INFORMATION ON THE PROCESSING OF PERSONAL DATA
This information on the processing of personal data is provided pursuant to art. 13 of EU Regulation 679/2016 (General Data Protection Regulation – hereafter, “GDPR”) and describes in detail how and for what purposes your personal data will be processed during your navigation on the website www.mamoergosum.com and the use of the various functions and services made available inside it, including the eCommerce platform at www.mamoergosum.com
Customers under 14 years of age will be obliged to express their consent through the authorization of their parents or guardian (pursuant to art.8, c.1 of Regulation (EU) 2016/679 and art.2-Quinquies D.Lgs 196/2003).
A) PERSONAL DATA CONTROLLER
The owner of the processing of your personal data is Mamo Ergo Sum S.R.L..
You may contact the data controller, for questions, requests or clarifications regarding this informative note or in general the processing of your personal data, at the following addresses:
e-mail address (indicating on subject “Privacy”): firstname.lastname@example.org
address: headquarters in Tortoreto, via A. Canova, 14
telephone number: 3483842590
B) CATEGORY OF PERSONAL DATA PROCESSED
The owner processes the following categories of personal data during your navigation on the Site and the use of the related functions / services:
- information and data related to your navigation on the website (including but not limited to, information about pages and sections of the website visited, your activities on the website, the time spent on individual pages and sections of the website, etc.);
- information and data relating to the devices used by you to navigate the Site and use its functions and services (by way of example, IP address, browser used, type of device used, data relating to its geographical location, only if you have previously given your consent to such processing) information from cookies or similar tools issued by the pages of the site;
- if you intend to register or have already registered in the reserved area of the website called “My Account” (hereafter, “reserved area”), the personal data required for the purposes of creating the account (name, surname, e-mail address, password) and information relating to the activities you carry out within the site once you have logged in (e.g. use of services reserved for registered users), or within the reserved area;
- if you wish to conclude a commercial transaction in the “eCommerce” section of the site, personal data and information relating to the transaction (for example, but not limited to, identification data, contact data, delivery data for any shipments, payment data, billing data in case of selection of this option);
- your e-mail address indicated when finalizing the transaction on the website, for sending communications regarding news, promotions and offers valid on products or subject of the transaction, or similar products and services;
- if you intend to get in touch with the owner by filling out the appropriate form in the “Contact Us” section of the site (or by sending communications to the owner’s contacts on the site), the personal data and information required to send the contact request and to manage your communication (name, surname, e-mail address for feedback, as well as the content of the information or requests sent by you);
- your contact details (including but not limited to e-mail address), if you wish to receive commercial communications from the data owner (e.g. newsletter) and only after you express your consent by selecting the appropriate checkbox;
- your contact details (including but not limited to e-mail address) and the information/ preferences that emerged in the surveys conducted, if you participate to market survey and more generally to statistical surveys proposed by the Data Owner or by third parties, and only after you express your consent by selecting the appropriate checkbox;
- if you participate to any communication initiatives or prize-winning events promoted by the data owner through the Website: identification data (for example, name and surname), contact information (including but not limited to, e-mail address, address telephone) and address (including but not limited to, physical address) necessary to allow his participation and the possible management of the win/selection phase;
- if you permit any kind of interation between the website contents and your profiles on the social networks Facebook and Instagram (e.g. “like”, “share” keys), data and information relating to said profiles will also be processed.
The personal data in categories a) and b) are automatically collected by the Owner during your navigation on the website.
The Personal Information belonging to all other categories are provided by the customer directly and voluntarily.
C) CONSEQUENCES OF NOT PROVIDING PERSONAL INFORMATION
The processing of personal data in categories a) and b) of the previous section is necessary for the owner in order to guarantee you the best possible browsing experience, and to provide you with all the functions and services provided through the website. However, it is possible to restrict the processing of personal data through some function made available by the website (particularly with reference to the transmission of cookies or similar tools – on this point, please refer to the cookie information of the site) or by your device or browser / navigation app. In this case navigation on the website may be limited and some of its functions/services may be inaccessible.
The processing of personal data mentioned in remaining categories of the previous section is necessary in order to fulfil contractual obligations (i.e., to allow you to access and use specific functions/services of the site, such as, by way of example and not limited to, the Reserved Area) and legal obligations (with reference to the performance of regulatory obligations on the part of the owner); the customer is therefore obliged to provide such personal data in order to use the services and functions of the site from time to time requested.
In case of failure to provide the above mentioned data, it will not be possible for the Owner to provide the functions and services of the site requested by you.
