PRIVACY NOTICE

Pursuant to Article 13 of the Regulation (EU) 2016/679 containing provisions for the protection of natural persons with regard to the processing of personal data and for the free movement of such data (hereinafter the “GDPR”), we hereby provide you with information regarding the processing of your personal data provided by you and/or collected via the websites www.mbe.it and www.mbe-franchising.it (together the “Websites”).

1. Data controller

Personal Data collected via the Websites will be processed by Sistema Italia 93 S.r.l., with registered office in Milan, Viale Lunigiana 35-37, 20125, exclusive licensee for Italy of the brand “Mail Boxes Etc”, in its quality of data controller (hereinafter the “Controller” or “MBE”).

2. Categories of Personal Data processed

The following Personal Data provided by you (hereinafter the “Personal Data”) may be processed via the Websites:

• the IP address;
• navigation data on the Websites;
• information on the browser and on the device;
• information collected through cookies, pixel tags, provided by you and without disclosing your specific identity;
• demographic information and other information provided by you and without disclosing your specific identity;
• information that has been aggregated in such a way as to no longer reveal your specific identity.

Moreover, the following Personal Data provided by you may be processed if you decide to interact with the Websites:

3. Purposes of processing Personal Data

The Controller will process your Personal Data for the following purposes:

1. to allow you to benefit from the features offered by the Websites, and more in detail:

2. to provide you with the services you request, and more in detail:

3. to send you, by any means of communication (fax, e-mail, text message, multimedia messaging service, paper-based mail, operator-assisted phone calls), advertising material and literature of a promotional nature or in any case involving commercial solicitation pertaining to services, products or discounts offered by the Controller, as well as for conducting studies and surveys of the market, and elaborating related statistics;

4. communicate the Personal Data to MBE Worldwide S.p.A, Jonathan & Assist S.r.l, Eurocubia S.r.l, DireFareStampare S.r.l and Forama S.r.l. and CZ Mail S.r.l. (hereinafter the “MBE Group”) and to the MBE centers to send you, by any means of communication (fax, e-mail, text message, multimedia messaging service, paper-based mail, operator-assisted phone calls), advertising material of promotional nature or in any case involving commercial solicitation pertaining to services, products or discounts offered by the MBE Group and the relevant MBE center, as well as for conducting studies and surveys of the market, and elaborating related statistics.

The Personal Data collected may also be processed in the context of any corporate events (sale of the company or business units), due diligence or in the case of defence of a legal claim and the related preliminary activities.

4. Legal basis for processing Personal Data

The processing of your Personal Data for the purposes referred to in Section 3, a. is carried out in order to comply with your request and on the basis of a legitimate interest of the Controller, which business is inevitably linked to the quality of the services offered by its Websites, to the users’ interaction experience and to the satisfaction of their expectations. Any refusal to provide the Personal Data for the purposes set out above will make it impossible to send your contact request to the Controller and/or the selected MBE center.

The processing of Personal Data for the purposes referred to in Section 3, b., is necessary in order to perform the pre-contractual and contractual measures adopted upon your request when you ask for the services offered by the Websites. Any refusal to provide the Personal Data for the purposes set out above will make it impossible to use and enjoy the services above.

The processing of your Personal Data for the purposes referred to in Section 3, c. and d., is optional and is based on your freely given consent. Any refusal to provide the Personal Data for the purposes set out above will have the sole consequence of making it impossible for the Controller, the MBE Group and/or the selected MBE center to send you advertising and promotional messages, to conduct studies and surveys of the market, and elaborating related statistics.

In case of processing in the event of any potential corporate events (sale of the company or business units), due diligence or in the case of defence of a legal claim and the related preliminary activities, such processing will be carried out on the basis of legitimate interests of the Controller in the continuation of its commercial activities and for the protection of its rights.

5. Modalities of processing of Personal Data   �

The processing will be carried out with the assistance of both automated instruments and on paper suitable for guaranteeing the security and confidentiality of Personal Data, this to collect, consult, store, manage, extract and transmit the Personal Data.

6. Recipients of Personal Data

The Personal Data will be disclosed to the persons authorized for the processing within the Controller's staff.

The Personal Data may be disclosed by the Controller solely and exclusively for the purposes indicated and where necessary, to the following categories of subjects:

1. agents or collaborators of the Controller who are located within the territory of the European Union;
2. MBE centers that are located in Italy and which may process your Personal Data to carry out the services you requested and any ancillary activities (e.g. invoicing) and for marketing purposes where the relevant consent has been obtained;
3. service providers for marketing activities;
4. MBE Group companies as specified above, including – as of the date of this privacy notice - MBE Worldwide S.p.A., Jonathan & Assist S.r.l.; Eurocubia S.r.l.; DireFareStampare S.r.l., Forama S.r.l. and CZ Mail S.r.l.
5. consultants for accountancy, administrative, legal, tax and financial matters;
6. where required, the competent judicial authorities;
7. where required, public administrations and supervisory and control authorities.

