Comano Spa Skincare Loyalty Program Regulations

The Terme di Comano Skincare 2024 Loyalty Programme (hereinafter the “Initiative”) has been created by AZIENDA CONSORZIALE TERME DI COMANO, Loc. Terme di Comano, n. 6 - 38070 STENICO (TN), VAT no. and Tax ID 00180160228 (hereinafter “Terme di Comano”) for all its customers (“Customers” or, individually, “Customer”).
The Initiative is excluded from the scope of prize operations as provided for by art. 6, paragraph 1, letter c-bis), d) and e) of Presidential Decree no. 430 of 26 October 2021, as integrated by art. 22 bis of Law no. 116/2014, converting Decree-Law no. 91/2014.

Participation in the Initiative implies acceptance of the conditions established in these Regulations, the updated version of which will always be available on the website www.termecomanoskincare.it

All personal data provided by Customers for registration in this Initiative will be processed according to the information notice ex art. 13 EU Reg. 2016/679 (GDPR), available at the following link:

https://termecomanoskincare.it/pages/privacy-e-note-legali

1. THE INITIATIVE
Participation in the Initiative is free, strictly personal and cannot be assigned and/or transferred to third parties, either inter vivos or by succession in the event of the Customer's death.

The Initiative is reserved for individuals over 18 years of age.

The Initiative involves the allocation of cumulative points (“Point” or “Points”)
- on purchases of Terme di Comano brand products (“Products”) made through the website www.termecomanoskincare.it (“Website”),
- through interactions with the Website and official Terme di Comano Skincare social profiles,
- through other actions specified in the text of these regulations.

2. DURATION
The Initiative has no expiration date: each Customer can accumulate Points and enjoy the benefits associated with the Initiative without time limits, under the conditions established from time to time by the current Regulations.

Terme di Comano reserves the right to vary the content of the benefits associated with the Initiative by notifying the Customer of the changes introduced at least 30 days before their entry into force.

3. REGISTRATION AND ACCOUNT CREATION METHODS
The Customer can subscribe to the Initiative exclusively online, by clicking on "Subscribe to the Loyalty Programme" on the Website Homepage and creating an account by filling out the specific form. Once registered, the Customer will receive a confirmation email of successful registration at the address provided in the form.

All Customers who, as of 03/09/2024, have an account on the online shop present on the Website are automatically registered for the Initiative and can immediately accumulate Points for their purchases without the need for further subscriptions.
It should be noted that, for the purpose of assigning points (pursuant to paragraph 4, “POINTS INITIATIVE MECHANICS”), for the definition of Customer Status (as provided for in paragraph 5, “CUSTOMER STATUS”), only purchases made from 03/09/2024 onwards will be considered.

The Customer may unsubscribe from the Initiative at any time by sending an email to the following address: shoponline@termecomanoskincare.it.

Each Customer is entitled to only one account. Should Terme di Comano detect the presence of multiple accounts attributable to the same customer, it will, after appropriate checks, delete one of the two accounts, retaining the one with the highest number of points.

4. POINTS INITIATIVE MECHANICS
During the validity period of the current version of the Regulations, Customers will be awarded 5/6/7 Points – based on their Customer Status - for every euro spent on the purchase of Products.

Customers will also be entitled to obtain Extra Points, based on their Customer Status and as per the table in point 5, upon completion of additional activities, such as:
• Creating an account and subscribing to the Loyalty Programme
• Subscribing to the Terme di Comano Skincare Newsletter
• Entering their date of birth (points will be awarded on their birthday)
• Inviting a friend, if the friend accepts the invitation by performing the required activities
• Following Terme di Comano Skincare on Social Media: Instagram, Facebook, YouTube

Points earned with a purchase can be used 15 (fifteen) days after the actual completion of the purchase itself (e.g., without the right of withdrawal being exercised by the Customer).

In case of prolonged Customer inactivity since the last purchase – i.e., if the Customer does not make purchases for 12 or more months – the overall Points balance will be reset, without implying the cancellation of the Customer from the Initiative. The Customer will receive an email notification of points reset 14 days before the effective cancellation of the points accumulated up to that moment.

