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Regulations for the TWINSET For You Loyalty Program


Introduction

Welcome to the “TWINSET For You” Loyalty Program ("the TFY program") and its many benefits, including access to discounts, gifts and exclusive services, both at “Twinset” stores and on our website www.twinset.com. Membership of the TFY program is completely free and no initial purchase is required. The terms and conditions of use, applied as soon as TWINSET For You is activated, are set out below. The latest version of these Regulations is always available for consultation on our website www.twinset.com.


1) Ownership of the Loyalty Program

The TWINSET For You Loyalty Program is owned by Twinset Spa, Company registration and VAT no. 0788918180969, registered office at Viale del Commercio 31 - 41012 Carpi (MO) - Italy (“Twinset”).


2) Duration and Geographical validity

The TFY program will have an initial duration of 2 years, from 5 September 2023 to 31 October 2025. On expiry, the program will renew automatically each year, unless specified otherwise, revoked or terminated early, following timely notification from Twinset. From the start date, the TFY program will be active in the following channels in which you can make purchases:

  • Stores and mono-brand outlets managed directly by the Twinset Group (the “Participating Stores” - click here to find them)
  • Our website www.twinset.com (the “Official Website”) and purchases made in Participating Stores using their in-store iPads

together, the “Purchasing Channels”.


The TFY program will be accessible and valid in the following territories-nations (individually, the “Country”):

  • Stores and participating mono-brand outlets are present in the following Countries: Italy (including the Republic of San Marino) France, Spain, Belgium. Find Participating Stores by clicking here.
  • Countries in which on-line purchases can be made via our website www.twinset.com.

At this time, the TFY program is not active in department stores, franchise stores, marketplace websites or any channels other than the Official Website. At our discretion, Twinset may increase or reduce the Countries and/or Purchasing Channels in which the TFY program is active. Any restrictions or changes relating to individual Participating Stores will be notified to TFY program members in the Country concerned and posted on our website in the relevant section.


3) Membership and how to join the TFY program

Membership of the TFY program is available to any adult natural person (the “Member”) who makes purchases for personal use via one of the Purchasing Channels. Membership of the TFY program is automatic when you register on our website www.twinset.com, or at a Participating Store by completing the relevant paper or electronic form available there.

Customers whose details are already held on Twinset databases used by stores, or registered on the Official Website, will automatically become program members on the launch date of the TFY program, without need for any further action.
If you do not wish to join the TFY program, but still want to purchase products from our website www.twinset.com, just choose the “Guest” option presented during the check-out process; similarly, when purchasing items at Twinset stores you can, where applicable, ask the cashier not to associate the sale with your user profile already held on Twinset databases.

Members registered on the Official Website can view their data, as provided during the registration process, and amend it as necessary in the private area reserved for their account. That area will also display the spending threshold reached by them during the validity period of the TFY program. Members who are only registered at a Twinset store, without an account on the Official Website, can ask the staff at the Participating Store for their spending threshold status.
In order to join the TFY program and gain access to the related benefits and advantages, Members must provide true and valid personal identification details. Twinset does not check, in any way, the truth or accuracy of the information provided and declines all responsibility in that regard.

Members are forbidden to create more than one account or use altered forms of their personal identification details (e.g. incorrect date of birth, use of second names, pseudonyms, third-party or invented data etc.), even when registering at Participating Stores, in order to create multiple user/customer profiles attributable to the same Member and/or infringe the terms and conditions for using the TFY program.
If the creation of false accounts is suspected, with fictitious identities, multiple accounts on the Official Website or multiple registrations at Participating Stores, Twinset reserves the right to exclude those profiles from the TFY program and, in more serious and repeated cases, to file reports with the competent authorities.
Employees of the Twinset Group are not eligible to participate in the TFY program.


4) Object and Purposes of the TFY Program

TWINSET For You is a tool created so that interested customers can obtain more information about Twinset brands and the products offered, enhancing their loyalty and offering them a series of special benefits and services.
Members can obtain early and exclusive access to the initiatives promoted by Twinset, including customised discounts and gifts, special offers and services, attend events organised by Participating Stores and enjoy other advantages too.


5) How Status is assigned

Members who use the Purchasing Channels to purchase Twinset products during the validity period of the TFY program will be assigned a status, based on the spending threshold reached during the period, that allows them to obtain certain benefits and services depending on the level reached (the “Status”).

