on the processing of personal data pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR).
Effective as of 01/11/2022
- This information takes into account the provisions of the GDPR and the Italian Privacy Code (Legislative Decree 30 June 2003 n. 196). The document has also been drafted in accordance with the Guidelines of the Italian Privacy Guarantor (especially the Guidelines for combating spam issued by the Privacy Guarantor on July 4, 2013).
- Data Controller: VETROFUSO di Daniela Poletti, registered address: Viale G. Oberdan, 360 – 47521 Cesena (FC), Italy – VAT Nr: 02483350407 – Registration Number: 278218 – Tel. +39 0547 402553 – Email firstname.lastname@example.org
- The Data Controller has not appointed a DPO (Data Protection Officer). Therefore, you may send any inquiries directly to the Data Controller.
- This document describes how the Data Controller processes your personal data.
- This document also describes, to the extent in which it’s compatible, how the Data Controller processes the personal data you provide by electronic correspondence (email), either following your requests sent via the Site or if this document is appropriately made available to you.
- The following describes the main processing of your personal data. In particular, we explain the legal basis of the processing, whether the provision of personal data is compulsory and the consequences of not providing personal data. To better describe your rights, if necessary, we have specified if and when a certain processing of personal data is not carried out. On the Site you have the possibility to enter personal data of third parties. In this case you guarantee to have obtained the consent of these subjects to the insertion of these personal data. Therefore, you agree to indemnify and hold harmless the Data Controller from any liability.
- The information and data requested in case of registration will be used to allow you both to access the private area of the Site and to use the online services offered by the Data Controller to registered users. The legal basis of the processing is the need for the Data Controller to execute pre-contractual measures taken at the request of the data subject. The conferment of data is optional. However, your refusal to provide the data will make it impossible to register on the Site.
- Your personal data will be processed to allow you to make purchases, either through the Site or by email. In the case of making an online purchase order, to allow the conclusion of the purchase contract and the proper execution of transactions related to the same (and, if necessary under the legislation, to fulfill tax obligations). The legal basis for the processing is the obligation of the Data Controller to execute the contract with the data subject or to comply with legal obligations. Apart from the above (and therefore your consent), the Data Controller may process your data for the purpose of so-called “soft-spam”, governed by art. 130 of the Italian Privacy Code (Codice della Privacy).
- This means that limited to the email you provide in the context of a purchase through the Site or by email, the Data Controller will process the email to allow the direct offer of similar products/services, provided that you do not object to this treatment in the manner provided for by this information. The legal basis for processing is the legitimate interest of the Data Controller to send this type of communication. This legitimate interest can be considered equivalent to the interest of the data subject in receiving “soft-spam” communications. The Data Controller may send emails to remind the user to complete a purchase. The legal basis for this processing is the legitimate interest of the Data Controller in sending this type of communication.
Answering your Requests
- Your data will be processed to respond to your requests for information. The conferment is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis for the processing is the legitimate interest of the Data Controller in fulfilling your requests. This legitimate interest is equivalent to the user’s interest in receiving a response to communications sent to the Data Controller.
- The Data Controller will not send you advertising material and/or newsletters regarding its own products or those of third parties.
Analysis and Profiling
- Subject to your consent, the Data Controller may process your personal data for profiling purposes, i.e. for the analysis of your consumption choices by revealing the type and frequency of purchases you have made, in order to send you advertising material and /o newsletters relating to own or third party products, of specific interest to you. The legal basis of this treatment is your consent. The provision of data for this purpose is purely optional. Failure to consent to the processing of your personal data for profiling purposes will make it impossible for the Data Controller to process your commercial profile, through the detection of your choices and purchasing habits as well as to send you advertising material relating to the Controller’s products of the Processing and/or third parties, of your specific interest.
- Under the same conditions as in the previous paragraph, the Data Controller may collect information on the use of the Site and use this information for statistical analyses, to improve the Site and simplify its use, as well as to monitor its correct functioning. If the processing of such statistical analyzes is entrusted to third parties, user data must be minimized in advance and cannot be combined with other processing or transmitted to other third parties.
- The Data Controller does not transfer your personal data to third parties.
- The Site does not implement tools to geolocate the user’s IP address.
Communication of Personal Data
- As part of its ordinary business, the Data Controller may communicate your personal data to certain categories of subjects. In article 2 you can find the list of subjects to which the Data Controller communicates your personal data. In order to facilitate the protection of your rights, Article 2 may specify in certain cases when your data is not communicated to third parties.
- The “communication” of personal data to third parties is different from the “transfer” (governed by the preceding point). In fact, in the communication the third party to whom the data is transmitted can use it only for the specific purposes described in the relationship with the Data Controller. In the transfer, instead, the third party becomes the autonomous Data Controller. Moreover, to transfer your personal data to third parties is always required your consent.
- Without prejudice to the foregoing, it is understood that the Data Controller may still use your personal data in order to correctly fulfill the obligations provided for by the laws in force.
Art. 1 Processing Methods
- The processing of your personal data will be mainly carried out with the help of electronic or automated means, according to the methods and with the tools suitable to ensure their security and confidentiality in accordance with the GDPR.
