user provides data that is incorrect, untrue, or relates to third parties, including minors, for which the user has no lawful permission and/or is not expressly authorised to provide and consent to the processing thereof. The user accepts full responsibility for such conduct.

Cookies

This website uses certain types of cookies. To find out more, please consult the full cookie notice at the following link: https://www.iubenda.com/privacy-policy/994636/cookie-policy.

Purposes of the processing and legal basis

Provision of the above-mentioned personal data is always optional and they will be processed for the following purposes:

Registration in the “MyClem” area:

enabling users to get the most out of their Clementoni products in the reserved access area and dedicated sections (“MyClem”, “Competition Area”) – Purpose 1;
using the data processed for statistical and profiling purposes, for developing, maintaining and improving products and and our services, as well as for sending information, notifications and sales offers – Purpose 2.

The above-mentioned types of processing are based on user consent (Article 6(1)(a) of the GDPR), to be provided separately for each purpose, through the electronic form displayed during registration.

The user has the right to revoke consent at any time without compromising the lawfulness of the processing carried out prior to such revocation. For the methods for exercising the right to revocation, see the section on “Exercise of the rights of the Data Subject”.

Refusal on the part of the Data Subject to provide personal data, failure to consent to Purpose 1, or revocation of that consent, will make use of the “MyClem” area and its related sections impossible.

Consent for Purposes 2 and 3 is optional and, if not given or later revoked, will not affect the right to access the “MyClem” area.

Request for delivery of “Triops” (dedicated section in “MyClem” area):

handling the delivery of the “Triops” product after purchase by the customer – Purpose 3.

This information needs to be processed for Clementoni’s contractual obligations towards its customers resulting from the latter’s purchase of the product (Article 6(1)(b) GDPR).

Competition area (dedicated section in “MyClem” area):

ascertaining the winner and handling the delivery of prizes – Purpose 4.

This information needs to be processed for Clementoni’s contractual obligations towards the winners of competitions (Article 6(1)(b) GDPR) and those resulting from applicable legislation on prize competitions (Article 6(1)(c) GDPR)

Purchase of refills:

handling purchase transactions, payments and deliveries of refills – Purpose 5.

This information needs to be processed for the contractual obligations between Clementoni and its customers (Article 6(1)(b) GDPR).

“My Frame me up” Area:

manage the “My Frame me up” product purchase transaction, payment and shipping - Purpose 5.
use the data to send information, notifications and sales offers relating to the product and to other products in the Puzzles range - Purpose 6.

The first set of processing is necessary for correct fulfilment of the contractual obligation (Art. 6(1)(b) GDPR), for compliance with legal obligations laid down by current statutory and fiscal regulations (Art. 6(1)(c) GDPR) and for a legitimate interest pursued by the Controller in a legal defence (Art. 6(1)(f) GDPR).

The second processing is based on the consent of the User (art. 6(1)(a) GDPR), to be expressed on the specific electronic form displayed in the specific section.

The User has the right to withdraw consent at any moment, without affecting the lawfulness of processing based on consent before its withdrawal. See the section “Exercising of the rights of the data subject” for the methods of exercising the right of withdrawal.

It will not be possible to process the data for the aforesaid purposes if the data subject refuses to provide the personal data, does not provide consent or withdraws it.

“Job Opportunities” area:

handling of job applications - Purpose 6.

This type of processing is based on user consent (Article 6(1)(a) GDPR), to be granted through the electronic form displayed when the data is being provided.

Refusal on the part of the Data Subject to provide personal data, failure to provide consent, or revocation of that consent, will make it impossible to process the date for the aforesaid purpose.

Customer Support:

handling of customer requests - Purpose 7.

This type of processing is based on user consent (Article 6(1)(a) GDPR), to be granted through the electronic form displayed when the data is being provided.

Refusal on the part of the Data Subject to provide personal data, failure to provide consent, or revocation of that consent, will make it impossible to process the date for the aforesaid purpose.

Period for which personal data is stored

The personal data will be stored for the following periods:

registration in the “MyClem” area: 2 years from the date of the last access to the “MyClem” area.
request for delivery of “Triops” (dedicated section in “MyClem” area): 10 years from the date of delivery of “Triops”;
competition area (dedicated section in “MyClem” area): deadline for storage set out in applicable prize competition legislation;
purchase of refills: 10 years from the date of delivery of the refills;
“My Frame me up” area: 6 months from upload for the original image placed in the cart without placing an actual order; two years from the order for the original image; ten years from the product shipment date;
“Job Opportunities” area: period necessary for the selection of applicants and, at the latest, two years from the date of application;
Customer Support: 10 years from the end of the individual support request.

At the end of these periods, all data, including the user’s “MyClem” account, will be deleted.

