via Vincenzo Bellini,7
Salaparuta
91020
Italy
IT 01555820818
Information on the processing of personal data pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR). In force from 12/06/2023
PREMISE
This information notice takes into account the provisions of the GDPR and the Privacy Code (Legislative Decree 30 June 2003 no. 196). The document was also drafted based on the Guidelines of the Privacy Authority (especially the Anti-Spam Guidelines issued by the Privacy Authority on July 4, 2013).
Data Controller: PINO OLIVERI
Site to which this privacy policy refers: https://rekale.it/ (Site).
The Data Controller has not appointed a DPO (Data Protection Officer). Therefore, you may send any request for information directly to the Data Controller.
GENERAL INFORMATION
This document describes how the Data Controller processes your personal data provided on the Site.
Below are described the main processes involving your personal data. In particular, the legal basis for the processing is explained, whether providing the data is mandatory, and the consequences of not providing personal data. To best describe your rights, where necessary, we have specified if and when a certain processing of personal data is not carried out.
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 for the processing is the necessity for the Data Controller to carry out pre-contractual measures adopted at the request of the data subject. Providing the data is optional. However, your refusal to provide the data will make it impossible to register on the Site. It is possible to register on the Site also using external services. In this case, your registration data will be shared with the companies of these external services solely for the purpose of enabling registration on the Site. The legal basis for this processing is the legitimate interest of the Data Controller in allowing registration on the Site through external services. Providing personal data for this purpose is purely optional. However, failure to consent to the processing of data will make it impossible to register through external services.
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 enable the conclusion of the purchase contract and the correct execution of the related operations (and, if necessary according to sector regulations, to fulfill tax obligations). The legal basis for the processing is the obligation of the Data Controller to execute the contract with the data subject or to comply with legal obligations. Regardless of the above (and therefore of your consent), the Data Controller may process your data for so-called "soft-spam" purposes, governed by art. 130 of the Privacy Code. This means that, limited to the email you provided 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 manner provided for in this notice. The legal basis for the processing is the legitimate interest of the Data Controller to send this type of communication. This legitimate interest can be considered equivalent to the interest of the data subject in receiving "soft-spam" communications. The Data Controller may send emails to remind the user to complete a purchase. The legal basis for this processing is the legitimate interest of the Data Controller to send this type of communication. Through the "follow on shop" option, the Data Controller may also process your personal data to send updates via email and/or phone (depending on the options available on the Site from time to time) on the status of orders, shipments, and/or supplies. The legal basis for this processing is the legitimate interest of the Data Controller to send this type of communication. This interest is equal to your interest in receiving this type of update. Providing personal data for this purpose is optional. However, if personal data is not provided, the Data Controller will not be able to send this type of communication.
Respond to your requests
Your data will be processed in order to respond to your information requests. Providing your data is optional, but refusal will make it impossible for the Data Controller to answer your questions. 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 a reply to communications sent to the Data Controller.
Generic marketing
With your prior consent, the Data Controller may process the personal data you provide 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. Providing personal data for this purpose is entirely 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 for the Data Controller to conduct market surveys, including those aimed at assessing user satisfaction, and to send you newsletters.
Profiling
With your prior consent, the Data Controller may process your personal data for profiling purposes, that is, for the analysis of your consumer choices through the disclosure of the type and frequency of purchases you make, in order to send you advertising material and/or newsletters related to its own or third-party products that are of specific interest to you. The legal basis for this processing is your consent. Providing data for this purpose is entirely optional. Failure to consent to the processing of your personal data for profiling purposes will make it impossible for the Data Controller to develop your commercial profile, by detecting your purchasing choices and habits, as well as to send you advertising material related to products of the Data Controller and/or third parties that are of specific interest to you.
Data transfer
The Data Controller does not transfer your personal data to third parties.
Geolocation
The Site does not implement tools for geolocating the user's IP address.
Curriculum Vitae
It is not possible to send résumés through the Site. Therefore, your data will not be processed for these purposes.
Appointment booking
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 using the contact details provided above.
Disclosure of personal data
As part of its ordinary activities, the Data Controller may disclose your personal data to certain categories of subjects. In Article 2 you can find the list of subjects to whom the Data Controller discloses your personal data. To facilitate the protection of your rights, Article 2 may specify in some cases when your data is not disclosed to third parties.
The "communication" of personal data to third parties is different from "transfer" (regulated in the previous point). In fact, in communication, the third party to whom the data is transmitted can use it only for the specific purposes described in the relationship with the Data Controller. In the case of transfer, however, the third party becomes the autonomous 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 in any case use your personal data to properly fulfill the obligations provided for by the laws in force.
SPECIFIC PRIVACY NOTICE
Art. 1 Methods of processing
1.1 The processing of your personal data will mainly be carried out using electronic or otherwise automated means, in accordance with the methods and tools suitable to guarantee their security and confidentiality in compliance with the GDPR. If the automatic chatbot service is operational, your personal data will also be processed to enable the activation of this service, through which the user can contact and be contacted by the Data Controller, subject to consent. The legal basis is the legitimate interest of the Data Controller to respond to the user's requests through the chatbot service. This legitimate interest can be considered equivalent to the data subject's interest in using the automatic chatbot service.
