Processing means: any operation or set of operations, which is performed on personal data whether or not by automated means and applied to the personal data or set of personal data, such as the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmissions, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Personal data means: any information relating to an identified or identifiable natural person in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
This privacy notice may be updated in line with laws and technological developments that may occur. In that case, due publicity will be given on the Site to any updated versions.
- Who is the data controller of the Users’ personal data?
- What type of data is processed?
- What is the purpose of the processing of the Users’ personal data?
- What is the legal basis for processing the Users’ personal data? Can consent be revoked?
- What will happen if the Users do not provide their personal data?
- How are the User’s personal data processed? Might FIRERA SRLS share the Users’ personal data with any third parties?
- How long will the Users’ personal data be stored for?
- Will the Users’ personal data be sent abroad?
- What rights do the Users have?
1. Who is the data controller of the Users’ personal data?
The data controller of the Users’ personal data is FIRERA SRLS, tax code and VAT number 01737810885, with registered office in Pozzallo (RG) 97016 Street Via Sacco e Vanzetti Number 34.
2. What type of data is processed?
a) Browser data
The computer systems and software procedures for the operation of the sites owned by FIRERA SRLS automatically acquire, in their normal course of operation, some personal data relating to the User’s browser history.
This is anonymous information collected purely to obtain information regarding the use of the Site and to check its correct operation, and is used solely within FIRERA SRLS; such information, however, may, by its very nature, allow the User’s identity to be traced, also through processing and association with data held by third parties.
This category of data includes:
- IP addresses of the computers used by the Users using the service;
- number of accesses;
- pages viewed;
- date and time of access;
- the Url in which the browser was before viewing our page;
- the browser used;
- the operating system used.
b) Data provided voluntarily by the User
- contact information: data optionally and freely provided by the User when completing the form necessary to access the services of FIRERA SRLS, including e-commerce services, will be acquired by it together with the User’s e-mail address. These data will only be used by FIRERA SRLS to render the service requested and to improve it and make it more effective, within the limits of the purposes for which the data were collected.
- credit card data: if the User opts to pay by credit card, he/she will have to provide the credit card information on the payments service provider’s web site so as to complete the purchase (card number, holder, expiry date, security code and email address). Those data will be acquired by the payments service provider which will act as an independent data controller, without transiting on the server of FIRERA SRLS which, therefore, will not process the credit card data in any way.
- Prior purchase and returns: FIRERA SRLS keeps information relating to purchases and returns made on line by the Users. Such information includes the product, price and date of purchase. This allows Users who have registered an account to keep track of their purchases and returns.
- Purchases preferences: with the User’s express consent FIRERA SRLS may, for the purposes stated at point 3) letter e), collect information relating to consumer choices, purchase preferences also through specific cookies for the purpose and gender data (male/female) and personal data of the Users.
Specific summary privacy policies may be listed or viewed on the pages of the Site relating to particular services upon request and in the conditions of sale.
Cookies are small text files that are installed by a website on the User’s browser and that record some information related to the browsing; such data, unless the cookies are disabled, are communicated to the site that installed them every time the User returns to visit the website.
3. What is the purpose of the processing of the Users’ personal data?
FIRERA SRLS will process the data provided by the Users for the following purposes:
- To allow registration on the Site and the use of the services reserved to registered Users, including the possibility to make online purchases;
- To meet requests of Users, even if the same are not registered, about on line purchases and for information or clarifications regarding products for sale on the Site;
- To allow the completion of the purchase contract and the correct performance of the operations connected with it, including the after-sales service;
- For administrative and accounting purposes and in order to comply with the obligations provided by law, regulations, EU law and the instructions issued by the supervisory authorities and bodies;
- Subject to the specific consent on the part of the User, for the sending of information, commercial and marketing communications of specific interest to the User relating to products and services of FIRERA SRLS and based on the User’s purchase preferences by capturing the type and frequency of purchases made on the Site, as well as on the basis of gender data (male/female) and personal data (“profiled marketing“). Said activities may also include, inter alia, promotional activities such as the taking part in games and competitions, direct sales, customer care and customer satisfaction activities, market and statistical research and analysis, check an enquiries on product and service quality. The sending of communications for the above mentioned purposes by FIRERA SRLS may take place both via traditional routes (eg. Post, telephone calls with an operator) or automated methods such as email and SMS. The User may at any time request that said processing be terminated – also in part – by simple email sent to email@example.com. Limited to the email address provided by the User in the contract for the purchase of a product or service offered and sold over the Site directly by FIRERA SRLS, the latter may use the same to send information and promotional messages (including the “newsletter”) regarding similar products and services without need for the express prior consent of the User and providing that the User does not raise any objection (so-called “soft spamming“);
4. What is the legal basis for processing the Users’ personal data? Can consent be revoked?
Legal basis for processing the data subject’s data
The legal basis for processing the User’s data for the above purposes:
- point 3 letter a), provision of the service requested;
- point 3 letter b), reply to a request from the User;
- point 3 letter c), compliance with contractual obligations of FIRERA SRLS arising when the User buys products from FIRERA SRLS or requests any service from FIRERA SRLS;
- point 3 letter d), compliance with a legal obligation;
- points 3 letter e), User’s consent.
