OWNER OF THE TREATMENT AND RESPONSIBLE FOR DATA PROTECTION
The owner, with headquarters in Via Cella 50, 48124 Madonna dell'Albero, Ravenna, Italy acts as data controller for the purposes of marketing and profiling your data, if you provide your express consent to such processing. For any clarification, question or need related to your privacy and the processing of your personal data, you can contact the Data Protection Officer ("DPO") of the owner at the following address: firstname.lastname@example.org
PERSONAL DATA SUBJECT TO PROCESSING
The Data Controller processes, with your consent, the data you provide us when you wish to receive communications or promotional information from the Data Controller, such as name and surname, e-mail address, date of birth, mobile phone number, profession, preferences (for example the interest in receiving communications about our products). The Data Controller also processes the data relating to your purchases, when you express your express consent to the recording of your consumption habits, preferences and lifestyle to use them for the creation of group and individual profiles ("profiling") which are used to the sending of personalized communications and for carrying out market research and statistical research with anonymous data, organized in aggregate form.
Your personal data is processed for the following purposes:
- provide you with the services of the Site such as subscribing to the newsletter;
- allow you to register on the Site and use the services reserved for registered users;
- manage your requests forwarded to our customer service.
In the aforementioned cases, the processing of your personal data is legitimate as it is necessary to execute a contract concluded with you or to provide you with the service you specifically requested from us.
Only with your express consent instead, we process your personal data for:
- carry out commercial communications activities;
- analyze your consumption habits for the creation of individual or group profiles;
PERSONAL DATA PROCESSED THROUGH THE SITE
Name, contact details and other Personal Data
In various sections of the Site, in particular that relating to the creation of a personal account, you will be asked to enter information such as your name, telephone number, email address, date of birth, country of residence, address , etc.
Furthermore, if you participate in surveys or any promotions that are made available through the Site, as well as when you communicate with the Owners through the contacts you find on the Site or with Customer Care, the Owners will be able to collect any additional information you decide to provide.
To provide you with increasingly precise and useful Services, the Owner may ask you to manually enter a physical address, postal code or simply the State.
Alternatively, and subject to prior and explicit consent, your Internet browsing program (so-called "Browser") could share an approximation of your geographical position with the Site through information on wireless access points in your vicinity and on the IP address of your device.
In both cases, it is a treatment for the use of a Personal Data that is completely optional but extremely useful to the Owner for the provision of increasingly useful Services. If you feel that accessing your approximate location through browser sharing is too intrusive, you can always withdraw your consent from your browser settings (or operating system settings).
For more information, please consult the specific privacy policies of your browser.
Special categories of personal data
Some sections of the Site include free fields in which you can provide the Owner with some information, which may contain Personal Data.
Since these fields are free, you could use them to communicate (voluntarily or not) some sensitive categories of Personal Data, such as data suitable for revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data intended to uniquely identify a natural person, data relating to the person's health or sex life or sexual orientation.
The Data Controller invites you not to send such Personal Data unless strictly necessary. Indeed, these special categories of Personal Data can only be processed with your explicit consent (manifestable via the flag on the Application screen) and in compliance with the pro tempore legislation in force. The Data Controller therefore underlines the importance of expressing your explicit consent to the processing of special categories of Personal Data, should you decide to share such information.
Data provided voluntarily by the interested party
As already mentioned above, in some parts of the Site (such as entering an email address to subscribe to the newsletter or when, by purchasing a product on the Site, you want to insert a message such as "best wishes" attached to sending the product) You are allowed to enter text messages or information, visible to the Data Controller, which may contain Personal Data of other people.
With respect to these hypotheses, you act as an independent data controller, assuming all the legal obligations and responsibilities. In this sense, it grants the widest indemnity on this point with respect to any objection, claim, request for compensation for damage from treatment, etc. that should reach the Data Controller from third parties whose Personal Data have been processed through your use of the functions of the Site in violation of the applicable personal data protection regulations. In any case, if it provides or otherwise processes Personal Data of third parties in the use of the Site, it guarantees from now on - assuming all connected responsibility - that this particular hypothesis of treatment is based on the consent of this interested third party or on another appropriate legal basis that legitimizes the processing of the information in question.
The computer systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user's IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, to identify anomalies and/or abuses, and are canceled immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the site or third parties: except for this eventuality, currently the data on web contacts do not persist for more than 50 days.
WHO WILL PROCESS YOUR DATA?
