Information on the processing of personal data

Information on the processing of personal data. In force from 09/23/2023

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 : Lea Ballerina di Anna Oprandi via Guzzanica 24A Stezzano BG VAT number 04456140161 info@negoziodidanzaonline.com

Site to which this privacy policy refers: www.negoziodidanzaonline.com ( 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. It is also possible to register on the Site using external services. In this case your registration data will be shared with the companies of these external services for the sole purpose of allowing registration on the Site. The legal basis of this processing is the legitimate interest of the Data Controller in allowing registration on the Site through external services . The provision of personal data for this purpose is purely optional. However, failure to consent to the processing of data will make it impossible to register via 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 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. Through the "follow on shop" option, the Data Controller can process your personal data also to send updates by email and/or telephone (depending on the options present from time to time on the Site) on the status of orders, shipments and/or supplies. The legal basis of this processing is the legitimate interest of the Data Controller in sending this type of communications. This interest is equal to your interest in receiving this type of updates. The provision of personal data for this purpose is optional. However, if personal data is not provided, it will not be possible for the Data Controller to send this type of communication.

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 e-mail and/or telephone number provided by you on the Site (in the latter case also via text message and/or WhatsApp).

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 your email and/or telephone number (in the latter case also via text message and/or WhatsApp).

Transfer of data

To send promotional communications, subject to your explicit consent, your personal data may be transferred 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

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

The information and data requested when booking an appointment and/or a service will be used to allow you to make the booking in question with the Data Controller in the manner indicated on the Site. The legal basis of the processing is the need of 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 book an appointment and/or service on the Site.

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. If the automatic chatbot service is operational, your personal data will also be processed to allow 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 in responding to user requests via the chatbot service. This legitimate interest can be considered equivalent to the interest of the interested party in using the automatic chatbot service.

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. On the Site, you will have the possibility to create a public profile in which other users will be able to view the material you publish and your personal data (e.g. photographs or videos). Therefore, you acknowledge and accept that the Data Controller is not responsible for the use that users may make of this material and your personal data.

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.
  • For customer assistance purposes, the Data Controller uses one or more companies appointed to provide customer care services. For this purpose only, your personal data may be communicated to these companies.
  • 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.
  • As required 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 the event of an audit.
  • 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.

  • Your personal data may be transferred to the USA as established by the adequacy decision of the European Commission. With this decision, the European Commission has decided that the USA offers personal data protection similar to that offered by the European Union.
  • To allow the correct operation of the Site, your personal data may be transferred abroad. This is permitted according to the European Commission decision of 20 December 2001 n. 2002/2/EC (published in the Official Journal of the European Communities L 2/13 of 4 January 2002) which established that Canada guarantees an adequate level of protection of personal data transferred from the European Union to recipients subject to the law Canadian Personal Information Protection and Electronic Documents Act ("the Canadian Act") of 13 April 2000.

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.

  • The Site processes personal data of natural persons located in Australia. This information has been drawn up taking into account the provisions of Australian national and federal legislation. In particular, reference is made to the Federal Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).
  • The Site also manages personal data of Brazilian users. Brazilian users are informed that this privacy policy complies with the provisions of the Brazilian law on the protection of personal data (LGPD), which came into force on 18 September 2020. All the rules indicated above therefore apply.
  • The Site also manages personal data of Canadian users. Therefore, Canadian users are informed that this privacy policy also complies with the provisions of the Personal Information Protection and Electronic Documents Act.
  • The California Consumer Privacy Act (CCPA) is a California law that was passed in June 2018. The Data Controller processes the personal data of California users pursuant to this law. The user is informed that the personal data processed are those communicated on the Site to allow the execution of the contract. The user can exercise the rights provided by the CCPA by contacting the Data Controller at the contact details published in the introduction.
  • The Virginia Consumer Data Protection Act (CDPA) is a Virginia law that was passed in March 2021. The Data Controller processes the personal data of Virginia users pursuant to this law. The user is informed that the personal data processed are those communicated on the Site to allow the execution of the contract. The user can exercise the rights provided by the CDPA by contacting the Data Controller at the contact details published in the introduction.
  • The Nevada Privacy Law (Senate Bill 220) is a Nevada law, passed in 2019, that protects the privacy of user data. The Data Controller manages the personal data of Nevada users in accordance with the aforementioned legislation. Users are advised that the personal data being processed are those provided through the Site to finalize the contract. Users can assert the rights guaranteed by the Nevada Privacy Law by contacting the Data Controller using the contact details provided above.
  • New Zealand's Privacy Act 2020, which underwent significant changes in December 2020, regulates the protection of your personal data. In accordance with this legislation, the Data Controller carefully manages the personal data of New Zealand users that are collected through the Site in order to ensure the correct execution of the contract. Users are advised that they can exercise their rights under New Zealand privacy law by contacting the Data Controller at the contact details indicated initially.
  • The Personal Information Protection Law (PIPL) is a Chinese regulation that came into effect on November 1, 2021 and regulates the protection of users' personal data. In compliance with this law, the Data Controller is committed to the responsible and secure management of personal data of Chinese users that are collected through the Site, in order to ensure the appropriate fulfillment of the contract. Users are informed that they can exercise the rights guaranteed by the Personal Information Protection Law by contacting the Data Controller using the contact details provided above.
  • The Personal Data Protection Act (PDPA) is a Singapore law that regulates the protection of your personal data. In accordance with the PDPA, the Data Controller undertakes to responsibly manage the personal data of Singapore users collected through the Site, to ensure adequate fulfillment of the contract. We inform you that you can exercise your rights under the PDPA by contacting the Data Processor at the contact details provided above.
  • In Malaysia, the protection of your personal data is guaranteed by the Personal Data Protection Act 2010 (PDPA). The Data Controller scrupulously adheres to the principles and provisions of this law for the management of personal data collected on the Site from Malaysian citizens, in order to properly conclude the contract. Users are invited to take note that they have the right to exercise the rights outlined in the PDPA by contacting the Data Controller through the contact details mentioned above.
  • For users in the Philippines, please note that the Data Controller undertakes to comply with the Data Protection Act of 2012 (DPA) in the management of personal data collected through the Site. This law aims to protect the rights and privacy of individuals. Users can exercise their rights under the DPA by contacting the Data Controller using the contact details provided.
  • We would like to inform South African users that personal data collected via the Site is handled in accordance with the South African Data Protection Act 2013 (POPIA). The Data Controller undertakes to comply with the provisions of this law. South African users can assert the rights guaranteed by POPIA by contacting the Data Controller through the communication channels provided.
  • Please be advised that for users residing in the State of Connecticut, the Data Controller carefully observes the Connecticut Consumer Data Protection Act (CTDPA), which came into force on July 1, 2023, in the processing of personal data collected through the Site. This law was established to safeguard consumer data privacy. Users residing in Connecticut can exercise the rights guaranteed by the CTDPA by contacting the Data Controller at the contact details provided.
  • Thai users are advised that the Data Controller carefully follows Thailand's Personal Data Protection Law 2019 (PDPA) when handling personal data collected on the Site. This is critical to ensuring the privacy and security of user data. To exercise the rights established by the PDPA, Thai users can contact the Data Controller using the contact details indicated.

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.

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