D) THE PURPOSE OF PROCESSING OF DATA AND ITS LEGAL BASIS
Purpose and legal basis
- Allow navigation on the site, access its pages and sections, use its functions and services (including interactions with social network profiles). Treatment required on a contractual basis (Art. 6(i)(b) GDPR);
- Allow your subscription/registration to the Reserved Area, and the use of the services offered to registered users . Treatment necessary on a contractual basis (art. 6(i)(b) GDPR);
- Allow the execution and finalization of commercial transactions at the appropriate areas of the website and consequently manage each phase of the transaction (acceptance of payment, possible shipment of products or provision of services). Treatment necessary on a contractual basis (art. 6(i)(b) GDPR);
- In case of transactions on the site, allow the owner to regularly keep the accounting records and comply with the related obligations in accounting, tax and administrative matters (by way of example, pursuant to art. 2220 of the Italian Civil Code). Treatment necessary to comply with legal obligations to which the owner is subject (art. 6(i)(c) GDPR);
- Receive communications of a commercial nature from the owner. Processing carried out with the prior consent of the interested party (art. 6(i)(a) GDPR);
- Receive commercial communications from the data Processing carried out with the prior consent of the interested party (art. 6(i)(a) GDPR);
- Allow your participation in market surveys, polls, market research and more generally in statistical surveys proposed by the owner or third parties. Processing carried out with the prior consent of the data subject (art. 6(i)(a) GDPR);
- Allowing the data owner to verify requests made by administrative, judicial or public security authorities (including but not limited to, pursuant to art. 210 of the Italian Criminal Code and art. 248 of the Italian Criminal Code). Treatment necessary in compliance with legal obligations to which the owner is subject (art. 6(i)(c) GDPR);
- Allowing the Owner to ascertain, exercise or defend his or her own rights in or out of court, or in any case in the context of disputes or controversies (established by you, the Owner, third parties or judicial or administrative authorities). Treatment necessary for the pursuit of the legitimate interest of the Owner (art. 6(i)(f) GDPR);
- Evaluate your browsing experience on Website in order to update it and improve it according to information emerged. Treatment necessary to pursue the legitimate interest of the Owner (art. 6(i)(f) GDPR);
- Allow the data owner or third parties appointed by him/her to verify the correct navigation of users on the site and/or the correctness of the transactions carried out. Treatment necessary for the pursuit of the legitimate interest of the Owner (art. 6(i)(f) GDPR);
- Send you communications and commercial information about news, promotions and offers related to the products or services involved in the transaction, or similar products and services, after the transaction on the website is completed. Treatment necessary for the pursuing of the Data Owner’s legitimate interest (art. 6 (i)(f) GDPR)
If you wish more and more specific information about the assessment made by the data owner regarding the balance between the legitimate interests pursued and the interests or fundamental rights and freedoms of the interested persons, you may contact the owner at the contact details in section A).
E) CATEGORIES OF RECEIVERS OF PERSONAL DATA PROCESSED
In order to fulfill the purposes mentioned above, your personal data will also be processed by third parties in addition to the Data Owner.
These subjects will process your personal data both on behalf of the owner (therefore, as managers), and as autonomous owners, upon specific communication by the Owner.
Specifically, your personal data will be processed by the following categories of receivers:
- service providers necessary for the proper functioning of the site and its functions/services (for example, but not limited to, ICT service providers, hosting service providers, providers of IT platforms and applications);
- service providers necessary for the performance of transactions on the site, and for any related and consequent fulfilment (for example, but not limited to, payment service providers and banking operators, shippers / couriers for the delivery of products sold);
- jurisdictional, administrative and / or public security authorities, in accordance with the instructions of legal provisions, for the purpose of investigating and prosecuting offences, preventing and safeguarding risks or threats to security and public order, and for any reason related to the protection of the rights and freedoms of individuals;
- communication and marketing service providers (for example, but not limited to, communication agencies);
- market research and statistical surveys.
If you want more details about the identification details of all the receivers listed above by categories, you can contact the data owner at the contact details in section A).
F) TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA
The data owner will not process your personal data outside the European Economic Area.
If one or more third parties in charge of processing, as data controllers, process personal data outside the European Economic Area, the transfer will take place to third countries that ensure an adequate level of protection of the personal data of the data subjects, on the basis of an adequacy decision adopted by the European Commission.
In case of transfer to countries outside the European Economic Area that do not ensure an adequate level of protection of personal data of the data subject, transfer will take place only as follow:
- after the adoption of suitable or appropriate guarantees (including but not limited to, the stipulation of data transfer agreements that incorporate the standard contractual clauses approved by the European Commission);
- if necessary for the conclusion of a contract or the fulfillment of contractual obligations between you and the data owner.
However, in such cases, the data owner will take care to provide you, upon your simple request, with detailed information on the modalities of data transfer to third countries, any appropriate or appropriate guarantees adopted and the means to obtain copies of such data or the place where they have been made available.