Disclosure of data

The personal data may be disclosed to outside subjects, duly appointed processors (art. 28 of the GDPR), who process the data on behalf of Clementoni S.p.A.

In particular, the data processed through our website are disclosed to:

Beesoft.it S.r.l., with registered office at Via San Giovanni Scafa, 7 - 63074 San Benedetto del Tronto (AP) – Italy (https://www.iubenda.com/privacy-policy/813188/cookie-policy?an=no&s_ck=false), which assists Clementoni S.p.A. In the management of the website;
Shopify International Limited, with registered office c/o Intertrust Ireland, 2nd Floor 1-2 Victoria Buildings, Haddington Road, Dublin 4, D04 XN32, Republic of Ireland (link to privacy policy: https://www.shopify.com/legal/privacy), which supplies the infrastructure for the Clementoni online shop;
Zendesk, Inc., with registered office at 1019 Market Street, San Francisco, CA 94103, USA, represented in Europe by Zendesk International Ltd, with registered office at 1 Grand Parade Dublin 6 D06 R9X8, Republic of Ireland (https://www.zendesk.it/company/customers-partners/privacy-policy/), which provides the infrastructure for the website’s customer support;
Overside srl, with registered office at Via della Repubblica 90 bis, 63822 Porto San Giorgio (FM), Italy, which provides technical support for sections of our website;
Talentia Software Italia S.r.l., Via Valtellina, 63, 20159 Milano, Italy (https://www.talentia-software.it/informativa-privacy/), which provides the infrastructure for the “Job Opportunities” area.

Furthermore, the data may be disclosed to the following categories of recipients:

technical experts and software houses who assist the Data Controller with the development, maintenance and upkeep of the website;
companies providing the hosting service for the processed data;
companies that manage customer support through the site;
companies that handle the ordering of products purchased in the online shop;
companies that provide accounting and tax services (invoicing and payment management);
companies that handle the delivery of materials ordered on the website.

The list of recipients of personal data can be viewed in the “Privacy” section of the www.clementoni.it website.

For logistical and operating purposes linked to the hosting service, personal data may be transferred to non-EU countries for which an EU Commission adequacy decision exists, that is to say, which provide adequate guarantees pursuant to Article 46 of the GDPR.

The processed personal data will not be disseminated or transferred to third countries or international organisations.

Security measures

The personal data will be processed using paper-based and IT procedures. For that purpose, all suitable procedures will be used to safeguard the confidentiality, integrity and availability of the data, in compliance with regulations in force.

Rights of the Data Subject

In accordance with the provisions of Articles 13 to 21 of the GDPR, the Data Subject may at any time exercise the following rights as regards Clementoni S.p.A.:

the right to revoke consent to data processing (see the section on “Purposes of the processing and legal basis”)
right of access (the user has the right to confirmation as to whether or not personal data concerning him or her is being processed, as well as information about the data processed and to receive a copy of that data);
right to rectification (the user may request updating or correction of the personal data concerning him or her);
right to the erasure of the data (the user may request the erasure of the personal data concerning him or her, in the cases and under the conditions indicated in Article 17 of the GDPR);
right to data portability (in the cases and under the conditions in art. 20 of the GDPR, the User has the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and, where technically feasible, the right to transmit that data to another controller without hindrance from the controller to which the personal data has been provided).
right to restriction of processing (the User shall have the right to obtain from the controller restriction of processing of personal data concerning him or her, in the cases in art. 18 of the GDPR. Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of public interest).
right to object (when the personal data is processed in the public interest or the legitimate interests pursued by the Controller, the User has the right to object to the processing on grounds relating to his or her particular situation. Where personal data is processed for direct marketing purposes, the data subject shall have the right to object to the processing without providing a reason).
right to lodge a complaint with the Italian Supervisory Authority (www.garanteprivacy.it).

Exercising of the rights of the data subject

For the exercise of these rights, excluding the right to lodge a complaint with the Italian Supervisory Authority, users can contact Clementoni S.p.A. by writing to privacy@clementoni.it.

Data Protection Officer (DPO)

Clementoni S.p.A. has appointed a Data Protection Officer in accordance with art. 37 of the GDPR (Data Protection Officer – D.P.O.).
For any request and to exercise their rights, users can contact the DPO by writing to the e-mail privacy@clementoni.it or by post addressed to:

Data Protection Officer
Clementoni S.p.A.
Zona Ind.le Fontenoce scn
62019 Recanati (MC)

Changes to this privacy policy

Clementoni S.p.A. reserves the right to make changes to this privacy policy at any time, providing suitable information notices to Users, who may revoke consent to processing of the related personal data.

Last updated: 09 January 2024