5. CUSTOMER STATUS
Depending on the accumulated spending level (purchase history), the Customer will belong to one of three incremental levels (“Status”): Beauty Essential, Beauty Advance, Beauty Premium.
Specifically:
- the Beauty Essential level is assigned to Customers whose spending level is between 0.00 and 99.99 euros;
- the Beauty Advanced level is assigned to Customers whose spending level is between 100.00 and 199.99 euros;
- the Beauty Premium level is assigned to Customers whose spending level is equal to or greater than 200.00 euros;

Below is a summary table of the benefits associated with each Status.

Benefits (points)	Beauty Essential	Beauty Advanced	Beauty Premium
Make a purchase	5	6	7
Create an account	150	150	150
Subscribe to our Newsletter	75	75	75
Add Birthday	350	700	1050
Invite a friend	1000	1000	1400
Follow us on Instagram	25	25	25
Like us on Facebook	25	25	25
Visit our YouTube page	25	25	25

  

6. DISCOUNT CODES
Subscription to the Initiative and the collection of Points will entitle Customers to receive a “Discount Code” – which cannot be combined with others – to be used for subsequent purchases on the Website.

Points can be redeemed to obtain Discount Codes only upon reaching the following point thresholds (“Threshold” or “Thresholds”):
• at 350 Points the Customer will receive a 5% Discount Code
• at 700 Points the Customer will receive a 10% Discount Code
• at 1050 Points the Customer will receive a 15% Discount Code

Discount Codes are not convertible into cash and will be valid for 90 (ninety) days from the date of issue of the Discount Code.

After these terms, the Discount Codes will no longer be effective and cannot be used: under no circumstances and for no reason will Terme di Comano agree to any Customer requests to extend their validity terms.

Pursuant to art. 6, paragraph 1, letter c-bis) of Presidential Decree no. 430/2001 and subsequent amendments, it is reiterated that the Initiative is excluded from the scope of Prize Operations as the purchases for which the Discount Codes can be used relate to Products present on the Website.

7. EXERCISE OF THE RIGHT OF WITHDRAWAL AND ITS EFFECT ON POINTS
In case of exercise of the right of withdrawal, the Customer will be required to return the Product within the period indicated in the "Right of withdrawal" section on the Website, which can be accessed by clicking here.

In the event of a return of Products purchased on the Website, the Customer's overall Points balance may be updated based on the amount of the returned Products: specifically, the Points assigned for each returned Product may be deducted from the Customer's overall balance.

The assigned Points may also be deducted in case of return of the Product due to defects or flaws without replacement with another identical one, without prejudice to the Customer's right to receive a full refund of the sums originally paid.

8. ABNORMAL USE OF POINTS AND DISCOUNT CODES
By adhering to the Initiative, the Customer undertakes to act in accordance with the procedures set out in these Regulations.

Should an abnormal use of Points and/or Discount Codes be detected (by way of example and not exhaustive, use of Points relating to a Product for which the Customer has exercised the right of withdrawal), Terme di Comano reserves the right to:
- where possible, deduct from the Customer's overall balance the Points corresponding to the returned Product;
- notify the deduction by sending a specific communication to the email address provided during registration;
- for more serious cases – to be evaluated at the sole discretion of Terme di Comano – inform the Customer of the intention to proceed with the suspension of the Customer's account until the matter is clarified.

9. INFORMATION AND REPORTS
For information and/or reports, you can contact Terme di Comano, by phone at +390465763350 or by filling out the form by clicking here.

10. PROCESSING OF PERSONAL DATA
As better specified in the privacy policy to which express reference is made in the paragraph below (INFORMATION ON THE PROCESSING OF PERSONAL DATA), Terme di Comano, as data controller, guarantees that the data provided by the Customer will be processed in compliance with the provisions of Legislative Decree no. 196/2003 and subsequent amendments and EU Regulation 2016/679 and any other applicable legislation on Privacy.
Without prejudice to the rights recognized by articles 15 et seq. of EU Regulation 2016/679, the Customer's data will be processed according to the methods and for the purposes indicated in the Privacy Policy and for which he/she has expressed his/her consent, where required.

