Privacy Policy

This Privacy Policy governs the processing of personal data collected at Comebag locations. The processing is managed by Temi Spa, headquartered at Via Alberto da Giussano, 23 – 20145 Milan (MI), Italy, which owns the Comebag® brand (hereinafter referred to as “Temi Spa\Comebag,” “Data Controller,” or simply “Controller”).

1. Purposes and Methods of Data Processing and Categories of Personal Data

As the Data Controller, Temi Spa\Comebag collects and processes your personal data through both manual and IT and/or telematic methods. This processing is conducted in compliance with the principles outlined in EU Regulation 679/2016 (“Regulation”) and Legislative Decree 196/03 and subsequent additions and amendments (“Privacy Code”).

Your personal data are collected and processed for the purposes outlined in the privacy notices preceding the data collection forms on the website www.comebag.it Your personal data will be:

  • processed lawfully and fairly;
  • collected for specific, explicit and legitimate purposes, and not further processed in ways that are incompatible with those purposes;
  • accurate and, when necessary, kept up to date;
  • relevant, complete and not excessive in relation to the purposes for which they are collected and subsequently processed;
  • stored in a form that allows for the identification of the data subject for no longer than necessary for the purposes for which they are collected and subsequently processed.

In particular, your data will be processed for the following purposes:

  • Activation and Management of Services: To activate and manage the services and online tools provided through the website (e.g., registration, account creation, Track & Trace, pick-up requests, shipment history viewing, etc.), as well as to handle related administrative and accounting tasks. The legal basis for processing your personal data for these purposes is the necessity to fulfill the service explicitly requested by you;
  • Information and Communication: To send information and communications, including promotional content, to the email address you have provided, regarding new services offered by Temi Spa\Comebag and similar to those you are already using. The legal basis for this processing is the legitimate interest of Temi Spa\Comebag in keeping you informed about similar services that you may find relevant, in accordance with Recital 47 of the General Data Protection Regulation (GDPR). While your consent is not required for this processing, you have the right to object to such communications at any time.
  • Marketing Activities: Subject to your prior consent, to engage in marketing activities, which include sending informational and promotional materials and commercial communications about the Company’s services and/or products. These activities may be carried out using both automated and non-automated methods (e.g., email, SMS, postal mail, etc.). The legal basis for this processing is your explicit, voluntary, and optional consent, which will be obtained through the relevant data collection form. You may withdraw your consent at any time (including partially, with respect to different contact methods) without affecting your ability to access and use the services offered by the website and Temi Spa\Comebag.
  • Sharing with Group Companies and Partners: Subject to your prior consent, your personal data may be shared with entities within the Temi Spa\Comebag Group, including franchisees and commercial partners operating in the automotive, insurance, and media sectors. This sharing may be for marketing purposes, such as sending informational and promotional materials about the products and services of these entities, through both automated (e.g., email, text messages) and non-automated methods (e.g., email, text messages, postal mail). Consent will be explicitly requested at the end of relevant forms on the website. A comprehensive list of these commercial partners can be obtained upon request by contacting us at info@comebag.it. The legal basis for processing your data in this context is your explicit, voluntary, and revocable consent. Refusal to provide consent will not impact your ability to use the services offered by the website and Temi Spa/ Comebag.
  • Legitimate Interests: To pursue the legitimate interests of Temi Spa/ Comebag and/or third parties, including companies within the Temi Spa/ Comebag Group and franchisees. This may involve activities such as legal defense, accurate billing, handling complaints and disputes, debt recovery (both judicial and extrajudicial), fraud prevention, and the prevention of illegal activities. These activities are deemed to not override your fundamental rights and freedoms and constitute the legal basis for processing your personal data.
  • Legal Compliance: To comply with legal obligations, regulations, national and EU legislation, as well as directives issued by legally authorized authorities. Compliance with such obligations represents the legal basis for processing your personal data.

Providing your personal data to access the services and online tools offered by the website is voluntary. However, please be aware that if you choose not to provide the required data, certain services may be unavailable or only partially accessible.

Personal data is collected through registration forms on the website, where mandatory fields are highlighted in bold. Completion of these mandatory fields is necessary for the provision of the requested services. Failure to provide the required data will result in our inability to offer the service or grant related opportunities.

Data requested in non-bold fields is optional. Similarly, consent for marketing activities and receipt of promotional communications from Temi Spa/ Comebag and/or third parties is also optional. Not providing this consent will not affect your ability to register on the website or use its services.

