Privacy disclaimer
Information on the processing of personal data. Effective November 22, 2023
PREMISE
This information takes into account what is indicated in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and the Privacy Code (Legislative Decree 30 June 2003 n. 196). The document was also drawn up based on the Guidelines of the Privacy Guarantor (especially the Guidelines for combating spam issued by the Privacy Guarantor on 4 July 2013).
Data Controller : ellebigenova - VAT number IT02745400990 - Via Carlo Montanari 6, Genoa 16135 - Email info@ellebigenova.it
Site to which this privacy policy refers: https://ellebigenova.it/ ( Site ).
The Data Controller has not appointed a DPO (Data Protection Officer). Therefore, you can send any request for information directly to the Data Controller.
GENERAL INFORMATIONS
This document describes how the Data Controller processes your personal data provided on the Site.
The main processing of your personal data is described below. In particular, the legal basis of the processing is explained, whether the provision is mandatory and the consequences of failure to provide personal data. To better describe your rights, if necessary, we have specified if and when a certain processing of personal data is not carried out. On the Site you have the possibility to enter personal data of third parties. In this case you guarantee that you have obtained the consent of these subjects to enter this personal data. Therefore, you undertake to indemnify and hold the Data Controller harmless from any liability.
Registration on the Site
The information and data requested in case 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 need for the Data Controller to carry out pre-contractual measures adopted at the request of the interested party. 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 placing 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 based on the sector legislation, to fulfill tax obligations). This processing of personal data also includes the possibility of sending communications (e.g. tracking and order information) via automated tools such as text messages and/or WhatsApp. The legal basis of the processing is the obligation of the Data Controller to execute the contract with the interested party or to fulfill legal obligations. Regardless of the above (and therefore your consent), the Data Controller may process your data for the purposes of so-called "soft-spam", governed by art. 130 of the Privacy Code. This means that, limited to the email provided by you in the context of a purchase through the Site, the Data Controller will process the email to allow the direct offer of similar products/services, provided that you do not object to such processing in the methods provided for in this information. The legal basis of the processing is the legitimate interest of the Data Controller in sending this type of communications. This legitimate interest can be considered equivalent to the interest of the interested party in receiving "soft-spam" communications. The Data Controller may send emails to remind the user to complete a purchase. The legal basis of this processing is the legitimate interest of the Data Controller in sending this type of communications.
Respond to your requests
Your data will be processed to respond to your requests for information. The provision is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis of the processing is the legitimate interest of the Data Controller in following up on the user's requests. This legitimate interest is equivalent to the user's interest in receiving responses to communications sent to the Data Controller.
Generic marketing
Subject to your consent, the Data Controller may process the personal data provided by you in order to send you advertising material and/or newsletters relating to its own or third party products. 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 as well as the impossibility for the Data Controller to carry out market research, also aimed at evaluating the level of user satisfaction, as well as sending you newsletters. These communications will be sent to the email address you provided on the Site.
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 by revealing the type and frequency of purchases made by you, in order to send you advertising material and /or newsletters relating to own or third-party products of specific interest to you. 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 process your commercial profile, by detecting your choices and purchasing habits as well as sending you advertising material relating to the Data Controller's products. of the Processing and/or of third parties, of specific interest to you. These communications will be sent to the email address you provided on the Site.
Transfer of data
The Data Controller does not transfer your personal data to third parties.
Geolocation
The Site does not implement geolocalization tools for the user's IP address.
Curriculum vitae
It is not possible to send CVs via the Site. Therefore your data will not be processed for these purposes.
Booking appointments
There are no third-party appointment booking systems active on the Site with the Data Controller. Therefore, your data will not be processed for this purpose. In any case, you can always contact the Data Controller at the contacts indicated in the epigraph.
Communication of personal data
As part of its ordinary activity, the Data Controller may communicate your personal data to certain categories of subjects. In article 2 You can find the list of subjects to whom the Data Controller communicates your personal data. To facilitate the protection of your rights, article 2 may specify in some cases when your data is not communicated to third parties.
The "communication" of personal data to third parties is different from the "transfer" (governed in the previous point). In fact, in the communication the third party to whom the data is transmitted can only use it for the specific purposes described in the relationship with the Data Controller. In the case of transfer, however, the third party becomes the independent Data Controller of the personal data. Furthermore, your consent is always required to transfer your personal data to third parties.
Without prejudice to the foregoing, it is understood that the Data Controller may still use your personal data to correctly fulfill the obligations established by the laws in force.