From the launch of the TFY Program until its expiry, the Status of each Member is determined with reference to the cumulative total value of purchases made across the various Purchasing Channels over the 12-month period ended on the last day of the reference month (“Validity Period”). An example is provided for the sake of clarity: First purchase on 15 November. From that date, the value of all purchases made by the Member across the various Purchasing Channels until 30 November of the following year will be summed to determine whether to maintain or change the Status of that Member. From then on, subsequent Validity Periods will run from 1 December to 30 November of the following year.


The Status of each Member depends on the spending threshold reached in each Validity Period:

• Bronze: €0 – €499.99

• Silver: €500 – €1,499.99

• Gold: €1,500 – €3,999.99

• Black: €4,000 – up


From the start date of the TFY program, new Members will be assigned “Bronze” Status automatically on registration, even before making an initial purchase. At the start date of the TFY program, all customers already held on the Twinset database for at least one year, after having registered on the Official Website or at a Participating Store and given the relevant marketing consents, will be assigned a Status based on the value and frequency of their purchases over time.

From the start date of the TFY program, the Status of each Member can be upgraded at any time during the Validity Period, based on the spending threshold reached and confirmed in the meantime. In order to maintain the Status reached, it is necessary to purchase at least one product, regardless of value, in the period of 6 (six) months prior to expiry of the Validity Period.

From the start of each new Validity Period (being the first day of the month following that of expiry), the cumulative spend in the prior year will be maintained as the new initial spending threshold, to which the value of the purchases made in the new 12-month Validity Period will be added, in order to maintain the Status reached or obtain an upgrade. If at least one purchase is not made in the last 6 months of the Validity Period, the Member will be downgraded by one Status level, restarting from the associated minimum spending threshold.

For example: the first 12-month validity period starts on the date of registration, say 14 June, and expires on the last day of that month, being 30 June, in the following year. Confirmed purchases during that period (14 June – 30 June of the following year) total € 1,850, with the last purchase made during the 6-month period prior to the expiry date (1 January – 30 June). In this case the Status reached, being Gold Status (€ 1,500 - € 3,999.99), is confirmed for the next Validity Period and, from 1 July, the new initial spending threshold is confirmed as € 1,850.

If by contrast no purchase is made during the last 6 months (1 January – 30 June) prior to expiry of the Validity Period, from 1 July the initial spending threshold will restart from the minimum for Silver Status, being the next level down. In this case, the Member will restart from € 500, to which the purchases made in the new Validity Period will be added.

Under the right conditions, a Member may be upgraded by several Status levels during the same Validity Period, but can only be downgraded by one Status level after each Validity Period. Bronze Status is guaranteed, even if no purchases are made in the Validity Period. On automatic renewal of the TFY program, the spending threshold reached by each Member whose 12-month Validity Period has not yet been completed will be maintained, unless the program is revoked or terminated early, as notified to the Member in advance.


6) Advantages and Benefits

Depending on the Status reached, each Member can receive different advantages and benefits, such as: discount codes, special offers, advance notice of new products or collections, special presents and gifts, free standard shipping, access to the Home Shopping Service, in-store services such as attendance at boutique events, dedicated customer care and other exclusive experiences. To learn about all the advantages and benefits associated with each Status level, see the relevant section (Click here). The dedicated experiences and services associated with each Twinset store are only available at Participating Stores in the Country of residence indicated by the Member when registering, unless specified otherwise for the Status level and/or notified by Twinset.

The gifts, benefits and services indicated and offered by Twinset for each Status level cannot be exchanged for advantages or benefits of other types or from other Status levels, or converted into cash. The award of accumulated benefits and advantages and the basis and timing for their use may be notified to Members at the e-mail address indicated when registering, or verbally on visiting a Participating Store; in all cases, they are shown in the private area reserved for each Member on the Official Website. Members may enjoy the benefits and advantages awarded prior to and no later than the deadline specified by Twinset. Failure to enjoy them by the specified date results in the loss of the benefits or advantages concerned, which cannot then be reinstated or replaced.

For gifts to be collected from Participating Stores, Members can obtain them at a Participating Store in the Country indicated by them when registering, unless stated otherwise by Twinset.

For gifts involving the delivery of a product or goods to the home of the Member, the address given when registering will be used (note that this can always be changed by visiting the area reserved for your profile on our website www.twinset.com or by notifying the Participating Store where you registered). Failure to deliver the gift, due to the absence or unavailability of the Member, does not mean that a new delivery date or method can be requested at the expense of Twinset.