2. Data communication

The personal data you provide, as well as data collected through the website in connection with its services, will not be disclosed except as described below. Data may be communicated, including to non-EU countries, only for the purposes outlined above, to the following categories of recipients:

  • Employees, Consultants, and Freelancers: Individuals employed by or collaborating with Temi Spa/ Comebag for technical or organizational tasks related to the provision and operation of its services, and for the distribution of informational and promotional materials concerning the services offered by Temi Spa/ Comebag.;
  • Professional Advisors: Individuals, companies, or professional firms that provide advisory services to Temi Spa/ Comebag, particularly but not exclusively in areas such as accounting, administrative, legal, tax, and financial matter;
  • Group Companies and Partners: Affiliates, franchisees, and commercial partners of Temi Spa/ Comebag for marketing purposes, as outlined above, provided that such communication is in compliance with legal requirements and subject to user consent where necessary;
  • Regulatory and Legal Entities: Organizations whose access to the data is mandated by legal provisions or orders from competent authorities.

In connection with the provision of local services related to the express courier activities of Temi Spa/ Comebag, your personal data may be disclosed to local companies responsible for managing these services. In cases involving international shipments to non-EU countries, your data may also be transferred to these non-EU countries. Such transfers, as per Article 49 of the Regulation, do not require your consent if they are necessary for the performance of a contract between the data controller and another entity on your behalf. If the data transfer falls outside these scenarios, Temi Spa/ Comebag will implement appropriate privacy measures to ensure the legality of such transfers, including the use of standard contractual clauses approved by the European Commission.

Entities within the above categories will handle data either as independent data controllers in accordance with legal requirements or as data processors appointed by Temi Spa/ Comebag. For details on specific data recipients, please contact us at info@comebag.it.

3. Data retention

Personal data are processed for the duration necessary to provide the services you have requested and to perform activities related to and instrumental to those services, as described in Section 1. Data are deleted once the purposes for which they were collected no longer exist, including any statutory limitation periods as per the Civil Code. Conversely, data collected for marketing purposes will be retained until you unsubscribe or opt-out, after which they may be stored anonymously for analysis and statistical purposes.

4. Your rights

As a data subject, you may exercise your rights at any time by contacting Temi Spa/Comebag. Specifically, you have the right to:

  • Obtain confirmation as to whether personal data concerning you is being processed and, if so, request access to the information related to the processing (e.g., purposes, categories of data processed, recipients or categories of recipients, retention period, etc.);
  • Request the rectification of inaccurate or incomplete data;
  • Request the deletion of data (e.g. if the personal data are no longer necessary with respect to the purposes for which they were collected, if you withdraw the consent on which the processing is based, etc.);
  • Request the restriction of processing (e.g. if you contest the accuracy of the data; if the processing is unlawful and you oppose to the deletion of personal data; if the data are necessary for the exercise or defense of legal claims, even if the Data Controller no longer needs them; if you exercise the right to object, pending verification of legitimate grounds).
  • Receive your personal data in a machine-readable format (e.g., PDF) and transmit them to another owner, or obtain direct transmission from one data controller to another, when technically feasible (data portability).

Additionally, you have the right to object, in whole or in part, on legitimate grounds, to the processing of your personal data. You also have the right to object, even partially, to the processing of personal data for commercial, advertising, or marketing purposes, through different means of communication.

You may exercise the rights by sending an e-mail to dataprotection@temispa.it , as well as the e-mail addresses provided in the Privacy Information on the website www.comebag.it

Should you believe that the processing of your data violates data protection regulations, you have the right to lodge a complaint with the Data Protection Authority (www.garanteprivacy.it ).

To assist Temi Spa\Comebag in promptly responding to your requests to exercise the aforementioned rights, we encourage you to complete the form available here and send it to dataprotection@temispa.it , as well as to the e-mail addresses provided in the Privacy Information on the website www.comebag.it .

5. Data Protection Officer

The Data Protection Officer for Temi Spa\Comebag and the affiliated companies within the Temi Spa Group is domiciled at Temi Spa\Comebag S.p.A. It can be contacted via email at dataprotection@temispa.it.

6. Amendments to the Internet Privacy Policy.

Temi Spa\Comebag reserves the right to amend this Internet Privacy Policy at any time. Notice of such changes will be provided by posting the updated policy on our website. We encourage you to regularly review the website for any updates. Should any significant changes be made that could substantially affect your rights, the Company may also provide notification through other means, such as via email.

In addition to the information provided herein, Temi Spa\Comebag remains available to address any questions regarding the processing of your personal data collected on our website www.comebag.it .

For further information, please send an e-mail to: dataprotection@temispa.it

Consent to Processing of Personal Data

Having read the information provided pursuant to Legislative Decree. 196/2003 and subsequent amendments, and to the GDPR (EU) 2016/679, and subsequent amendments and additions, I hereby acknowledge and understand its content and freely and knowingly give my consent to the processing of my personal data by Temi Spa\Comebag, as specified below:

  • ◻ I consent ◻ I DO NOT consent to the processing of my personal data, including those classified under specific categories of data. -required for service provision-
  • ◻ I consent ◻ I DO NOT consent to the communication of my personal data to public entities and private companies for the purposes stated above. -required for service provision-
  • ◻ I consent ◻ I DO NOT consent to the processing of specific categories of my personal data by third-party entities or companies in compliance with current legislation, for commercial and marketing purposes. -optional-
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