1. DATA CONTROLLER
Sub Divo S.r.l., with registered office in Viale Zante 14, 20138, Milano is the Data Controller that determines the purposes and means of the processing of your personal data on the Website.
2. PERSONAL DATA COLLECTED
Pursuant to Article 4.1 of the Regulation, here are some examples of your personal data collected by the Company (either from you directly or, indirectly, when you interact with the Company):
a. the personal data provided on a voluntary basis by each user in order to use the services offered thorough the Website including name, surname, contact details, delivery address, e-mail address, billing address, telephone number, payment information etc.
b. navigation data, which include those data automatically acquired during navigation of the Website by the systems and programs responsible for the functioning of the Website and are necessary for the use of the webservices (including, by way of example, IP addresses or domain names of the terminals used by users, the type of browser or operating system used, information on the pages visited by the user within the Website, the time of access, etc.).
3. PURPOSES AND LEGAL BASIS OF DATA PROCESSING
Your data are collected and processed for the following purposes:
a. management of purchase orders and deliveries;
b. management of the requests of each user to transmitted through the Website
c. submission of a spontaneous application or answering to a job announcement published on the Website
d. correct use of the Website and the services requested by the user, as well as optimization of the user experience;
e. statistics on anonymous data
Data processing for the purposes set out in letters a), b) and c) is required for the proper execution of your contract with the Company. Please consider that, even if the provision of your personal data for such purposes is optional, any refusal will prevent or limit the possibility to purchase products on the Website or to answer your request or to consider your application.
Instead, data processing for the purposes set out in letters d) and e) is not required your consent.
4. WHO CAN ACCESS TO YOUR PERSONAL DATA?
- employees of the Company – appointed as persons in charge of the processing – to the extent it is necessary for the performance of their tasks in connection with the provision of the services in your favour;
- other companies involved in various operations on behalf of the Company (e.g. provision of Internet platform, marketing services, deliveries, customer support and fraud prevention), which will be appointed as data processors;
- public authorities, when necessary to comply with legal obligations/orders;
- potential assignees of the Company, in case of transfers of the Company or of Company branches.
5. WHERE THE COMPANY STORES YOUR PERSONAL DATA AND RETENTION PERIOD
Your personal data will be stored on the Company’s servers located in the European Union.
Any transfer of personal data outside the EU or the European Economic Area (so-called Third Party Countries) will only take place to recipients located in third countries that are beneficiaries of an adequacy decision of the European Commission, or in the presence of adequate guarantees and, in any case, in compliance with the provisions of Articles 44 and ss. of the Regulation.
The Company will retain the data collected for the purposes set out in paragraph 3, letters a), b), c), and e) for as long as necessary for the performance of the contract between you and the Company, and subsequently for a period not exceeding the statutory limitation period.
6. YOUR RIGHTS
The Company reminds you that you have the following rights according to articles 15-22 of the Regulation:
- to obtain information as to the purposes for which your personal data are processed, the processing period and the persons to whom the data are disclosed (i.e. right of access);
- to obtain the rectification or updating of inaccurate personal data concerning you (i.e., right to rectification);
- to obtain the erasure of personal data concerning you in the following cases (a) the data are no longer necessary for the purposes for which they were collected; (b) you withdrew your consent to the processing of data where such data are processed on the basis of your consent; (c) you objected to the processing of personal data concerning you in the event where they are processed strictly for a legitimate interest of the Company; or (d) the processing of your personal data does not comply with the law. However, please note that the storage of personal data by the Company is permitted when it is necessary to permit fulfilment of a legal obligation or to establish, exercise or defend a right in court (i.e. right to erasure);
- to ensure that the personal data concerning you are only stored, without such data being used otherwise, in the following cases: (a) you contest the accuracy of the personal data, such data will be stored for the period necessary to enable us to verify the accuracy of the personal data; (b) the processing is unlawful but you oppose the erasure of the personal data by us; (c) the personal data are required by you to establish, exercise or defend legal claims; (d) you objected to processing and verification of whether the legitimate grounds of the Company override those of the data subject is pending (i.e. right to restriction);
- to obtain the termination of processing in cases where personal data are processed for the legitimate interest of the Company and you contest the existence of that interest (i.e., right to object);
- to receive personal data concerning you in a structured, commonly used, machine-readable and interoperable format where processed by automated means, provided the personal data are processed on the basis of your consent (i.e. portability right).
The Company reminds you that (i) the Data Controller may be reached out to for requests or notifications relating to the processing of personal data at the following address: Viale Zante no. 14, 20138 Milano, email@example.com and, in any case, that (ii) you have the right to apply to the Italian Data Protection Authority (Piazza Venezia n. 11 – 00187 Roma (RM) to enforce your rights with regard to the processing of your personal data.