- The information acquired and the methods of treatment will be relevant and not excessive in relation to the type of services rendered. Your data will also be managed and protected in secure computer environments appropriate to the circumstances.
- Through the Site are not processed “special data”. Particular data are those that can reveal racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade union, health and sex life.
- No judicial data is processed through the Site.
- The Site does not address nor knowingly collect personal data from anyone under the age of 16. If the Data Controller becomes aware that the Site have collected personal data from anyone under the age of 16 without verification of parental consent, the Data Controller will take steps to delete that information.
Art. 2 Communication of personal data
- The Data Controller may communicate your personal data to certain categories of subjects. The subjects to whom the Data Controller reserves the right to communicate your data are indicated below:
- The Data Controller may communicate your personal data to all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative measures.
- Your personal data may also be disclosed to all those public and / or private individuals and / or legal entities (legal, administrative and tax, judicial offices, Chambers of Commerce, Chambers and Offices of Labor, etc..), if the communication is necessary or functional to the proper fulfillment of obligations under the law.
- The Data Controller uses employees and/or collaborators in any capacity. For the correct functioning of the Site, or for the purposes of processing your requests for information or purchase orders, the Data Controller may communicate your personal data to these employees and/or collaborators.
- In its ordinary activity of managing the Site, the Data Controller makes use of companies, consultants or professionals in charge of the installation, maintenance, updating and, in general, the management of the hardware and software of the Data Controller or which the latter uses for the provision of its services. Therefore, only with reference to these purposes, your data may also be processed by these subjects.
- The Data Controller does not use CRM platforms (companies that carry out the activity of sending automated communications to users. Therefore, your personal data are not communicated to these companies.
- The Data Controller does not use external companies to provide customer care services. Therefore, your personal data will not be processed for this purpose.
- The Data Controller reserves the right to modify the above list in accordance with its ordinary operations. Therefore, you are invited to regularly access this information to check to which subjects the Data Controller communicates your personal data.
Art. 3 Personal Data Retention
- This article describes how long the Data Controller reserves the right to retain your personal data.
- User data will be kept only for the time necessary to ensure the proper provision of the services offered through the Site.
- As provided for in Article 2220 of the Italian Civil Code (Codice Civile), invoices, as well as all accounting records in general, are kept for a minimum period of ten years from the date of registration, so that they can be presented in the event of an audit.
- Without prejudice to the provisions of Article 3.1, the Data Controller may retain your personal data for the time required by specific regulations, as amended from time to time.
Art. 4 Transfer of Personal Data
- The Data Controller is based within the European Union. Therefore, the processing of your data is safe from a regulatory point of view as it is governed by the GDPR. If the transfer of your personal data takes place in a non-EU country and for which the European Commission has issued an adequacy opinion, the transfer is in any case considered safe from a regulatory point of view. This Article 4.1 indicates from time to time the countries to which your personal data may possibly be transferred and where the European Commission has issued an adequacy opinion.
- You are therefore invited to access this article regularly to check whether the transfer of your personal data takes place in a country with these characteristics.
- Without prejudice to what is stated in article 4.1, your data may also be transferred to countries outside the EU for which the European Commission has not issued an adequacy opinion. You are therefore invited to regularly review this article 4.2 to find out to which of these countries your data may be transferred.
- In order to allow for the proper functioning of the Site, your personal data may be transferred to the U.S.A.. In these cases, the Data Controller will take all appropriate contractual measures to ensure an adequate level of protection of personal data, including, among others, the Standard Contractual Clauses approved by the European Commission on June 4, 2021.
- In this article, the Data Controller indicates the countries in which it may specifically direct its activities. This circumstance may imply the application of the legislation of the country of reference, together with that of the GDPR.
- The Site processes personal data of individuals located in Australia. This notice has been prepared taking into account the provisions of Australian national and federal legislation. In particular, reference is made to the Federal Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).
- The Site also handles personal data of users from California. The California Consumer Privacy Act (CCPA) is a California law that was passed in June 2018. The Data Controller processes personal data of California users under this law. The user is informed that the personal data processed are those communicated on the Site to allow the execution of the contract. The user may exercise their rights under the CCPA by contacting the Data Controller at the contact details published in the foreword.
- At the request of the user, the Data Controller will apply to the processing of personal data any more favourable legislation provided for by the user’s national legislation.
Art. 5 Your rights under the GDPR
- Pursuant to art. 13 of the Italian Privacy Regulations (Regolamento Privacy), the Data Controller informs you that you have the right:
- to request from the Data Controller access to your personal data and the rectification or erasure of the same or the restriction of the processing thereof or to object to the processing thereof, in addition to the right to data portability,
- revoke consent at any time without affecting the lawfulness of the processing based on the consent given before revocation,
- to lodge a complaint with a supervisory authority (e.g. the Italian Data Protection Authority).
- The rights referred to above may be exercised by making a request without formalities to the contacts indicated in the Introduction.
Art. 6 Amendments and Miscellanea