Contents

1. Definitions used in this Privacy Policy
2. Data protection principles we follow
3. What are your rights regarding your Personal Data
4. What personal data we collect about you
5. How we use your personal data
6. Who has access to your personal data
7. How we keep your data safe
8. Cookie information
9. Contact Information

Definitions

Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations that is performed on Personal Data or a set of Personal Data.
Data subject – A natural person whose personal data is being processed.
Child – A natural person under the age of 16.

Data protection principles

We follow the data protection principles listed below:

• Processing is lawful, fair and transparent. We always take your rights into account before processing your personal data. We will be happy to provide any information you request regarding the process.
• Processing is limited to the purpose. Our processing activities fit the purpose for which the personal data was collected.
• Processing is performed with minimal data. We only collect and process the minimum amount of Personal Data required for any purpose.
• Processing is limited to a period of time. We will not store your personal data for longer than necessary.
• We will do our best to ensure the accuracy of the data.
• We will do our best to ensure the integrity and confidentiality of your data.

Rights of the interested party

The interested party has the following rights:

1. Right to information – you have the right to know if your personal data is being processed; what data is collected, from where it was obtained and why and by whom it is processed.
2. Right of access – you have the right to access the data collected from / about you. This includes the right to request and obtain a copy of the personal data collected.
3. Right of rectification: you have the right to request the rectification or deletion of your personal data if it is inaccurate or incomplete.
4. Right to erasure: in certain circumstances it is possible to request the erasure of personal data from our archives.
5. Right to restrict processing – meaning that if certain conditions apply, you have the right to restrict the processing of your personal data.
6. Right to object to processing: in some cases you have the right to object to the processing of your personal data, for example in the case of direct marketing.
7. Right to object to automated processing: you have the right to object to automatic processing, including profiling; and not to be subject to a decision based solely on automated processing. This right can be exercised whenever there is a profiling result that produces legal effects that affect or significantly affect you.
8. Right to data portability: You have the right to obtain your personal data in a machine-readable format or, if possible, as a direct transfer from one processor to another.
9. Right to lodge a complaint: In the event that we refuse your request under the Access Rights, we will provide you with the opportunity to explain why. If you are not satisfied with the way your request has been handled, please contact us.
10. Supervisory Authority right to help – you have the right to help from a supervisory authority and other legal remedies such as claiming compensation damage.
11. Right to withdraw consent – the user has the right to withdraw any consent for the processing of their personal data

What data we collect

The information you have provided to us
For example your e-mail address, name, billing address, home address etc. This is mainly information that is necessary to provide you with a product / service or to improve your customer experience. We save the information you provide to us in order for you to comment or perform other activities on the website. This information includes, for example, your name and e-mail address.

Automatically Collected Information About You
This includes information automatically stored by cookies and other session tools. For example, shopping cart information, IP address, purchase history (if any) etc. This information is used to improve the customer experience. When using our services or viewing content on our website, activities may be logged.

Information from our partners
We collect information from our trusted partners with confidence that they have a legal basis to share that information with us. This information was provided directly or was collected legally for other reasons.

Information available
We may collect public information about you.

How we use your personal data

We use your personal data to:

• provide you with our service, this includes for example registering your account. Provide you with other products and services that you have requested; promotional items at your request; by communicating with you in connection with such products and services; notifying you of changes to any services.
• improve your customer experience;
• fulfill an obligation established by law or by contract;

We use your personal data for legitimate reasons and / or with your consent.

For reasons related to the conclusion of a contract or the fulfillment of contractual obligations, we process your personal data for the following purposes:

• to identify you;
• to provide you with a service or to send / offer you a product;
• for communications on sales or billing;

For reasons of legitimate interest, we process your personal data for the following purposes:

• to send you personalized offers * (from us and / or our carefully selected partners);
• to administer and analyze our customer base (purchasing behavior and history) in order to improve the quality, variety and availability of the products / services offered / provided;
• to conduct customer satisfaction questionnaires;

Unless you have informed us otherwise, we will advise you in offering products / services similar or identical to your purchase history or regarding your browsing, as is in our legitimate interest.

With your consent we process your personal data for the following purposes:

• to send you newsletters and promotional offers (from us and / or our carefully selected partners);
• for other purposes for which we have asked for your consent;

We process your personal data in order to fulfill the obligations arising from the law and / or use your personal data for the options provided by law. We reserve the right to anonymize the personal data collected and to use such data. We will use data outside the scope of this policy only if it is anonymized. We will retain your billing information and other information collected about you for as long as is necessary for accounting purposes or other obligations deriving from law, but no longer than

We may process your personal data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was collected.

To do this, we will make sure that:

• the link between purpose, context and nature of Personal Data is suitable for further processing;
• further processing would not harm your interests and
• would there be adequate protection for processing.

We will notify you of any further processing and purposes.

Who else can access your personal data

We will not share your personal data with strangers. Your personal data is in some cases provided to our trusted partners in order to make it possible to provide the service or improve the customer experience.

We only work with data processing partners who are able to guarantee an adequate level of protection of personal data. We disclose your personal data to third parties or public officials only if legally obliged to do so. We may disclose your personal data to third parties if you have consented or if there are other legal reasons for doing so.

How we protect your data

We do our best to keep your personal data safe. We use secure protocols for communication and data transfer (such as HTTPS). We use anonymity or pseudonyms where appropriate. We monitor our systems for possible vulnerabilities and attacks.

Even if we try our best, we cannot guarantee the security of your information. However, we are committed to reporting data breaches to the relevant authorities. We will also notify you if there is a threat to your rights or interests. We will do everything reasonably possible to prevent security breaches and assist authorities in the event of breaches.

If you have an account with us, please note that you must keep your username and password secret.

Children

We do not intend to collect or knowingly collect information about children. Our services do not target children.

Contact information

Supervisory Authority
Email: garante@garanteprivacy.it
Phone: +39 06 69677 1

Changes to this privacy policy

We reserve the right to make changes to this Privacy Policy.