INFORMATION ON THE PROCESSING OF PERSONAL DATA
Loyalty Programme
September 2024

This information describes the processing carried out by Azienda Consorziale Terme di Comano in relation to the “Terme di Comano Skincare 2024” loyalty programme.

1. DATA CONTROLLER

1.1. The data controller is Azienda Consorziale Terme di Comano (hereinafter “ACTC”), with registered office in Loc. Terme di Comano no. 6 – 38070 Stenico (TN), VAT no. and Tax ID 00180160228.
1.2. Contact details: a) e-mail: privacy@termecomano.it; b) telephone: 0465763300.

2. DATA PROTECTION OFFICER

2.1. The data protection officer (DPO), who can be contacted for all matters concerning the processing of personal data and the exercise of rights, can be reached at the following contact points: a) telephone: 055750808; b) e-mail: dpo.sicurdata@opendata.it

3. PURPOSE OF PROCESSING, LEGAL BASIS OF PROCESSING, NATURE OF PROVISION

3.1. Within this paragraph, we will indicate the purposes for which your personal data will be processed, the personal data that will be processed, the legal basis under which the data will be processed, and the retention period.
A. Loyalty program enrollment and personalized marketing activities. Personal data processed: first name, last name, email address, password, residence/domicile address, telephone number. Purpose: enrollment in the Terme di Comano Skincare 2024 loyalty program. Enrollment and participation in the loyalty program give ACTC the possibility to send you personalized advertisements and promotional offers based on your previous purchases and your browsing style on the company's website. Once enrolled, you will receive a confirmation email to the email address provided during the form completion. During your participation in the program, you will be informed about its progress and other initiatives through periodic emails. Legal basis: your consent pursuant to Art. 6.1 lit. a) GDPR. Consent can be revoked at any time by writing to the data controller at shoponline@termeskincare.it or to the data protection officer at one of the contact points indicated in this privacy policy. The revocation of consent does not affect the lawfulness of processing based on consent before its withdrawal. Retention period: your personal data will be stored as long as you maintain your loyalty program enrollment and, in any case, for the subsequent ten (10) years from that moment for accounting purposes related to individual purchases.
B. Purchase of products and services and related delivery/provision. Personal data processed: data necessary for order processing and completion, delivery, and post-sale customer service, such as: first name, last name, shipping address, email address, telephone number, and other information that may be necessary to fulfill product delivery or service provision, or that the user may voluntarily communicate (e.g., tax code). For the points initiative mechanics, please refer to the specific regulations. Purpose: to receive and manage orders, provide services and deliver requested products, manage payments, and strictly related activities. In relation to payment, depending on the chosen method, it may be necessary to transfer personal data to the chosen service provider and to those parties to whom communication is necessary to allow the completion of the transaction. Such parties will act as independent data controllers, and for their privacy policies, please refer to their respective websites. Legal basis: Art. 6.1 lit. b) GDPR as processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Retention period: for the entire duration of order management and related delivery, and for ten (10) years from product delivery or service provision for administrative and accounting purposes.
C. Abandoned cart. Personal data processed: first name, last name, email address, and information relating to products placed in your cart but not yet purchased. Purpose: if products are placed in the cart and the page is subsequently abandoned, the user will be recontacted by sending an email to the provided address. Legal basis for processing: Art. 6.1 lit. f) GDPR as processing is necessary for the legitimate interests pursued by the controller. The user may object to this processing by clicking on the appropriate link contained in the emails containing the aforementioned reminder, or by sending an email to the controller indicating the wish not to receive further communications. Retention period: your data will be processed for this purpose for a maximum of six (6) days from the moment you started the purchase procedure, after which you will no longer be contacted for this purpose. If you object to the processing, your personal data will not be processed for this purpose once your request is received.
D. Legal obligations. Personal data processed: the same data collected during the purchase of products and services and related delivery/provision. Purpose: to fulfill legal, accounting, and tax obligations related to the sale of products and services. Legal basis: Art. 6.1 lit. c) GDPR as it is necessary for compliance with a legal obligation to which the controller is subject. Retention period: ten (10) years from product delivery or service provision for administrative and accounting purposes.
The user's personal data may be processed, if necessary and after their provision for the purposes mentioned above, to ascertain, exercise, or defend a right in court, based on ACTC's legitimate interest (Art. 6.1 lit. f) GDPR).