The personal data of the User may also be processed on the basis of a legitimate interest of FIRERA SRLS, such as to defend its rights in a dispute with the User, to prevent fraud or abuses.
Revocation of consent
If the User wishes to revoke his consent he may do so at any time by writing to: firstname.lastname@example.org
If the User is registered, he may revoke his consent by accessing his personal page and managing his preferences regarding the use of his/her personal data.
The User’s right to oppose the processing of his/her personal data for marketing purposes effected by automated contact (e-mail, SMS) also applies to the traditional forms of contact (post), save always the User’s entitlement to exercise that right in part, opposing for example merely the sending of promotional communications via automated means, by writing to: email@example.com.
Limited to the sending of the newsletter, the User may oppose the processing of his/her personal data also using the link present at the foot of any advertising email sent by FIRERA SRLS, that allows the automatic cancellation of the subscription to the newsletter.
The revocation of the User’s consent will not in any way affect the right of FIRERA SRLS to process the User’s data if said processing is necessary in order to meet its contractual obligations and/or insofar as FIRERA SRLS is obliged to process the User’s personal data to comply with a legal obligation or to defend its rights in a dispute with the User, in order to prevent fraud or abuses.
5. What will happen if the Users do not provide their personal data?
Save always as specified above in relation to the browsing data, the personal data that must obligatorily be provided by the Users are marked with an asterisk in the margin. These mandatory data are normally the User’s name and surname and email address. The provision of any other personal data requested in the forms for access to the service is facultative and left to the User’s discretion.
With reference to the purposes of the processing referred to in the above letter (e) (“profiled marketing” and “soft spamming“), the provision of the User’s personal data is merely optional. Failure to provide the personal data will not affect the possibility for the User to register on the Site and/or make purchases on it but will only result in the impossibility on the part of FIRERA SRLS to send the User information and promotional information (including the “newsletter”) and/or to analyse the User’s purchase preferences on the basis of the type and frequency of purchases made on the Site for the purpose of sending information and/or advertising material of specific interest to the User and in the impossibility on the part of the User to receive personalized promotional offers.
6. How are the Users’ personal data processed? Can FIRERA SRLS share the User’s personal data with any third parties?
Modalities of the data processing
The processing of the Users’ personal data will mainly be carried out using electronic or automated means, in the manner and using the means suitable to ensure the security and confidentiality of the said data, in conformity with the rules on personal data protection. In particular, adequate technical, IT, organisational, logistical and procedural safety measures will be adopted, so that the minimum level of protection of data as provided by law is guaranteed, allowing access only to persons in charge of the processing.
Ambit of sharing of data
The Users personal data may be communicated to the following subjects:
- Employees and/or collaborators of FIRERA SRLS, for the performance of administration, accounting and IT and logistical support, who act as, respectively, data processors and persons in charge of the processing;
- Companies or consultants appointed for the installation, maintenance, updating and, in general, management of hardware and software of FIRERA SRLS (including the Site);
- Companies appointed by FIRERA SRLS for sending online communications;
- Subjects appointed for the repair of products purchased, in compliance with the legal guarantee of conformity;
- to all those public and/or private subjects, individuals or legal entities (legal, administrative and tax advisors) if the communication is necessary or functional to the correct performance of the contractual obligations undertaken in relation to the services rendered over the Site, as well as any legal obligations;
- to shippers and subjects appointed for the delivery and/or collection of the purchased products;
- to all those subjects (including Public Authorities) that have access to the data pursuant to legal or administrative orders;
- to subjects, other than those listed above, appointed as data processors or in charge of the processing by FIRERA SRLS, for the performance of the activities connected with the conclusion of the purchase contract.
Said subjects act either as independent data controllers or as data processor. The updated list of the data processors can be requested by writing to: firstname.lastname@example.org.
The data will not in any way be divulged or communicated to other third parties, save as required pursuant to any obligations at law.
7. How long will the Users’ personal data be stored for?
The Users’ personal data will be stored only for the time necessary to ensure the correct rendering of the services offered by FIRERA SRLS.
