The Data Controller has not appointed a DPO. Therefore, you may send any request for information directly to the Data Controller.

GENERAL INFORMATION

This document describes how the Data Controller processes your personal data provided on the Site.

The main processing operations of your personal data are described below. 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. In order to better describe your rights, we have specified if and when a certain processing of personal data is not carried out.

Site registration

The information and data requested in the event of registration will be used to allow you both to access the reserved 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 Data Controller's need to execute pre-contractual measures adopted at the request of the data subject. The provision of data is optional. However, your refusal to provide the data will make it impossible to register on the Site.

Purchases on the Site

Your personal data will be processed to allow you to make purchases on the Site. In the case of an online purchase order, to allow the conclusion of the purchase contract and the correct execution of the operations connected to the same (and, if necessary according to sector regulations, to fulfil tax obligations). The legal basis for the processing is the obligation of the Data Controller to perform the contract with the data subject or to comply with legal obligations. Irrespective of the above (and therefore of your consent), the Data Controller may process your data for so-called "soft-spam" purposes, governed by art. 130 of the Privacy Code. This means that, limited to the email you provided in the context of a purchase through the Site, the Data Controller will process the email to allow a direct offer by similar products/services, unless you object to such processing in the manner provided by this policy. The legal basis of the processing is the legitimate interest of the Data Controller in sending this type of communication. This legitimate interest can be considered equivalent to the interest of the data subject to receive "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 to send this type of communication.

Responding to your requests

Your data will be processed to respond to your requests for information. Providing your data is optional, but refusal to do so will make it impossible for the Data Controller to answer your questions. The legal basis for the processing is the legitimate interest of the Controller in fulfilling your requests. This legitimate interest is equivalent to the user's interest in receiving a reply to communications sent to the Data Controller.

Generic marketing

Subject to your consent, the Data Controller may process the personal data you have provided in order to send you advertising material and/or newsletters about its own products or those of third parties. The legal basis for this processing is your consent. The provision of personal data for this purpose is purely optional. Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to products/services of the Data Controller and/or third parties, and will also make it impossible for the Data Controller to carry out market surveys, including those aimed at assessing the degree of user satisfaction, and to send you newsletters. These communications will be sent to the e-mail address you have provided on the Site.

Profiling

Subject to your consent, the Data Controller may process your personal data for profiling purposes, i.e. to analyse your consumption choices by revealing the type and frequency of your purchases, in order to send you advertising material and/or newsletters relating to its own products or those of third parties, of your specific interest. The legal basis for this processing 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 elaborate your commercial profile, by surveying your choices and purchasing habits, as well as to send you advertising material regarding products of the Data Controller and/or third parties of your specific interest. These communications will be sent to the e-mail address you have provided on the Site.

Data transfer

The Data Controller does not pass on your personal data to third parties.

Geolocation

The Site does not implement tools for geolocating the user's IP address.

Disclosure of personal data

In the ordinary course of its business, the Controller may disclose your personal data to certain categories of persons. In Article 2 you will find a list of the persons to whom the Controller communicates your personal data. In order to facilitate the protection of your rights, Article 2 may specify in certain cases when your data are not communicated to third parties.

The 'communication' of personal data to third parties is different from the 'transfer' (regulated in the preceding point). In fact, in the communication, the third party to whom the data is transmitted may only use it for the specific purposes described in the relationship with the Data Controller. In the transfer, on the other hand, the third party becomes the autonomous Data Controller. Furthermore, your consent is always required for the transfer of your personal data to third parties.

Notwithstanding the foregoing, it is understood that the Data Controller may still use your personal data in order to properly fulfil its obligations under applicable laws.

SPECIFIC PRIVACY POLICY

Art. 1 Processing arrangements

1.1 The processing of your personal data shall mainly be carried out with the aid of electronic or automated means, in accordance with the methods and tools suitable to guarantee their security and confidentiality in accordance with the GDPR.

1.2 The information acquired and the methods of processing 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.

1.3 The Site does not process "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 organisations of a religious, philosophical, political or trade-unionist character, state of health and sexual life.

1.4 No judicial data are processed through the Site.

Art. 2 Communication of personal data

The Data Controller may disclose your personal data to certain categories of persons. The following are the subjects to whom the Data Controller reserves the right to communicate your data:

The Data Controller may communicate your personal data to all those entities (including Public Authorities) that have access to your personal data by virtue of regulatory or administrative measures.

Your personal data may also be communicated to all those public and/or private subjects, natural and/or legal persons (legal, administrative and fiscal consultancies, Judicial Offices, Chambers of Commerce, Chambers and Offices of Labour, etc.), if the communication is necessary or functional to the correct fulfilment of the obligations deriving from the law.

The Data Controller makes use of employees and/or collaborators in any capacity. For the proper functioning of the Site, 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 avails itself of companies, consultants or professionals in charge of the installation, maintenance, updating and, in general, of the management of the hardware and software of the Data Controller or which the latter uses to provide its services. Therefore, only with reference to these purposes, your data may also be processed by these subjects.

In order to send its communications, the Data Controller uses external companies that are responsible for sending this type of communication (CRM platforms). Your personal data (in particular your email address) may therefore be communicated to these companies.

For the purposes of customer care, the Data Controller uses one or more companies to provide customer care services. For this purpose only, your personal data may be communicated to these companies.

The Data Controller reserves the right to modify the above-mentioned list on the basis of its ordinary operations. Therefore, you are invited to regularly access this notice to check to which subjects the Controller communicates your personal data.

Art. 3 Storage of personal data

3.1 This article describes for how long the Data Controller reserves the right to store your personal data.

Your personal data will be kept only for the time necessary to ensure the proper provision of the services offered through the Site.

For marketing purposes, personal data will be stored until consent is revoked. For inactive users, personal data will be deleted after a period of one year from the sending of the last email viewed.

For customer care purposes, the data will be deleted once the service has been completed.

For the purpose of executing the sales contract, the data will be stored for 10 years from the date of receipt of the purchase order. This is to allow the Data Controller to exercise its right of defence and to prove that it has correctly executed the contract.

As provided for in Article 2220 of the Civil Code, 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.

3.2 Without prejudice to 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

4.1 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 country outside the EU and for which the European Commission has issued an adequacy opinion, the transfer is deemed to be safe from a regulatory point of view in any case. 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 your personal data is being transferred to a country with these characteristics.

4.2 Without prejudice to Article 4.1, your data may also be transferred to countries outside the European Union for which the European Commission has not issued an adequacy opinion. You are therefore invited to regularly review this Section 4.2 to find out to which of these countries your data may be transferred.

Article 5. Rights of the data subject

Pursuant to Article 13 of the Privacy Regulations, the Data Controller informs you that you have the right to:

to request from the Data Controller access to and rectification or erasure of your personal data or restriction of the processing of your personal data, or to object to the processing of your personal data, as well as the right to data portability

withdraw consent at any time without prejudice to the lawfulness of the processing based on the consent given before withdrawal

complain to a supervisory authority (e.g. the Data Protection Authority).

The above-mentioned rights may be exercised by making a request to the contacts indicated in the Foreword.

Art. 6. Amendments and Miscellaneous

The Data Controller reserves the right to make changes to this policy at any time, giving appropriate publicity to users of the Site and ensuring in any case an adequate and similar protection of personal data. In order to view any changes, you are invited to regularly consult this policy. In the event of substantial changes to this privacy policy, the Data Controller may give notice of such changes by email.