Your personal data is processed by duly trained personnel of our company and, for organizational and functional needs relating to the provision of services on the Site, by our suppliers. The latter have been evaluated and chosen by the Owner for their proven reliability and competence.
HOW LONG DO WE KEEP YOUR DATA?
WHAT ARE YOUR RIGHTS?
At any time, depending on the specific treatment, you can: revoke your consent to the treatment, know which personal data we hold about you, their origin and how they are used, request their updating, rectification or integration as well as, in the cases provided for by the provisions in force, the cancellation, the limitation of the treatment or to oppose their treatment. If you wish, you can request to receive the personal data held by the Data Controller concerning you in a format readable by electronic devices and, where technically possible, we will be able to transfer your data directly to a third party indicated by you. If you believe that the processing of your personal data has been carried out unlawfully, you can file a complaint with the Guarantor for the Protection of Personal Data (http://www.garanteprivacy.it/), the competent supervisory authority for compliance with the rules regarding the protection of personal data. This document may undergo changes and additions over time, we therefore invite you to periodically check its contents. Where possible, we will try to inform you promptly about the changes we have made.
The company Associazione Culturale Bronson as data controller informs you of the following on the processing of your personal data pursuant to art. 13 of EU Regulation 2016/679 on the protection of personal data ("Regulation").
PURPOSE OF THE TREATMENT
The Data Controller will use your Personal Data, collected through the Site, for the following purposes:
- provide Services such as: verifying your identity and helping you, in case you lose or forget the login/password details of your personal account on the Site;
- purchase a nominative Card;
- allow you to consult your purchase history;
- send you the newsletter of the Data Controller that you requested as a Service by subscribing;
- finalize your purchase order and deliver the products you can purchase on the Site;
- allow you to save your favorite items and provide you with any other service you request ("Provision of the Service");
- send you marketing communications, promotions and advertising, market research and surveys, by e-mail, SMS, push notifications, by telephone, by banner, instant messaging, through an operator, through the official social media pages of the Owner, relating to products and/or services referable to the Owner and/or to third parties (“Marketing“);
- send you marketing communications via email regarding products and services similar to those you have purchased through the Site ("Soft Spam");
- to create your profile through the use of profiling cookies, where accepted, therefore collecting and analyzing information on the selections and choices you make on the Site;
- as well as your general activities on the Site when you are a registered user, therefore collecting information on your proceeding purchases, wishlists and navigations.
This profile will be used to provide you with information on other products and/or services that the Owner deems may be of interest to you and to show you advertisements that may be relevant to your tastes. All the algorithms involved in this automated or semi-automated process are regularly tested to ensure that you are not offered products that do not interest you ("Profiling");
fulfill legal obligations that require the Data Controller to collect and/or further process certain types of Personal Data (“Compliance”);
prevent or identify any abuse in the use of the Site, or any fraudulent activity and therefore allow the Owners to protect themselves in court ("Abuse/Fraud").
LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF THE TREATMENT
The legal bases used by the Data Controller to process your Data, according to the purposes indicated in the previous paragraph, are as follows:
Provision of the Service: the processing for this purpose is necessary in order to be able to provide you with the Services and, therefore, for the execution of the contract with you. It is not mandatory to provide the Data Controller with your Personal Data for this purpose, but otherwise it will not be possible provide you with any Services. The same applies to the newsletter service which arises from your specific request by entering an e-mail address and which you can revoke at any time by following the instructions in Paragraph 8 of this Information.
Marketing: the processing for this purpose is based on your consent. It is not mandatory to give your consent to the Owner for this purpose and you are free to revoke it at any time without any consequences (except for the fact that you will no longer receive marketing communications from the Owner). You can revoke your previously granted consent by following the instructions in Paragraph 8 of this Information.
Soft Spam: the processing for this purpose is based on the Data Controller's interest in sending you marketing communications via email regarding products and services similar to those you have already purchased through the Site. You can stop receiving these communications, without any consequences for you (besides the fact that you will no longer receive further communications of this kind from the Data Controller) using the link at the bottom of each of these emails;
Profiling: the processing for this purpose is based on your consent. It is not mandatory to give your consent to the Owner for this purpose and you are free to revoke it at any time without any consequences (except the impossibility of benefiting from the personalization of the commercial offers you will receive from the Owner). You can revoke your previously granted consent by following the instructions in Paragraph 8 of this Information.
Compliance: the processing for this purpose is necessary for the Data Controller in order to fulfill any legal obligations. When you provide Personal Data to the Data Controller, they must be processed according to the applicable legislation, which could involve their conservation and communication to the Authorities for accounting, tax or other obligations.