Personal Data will not be publicly disclosed.

Entities belonging to the categories listed above, may act, as the case may be, as data processors (and in this case they will receive appropriate instructions from the Controller) or as autonomous data controllers. In the latter case, the Personal Data will be communicated only with the express consent of the data subjects,  except where the communication is mandatory or necessary pursuant to the applicable law or for the pursue of purposes for which the consent from the data subject is not required.

The Controller also have the right to transfer your Personal Data to third countries. Transfers of Data outside the European Economic Area are subject to a special regime pursuant to the GDPR, and are only made in respect of countries that ensure an adequate level of personal data protection, on the basis of an adequacy decision of the Commission or where adequate safeguards have been adopted (including the standard contractual conditions provided by the European Commission), provided that the data subjects have enforceable rights and effective judicial remedies.

7. Cookies

The Controller may use "cookies" within the Websites (i.e. text files sent and stored on users hard disk to be then retransmitted during the next visit of the same Websites), or other similar tools in order to facilitate the use of services requested by the user himself, as well as the user’s collection of information, the navigation of the Websites and the choices and preferences expressed on products/services. The user may revoke at any time the authorization granted and oppose to the use of cookies by selecting the appropriate settings on its Internet browser. For more information on how to disable cookies read our Cookies Policy

8. Retention of Personal Data

Personal Data will be stored, in compliance with the applicable law, for a term not exceeding what is necessary to pursue the purposes for which they are processed, save for the right to withdraw the consent at any time where it constitutes the legal basis for the processing.

The criteria for determining the storage period of the Personal Data takes into account the allowed processing period and the applicable laws on the statute of limitation of rights and legitimate interests of the data subject where they are the applicable legal basis for processing.

Subsequently, the Personal Data will be deleted, aggregated or anonymized.

9. Rights of the data subject

At any time, you will be entitled to:

1. obtain confirmation from the Controller as to whether your Personal Data is being processed, and where that is the case, to access to the personal information pursuant to art. 15 of the GDPR;
2. obtain the rectification of inaccurate Personal Data concerning you, or, taking into account the purpose of the processing, the integration of incomplete Personal Data;
3. obtain the erasure of your Personal Data, where one of the grounds under art. 17 of the GDPR applies;
4. obtain the restriction of processing of your Personal Data, where one of the cases under art. 18 of the GDPR applies;
5. object to the processing of your Personal Data on grounds relating to your particular position, where applicable;
6. receipt in a structured, commonly used and machine-readable format Personal Data concerning you and provided by you, as well as to transmit those Personal Data to another controller, in the cases and within the limits referred to in art. 20 of the GDPR, where applicable.

You also have the right to withdraw your consent to the processing of your Personal Data (where given) at any time, without prejudice to the lawfulness of the processing based on your consent before its withdrawal. You will have the possibility to opt-out from marketing via email by clicking on the relevant “unsubscribe” link.

According with the GDPR, the Controller may not charge for complying with any of the requests mentioned in this paragraph, unless they are clearly unfounded or excessive and repetitive. Should you request more than one copy of your Personal Data or in cases of excessive or unfounded requests, the Controller may: (i) charge a reasonable expense, considering the administrative costs incurred to fulfil the request; or (ii) refuse to fulfil the request. In these cases the Controller will inform you of the costs before fulfilling the request. 

The Controller may ask for further information before fulfilling the requests if it needs to verify the identity of the person who has made them. 

Without prejudice to any administrative or legal remedy, you also have the right to lodge a complaint to the relevant supervisory Authority (for Italy: the “Garante per la protezione dei dati personali”), if you believe that processing of your data is in breach of the GDPR. More information is available on the website https://www.garanteprivacy.it/en/home_en

In any case, the Controller is interested in knowing the reasons for the complaint and requests that you use the above contact methods before turning to the authorities, in order to prevent and resolve any disputes, amicably and promptly, with the greatest courtesy, professionalism and discretion.

For more information about the provisions contained in Articles from 15 to 22 of the GDPR, click on the following link:

http://eur-lex.europa.eu/legal-content/IT/TXT/PDF/?uri=CELEX:32016R0679&from=it

10.  Contacts for the exercise of the rights of the data subject and for further information

With respect to the exercise of your rights in relation to the purposes as per Section 3 above and/or to obtain any type of information you may need in relation to the Controller pursuant to this privacy notice, you can send a written communication to Sistema Italia 93 S.r.l. (Fiscal Code and VAT number 10697630159), with registered office in Milan, Viale Lunigiana 35-37, or a fax by dialling 02 67625625 or an email to privacy@mbe.it.

11. Changes to this privacy notice

This privacy notice will be valid as of the date indicated below. It is advisable to regularly monitor this privacy notice by visiting the Websites in order to keep up to date with any future changes.