Some benefits and advantages can only be used on certain conditions and with limitations, as indicated by Twinset below:

- Welcome Coupon -10% on registration: this 10% discount, valid for 30 days from the date of joining, only applies to garments in the seasonal collection, excluding those on promotion or in clearance sales. The Welcome Coupon is valid for single purchase at Participating Stores or on the Official Website, but cannot be used for purchases at Outlets or from the Outlet section of the Official Website. The Welcome Coupon cannot be used together with other discount codes made available by the TFY program, except for the Gift Card received following a Status upgrade.

- Happy Birthday promotion: this 10% birthday discount applies to all garments at Participating Stores or on the Official Website; any excluded items will be clearly marked. The Happy Birthday promotion cannot be used together with other discount codes made available by the TFY program. The Happy Birthday discount is valid for a single purchase made from 7 days before to 14 days after the birthday stated when registering. The discount is applied automatically when payment is made, without any action needed by the Member.

- Free Standard Shipping: this advantage is only available for on-line orders placed via the Official Website in the Countries in which this shipping service is available. At this time, the service is not available in Cyprus, Malta, Ukraine, Switzerland, Norway or the United Kingdom.

- Status Gift Card: on Status upgrades with respect to the initial status, the Member received a free Gift Card whose value depends on the Status level reached:

• Silver, promo code worth € 50, usable on a minimum purchase of € 150;

• Gold, promo code worth € 75, usable on a minimum purchase of € 250;

• Black, promo code worth € 100, usable on a minimum purchase of € 350.

The “Status Gift Card” consists in a unique alphanumeric code sent to the e-mail address of the Member 30 days after reaching the next Status level. The code representing the Status Gift Card expires automatically after 6 months have elapsed from the date sent.
The Status Gift Card can be used to purchase all garments at Participating Stores or on the Official Website; any excluded items will be clearly marked. The Status Gift Card cannot be used together with other discount codes made available by the TFY program, except for the Welcome Coupon. If a Member reaches several higher Status levels during the same Validity Period, the corresponding Status Gift Cards will be awarded and sent separately, with the timing indicated above. Should a Member lose the Status reached at the end of a Validity Period, and drop back to the previous level, an additional Status Gift Card will not be awarded on reaching once again the higher Status previously held. Each Status Gift Card can only be used for a single purchase (with the minimum values indicated above) and cannot be used together with other Status Gift Cards.

- TWINSET Anniversary promotion: this 10% discount, celebrating the anniversary of the first purchase (day/month) made at a Participating Store or on the TWINSET Official Website, can be used to purchase all garments at Participating Stores or on the Official Website; any excluded items will be clearly marked. The start date for this discount will be communicated to the e-mail address given by the Member. The TWINSET Anniversary discount can only be used for a single purchase made from 21 days before to 23.59 hours on the anniversary of the first purchase. The discount is applied automatically when payment is made, without any action needed by the Member. The TWINSET Anniversary discount cannot be used together with other discount codes made available by the TFY program.

- Printed Lookbook: the seasonal catalogue of Twinset Collections will be sent to the residence of each Member who gives a postal address when registering for TWINSET For You.

- Special events

- Dedicated Customer Care: customer service dedicated to Members of the TFY program with Black Status, which can be contacted by telephone in the Countries where available (currently Italy – France – Belgium) or using the dedicated e-mail address found in the private area of the Official Website.

- Home Shopping Service: service dedicated to Members of the TFY program with Black Status, which consists in sending a box to the home of the Member containing a customised “look” selected by Twinset, which the customer can decide freely to purchase, in whole or in part, or to return without charge.


The ability of Members to benefit from certain discounts, such as Twinset Anniversary and Happy Birthday, or from other services and gifts, including event attendance and receipt of the printed Lookbook, depends on giving specific marketing and profiling consents during the registration process. Without said consents, the above benefits cannot be assigned or enjoyed. Members can always update, amend or revoke their consents and data by accessing their profiles on the Official Website, or by contacting the staff at Participating Stores.


7) Return of purchased products for Status recognition purposes

Members retain their right to change their minds about purchases in accordance with the terms and conditions applied by Twinset, pursuant to the applicable current legislation.

For Status recognition purposes under the TFY program, the value of purchases made on the Official Website (or via iPad at Participating Stores) during the Validity Period is “suspended” for 30 days from the product delivery date (also to allow the expiry of the period granted by law for returns following a change of mind or any longer periods granted at the discretion of Twinset), and the spending threshold is later updated automatically, on expiry of the aforementioned deadline, in proportion to the value of purchases not returned.
For immediate purchases made at Participating Stores, the value of the spend is recognised at the time of purchase and is only reduced by the value of any returns actually made.

