INTRODUCTION
This notice takes into account the provisions of the GDPR and the Privacy Code (Legislative Decree no. 196 of 30 June 2003). The document has also been drafted in accordance with the Guidelines of the Privacy Guarantor (especially the Guidelines against spam issued by the Privacy Guarantor on 4 July 2013).
Data Controller: E.A.U. SRLS – P.IVA. IT04769280407 – C.F.04769280407 – Viale Ceccarini 61/F – 47838 – Riccione (RN) – Tel:+39 333 1568020/+39 333 1568020 – Email: info@snouf.it
Site to which this privacy policy refers: https://www.snouf.it (Site). The Data Controller has not appointed a DPO. 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. The main processing of your personal data is described below. In particular, the legal basis of the processing, whether the provision of personal data is obligatory and the consequences of not providing personal data are explained. In order to better describe your rights, we have specified if and when a certain processing of personal data does not take place.On the Site you have the possibility to enter personal data of third parties. In this case, you warrant that you have obtained the consent of these parties to the inclusion of this personal data. Therefore, you undertake to indemnify and hold harmless the Data Controller from any liability.
Site Registration
The Site does not offer the possibility of registration. Therefore, the Data Controller does not process your personal data for this purpose.
Purchases on the Site
It is not possible to make purchases on the Site. Therefore, your personal data will not be processed for this purpose.The Data Controller does not process your data in order to send you ‘remainder’ emails to purchase products and/or services from the Data Controller.
Responding to your requests
Your data will be processed to answer your enquiries. Providing it is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis for the processing is the legitimate interest of the Data Controller in fulfilling your requests. This legitimate interest is equivalent to the user’s interest in receiving replies to communications sent to the Data Controller.
Generic marketing
Subject to your 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 products or those of third parties. 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, and will also make it impossible for the Data Controller to conduct market surveys, including those aimed at assessing the degree of user satisfaction, and to send you newsletters. These communications will be sent to the e-mail and/or telephone number provided by you 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 your purchases, in order to send you advertising material and/or newsletters relating to its own products or those of third parties, of your specific interest. 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 draw up your commercial profile, by surveying your purchasing choices and habits, as well as to send you advertising material relating to products of the Data Controller and/or third parties that are of specific interest to you. These communications will be sent to your e-mail and/or telephone number.
Data transfer
For the purpose of sending promotional communications, with your explicit consent, your personal data may be passed on to ‘third parties’. The legal basis of the processing is your consent. The provision of personal data for this purpose is purely optional. Failure to consent to the transfer will make it impossible to transfer your personal data to third parties for advertising purposes.
Geolocation
In the event of access to the Site, you may receive a notification on your device (fixed and/or mobile) which will give you the option of whether or not to allow the location of your device (so-called geo-localisation). You may freely allow or refuse this setting, without this entailing substantial changes to the functionality of the Site. You will be able to change your geolocation settings at any time through your device settings. The legal basis for the processing is the legitimate interest of the Data Controller in providing services relevant to your location. This legitimate interest is equal to the user’s interest in receiving services as relevant to his/her location as possible.
Communication of personal data
In the ordinary course of its business, the Controller may communicate your personal data to certain categories of persons. In Article 2 you will find a list of the persons to whom the Controller communicates your personal data. To facilitate the protection of your rights, Article 2 may specify in certain cases when your data are not disclosed to third parties. The ‘communication’ of personal data to third parties is different from the ‘transfer’ (regulated in the preceding point). In fact, in communication the third party to whom the data is transmitted may only use it for the specific purposes described in the relationship with the Data Controller. In the transfer, on the other hand, the third party becomes the autonomous Data Controller. Moreover, in order to transfer your personal data to a third party, your consent is always required. Notwithstanding the foregoing, it is understood that the Data Controller may still use your personal data in order to properly fulfil its obligations under applicable laws.
SPECIFIC PRIVACY POLICY
Art. 1 Method of treatment
1.1 The processing of your personal data will be mainly carried out with the aid of electronic or otherwise automated means, in the manner and with the tools suitable to guarantee their security and confidentiality in accordance 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 you can contact and be contacted by the Data Controller, subject to your consent. The legal basis is the legitimate interest of the Data Controller in responding to your requests via the chatbot service. This legitimate interest can be considered equivalent to the data subject’s interest in using the automated chatbot service.