SPECIFIC PRIVACY POLICY
Art. 1 Processing methods
1.1 The processing of your personal data will mainly be carried out with the aid of electronic or automated means, according to the methods and with the tools suitable to guarantee the security and confidentiality of the personal data.
1.2 The information acquired and the methods of processing will be relevant and not excessive with respect to the type of services rendered. Your data will also be managed and protected in secure IT environments appropriate to the circumstances.
1.3 No "special data" is processed through the Site. Special data are those that may reveal racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade union nature, health status and sexual life.
1.4 No judicial data is processed through the Site.
Art. 2 Communication of personal data
The Data Controller may communicate your personal data to certain categories of subjects. Below are indicated 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 subjects (including Public Authorities) who have access to personal data pursuant to regulatory or administrative provisions.
- Your personal data may also be communicated to all those public and/or private entities, natural and/or legal persons (legal, administrative and tax consultancy firms, judicial offices, chambers of commerce, labor chambers and offices, etc.) , if the communication is necessary or functional for the correct fulfillment of the obligations deriving from the law.
- The Data Controller makes use of employees and/or collaborators in any capacity. For the correct functioning of the Site, the Data Controller may communicate your personal data to these employees and/or collaborators.
- In its ordinary management activity of the Site, the Data Controller makes use of companies, consultants or professionals in charge of the installation, maintenance, updating and, in general, management of the hardware and software of the Data Controller or of which the latter is used to provide its services. Therefore, only with reference to these purposes, your data may also be processed by these subjects.
- To send its communications, the Data Controller uses external companies responsible for sending this type of communications (CRM platforms). Your personal data (in particular your email) may therefore be communicated to these companies.
- The Data Controller does not use external companies to provide the customer care service.
- The buyer's personal data may be communicated to post offices, couriers or shippers responsible for delivering the Products purchased through the Site.
The Owner reserves the right to modify the above list based on its ordinary operations. Therefore, you are invited to regularly access this information to check to which subjects the Data Controller communicates your personal data.
Art. 3 Storage of personal data
3.1 This article describes how long the Data Controller reserves the right to retain your personal data.
- Your personal data will be stored only for the time necessary to guarantee the correct provision of the services offered through the Site.
- For marketing purposes, personal data will be retained until consent is revoked. For inactive users, personal data will be deleted one year after the last email viewed is sent.
- For the purpose of executing the sales contract, the data will be retained for 10 years from the date of receipt of the purchase order. This is to allow the Data Controller to exercise his right of defense and to demonstrate that he has correctly executed the contract.
- For customer care purposes, the data will be deleted once the assistance service is completed.
3.2 Without prejudice to the provisions of 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 in a country that has an adequate level of security from a regulatory point of view. If the transfer of your personal data takes place in a non-EU country and for which the European Commission has expressed an opinion of adequacy, the transfer is in any case considered safe from a regulatory point of view. This article 4.1 indicates from time to time the countries to which your personal data may be transferred and where the European Commission has expressed an opinion of adequacy.
- The user is therefore invited to regularly access this article to check whether the transfer of his personal data takes place in a country with these characteristics.
4.2 Without prejudice to what is indicated in article 4.1, your data may also be transferred to non-EU countries for which the European Commission has not expressed an opinion of adequacy. You are therefore invited to regularly view this article 4.2 to ascertain which of these countries your data may be transferred to.
4.3 In this article the Data Controller indicates the countries in which it specifically directs its activity. This circumstance may imply the application of the legislation of the country of reference, together with that which regulates the relationship with the user based on what is indicated in the Introduction.
- Upon request of the user, the Data Controller will apply to the processing of personal data the most favorable legislation provided for by the user's national legislation.
Art. 5. Rights of the interested party
The Data Controller informs you that you have the right to:
- ask the Data Controller to access your personal data and to rectify or cancel them or limit the processing that concerns you or to oppose their processing, in addition to the right to data portability
- revoke consent at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation
- lodge a complaint with a supervisory authority.
The above rights may be exercised with a request addressed without formalities to the contacts indicated in the Introduction.
Art. 6. Modifications and Miscellaneous
The Data Controller reserves the right to make changes to this information at any time, giving suitable publicity to users of the Site and guaranteeing in any case adequate and similar protection of personal data. In order to view any changes, you are invited to regularly consult this information. In the event of substantial changes to this privacy policy, the Data Controller may also communicate via email.