This notice describes how Tristate International S.A. and Diana e-commerce corporation S.r.l., (collectively "Companies" or "we" or "us" or "our") as joint controllers process the personal data in relation to the registration and participation in "The Brotherhood" programme (hereinafter the "Programme"). For more information on how the Programme works, please refer to the Terms and Conditions of the Programme.

Types of data processed: The registration and participation in the Programme entails the processing of data included in your personal account, namely your identification data (full name, date of birth) and your contact data (phone number, email address and residential address). We also process data related to your purchases, namely date, amount, details of the products purchased and possible return of products, as well as the information related to your status and point balance.

Purposes of processing: We process your data for the following purposes; for each of them we indicate the types of data processed and the legal bases legitimizing our processing activity:

·      Programme Registration: we process your identification and contact data included in your personal account, as well as the manifestation of your will to sign up to the Programme for the purpose of allowing your registration to the Programme. Your date of birth is also processed to ensure that the Programme members are of legal age as well as to enable your receipt of the Birthday Gifts, as described in the Programme Terms and Conditions.

·      Programme Management: your identifying data, together with data relating to the purchases made as well as any returns, or data relating to your status and points balance are processed for the purposes of managing your participation in the Programme and awarding you with the relevant benefits. All details of your status as a Programme Member are also stored and available in your account on the Site.

Nature of the provision: The provision of personal data is necessary for the purposes of registering to and managing the Programme, in fact, without such personal data, it would not be possible to proceed with your registration or management of your participation as well as the allocation of the benefits.

Method of processing: The processing of your data may be carried out both manually and electronically, in accordance with the logics and procedures necessary for the protection and security of your data.

Disclosure and access: Your data may be accessed by our personnel authorized to process your data and by our service providers for the above purposes, who will act as data processors, duly appointed and instructed on the basis of an ad hoc agreement, such as providers of hosting services. Your data may also be disclosed to third parties when required by applicable laws or regulations, for instance, in case of requests from competent authorities, as well as in case of extraordinary transactions concerning the Companies (in which case recipients could be for example legal counsel or external consultants).

Storage: Your data will be stored for as long as strictly necessary to pursue the processing purposes mentioned above, including the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements, in compliance with applicable privacy laws. In particular, with respect to the Programme registration and management purposes, your data will be retained for the duration of the Programme and as long as your account remains active, unless you request erasure of data.

Your rights: You may contact Tristate International S.A., using the contact details mentioned below, to exercise your rights as provided for under applicable privacy laws,

Notice for California Residents

If you reside in California, we are required by California law to provide you with additional information about how we use and disclose your information, and you may have additional rights with regard to how we use your information. We have included this California-specific information below.

CA Personal Information. Consistent with the “Types of data processed” section above, we collect certain categories of Personal Information about California residents (“CA Personal Information”) for the purpose described in this privacy notice. Nonetheless, the specific Personal Information that we collect, use, and disclose relating to a California resident will depend on our specific relationship or interaction with that individual.

CA Personal Information Retention. Consistent with the above, we retain your California Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you; (ii) as required by a legal obligation to which we are subject to; or (iii) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).

California Consumer Rights. As a California resident, you have the right to:

·      request access to your CA Personal Information, including information about the categories of CA Personal Information we have collected, the categories of sources from which we have collected your CA Personal Information, the business or commercial purpose for collecting, selling, or sharing your CA Personal Information, the categories of third parties to whom we disclose CA Personal Information, and the specific pieces of CA Personal Information we have collected about you;

·      request meaningful information about automated decision making technology, including the logic involved in those decision-making processes, as well as description of the likely outcome of the process with respect to you;

·      request deletion of your CA Personal Information; however, to the extent permitted by applicable law, we may be required to retain some of your CA Personal Information, and certain CA Personal Information is strictly necessary for us to fulfill the purposes described in this privacy notice;

·      if we maintain any inaccurate information about you, request correction of that inaccurate CA Personal Information;

·      request that we transfer your CA Personal Information to another entity to the extent technically feasible, in a structured, commonly used, machine-readable format;

·      request information about the CA Personal Information about you that we have disclosed for a business purpose and the categories of persons to whom it was disclosed for a business purpose;

·      request information about the CA Personal Information about you that we have "sold" or "shared" (as such terms is defined under applicable California privacy laws) and the categories of third parties to whom the CA Personal Information was sold or shared;

·      opt-out of being subject to automated decision-making processes, including profiling; and

·      opt-out of the "sale" or "sharing" of your CA Personal Information (as such terms is defined under applicable California laws), if applicable.

Exercising Your California Consumer Rights. If you are a California resident and wish to exercise any of these rights or if you have questions regarding the CA Personal Information collected or shared with third parties, please: contact us as specified below with the specific nature of your request, referencing “Your California Privacy Rights”; When submitting your request, you must include name, last name, your relationship with us, and the email address associated with the account. You may be asked to provide additional proof of identification so that we can verify your identity and validate the request. Please note that you are limited by law in the number of requests you may submit per year. In some instances, we may decline to honor your request. For example, we may decline to honor your request if we cannot verify your identity or confirm that the CA Personal Information that we maintain relates to you. We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon you exercising your rights to your CA Personal Information.

Authorized Agents: To the extent that you elect to designate an authorized agent to make a request on your behalf, they must provide appropriate documentation, which may include written signed permission from you, proof of your identity, and verification of their identity; or a valid, designated power of attorney as defined under the California Probate Code.

Sources of CA Personal Information. Consistent with the above, we collect CA Personal Information that you provide in the course of your registration and participation in the Programme.

Purposes. We collect the CA Personal Information for business and commercial purposes. We also share your CA Personal Information as follows:

·      Sharing your CA Personal Information for Business Purposes: Consistent with the above, in the preceding twelve months, We may have shared CA Personal Information for business purposes. This information may be shared for the purpose of providing services to you, for legal compliance, or to protect legitimate interests, in compliance with law.

·      Sale of CA Personal Information. In the preceding twelve (12) months, we have not sold (as defined under CCPA) CA Personal Information. We do not knowingly share the CA Personal Information of individuals under sixteen (16) years of age, in a manner that constitutes a "sale" under California law.

Notice of Financial Incentive. We may provide price discounts, coupons, services and other perks for members of our Programme. Through these offerings, members may provide us with any categories of CA Personal Information depending on how they choose to interact with us when and after they opt-in to our Programme. There is no obligation to opt-in and consumers may opt-out at any time. We offer this loyalty program, among other things, to enhance our relationship with you so you can enjoy more of our products/services at a lower price. The value to our business of any individual’s data is dependent on a number of factors, including, for example, whether and to what extent you take advantage of any offerings, whether and to what extent you opt out of any offerings, and whether we are able to enhance the data through our efforts described in this privacy notice.

Contact details: Tristate International S.A. with registered office at Via Riva Albertolli 1 - Lugano, Switzerland, email: privacy@eu.tristateww.com and Diana e-commerce corporation S.r.l., with registered office at Torreglia (PD), 35038, via San Daniele n. 137/139, Italy, email: privacy@dianacorp.com