1.2 The information acquired and the manner in which it is processed will be relevant and not excessive in relation to the type of services rendered. Your data will also be managed and protected in secure computer environments appropriate to the circumstances.
1.3 No ‘special data’ are processed through the Site. Particular data are those which may reveal racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organisations of a religious, philosophical, political or trade-unionist character, state of health and sex life.
1.4 No judicial data are processed through the Site.
Art. 2 Communication of personal data
The Data Controller may communicate your personal data to certain categories of persons. The subjects to whom the Data Controller reserves the right to communicate your data are listed below:
- The Data Controller may communicate your personal data to all those entities (including public authorities) that have access to your 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, Chambers and Labour Offices, etc.), if the communication is necessary or functional to the correct fulfilment of the obligations arising from the law.
- The Data Controller makes use of employees and/or collaborators in any capacity. For the proper functioning of the Site, the Data Controller may communicate your personal data to these employees and/or collaborators.
- In its ordinary business of managing the Site, the Data Controller makes use of companies, consultants or professionals in charge of installing, maintaining, updating and, in general, managing the hardware and software of the Data Controller or which the latter uses for the provision of its services. Therefore, only with reference to these purposes, your data may also be processed by these subjects.
- In order to send its communications, the Data Controller makes use of external companies in charge of sending this type of communication (CRM platforms). Your personal data (in particular your email) may therefore be communicated to these companies.
- For customer care purposes, the Data Controller uses one or more companies to provide customer care services. For this purpose only, your personal data may be communicated to these companies.
The Data Controller reserves the right to amend the above-mentioned list on the basis of its ordinary operations. Therefore, you are invited to regularly access this notice to check to which entities the Controller discloses your personal data.
Art. 3 Storage of personal data
3.1 This article describes how long the Data Controller reserves the right to store your personal data.
- Your personal data will only be stored for as long as is necessary to ensure the proper provision of the services offered through the Site.
- For marketing purposes, personal data will be stored until consent is revoked. For inactive users, personal data will be deleted one year after the sending of any last viewed email.
- For customer care purposes, the data will be deleted once the service is completed.
- For the purpose of executing the sales contract, the data will be kept for 10 years from the date of receipt of the purchase order. This is to allow the Data Controller to exercise its right of defence and to prove that the contract has been properly executed.
- As stipulated in 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 the event of an audit.
3.2 Without prejudice to Article 3.1, the Data Controller may retain your personal data for as long as required by specific regulations, as amended from time to time.
Art. 4 Personal data transfer
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 the transfer of your personal data takes place in a country outside the EU and for which the European Commission has issued an adequacy finding, the transfer is in any case considered safe from a regulatory point of view. This Article 4.1 indicates the countries to which your personal data may possibly be transferred and where the European Commission has issued an adequacy finding. You are therefore invited to access this article regularly to check whether your personal data is being transferred to a country with these characteristics.
4.2 Notwithstanding Article 4.1, your data may also be transferred to countries outside the EU and for which the European Commission has not issued an adequacy finding. You are therefore invited to regularly review this Article 4.2 to find out to which of these countries your data may be transferred. In order to enable the proper functioning of the Site, your personal data may be transferred to the U.S.. In these cases, the Data Controller will take 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 4 June 2021.
4.3 In this article, the Data Controller indicates the countries in which it may specifically direct its activities. This circumstance may imply the application of the legislation of the country in question, together with that of the GDPR. At the user’s request, the Data Controller will apply to the processing of personal data the legislation that may be more favourable under the user’s national legislation.
Art 5. Rights of the data subject
Pursuant to Art. 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 its processing, as well as the right to data portability
- withdraw consent at any time without prejudice to the lawfulness of the processing based on the consent given prior to withdrawal
- file a complaint with a supervisory authority (e.g. the Data Protection Authority).
The aforementioned rights may be exercised by making a request to the contacts indicated in the Preamble without formalities.
Art. 6. Modifications and Miscellaneous
The Data Controller reserves the right to make changes to this policy at any time, giving appropriate publicity to users of the Site and ensuring in all cases adequate and similar protection of personal data. In order to view any changes, you are invited to consult this policy on a regular basis. In the event of substantial changes to this privacy policy, the Data Controller may also give notice thereof by email.