In relation to the administrative-accounting purposes associated with the conclusion of the contract and after-sales assistance, the Users’ personal data will be stored for the period provided for the keeping of contractual and accounting documentation and the limitation periods provided by law. FIRERA SRLS may store the Users’ personal data for a greater period of time in case it must defend itself in proceedings against the User or to prevent fraud or abuses.
Personal data relating to purchase preferences will be stored and processed for the purposes stated at letter (e) of point 3, for a maximum period of 36 months taking into account the type pf products and the annual average frequency of their purchase. At the end of said period FIRERA SRLS will cancel said personal data or render the same anonymous.
In relation to the sending of the newsletter, the personal data (name, surname and email address) will be held until such time as the User states his wish to cancel the subscription and, in any case, for a period of 24 months from their last use by FIRERA SRLS.
The criteria used to determine the period of retention of personal data take into account the permitted period of processing and the applicable tax rules, the period of prescription of rights and the nature of the legitimate interests where the same constitute the legal basis of the processing.
In accordance with the provisions of the applicable law, the personal data may be held for a period beyond that originally provided, in case of any dispute or request of the competent Authorities.
Further information on the period for which the Users’ personal data is held and the criteria used to determine said period can be requested by writing to: email@example.com.
8. Will the Users’ personal data be sent abroad?
It is possible that FIRERA SRLS may share the Users’ personal data with selected suppliers, who may process the same both inside and outside the EU/EEA. In the case of transfer of personal data to non-EU countries, that the European Commission does not consider as offering a level of protection similar to that in EU/EEA countries, FIRERA SRLS will adopt the appropriate security measures to ensure that the transfer of the same is safe and protected, such as, by way of example, the signing of the standard data protection contract clauses approved by the EU Commission.
For information on the possible transfer of your personal data abroad, please write to: firstname.lastname@example.org.
9. What rights do the Users have?
This section summarises the rights that the Users may exercise at any time and free of charge, by writing to: email@example.com.
The Users’ rights are:
- To obtain the confirmation of the existence or otherwise of personal data relating to him/her and to receive a copy of the same in a structured, commonly used and machine-readable format;
- To be made aware of the origin of the data, the purposes of the processing and the manner in which it takes place, and the logic applied to the processing carried out with electronic instruments;
- To request the updating, correction or – if he/she so wishes – the integration of the relevant data;
- To obtain the cancellation, transformation into an anonymised format or the block of any data processed in breach of the law, and to object, on lawful grounds, the processing;
- To object any processing aimed at sending advertising materials, direct sales, market research and business communications;
- To revoke given consent at any time. The revocation of consent does not prejudice the lawful nature of any processing based on the consent previously given;
- To request the limitation of the processing of his/her personal data in the case in which: (i) he/she should dispute the accuracy of his/her personal data, for the period necessary to FIRERA SRLS to verify the accuracy of the same; (ii) the processing is unlawful and the User opposes the cancellation of his personal data and askes instead that their use be limited; (iii) although FIRERA SRLS no longer requires the same for the processing, the User’s personal data are necessary to ascertain, exercise or defence a right before the courts; (iv) the User opposes a processing until such time as a decision is taken regarding the prevailing nature of the lawful grounds on which the data controller effects such processing as compared to those of the User;
- To obtain the portability of data that regard him/her, where technically feasible.
FIRERA SRLS may request additional information prior to satisfying the requests, should it need to verify the identity of the individual making the requests.
Pursuant to the Regulation (EU) 2016/679, FIRERA SRLS is not authorised to charge any sum for meeting the requests as stated in this paragraph, unless the same are clearly groundless or excessive, and in particular are repetitive in nature.
If a User requests more than one copy of his personal data or in the case of excessive or groundless requests, FIRERA SRLS may (i) charge a reasonable amount by way of expenses, taking into account the administrative costs borne in satisfying the request or (ii) refuse to meet the request. In these cases the FIRERA SRLS will inform the User of the costs before satisfying his/her request.
Save always any other administrative or jurisdictional remedy, the User is also entitled to make a claim to a supervisory Authority (in Italy the Garante per la protezione dei Dati Personali), if he/she considers that the processing that regards him/her is carried out in breach of the data protection rules. Further information is available on the internet website: http://www.garanteprivacy.it.
FIRERA SRLS does not intend to collect personal information from persons under 16 years of age. If a User considers that FIRERA SRLS may be in possession of personal informations relating to persons under 16 years of age, he/she can contact FIRERA SRLS at: firstname.lastname@example.org.
For any information, request, or clarification regarding the privacy of the Users, and in order to exercise any of the rights stated above, please write to: email@example.com.