INFORMATION ON THE PROCESSING OF PERSONAL DATA pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (GDPR)

Premise

This information is provided for the website “https://www.shop.sicurpal.it” (Website) owned by Sicurpal Srl, via dei Mestieri 12, 41030 Bastiglia (MO) Italy, P.IVA 02399900360, as the Data Controller under the GDPR (General Data Protection Regulation).

Purchases on the Website

Subject to your provision, your personal information will be processed to enable you to make purchases from the Website.

Registration

The information and data requested in the case of registration will be used to enable you both to access the restricted area of the Site and to use the online services offered by the Data Controller to registered users.

Marketing

Subject to your consent, the Data Controller may process the personal data you provide in order to send you advertising material and/or newsletters regarding its own or third parties’ products and/or services.

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 through the revelation of the type and frequency of your purchases, in order to send you advertising material and/or newsletters related to its own or third parties’ products and/or services of your specific interest.

Soft spamming

The Data Controller may use, for the purpose of the direct sale of products and/or services offered for sale through the Site, the e-mail coordinates provided by you in the context of a purchase on the Site, even without your consent, provided that it is for a product and/or service similar to the one that was the subject of the previous sale (so-called soft spamming). You may still refuse this processing at any time by notifying the Data Controller of your objection.

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In compliance with the GDPR, we hereby wish to inform you that the Data Controller will process your personal data under the following conditions.

Art. 1. Purpose and legal basis for processing. Mandatory or optional conferral. Consequences of refusing treatment.

The processing of personal data is directed toward achieving the following purposes:

1. to enable registration on the Site and access to services reserved for registered users as well as to enable compliance with obligations arising from the law or regulations in force, in particular, in the areas of administration, accounting, public safety. The legal basis for the processing is the Data Controller’s need to execute pre-contractual measures taken at the request of the data subject or to comply with a legal obligation;
2. in the case of placing an online purchase order, to enable the conclusion of the purchase contract and the proper execution of transactions related to it (and, if necessary under industry regulations, to fulfill tax obligations). The legal basis for processing is the obligation of the Data Controller to perform the contract with the data subject or to fulfill legal obligations;
3. limited to the email details you provide in the context of a purchase through the Site, to enable direct offers by the Data Controller of similar products and/or services (so-called soft spamming), provided that you do not object to such processing in the manner set forth in this policy. The legal basis for processing is the legitimate interest of the Data Controller in sending these types of communications. This legitimate interest can be considered equivalent to the data subject’s interest in receiving “soft-spam” communications;
4. subject to your consent, for sending newsletters and conducting market surveys, including those aimed at assessing the degree of user satisfaction, and sending advertising material relating to products and/or services of the Data Controller and/or third parties, by means of systems such as email, sms, traditional methods (paper mail and/or telephone) (marketing purposes); subject to your consent, for the processing of your commercial profile, through the detection and processing of your purchasing choices and habits, in order both to monitor the degree of customer satisfaction and to send you advertising material, related to products and/or services of the Data Controller and/or third parties, of your specific interest, by means of systems such as email, sms, traditional methods (paper mail and/or telephone) (profiling purposes). The legal basis for processing is the consent of the data subject;
5. if the chat service is operational, allow the activation of the service, through which the user can contact and be contacted of the Data Controller, subject to your consent, during your navigation on the Site. The legal basis is the legitimate interest of the Data Controller in carrying out this type of activity. This legitimate interest can be considered equivalent to the data subject’s interest in using the Site’s chat service;
6. To respond to your inquiries through the customer care service. Providing this information is optional, but your refusal will make it impossible for the Data Controller to answer your questions through this service. The legal basis for the processing is the legitimate interest of the Data Controller in fulfilling the user’s requests. This legitimate interest is equivalent to the user’s interest in receiving responses to communications sent to the Data Controller;
7. To respond by email, phone, mail to your inquiries. Providing it is optional, but your refusal will make it impossible for the Data Controller to respond to your requests. The legal basis for processing is the legitimate interest of the Data Controller in responding to user requests. This legitimate interest is equivalent to the user’s interest in receiving responses to communications sent to the Data Controller.

Consent to the processing of your data for marketing and profiling purposes is purely optional. Failure to consent will entail only the consequences described below.

Failure to consent to the processing of data for marketing purposes will result in the impossibility for you to receive advertising material related to products and/or services of the Data Controller and/or third parties as well as the impossibility for the Data Controller to conduct market surveys, including those aimed at assessing the degree of user satisfaction, as well as to send you newsletters.

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, through the detection of your purchasing choices and habits as well as to send you advertising material, related to products and/or services of the Data Controller and/or third parties, of your specific interest.

Notwithstanding the foregoing, it is understood that the Data Controller may nevertheless use your personal data for the sole purpose of properly fulfilling its obligations under applicable laws and its obligations arising from the contractual relationships existing between you and the Data Controller.