It is understood that any discount codes usable just once, on a one-time basis, or offers previously applied to the products returned, cannot be reinstated or otherwise converted into other discounts or benefits.


8) Nature of TWINSET For You communications and consultation of the Regulations

Information about the TFY program will be provided by Twinset via text messages, e-mail, post, and electronic or social media communications. The communications about TWINSET For You are sent so that Members can receive information about how to obtain and use the benefits and advantages of the loyalty program, find out about TFY program details and changes, and receive related service information; as such, these messages do not represent marketing communications.
Accordingly, should Members revoke the consent given when registering to receive marketing communications, this will not prevent Twinset from sending the above types of communication containing information about the TFY program and how to obtain and use benefits and advantages.

Members can read the Regulations at any time by:

- visiting the legal area of our website www.twinset.com or clicking on the related link in their private area

- asking the staff at Participating Stores;

- asking Twinset Customer Care using the dedicated form


9) Processing of personal data

The personal data of each Member will be processed by Twinset Spa, as the Controller, in compliance with Regulation (EU) 2016/679, as amended. The purposes of such processing are solely related to membership of the TFY program.
Processing may be carried out in part using automated electronic systems, always with due regard for the protections envisaged in the relevant current legislation. The complete privacy policy is available on our website www.twinset.com and can be read on request at Participating Stores.


10) Terminating membership of the TWINSET For You program

Members may at any time freely terminate their membership of the TFY program, simply by sending an e-mail to privacy@twinset.com requesting removal from the TWINSET For You program, or by contacting Twinset Customer Care using the on-line form available in the private area of our website.

The request to terminate membership of the TFY program results in automatic closure and deletion of the Member account created when registering on the Official Website, or removal of the customer profile from the Twinset database, in the case of registration at a Participating Store. In the event of a subsequent new registration on the Official Website or at a Participating Store, none of the data previously provided will be reinstated and membership of the TFY program will commence from Bronze Status.

Twinset reserves the right to exclude Members at any time for just cause, revoking their membership of the TFY program, by sending a reasoned communication to the e-mail address given when registering on the Official Website or at a Participating Store, with consequent elimination of the Status reached and immediate loss of the advantages and benefits awarded.

For example, but without limitation, just cause would include fraudulent or illegal use of the TFY program by providing false, invented or duplicated member information in order to create several accounts or obtain multiple access credentials; excessively frequent and unusual returns; infringement of these Regulations or applicable laws, and other conduct intended to use the TFY program and its benefits and advantages for profit-making purposes.


11) Changes to the Regulations

At any time, Twinset may expand or modify these Regulations, informing the Members promptly and keeping unchanged, as far as possible, the rights already acquired by them under this version of the Regulations. Should Members not wish to accept the changes made, they will be free to cancel their membership of the TFY program in accordance with the provisions of section 9 above.


12) Suspension or early termination of the TFY program

Twinset reserves the right to suspend temporarily or terminate early the TFY program for good reasons, giving reasonable notice to the Members except in the case of force majeure. These types of communication will be published on the Official Website, posted at the Participating Stores and, in all cases, sent to the contact details provided by the Members. In all cases, temporary suspension or early termination of the TFY program will not entitle Members to any form of compensation.


13) Liability

Twinset cannot be held responsible for any delays or failures to implement the TFY program due to force majeure, the activities of third parties, unforeseen objective impediments or excessively onerous costs. With reference to the IT systems used to manage the TFY program, Twinset cannot guarantee uninterrupted service or their freedom from errors, and cannot be held responsible for events caused by technical faults and problems affecting the electronic and other IT equipment used, which might result in the temporary suspension or early termination of the TFY program.


14) Applicable law and Jurisdiction

These Regulations and all charges and rights deriving from membership of the TFY program are governed by the applicable Italian laws. All disputes regarding the validity, efficacy and interpretation of these Regulations, as well as in general membership of the TFY program until its termination will be referred to the sole jurisdiction of the Court responsible for the place where the Member is resident.


