Privacy Policy

Information on the processing of personal data (Privacy Code – Legislative Decree 30.6.2003, No. 196 – Article 13 – EU Regulation 679/2016 on the processing of personal data – Article 13 – Legislative Decree 101/2018)  

Diffusione Orologi S.r.l., registered office at Corso Sempione, 30 – 20154 – Milan (MI), Tax ID and VAT number 02099340610 (hereinafter, “Owner”), as processing personal data controller, informs you pursuant to art. 13 Legislative Decree 30.6.2003 n. 196 (hereafter, “Privacy Code”), of the art. 13 EU Regulation n. 2016/679 (hereinafter “GDPR”) and Legislative Decree 101/2018 that your personal data will be processed in the following manner and for the following purposes:  

Subject of processing

The Controller processes personal data, including special data (for example, name, surname, company name, address, telephone number, e-mail address, bank and payment details, general and specific information on the interested parties for the correct execution of the contract) – later , “Personal data” or  “data” communicated by you on the conclusion of contracts for the services of the Data Controller. Processing of personal data means any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, even if not recorded in a database, such as collection, registration, organization, structuring, storage, processing, selection, blocking, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction.


  1. Purpose of the processing

Your personal data is processed:

A) Without your express consent (art. 24 letter a), b), c) Privacy Code and art. 6 letter b), e) GDPR), for the following Service Purposes:

– allow user access to the site;

– conclude the contracts for the owner’s services;

– fulfill the pre-contractual, contractual and fiscal obligations deriving from existing relationships with you;

– fulfill the obligations provided for by the law, by a regulation, by EU legislation or by an order of the Authority;

– exercise the rights of the Owner, for example the right to defend in court.

B) For the performance, subject to your express written consent (articles 23 and 130 of the Privacy Code and article 7 of the GDPR), of direct marketing activities, such as the sending – also by e-mail, SMS – of advertising material, newsletters and communications with informative and/or promotional content in relation to products or services provided and/or promoted by the Data Controller or its business partners, including free gifts and free samples.  

C) For the performance, subject to your express written consent, of individual, aggregated, market research and third-party profiling activities, aimed, for example, at analyzing consumption habits and choices, at processing of statistics on the same or to the evaluation of the degree of satisfaction with the products and services offered.

We inform you that for the provision of consent to the processing of your data carried out by third-party websites that profile through Cookies and similar tools (for example Facebook), the User is invited to visit the policies of the related social networks.

2.1 Type of data collected

Pursuant to EU Regulation 679/2016 on the processing of personal data when using our services, you agree that our company will collect some of your personal data. This statement aims to tell you what data we collect, why and how we use it.  

2.1.1. Data provided by the user

When you buy online or request a quote, we ask you to provide us with some data you need to use our services.

These are, by way of non-exhaustive example, the data we request from you: 

  • Name, Surname, Company and References
  • email address
  • Tax Code
  • Telephone number, fax, address
  • Payment information

2.1.2. Data that we collect automatically from the website

We collect the following data through the services we use

  • Technical data: for example, IP address, browser type, information on your computer, data relating to the current (approximate) position of the instrument you are using;
  • Data collected using cookies or similar technologies.


Processing methods

The processing of your personal data is carried out by means of the operations indicated in the art. 4 of the Privacy Code and to the art. 4 n. 2) GDPR and more precisely: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data is subject to both paper and electronic and/or automated processing. The data relating to the purposes referred to in point 2.A) will be kept for 10 years in relation to fiscal or legal obligations while all the remaining data, including those relating to the purposes referred to in point 2.B) and 2.C ), will be kept for 2 years from the date of termination of the purpose of the service offered. 

Access to data

Your data may be made accessible for the purposes referred to in art. 2.A) and, subject to your consent 2.B) and 2.C) to:

employees and collaborators of the Controller in their capacity as appointees and/or internal processors and /or system administrators;

to third-party companies or other subjects (as an indication, credit institutions, professional firms, consultants, business partners, insurance companies for the provision of insurance services, etc.) that carry out outsourced activities on behalf of the Owner, in their quality of external processors.

Communication of data

Without the need for express consent (pursuant to art. 24 letter a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2.A) to Supervisory Bodies, judicial Authorities, insurance companies for the provision of insurance services, as well as to those subjects to whom the communication is obligatory by law for the fulfillment of the said purposes. These subjects will process the data in their capacity as independent data controllers. Only with your consent for the purposes referred to in point 2.B) and 2.C) to third party companies such as business partners and event organizers.

Your information will not be disseminated. 

Data transfer

Personal data is not stored on servers located outside the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller ensures from now on that the extra-EU data will be transferred in compliance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses envisaged by the European Commission.  


Nature of data provision and consequences of refusal to respond

It should be noted that with reference to the purposes referred to in point 2.A) of the paragraph “Processing purposes” in the absence of the personal data concerning you and the relative consent to the processing, the service cannot be performed. Failure to provide data for the purposes referred to in points 2.B) and 2.C) of the paragraph “Purpose of processing” will have no effect on the provision of services. 

Rights of the interested party

As an interested party, you have the rights referred to in art. 7 Privacy Code and art. 15 GDPR and precisely the rights of:

  • obtain confirmation of the existence or not of personal data concerning you, even if not yet recorded, and their communication in an intelligible form;
  • obtain the indication: a) of the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in the case of processing carried out with the aid of electronic means; d) of the identification data concerning the data controller, data processors and the representative designated pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or appointees;
  • obtain: a) updating, rectification or, when interested, integration of data; b) the deletion, transformation into anonymous form or blocking of data processed in violation of the law, including those for which conservation is not necessary in relation to the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the event that such compliance occurs it proves impossible or involves a use of means manifestly disproportionate to the protected right;
  • object, in whole or in part: a) for legitimate reasons to the processing of personal data concerning you, even if pertinent to the purpose of collection;

Where applicable, the interested party also has the rights set forth in Articles 16-21 GDPR (Right of rectification, right to be forgotten, right to limitation of treatment, right to data portability, right to object), as well as the right to complain to the Guarantor Authority. 

Procedures for exercising the rights

You can exercise your rights at any time by sending:

A registered letter a.r. to – Diffusione Orologi S.r.l. with registered office at Corso Sempione, 30 – 20154 – Milan (MI) or an e-mail to the following address:

Owner, manager and appointees

The Data Controller is Diffusione Orologi S.r.l. with registered office at Corso Sempione, 30 – 20154 – Milan (MI), Tax Code and VAT No. 02099340610. The updated list of data processors and data processors is kept at the registered office of the Data Controller.

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