GENERAL INFORMATION :
2. PERSONAL DATA PROVIDED VOLUNTARILY BY THE USER
The expression “Personal Data” has the meaning given in the applicable legislation regarding the protection of personal data and indicates any information relating to the user and which could be used, directly or indirectly, to identify them.
Among the Personal Data collected by the Site, independently or through third parties, there are: name, surname, date and place of birth, tax code, address of residence/office, municipality, province, zip code, mobile phone number, email , certified email, data for invoice header, VAT number. It is therefore common data, not belonging to the category of sensitive data.
Fangorosa collects and processes the Personal Data that the user voluntarily provides when interacting with the features and services of the Site, for example in case of requests for information. In the sections of the Site where the User’s Personal Data are collected, specific information published pursuant to Article 13 of the GDPR and applicable laws are published.
The Data will be processed in compliance with the principles of purpose limitation, data minimization, accuracy, limitation of conservation, relevance, non-excess and protection of confidentiality.
2.A. NAVIGATION DATA ON THE SITE – COOKIES
This section specifies what data Fangorosa may collect during simple navigation on the Website, without logging in as a registered user. Unless otherwise indicated on the Site by requesting the user to perform specific actions that are required by local legislation, by accessing and using this Site you declare that you have read the provisions of this section of the Policy.
In case of visit and consultation of the Site, Fangorosa generally collects navigation data through cookies or other tracking technologies. In fact, the technological platform through which the Site is made available to the user automatically records some browsing data – the transmission of which is implicit in the use of Internet communication protocols – such as, for example, the name of the access provider to the Internet network, Site of origin, pages visited, date and duration of the visit, etc. This information allows access to the Site as well as the use of some services and can be used anonymously and in aggregate form for statistical purposes and to verify the correct functioning of the Site.
Fangorosa uses them to facilitate access to online services, authenticate the user if it is a previously registered user, store the items inserted in the shopping cart, study the users’ consumption choices in order to make the products and initiatives more responsive to the tastes and needs of its customers.
Browsing data are kept for no more than 7 days, and are deleted immediately after their aggregation (excluding specific needs in the context of legal proceedings).
2.B. CONTACTS AND REGISTRATION FOR INFORMATION SERVICES
This section clarifies what data Fangorosa may collect when you contact us and/or ask to receive our commercial communications.
If you contact us for specific requests relating to the Site, including technical assistance for navigation problems, we may receive some of your Personal Data (mainly contact data and identification data or information strictly related to your request). In this case, your personal data will be used by the owner’s staff in charge of managing your request for the sole purpose of processing the same and may be communicated to our service providers where necessary to manage your request and depending on the subject of the same.
By registering on our site, to our e-mail service to receive announcements and communications from Fangorosa, you provide us with contact details and identification data. The Personal Data required to complete the registration procedure is limited, but they are all essential in order to receive our communications.
Please make sure that your data are correct and, if the personal data you have provided to us change, we invite you to write to us as soon as possible, or to directly modify the data online in the “my account” area, in case the service “my account” is available. In this way we will be able to keep your Personal Data updated.
3. PURPOSE OF PROCESSING
Your personal data are processed:
A) without your express consent (art. 24 letter a)b), c) Privacy Code and art. 6 lett. b), e) GDPR), for the following Service Purposes:
1) operational management of navigation on the Site;
2) Site security management;
3) fulfillment of legal and regulatory obligations;
4) exercise of rights in court;
5) customer care;
6) management of sales and transactions carried out in the context of the Site;
7) management of orders, sale and delivery of products;
8) management of returns and guarantees and other activities necessary for the sale of products through the Site. In the cases indicated above, the legal basis for the processing of your personal data consists in executing a contract with you or in providing the service that you have specifically requested or in following up on a legal obligation or in protecting our legitimate interest.
B) Only subject to your specific and distinct consent (articles 23 and 130 of the Privacy Code and article 7 of the GDPR), for the following other purposes:
9) sending the Fangorosa newsletter after registering for users;
10) sending opinion and satisfaction surveys;
11) statistical and market analysis. The legal basis for these purposes is the consent you have issued which can be revoked at any time.
Limited to the purposes referred to in point B, the provision of your e-mail address and other requested data is optional, but it is necessary to be able to complete the subscription to the Fangorosa newsletter. Failure to provide such data will preclude your subscription to the Fangorosa newsletter.
4. DURATION OF THE PROCESSING AND DATA RETENTION PERIOD
Except as already indicated above for navigation data, pursuant to art. 2.A., the Data Controller will process personal data for the time necessary to fulfill the purposes referred to in the previous art. 3 and in any case in compliance with the terms established by law.
In any case, the data relating to the detail of the purchases with reference to identifiable customers are kept for profiling or marketing purposes for a period not exceeding, respectively, 12 (twelve) and 24 (twenty-four) months from their registration, subject to the real transformation into anonymous form that does not allow, even indirectly or by linking other databases, to identify the interested parties.