Version 1 dated 5 September 2023


TWINSET FOR YOU PRIVACY POLICY pursuant to art. 13 of REGULATION (EU) 2016/679 (GDPR) and DECREE 196/2003, as amended by DECREE 101/2018


Introduction

TWINSET S.p.A. (also “Twinset” or the “Company”) considers your privacy and the security of your personal data to be of paramount importance and, consequently, collects and processes said data with the utmost care and attention, adopting specific technical and organisational measures that ensure processing in a fully secure manner.
Consequently, pursuant to both art. 13 of Regulation (EU) 2016/679 and the Privacy Code, as amended by Decree 101/2018 (together, the “Regulations”), please note that - upon joining the “TWINSET For You” loyalty program - your personal data will be processed in the manner described in this privacy policy.


1. Data Controller

Twinset processes your personal data as the Controller of data processing, with registered office at Via del commercio 32, Carpi (MO), Italy.

For questions or information about the processing of your personal data, please contact us at the following addresses:

Company name: Twinset S.p.A. sole shareholder company
Registered office: Via del commercio 32 - 41012 Carpi (MO) Italy
E-mail: privacy@twinset.com


2. Types of personal data processed

As a member of the “TWINSET For You” loyalty program, Twinset will process the following types of your personal data. So that you can join the loyalty program, we will process your identification details (e.g. name and surname), your contact details (e.g. e-mail address, telephone number, postal address), and your user name and password. Twinset will only process your date of birth if you decide to share that information with us. Other data will also be processed: payment date, shipping address, invoicing address and purchasing details (date, quantity and type, product code, amount of the sale, VAT number if applicable, information about complaints, returns, warranties and reimbursements, and other sales information obtained during the on-line purchase of products).


3. Purposes and Legal Basis of processing

Once collected, your personal data will be processed for the following purposes:


  • Purpose
    Membership of the “TWINSET For You” loyalty program.
    Legal Basis
    Processing is necessary in order to execute a contract to which the data subject is a party (art. 6.b) GDPR).
  • Purpose
    Purchase of products.
    Legal Basis
    Processing is necessary in order to execute a contract to which the data subject is a party (art. 6.b) GDPR).
  • Purpose
    Loyalty building: assignment of a status based on the spending threshold reached during the reference period; assignment of bonuses and discounts based on the amount spent (welcome coupon, free shipping, card status)
    Legal Basis
    Processing is necessary in order to execute a contract to which the data subject is a party (art. 6.b) GDPR).
  • Purpose
    Marketing: delivery of seasonal catalogues to the postal address provided; notification of events and fashion parades; exclusive customer care.
    Legal Basis
    The data subject has given consent for personal data to be processed for one or more specific purposes (art. 6.a) GDPR).
  • Purpose
    Profiling: automated sending of personalised special discounts based on the interests and buying habits of the data subject (Twinset Anniversary promotion, Happy Birthday promotion).
    Legal Basis
    The data subject has given consent for personal data to be processed for one or more specific purposes (art. 6.a) GDPR).
  • Purpose
    Management of customer relations: administration, accounting and dealing with any complaints.
    Legal Basis
    Processing is necessary in order to comply with a legal obligation imposed on the Controller (art. 6.c) GDPR).
  • Purpose
    Compliance with obligations imposed by laws, domestic regulations and European regulations, as well as instructions received from Public Authorities.
    Legal Basis
    Processing is necessary in order to comply with a legal obligation imposed on the Controller (art. 6.c) GDPR).

In the context of the necessary activities described above, Twinset personnel - specifically Authorised and Designated, pursuant to art. 4, para. 10, GDPR and art. 2-quaterdecies Privacy Code - will process your personal data in accordance with specific instructions from the Controller.


4. Categories of data recipient

In order to pursue the purposes of processing indicated in section 3, your personal data may also be communicated to other companies that will process your data as independent controllers, in compliance with the current privacy regulations.

These independent controllers may belong to the following categories: on-line payment service providers in relation to purchases from the Website; acquirers (to allow payments for purchases); providers of fraud prevention services (analysis of orders to identify any fraudulent transactions); couriers and providers of logistic support (access points) that also administer the collection of products purchased from the Website.

Your data may also be communicated to the competent Authorities (e.g. in the context of dispute management) or to legal, tax or administrative advisors (should this be necessary or relevant to the proper fulfilment of contractual obligations inherent in the services included in the purchase contract or obligations imposed by law, or to the determination, exercise or defence of a right).

In addition, your data may be transmitted to third parties in the event of mergers, acquisitions, disposals of businesses or lines of business, or other special transactions, as well as to any party that is the legitimate recipient of communications required by law or other regulations.


5. Processors pursuant to art. 28 GDPR

Your personal data will also be processed by parties, appropriately selected by Twinset, that offer suitable guarantees of compliance with the regulations that govern the processing of personal data.