If you have registered for the Site, you may in any case change your consent for the purposes described above at any time by accessing your personal page.

Please note that you may also object to the processing of your personal data via the appropriate link at the bottom of any promotional content email sent by the Data Controller. Opposition expressed in this manner also extends to the sending of communications through the postal service.

Payment card data

To make a payment through one of the payment cards offered on the Site, the user will have to enter the confidential data of the payment card directly on a page that will communicate through secure encryption protocol with the payment service provider (who will act as an autonomous data controller), without transiting through the server of the Data Controller who, therefore, will not process such data in any way. The data will be captured in an encrypted format.

With reference to the payment card data, it should be noted that the processing of your personal data is necessary to enable the conclusion of the online purchase contract with the Data Controller. Failure to provide this data, therefore, will not allow you to complete the online purchasing process.

PayPal

On the Site you can also purchase via the PayPal payment tool. In this case, you will be directed to a page outside the Site, where you will have to indicate the personal data required by PayPal – which will act as an autonomous data controller – to complete the purchase process. Personal data will not pass through the server of the Site, which, therefore, will not process such data in any way. The processing of your personal data is necessary to enable the conclusion of the online purchase contract with the Data Controller. Failure to provide this data, therefore, will not allow you to complete the online purchasing process.

Bank transfer

If you choose bank transfer as the payment instrument, in the presence of any hypothesis of reimbursement, the Data Controller will provide you with the useful bank details in order to arrange the payment.

Special or judicial data

The Data Controller does not process special or judicial data.

Public Profile

If you have registered for the Site, you will have the opportunity to make your profile public, through which users can view your personal information. You agree to indemnify the Data Controller against any damage or harm, even potential, that you have suffered from the publication of personal data posted on your profile.

Art. 2. Method of treatment

The processing of your personal data will be mainly carried out with the aid of electronic or otherwise automated means, in the manner and with the appropriate tools to ensure their security and confidentiality in accordance with the GDPR.

The information acquired and the manner of processing will be relevant and not excessive in relation to the type of services rendered. Data will also be managed and protected in environments whose access is under constant control.

Art. 3. Communication and dissemination of data

Your data may be disclosed:

• to all those entities (including Public Authorities) that have access to personal data by virtue of regulatory or administrative measures
• To companies or third parties engaged to provide printing, enveloping, shipping and/or delivery and/or pickup services for products purchased through the Site
• to post offices, couriers, suppliers (e.g., drop shipping sales) or freight forwarders responsible for delivery of products purchased through the Site
• to banking institutions and companies that operate national or international payment circuits through which online payments are made for products purchased through the Site
• to companies, consultants or professionals that may be entrusted with the installation, maintenance, updating and, in general, the management of the hardware and software of the Data Controller or that the latter uses for the provision of its services
• to external companies in charge of sending advertising communications on behalf of the Data Controller
• To the company in charge of carrying out customer care activities
• To entities that handle online payment transactions
• to all those public and/or private entities, individuals and/or legal entities (legal, administrative and tax consulting firms, Judicial Offices, Chambers of Commerce, Chambers and Offices of Labor, etc.), if the communication is necessary or functional for the proper fulfillment of obligations arising from the law.

Your data will not be disseminated, except in anonymous and aggregate form, for statistical or research purposes.

Art. 4. Data Controller

The Data Controller can be contacted at the following contact details:

Sicurpal Srl – Via dei Mestieri, 12 – 41030 Bastiglia (MO) – Italy
Phone number: + 39 059 818179
Email: ecommerce@sicurpal.it
Through the contact form on the Site.

Art. 5. Storage of personal data

Personal data will be stored and processed for marketing purposes for a period of 24 months and for profiling purposes for a period of 12 months. At the end of this period, the Data Controller may ask you to renew your consent to the processing of your data for these purposes or make them anonymous and keep them only for statistical or historical purposes.

For all the remaining purposes set forth in the privacy policy, personal data will be kept only as long as necessary to ensure the proper provision of the services offered.

If the Site account is closed at the user’s initiative, the data in it will be retained for administrative purposes for a period not exceeding 90 days, subject to any specific legal requirements on the retention of accounting records or for public safety purposes.

Art. 6. Rights of the data subject

In accordance with 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 personal data or restriction of processing concerning you or to object to its processing, as well as the right to data portability
• Revoke consent at any time without affecting the lawfulness of processing based on consent given before revocation
• Propose a complaint to a supervisory authority (e.g., the Data Protection Authority).

The above rights may be exercised with a request addressed without formality to the Data Controller at the contacts indicated above.

Art. 7. Changes

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 all cases adequate and similar protection of personal data. In order to view any changes, you are encouraged to review this policy on a regular basis.