Abuse/Fraud: the information collected for this purpose will be used exclusively to prevent and/or identify any fraudulent activity or abuse in the use of the Site and therefore allows the Owner to protect himself in court.
RECIPIENTS OF PERSONAL DATA
Your Personal Data may be shared with the subjects listed below (the "Recipients"):
subjects who typically act as data processors, i.e.: i) people, companies or professional firms that provide assistance and advice to the Data Controller in accounting, administrative, legal, tax, financial and debt collection matters relating to the provision of the Services;
subjects with whom it is necessary to interact for the provision of the Services (for example hosting providers or platform providers for sending emails);
subjects delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communication networks);
persons authorized by the Data Controller to process Personal Data necessary to carry out activities strictly related to the provision of the Services, who are committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees of the Data Controller);
delegated companies for internal administrative purposes;
subjects, bodies or authorities to whom it is mandatory to communicate your Personal Data for purposes of Compliance, Abuse or Fraud, or by order of the authorities;
TRANSFERS OF PERSONAL DATA
The management and storage of personal data takes place in the cloud and on servers located within the European Union owned and/or available to the Data Controller or appointed third-party companies, duly appointed as data processors. Your personal data will not be disclosed.
Given the international presence of the Data Controller, however, some of your Personal Data is shared with Recipients who could be found outside the European Economic Area.
The Data Controller ensures that the processing of your Personal Data by these Recipients takes place in compliance with the applicable legislation. Indeed, the transfers are carried out through adequate guarantees, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission or others. More information is available by writing to the following address: email@example.com
STORAGE OF PERSONAL DATA
The Personal Data processed for the purpose of Providing the Services will be kept by the Data Controller for the time strictly necessary for the aforementioned purpose (e.g. for sending the purchased product). In any case, since these Personal Data are processed to provide you with the Services, the Owner may keep them for a longer period, in particular for what may be necessary in order to protect the interests of the Owner from possible complaints relating to the Services.
Personal Data processed for Marketing and Profiling purposes will be kept by the Data Controller until you revoke your consent. In any case, we will remind you of the consents you have given us every 24 months. Once the consent has been revoked, the Data Controller will no longer use your Personal Data for these purposes, but may still keep them, in particular for what may be necessary in order to protect the interests of the Data Controller from possible claims based on such treatments.
The Personal Data processed for the purpose of Soft Spam will be kept by the Data Controller until you object to this processing through the link at the bottom of each Soft Spam e-mail.
Personal Data processed for Compliance purposes will be kept by the Data Controller for the period established by specific legal obligations or by applicable legislation.
The Personal Data processed in order to prevent Abuse/Fraud will be kept by the Data Controller for the time strictly necessary for the aforementioned purpose and therefore until the moment in which the Data Controller is required to keep them to protect himself in court and to communicate said data to the competent Authorities.
RIGHTS OF THE INTERESTED PARTY
You have the right to ask the Owners, at any time:
access to your Personal Data, (or a copy of such Personal Data), as well as further information on the treatments in progress on them;
the rectification or updating of the Personal Data processed by the Data Controller, where they are incomplete or out of date;
the deletion of your Personal Data from the Data Controller's databases;
the limitation of the processing of your Personal Data by the Owner;
to obtain the Personal Data concerning you in a structured, commonly used and machine-readable format;
as well as can:
object to the processing of your Personal Data by the Data Controller (e.g. Soft Spam);
revoke your consent for Marketing and Profiling purposes.
We point out that most of the Personal Data that you have provided to the Data Controller can be modified at any time, by accessing, where possible, your personal account created on the Site.
When requesting the Services, you may have selected the communication channels through which you wish to be contacted for Marketing purposes (i.e. telephone, sms, email, mail, push notifications, social media).
You can revoke your consent for Marketing relating to each of these communication channels through your personal account on the Site, by deselecting the relevant options. You can also revoke your consent to Marketing sent by e-mail and stop receiving Soft Spam using the appropriate link at the bottom of each e-mail received. The same method can be used to stop receiving the Owner's newsletter, should he have requested it as a Service.
Consent to profiling through cookies can be revoked using the methods indicated in the previous paragraph.
In addition to the above, you can also exercise your rights by writing to the Data Controller at the following address: firstname.lastname@example.org
In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Guarantor for the Protection of Personal Data) if you believe that the processing of your Personal Data is contrary to the legislation in force.
OWNER OF THE TREATMENT
METHOD OF ACCEPTANCE