These parties are appointed as Processors pursuant to art. 28, GDPR and are required to carry out their activities in accordance with specific instructions from the Controller and under our supervision.

These parties may belong to the following categories: providers of IT services, customer support and virtual infrastructure, providers of CRM solutions, companies that offer data entry and postage services, brand managers and, in the case of participation in prize competitions or events, companies that organise and manage said activities on behalf of Twinset.

A detailed, up-to-date list of these parties is available at the registered office of the Controller and may be consulted by the data subject upon the request.


6. Transfer of data outside of the EU

Twinset may transfer your data to non-EU countries.

Personal data will only be transferred to parties resident or located in countries outside of the European Union on the basis of adequacy decisions or following their signature of specific agreements with Twinset containing appropriate safeguards and guarantees for the protection of personal data (“standard contractual clauses”), also approved by the European Commission, or if necessary in order to conclude and execute the contract between Twinset and the data subject and manage requests from the latter or, otherwise, following consent given by the data subject.


7. Data retention

Consistent with the principles of proportionality and necessity, your data will not be retained for periods longer than absolutely essential to achieve the purposes described above and, therefore, for longer than the time strictly needed to pursue the purposes indicated in section 3.

In particular, Twinset retains the data needed to build customer loyalty and therefore: to assign a status based on the spending threshold reached during the reference period; to assign bonuses and discounts based on the amount spent (welcome coupon, free shipping, card status), for the entire duration of the TWINSET For You loyalty program, unless your profile is deleted.

Data retention for other purposes is described in the Data Retention Procedure that can be consulted at the offices of the Company or requested by writing to the following e-mail address: privacy@twinset.com

Your data will be definitively erased by Twinset at the end of the above retention periods or, in any case, irreversibly anonymised.


8. Mandatory or optional provision of data

The provision of your data is optional, but necessary in order to become a member of the “TWINSET For You” loyalty program. Any refusal by you would make it impossible for Twinset to action your application and, therefore, for you to benefit from discounts, rebates, bonuses etc.


9. Your rights

You may exercise the following rights in relation to the personal data addressed by this Privacy Policy, as envisaged and guaranteed in the Regulations and the GDPR in particular:

  • Right of access and rectification (arts. 15 and 16, GDPR): you have the right to access your personal data and request its rectification, modification or completion. Upon request, we will give you a copy of your personal data held by us.
  • Right of erasure (art. 17, GDPR): you may request the erasure of your personal data in the cases envisaged by current regulations. Having received and examined your request, we will cease processing and erase your personal data if your request is deemed legitimate.
  • Right to the restriction of processing (art. 18, GDPR): you have the right to request the restriction of processing, if said processing is unlawful or you contest the accuracy of the personal data held.
  • Right to data portability (art. 20, GDPR): in the cases envisaged in this article, you have the right to request and obtain your personal data from the Controller for transmission to another controller.
  • Right to object (art. 21, GDPR): you have the right to object at any time to the processing of your personal data carried out in our legitimate interests, explaining the reasons for your objection. Twinset will assess your reasons before deciding whether to agree to your request.
  • Right to lodge a complaint (art. 77, GDPR): you have the right to lodge a complaint with the competent Data Protection Authority if you believe that your rights in relation to the processing of your personal data have been, or are being, infringed.


To exercise your rights, you may contact the Controller directly at the following e-mail address: privacy@twinset.com or by sending a letter to the Company at Via del commercio 32 - 41012 Carpi (MO) Italy.


10. Security measures

In compliance with arts. 5 and 32, GDPR, Twinset has adopted appropriate security measures to protect the confidentiality, integrity, completeness and availability of the personal data of data subjects. Accordingly, specific technical, logistical and organisational measures have been adopted for paper-based and IT documents, in order to prevent damage, losses - whether accidental or otherwise - alterations and/or the improper and unauthorised use of said data, as well as to ensure our ability to restore promptly the availability of and access to personal data following adverse physical or technical events (e.g. data breaches).

Twinset also periodically tests, checks and assesses the effectiveness of the above security measures, in order to ensure that the security of data processing is improved continuously.


11. Amendments to this privacy policy

With respect to the above, the continuous evolution of our services may lead to changes in how your personal data is processed. Accordingly, this privacy policy may be amended or extended over time, consequent to the introduction of new data protection laws, the evolution of our services or changes to them.



Last updated on 05/09/2023

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