1) IMPORTANT INFORMATION AND WHO WE ARE
Our office is located Via Pescara 44, Milano (MI) – CAP 20142. You have the right to make a complaint at any time to the Office of the he Italian Data Protection Authority(IDPA), the Italian supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the IDPA. So please contact us in the first instance.
This version was last updated on 24/09/2018. It is important that the personal data we hold about you are accurate and current. Please keep us informed if your personal data change during your relationship with us.
2) THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Information You Give Us: We receive and store any information you enter on our website or give us in any other way. Mostly, you provide such information when you search, buy, post, or communicate with customer service. For example, you provide information when you search for a product; place an order; communicate with us by phone, E-mail, or otherwise. As a result of those actions, you might supply us with such information as your name, address, E-mail and phone numbers; people to whom purchases have been shipped, including addresses and phone number.
Automatic Information: We receive and store certain types of information whenever you interact with us. For example, like many websites, we use “cookies,” and we obtain certain types of information when your web browser accesses our website.
Information from Other Sources: We might receive information about you from other sources and add it to our account information. Examples of information we receive from other sources include updated delivery and address information from our carriers, which we use to correct our records and deliver your next purchase or communication more easily.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods). In this case, we may have to cancel an order you have placed with us but we will notify you if this is the case at the time.
3) HOW ARE YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you.
Information you give us. This is information about you that you give us when you search, buy, post or communicate with customer service. You give us this information by filling a form of order or by communicating with our customer service.
Third parties or publicly available sources. We may receive personal data about you from analytics providers such as Google based outside the EU or from our carriers, which we use to correct our records and deliver your next purchase or communication more easily.
4) HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
If you need details about the specific legal ground we are relying on to process your personal data, please consider the information set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
|To process and deliver your order||(a) Identity
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content to you||(a) Identity
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform about our marketing strategy)|
|To use data analytics to improve our website, products/services, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform about our marketing strategy)|
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6) DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
1. Third Parties such as our carriers to deliver your goods;
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7) INTERNATIONAL TRANSFERS
We share your personal data with our contractors to fulfill the purposes we collected them for. This involves transferring your data outside the European Economic Area (EEA), namely to the Russian Federation, Ukraine, Belarus, and the United States.We ensure your personal data are protected by requiring all our contractors to follow the same rules when processing your personal data.
Please contact us if you would like to obtain further information on the specific mechanism used by us when transferring your personal data outside the EEA.
8) DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9) DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
In some circumstances you can ask us to delete your data (request erasure). In some circumstances we may anonymise your personal data (so that they can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10) YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data, namely:
а) Request access to your personal data.
b) Request correction of your personal data.
c) Request erasure of your personal data.
d) Object to processing of your personal data.
e) Request restriction of processing your personal data.
f) Request transfer of your personal data.
g) Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.