G) STORAGE PERIOD OF PERSONAL DATA PROCESSED
Your personal data will be stored for a variable period depending on the type and purpose of processing. At the end of the storage period, your personal data will be deleted or made irreversibly anonymous. The periods of storage of personal data are specified below:
- data relating to commercial transactions carried out on the Site (including payment data): they will be kept until the finalization of any administrative, fiscal, civil law fulfillment (by way of example, the term of forfeiture to exercise the right of withdrawal or contest the payment). Invoicing data will be kept for ten years;
- navigation data: for the duration of your access to the Site and for the storage times foreseen by the relative technologies in use, in relation to which you may consult the website’s cookie information;
- data relating to your registration in the Reserved Area: they will be kept until your request to cancel your account (or exercise any other right recognised by current legislation);
- data and information relating to contacts between you and the Owner: will be kept until your requests are processed and fulfilled;
- data relating to the transmission of commercial communications concerning news, initiatives and offers of the Owner about products / services already purchased: data will be kept until the exercise of the right of opposition of the person concerned or in case of cancellation of the data processed (also by selecting the appropriate function in the communications sent – so-called unsubscribe link);
- data relating to the transmission of commercial communications (also by third party commercial partners), market research and statistical surveys, carried out with the consent of the interested party: data will be kept until the exercise of the right of opposition of the person concerned or in case of cancellation of the data processed (also by selecting the appropriate function in the communications sent – so-called unsubscribe link), and in any case after 2 (two) years from your last interaction with the website.
If, at the end of the above mentioned period, personal data should be processed for specific purposes (e.g. to protect the rights of the owner in the context of a dispute), they will be kept until these purposes are exhausted (e.g. until the dispute is settled).
At the end of the storage periods indicated above, your personal data will be deleted, or in any case made unintelligible by the owner.
H) PROCESSING OF PERSONAL DATA BY AUTOMATED DECISION-MAKING PROCESSES
There is no provision for the processing of your personal data by automated decision-making processes (including profiling in accordance with Article 22, paragraphs 1 and 4 of the GDPR).
I) YOUR RIGHTS REGARDING THE PROCESSING OF PERSONAL DATA
You have the right to request the owner access to your personal data, pursuant to art. 15 GDPR.
By exercising your right of access, you may request information about:
- the purpose of the processing;
- the categories of personal data concerned;
- the addressees or categories of addressees to whom the personal data have been or will be comunicated, especially if they are addressees in third countries or international organisations;
- where possible, the intended period of retention of personal data or, where this is not possible, the criteria used to determine that period;;
- the existence of the right to ask the data owner to correct or delete your personal information, or to limit the processing of your personal data, or to object to their processing;
- the right to lodge a complaint with a supervisory authority: if the personal data are not collected from you, you can ask for all the available information about their origin;
- the existence of an automated decision making process, including profiling as referred to the art. 22, paragraphs 1 and 4 of GDPR, and at least in such cases, significant information on the logic used, as well as the importance and the expected consequencies of such treatment for you.
You are also guaranteed the following rights:
- the right to revoke the consent given, in accordance with article 7(3) GDPR, without prejudice to the lawfulness of the processing carried out before the revocation;
- the right to obtain from the data owner the adjustment of inaccurate personal information, or the integration of the incomplete data, pursuant to art. 16 GDPR;
- the right to obtain from the data owner the cancellation of personal pursuant to art. 16 GDPR. The exercise of this right may not be guaranteed by the data owner (or the data owner may satisfy the requests only partially) if the processing of personal information, that is the object of the request of elimination, is expected in fulfillment of legal obligations or for the verification, the exercise or defence of a right in court;
- the right to obtain from the data owner the limitation of the processing pursuant to art. 18 GDPR;
- the right to obtain from the Data Owner the portability of personal data processed following consent or on a contractual basis pursuant to art. 6, paragraph 1, letters a) and b) of GDPR; if you exercise this right, the data owner will be responsible for providing you with all information concerning you, acquired with your consent or in execution of a contractual obligation, in a structured and interoperable format; where technically possible, such personal data may also be transferred, in the same manner, to third parties selected by you and indicated with a specific request;
- the right to object to the processing of your personal pursuant to art. 21 GDPR, unless the data owner proves, upon receipt of a request in this regard, the existence of legitimate compelling reasons for processing that prevail over the interests, rights and freedoms of the customer, or for the establishment, exercise or defence of a right in court.
The above requests should be addressed to the contact details in section A).
The data owner will verify the requests without undue delay.
With specific reference to the right to revoke consent, this may also be exercised by selecting the appropriate functions made available at the bottom of each communication of a commercial nature (or related to participation in market research or statistical surveys).
you do not receive or receive a negative, untimely or unsatisfactory response to your request, or if you believe in any case that the data controller processes your data in an illegitimate or non-transparent manner, you may contact a supervisory authority.
If you are an Italian citizen, habitually resident or working in Italy, or if you believe that the alleged violation by the Data Controller with reference to the processing of your personal data has been carried out in Italy, you may contact the Data Protection Authority – www.garanteprivacy.it – to obtain adequate protection of your rights.
If you are a citizen of another EU member state, habitually resides or works in another EU member state, or if you believe that the alleged breach by the Data Controller with regard to the processing of your personal data has been carried out in another EU member state, you may consult the European Data Protection Supervisor’s website (https://secure.edps.europa.eu/), for more information about the competent supervisory authority.
J) CHANGES AND UPDATES TO THE INFORMATION
We invite you, in any case, to periodically check the section of the Site where this Information is hosted, and to consult the most recent text of the Information (the entry into force is in the epigraph).