GENERAL INFORMATION ON DATA PROCESSING

 

"PRIVACY POLICY"

 

 Information on the processing of personal data

pursuant to European Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016, relating to the protection of natural persons with regard to data processing personal (for short "GDPR")

 

ABOUTLET is a trademark of SIROMA Srl (by hereinafter referred to as "owner") and considers privacy and the protection of personal data fundamental and invites its users and customers to carefully read this Policy which contains important information on Data Processing (in short, "Information").

 
In any case, the logical and physical security of the data and, in general, the confidentiality of the personal data processed will be guaranteed, implementing all the necessary technical and organizational measures to guarantee their security.
This Policy:
  • is intended for the sites https://www.aboutlet.it (hereinafter: "Site(s")) ;
  • constitutes an integral part of the site and the services offered by the company;
  • is provided in accordance with what is described in the General Conditions of Sale and Terms of Use;
  • is made pursuant to art. 13 of the Regulation, to those who interact with the web services of the Site, both through simple consultation and through the use of specific services made available through the Site or otherwise arranged by of the company.
  • is intended exclusively for adults to whom the company's services are aimed.

 A) Identity and contact details

ABOUTLET is a trademark of SIROMA Srl - Via S. Nullo. 100.2 - 80014 Giugliano in Campania (NA)
P.IVA 10057421215

 

B) What data do we collect and how

  • Data provided voluntarily by the interested party
During your use of the Website and the services offered by the company in general, we may ask you to provide us with certain personal data or personal information that can be used to identify you, e.g. via email or online form, via the membership forms for the Clubs and our Services or via another form of request. This information may include personal and contact information, such as your name, surname, address, email and telephone number, and some information such as your gender and profession. Specific summary information may be made available on the pages of the Site or in specific forms prepared for particular services on request.
 

The detailed General Information on Data Processing is always available to the interested party (in short, "Privacy Policy ") which we invite you to consult carefully.

  • Data collected automatically
During normal operation, the Website may automatically collect some personal data relating to the user, the transmission of which is implicit in the use of Internet and cellular telephony communication protocols. This data is collected through the use of systems capable of storing text or information files, for example Cookies or SDK (Software Development Kit).
This information may include navigation and functionality indications, statistical and technical information, and, if optional, some information about user preferences to improve your browsing experience. navigation or geolocation to locate the nearest store.
 
Through the website, certain data sharing permissions may also be requested via social networks (e.g. Facebook, Google) which allow it to perform actions with the relevant User accounts and to collect information, including personal data, from it. In this case you must also refer to the terms of use, permissions, settings and privacy policy of the individual social network.

The relevant Information on the Processing of Data collected automatically is always available to the user (in short, "Cookie Policy") which we invite you to consult carefully. And the option to manage preferences via the appropriate online section is also always available.

Some information is necessary in order to provide the services connected to the Site and failure to collect it would make it impossible to provide the aforementioned services or the partial functioning of the Site. While optional information does not affect the functioning of the services and can be managed freely by the user. It is always expressly indicated in the forms and forms which items are mandatory. Explicit consent will always be required, through specific request, where necessary.
 

C) Purpose of the processing for which the personal data are intended and related legal basis

Your personal data will be processed:
 
(i) without obligation of consent for the following purposes:
  • ensure the complete and correct functioning of the Site, online account registration, management of orders, purchases, sales and deliveries of products and related monitoring, management of customer service, management of payments, management of returns and repairs, management of contacts with the customer ( email/SMS/WhatsApp), management of vouchers and discounts;
  • administrative-accounting management and related obligations (issuing receipts, invoices, arranging payments) possible protection of credit positions and defense in court;
  • internal statistics, analysis and corporate economic management
  • in relation to the contact details provided in the contract, sending advertising of similar products with the right to immediate cancellation upon request;
The above treatments respond respectively to the following legal bases:
  • fulfillment of a contract or pre-contractual measures, satisfaction of a request from the interested party – condition of lawfulness article 6, letter b) GDPR;
  • legal obligation to which the Data Controller is subject - condition of lawfulness article 6, letter c) GDPR - or for the assessment, exercise or defense of a right in court;
  • pursuit of a legitimate interest of the Data Controller - condition of lawfulness article 6, letter f) GDPR - relating to the improvement of company functioning and market research, the improvement of the services provided to its customers,
  • pursuit of a legitimate interest of the Data Controller - condition of lawfulness article 6, letter f) GDPR and 130 Legislative Decree. 30 June 2003, n. 196 ("Privacy Code") - so-called. "soft spam" direct marketing and customer loyalty.

The provision of data, for the purposes referred to in the previous section (i) is required and the lack of data and/or any express refusal to process will make it impossible to the Data Controller to execute the contract or pre-contractual measures, to fulfill the obligation with possible non-fulfilment and liability of the interested party also to sanctions contemplated by the legal system (for example impossibility of regular invoicing).