The data provided for subscribing to the newsletter are kept until the eventual “unsubscription” from the newsletter service, freely available at any time through the link at the bottom of each message sent or directly on the homepage of the site and in any case no later than 24 (twenty four) months.
The data relating to billing and accounting entries will be kept for a period of 10 (ten) years from the issue of the invoice.
5. NATURE OF THE PROVISION
Except for the navigation data referred to in art. 2.A. (collected automatically by the system), the provision of data by the user for the purposes indicated above is optional. Any failure to provide data will have no consequence on its ability to access the features offered by the Site, except for the inability to proceed with the purchase of products and/or to send requests for information and/or to proceed to the registration for the newsletter.
6. PROCESSING METHODS AND SECURITY MEASURES
The user’s personal data are processed through IT and telematic methods, mainly with electronic and automated means and, limited to particular operations, via paper, for the purposes described in this Policy as well as to keep you informed, subject to your consent, by means of e-mail on Fangorosa and our products, services, promotions.
In compliance with the GDPR and applicable laws, specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access.
7. SUBJECTS INVOLVED IN THE PROCESSING
The user’s personal data are processed by employees and collaborators of the Data Controller as subjects authorized to process them in accordance with the provisions of the GDPR.
Fangorosa will not disclose your personal data to third parties for direct marketing purposes nor will it sell your data to third parties. However, we may need to share your contact details and identification data within the company as well as with our service providers (for example, technical service providers, craftsmen, shipping agents) who operate as our managers of the data processing or with other third parties, if this is necessary to allow you to receive our communications, as indicated in this section.
Your data may also be disclosed to third parties, independent data controllers, in particular to freelancers or companies that provide legal or tax advice and assistance, or to third parties to whom outsourcing activities have been entrusted.
In any case, Fangorosa undertakes to provide these third parties with only the data necessary for the performance of the functions and activities entrusted to them; it also undertakes to do everything possible so that third parties use the data received only for the purposes indicated by Fangorosa and in compliance with the applicable personal data processing legislation.
The user’s personal data may also be brought to the attention of third-party companies in the event of a merger or demerger, in the case of acquisitions, transfer of a company or business unit or other extraordinary corporate transactions. The user’s personal data may also be brought to the knowledge of legitimate recipients pursuant to law or regulation, for example in the event of requests from the competent public authorities and the judicial authority or, more generally, in the context of legal proceedings, as well as to protect and defend the Site and the rights of Fangorosa.
These subjects will process the data as independent owners or data processors as appropriate.
The updated list of all recipients of the data can be requested from the data controllers at the email address firstname.lastname@example.org or by writing a letter to the addresses below.
8. TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION
The management and storage of personal data will take place in Europe, on servers located in Italy.
By activating the newsletter, you consent to the processing of your data by Mailchimp for the methods and purposes indicated above.
The complete list of data recipients, established outside the European Union, or a copy of the guarantees adopted by the Data Controller can be obtained by writing an email to the following address: email@example.com or by writing a letter to the address below .
9. LINKS TO THIRD PARTY SITES AND SERVICES
Fangorosa therefore invites users to pay attention in adhering to the services offered by third parties and to read the information provided by the third party regarding the processing of personal data carried out by it, in relation to which Fangorosa cannot perform any control, nor be held accountable.
10. USER RIGHTS
Pursuant to current laws, at any time it is possible to request information on the personal data collected, used, disclosed or processed by the Data Controller, as well as request access to such personal data, request its integration, rectification or cancellation, request their restriction to processing and oppose their processing.
In particular, you have the right to object and revoke, in whole or in part, your consent to the collection, use, communication or processing of your personal data for the purpose of profiling or sending advertising materials, for direct sale or for carrying out market research or commercial communication both automated (e-mail, other remote communication systems such as, by way of example and not limited to: SMS, MMS, Whatsapp) and traditional (paper mail).
If you prefer that the processing of your personal data takes place exclusively with traditional contact methods, you can object to the processing of your personal data through automated contact methods. Furthermore, you can decide at any time to cancel your subscription to the newsletter by clicking on the link inserted at the end of all communications.
You will also have the right to receive the personal data concerning you, which you have provided to the Data Processors, in a structured format, commonly used and machine-readable and to transmit them to another holder without impediments on the part of this last, where: the processing is based on consent or on a contract and the processing is carried out by automated means.
To exercise the above rights and/or to submit requests or complaints regarding the processing of personal data and/or withdraw consent, it is possible to send a request to the Data Controller by writing to this e-mail address: firstname.lastname@example.org or to the postal and contact addresses indicated in the epigraph of this information.
It is also possible to lodge a complaint with the competent authority in the Member State in which he habitually resides or works or in the State in which the alleged violation occurred.
12. CHANGES TO THIS DOCUMENT
Last updated: April 2020