1.2 The information acquired and the methods of processing will be relevant and not excessive in relation to the type of services provided. 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 in parties, trade unions, associations or organizations of a religious, philosophical, political or trade union nature, health status and sexual life.
1.4 Judicial data is not processed through the Site.
Art. 2 Communication of personal data
The Data Controller may disclose your personal data to specific categories of subjects. Below are the subjects to whom the Data Controller reserves the right to disclose your data:
The Data Controller may disclose your personal data to all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative measures.
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 proper fulfillment of obligations arising from the law.
The Data Controller does not use employees and/or collaborators in any capacity. Therefore, your personal data will not be disclosed to this category of subjects.
In its ordinary activity of managing the Site, the Data Controller makes use of companies, consultants, or professionals responsible for the installation, maintenance, updating, and, in general, the management of the hardware and software of the Data Controller or those used by the latter for the provision of its services. Therefore, solely for these purposes, your data may also be processed by these parties.
For sending its communications, the Data Controller uses external companies responsible for sending this type of communication (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 customer care services.
The buyer's personal data may be communicated to post offices, couriers, or shipping agents responsible for delivering the Products purchased through the Site.
The Data Controller reserves the right to modify the above list based on its ordinary operations. Therefore, you are invited to regularly access this information notice to check which parties the Data Controller communicates your personal data to.
Art. 3 Retention of personal data
3.1 This article describes how long the Data Controller reserves the right to retain your personal data.
For marketing purposes, personal data will be retained until any withdrawal of consent. For inactive users, personal data will be deleted one year after the last email sent that may have been viewed.
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 their right of defense and to demonstrate that the contract has been properly executed.
As provided by Article 2220 of the Civil Code, invoices, as well as all accounting records in general, are kept for a minimum period of ten years from the date of registration, so that they can be presented in case of inspection.
Through the Site (or by making a request to the Data Controller), it is possible to delete the user's account. In this case, all stored personal data will be deleted and will not be retained by the Data Controller for any purpose.
If you have activated the option to be updated on orders, shipments and/or supplies, your personal data will be retained for this purpose only for the time necessary to perform this service.
For "profiled" marketing purposes, unless consent is withdrawn earlier, the data is retained for 12 months from the time it is provided. After consent is withdrawn or at the end of the 12-month period, the personal data will be deleted and no longer used for this purpose.
For marketing purposes, unless consent is revoked earlier, the data is retained for 24 months from the time it is provided. After consent is revoked or at the end of the 24-month period, the personal data will be deleted and no longer used for marketing purposes.
3.2 Without prejudice to the provisions of Article 3.1, the Data Controller may retain your personal data for the period required by specific regulations, as amended from time to time.
Art. 4 Transfer of personal data
4.1 The Data Controller is based within the European Union. Therefore, the processing of your data is safe from a regulatory point of view as it is governed by the GDPR. If your personal data is transferred to a non-EU country for which the European Commission has issued an adequacy decision, the transfer is in any case considered safe from a regulatory perspective. 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 issued an adequacy decision.
The user is therefore invited to regularly access this article to check whether the transfer of their personal data takes place in a country with these characteristics.
4.2 Without prejudice to the provisions of Article 4.1, your data may also be transferred to non-EU countries for which the European Commission has not issued an adequacy decision. You are therefore invited to regularly review this Article 4.2 to check to which of these countries your data may be transferred. To ensure the proper functioning of the Site, your personal data may be transferred to the U.S.A.. In these cases, the Data Controller will adopt all appropriate contractual measures to ensure an adequate level of protection of personal data, including, among others, the Standard Contractual Clauses approved by the European Commission on June 4, 2021.
4.3 In this article, the Data Controller indicates the countries to which they may specifically direct their activity. This circumstance may imply the application of the legislation of the reference country, together with that of the GDPR.
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Art. 5. Rights of the data subject
Pursuant to Article 13 of the Privacy Regulation, the Data Controller informs you that you have the right to:
to request from the Data Controller access to your personal data and the rectification or erasure of such data or the restriction of processing concerning you or to object to their processing, as well as the right to data portability
withdraw consent at any time without affecting the lawfulness of processing based on consent given before withdrawal
lodge a complaint with a supervisory authority (e.g.: the Data Protection Authority).
The above rights may be exercised by making a request without formalities to the contacts indicated in the Introduction.
Art. 6. Amendments and Miscellaneous
The Data Controller reserves the right to make changes to this policy at any time, providing appropriate notice to users of the Site and in any case ensuring adequate and similar protection of personal data. In order to view any changes, you are invited to regularly consult this policy. In the event of substantial changes to this privacy policy, the Data Controller may also notify you via email.
via Vincenzo Bellini,7
Salaparuta
91020
Italy
IT 01555820818