 
(ii) with your consent (article 7, GDPR), for the following purposes:
  • various types of marketing activities, including the promotion of products and services, the distribution of posters and paper and/or digital information and promotional material, the sending of newsletters and commercial communications via e-mail, invitations;
  • profiling activities of various types, including the analysis of behavior for promotional purposes, the creation of lists for promotional purposes, commercial communication and sending newsletters, the processing of profiles for the provision of targeted and personalized services for customer needs.

The provision of data for the purposes referred to in the previous section (ii) is optional, with the consequence that you may decide not to provide your consent, or to revoke it at any time. For these treatments, automated processes are used through the use of software which in any case provide for human decision-making intervention aimed at avoiding unwanted consequences for the interested party, always limited to the receipt of communications from the Data Controller.

D) Categories of recipients of personal data

 
For the purposes referred to in the previous paragraph, the personal data provided by you may be communicated or made accessible:
  1. to employees and collaborators of the Data Controller, in their capacity as authorized data processing employees (or so-called "data processors");
  2. to third parties who carry out activities in outsourcing on behalf of the Data Controller, in their capacity as Data Processors, including:
  • service providers for the management of the information system and telecommunications networks and to the company in charge of e-commerce management, service providers for the management of the archiving of paper and/or computerized documentation, service providers for the management of customer assistance activities, including through websites (e.g. call centers, help desks, etc.), service providers for the management of commercial communication activities;
  • freelance professionals, studios or companies in the context of assistance and consultancy relationships, also for the control of company organizational management;
  • banks and credit and insurance institutions for carrying out economic (payments/collections) and insurance activities;
  • subjects who carry out control, audit and certification obligations of the activities carried out by Siroma Srl also in the interests of customers, fraud detection and prevention bodies;
  1. ad Judicial or supervisory authorities, administrations, public bodies and bodies (national and foreign);

The complete and updated list of data controllers can be obtained by written request to the address privacy@aboutlet.it.

 

E) Storage and transfer of personal data abroad

 

The management and storage of personal data takes place in cloud and on servers located internally and externally of the European Union owned and/or available to the Data Controller and/or third-party companies duly appointed as Data Processors.

The transfer of data abroad to countries not belonging to the European Economic Area (EEA) takes place exclusively in the context of intragroup communications for the purposes indicated above or to contractual partners , in any case in compliance with the provisions contained in Chapter V, articles 45 and 46 GDPR.
 
Your personal data will not be disclosed.

F) Personal data retention period

 
The personal data collected for the purposes indicated in the previous paragraph (C), section (i) will be processed and stored for the entire duration of any contractual relationship established.

From the date of termination of this relationship, for any reason or cause, the data will be retained for the duration of the applicable limitation periods </span >ex lege, i.e. 10 years.

 
The personal data collected for the purposes indicated in the previous paragraph (C), section (ii) will be processed and stored for the time necessary to fulfill these purposes and in any case for a period not exceeding 3 years from the date on which we receive your consent.
After these retention periods have expired, the data will be destroyed or made anonymous.
 

G) Exercisable rights

In accordance with the provisions of Chapter III, Section I, GDPR, you may at any time exercise the rights indicated therein.
 
The request can be made by simply sending an email to the email address indicated in the footer of the website
In particular, reference is made to the following requests:
 
  • Right of access - Obtain confirmation as to whether or not personal data concerning you is being processed and, if so, receive information relating, in particular, to: purpose of the processing, categories of personal data processed and period of conservation, recipients to whom these may be communicated (Article 15, GDPR),
  • Right of rectification- Obtain, without unjustified delay, the rectification of inaccurate personal data concerning you and the integration of incomplete personal data (Article 16, GDPR),
  • Right to cancellation - Obtain, without unjustified delay, the cancellation of personal data concerning you, in the cases provided for by the GDPR (Article 17, GDPR),
  • Right of limitation - Obtain the limitation of processing, in the cases provided for by the GDPR (Article 18, GDPR)
  • Right to portability - To receive the personal data concerning you in a structured format, commonly used and readable by an automatic device, as well as to obtain that they are transmitted to another owner without impediments, in the cases provided for by the GDPR (Article 20, GDPR)
  • Right to object - Object to the processing of personal data concerning you, unless there are legitimate reasons for the Data Controller to continue processing (Article 21, GDPR)
  • Right to lodge a complaint with the supervisory authority- Propose a complaint with the GDPR Italian Authority for the Protection of Personal Data, Piazza Venezia n. 11, Rome - https://www.garanteprivacy.it/ - or "CNIL": < em>Commission Nationale de l'Informatique et des Libertés - French Personal Data Protection Authority -https://www.cnil.fr.