4. RECIPIENTS OF PERSONAL DATA

4.1. To provide the requested services, the data controller may entrust your personal data to various service providers, with whom a specific contract has been drawn up to protect your personal data and comply with personal data protection regulations.
4.1.1. These are subjects identified as data processors pursuant to Art. 28 GDPR to whom the controller has entrusted, non-exhaustively, the following services: a) shipment tracking; b) user and customer database management; c) technical maintenance activities (including maintenance of network equipment and electronic communication networks); etc.
4.2. The controller may need to communicate your personal data to third parties for other purposes such as, for example, shipping couriers, consulting in specific matters (privacy), legal actions, etc.
4.2.1. Such subjects may process, as the case may be, your personal data based on a specific assignment pursuant to Art. 28 GDPR – thus following the instructions and directives provided by the controller – or as independent data controllers.
4.3. In relation to payment, following the chosen method, a transfer of personal data to the chosen service provider and to the parties to whom the communication is necessary to allow the completion of the transaction may be required.
4.3.1. These will act as independent data controllers, and for their privacy policies, please refer to their respective websites.
4.4. The controller may communicate your personal data to subjects, entities, or authorities to whom communication is mandatory by virtue of legal provisions or orders from authorities.
4.4.1. Such subjects will operate as independent data controllers.
4.5. Your personal data may be processed by persons authorized by the controller to process data pursuant to Art. 29 GDPR, who have committed to confidentiality or have an appropriate legal obligation of confidentiality, such as the controller's employees.
4.6. The complete list of data processors is available by sending a request to the controller at one of the contact points indicated in this privacy policy.

5. DATA TRANSFERS TO NON-EU COUNTRIES

5.1. The management and storage of personal data carried out by the controller will take place on servers located inside and outside the EEA.
5.1.1. Regarding transfers outside the EEA, data will be transferred:
- to Israel, based on the European Commission's adequacy decision of January 31, 2011;
- to the United States based on standard contractual clauses.

6. DATA SUBJECT RIGHTS, COMPLAINT 

6.1. The following rights may be exercised, also by writing to the controller's contact points indicated in this privacy policy: a) the right of access pursuant to Art. 15 GDPR; b) the right to rectification pursuant to Art. 16 GDPR; c) the right to erasure (right to be forgotten) pursuant to Art. 17 GDPR; d) the right to restriction of processing when one of the cases provided for by Art. 18 GDPR applies; e) the right to receive confirmation that the operations carried out in accordance with Arts. 16, 17, and 18 GDPR have been brought to the attention of those to whom the data have been communicated, unless this proves impossible or involves a disproportionate effort (Art. 19 GDPR); f) the right to data portability pursuant to Art. 20 GDPR; g) the right to object to the processing of personal data pursuant to Art. 21 GDPR; h) the right not to be subject to a decision based solely on automated processing pursuant to Art. 22 GDPR; i) the right to withdraw consent at any time pursuant to Art. 7 GDPR, as described above; l) the right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR.

7. FURTHER INFORMATION

7.1. The controller remains available for any need for clarification and, should the processing be modified, will update this privacy policy.
7.2. If necessary in relation to specific and further purposes, the controller will provide you with a specific privacy policy.
7.3. The purchase of products made from this website is reserved for adults: the parent or legal guardian who believes that a minor has transmitted personal data to the controller is requested to contact us at the address indicated in this privacy policy.