This information note, (in short, “Information”), on the processing of personal data, according to article 13 of the Regulation (“GDPR”) and d.lgs. 196/03, is given by Inspirering srl, with headquarters in via G Battista 22, 20124 Milan, in its role as “Head” of processing. The data which are gathered are processed in conformity with the principles of correctness, legitimacy, transparency, while safeguarding your privacy and your rights as (“User”) of the website www.avellenttan.com and of our accounts/internet platforms, as Facebook and Instagram (“Platforms”).
(a) Objectives of processed
On the basis of art. 6, commas b,c,f, of GDPR, we inform you that the data that will be given to us will be processed with the following objectives:
i. Management of registration on the website, establishment, management and extinction of the contractual and commercial relationship: carrying out the pre-contract negotiations, execution of the stipulated transaction and carrying out legal obligations, among which accounting and tax obligations,
and, with your consent (ex arts. 6 and 7, GDPR), for the following objectives:
ii. statistical research, market analysis, creation of individual profiles (profiling) and marketing, that is, to send also by e-mail, sms and mms information and material of a promotional nature for products and special promotions and initiatives and discounts.
iii. Facilitate payments by means of memorization of the data of the credit cards with the only scope of avoiding the User to have to type them again;
iv. To keep the historical data of the User’s purchases and specifically the list of orders made for the period in which the User’s account is active and for the following three years after it is disactivated;
v. to prepare targeted advertising (for example, to see advertising adapted to your profile for third party websites, advertisements that could interest him/her or a new sale when he/she reads an email containing a particular offer).
This type of targeting is made possible by the technologies of our advertising partners, who link the navigation data of the User in question on these websites, social network platforms and third party websites, independently from the device used.
• Social network platforms (for example, Facebook or Instagram): you can disactivate this process at any time by configuring the advertising settings of your account;
• Third party websites: refer to our information note on cookies to find out how to take away your consent.
Giving your data for the reasons covered in the previous section (i) is compulsory. The lack of data and/or the eventual expressed refusal of processing will mean the Head will not be able to carry out the negotiation or could mean the possible violation of requests from competent Authorities.
Giving your data for the reasons listed in the previous section (ii, iii, iv, v) is optional, with the consequence that you can decide not to give your consent, or you can revoke it at any time, but if the User does not give his/her consent it will mean he/she cannot sign up for the newsletter, participate in contests and other initiatives, get feedback to requests and communications, obtain conservation of credit card data to facilitate payments.
The User will always be able to contest receiving promotional communications by e-mail: in every communication we will specify the means (easy and free) to oppose the processing and not to receive any other communication.
(b) Personal Data processed
As to the aims of the processing covered in the previous paragraph (a), only personal data such as, for example, name and surname, place and date of birth, partita IVA number and Fiscal Code, residence, domicile, details of the identification document, e-mail address or PEC, and phone number will be processed.
(c) Recipients of the personal data
For the reasons as in the previous paragraph (a), section (i) personal data you give can be made accessible to :
1. dependents and collaborators of the Head, in their quality as agents authorized to process data (o c.d. “in charge of processing”)
2. third party subjects who deal in outsourcing activities for the Head, in their quality as heads of processing
3. Judiciary or Security Authorities (national and foreign).
Where the User expresses his/her consent to the use of personal data for the purposes as in the previous paragraph (a), section (ii,iii,iv,v), these will be accessible to the subjects indicated in the previous points (1), (2), and (3), as well as, when it is the case and always with previous consent, to the other juridical entities listed during the phase of collection of consent.
(d) Conservation and transfer of personal data abroad
The management and conservation of personal data takes place in the cloud and on servers located inside the European Union owned by and/or available to the Head, and/or of appointed third party companies, duly named as responsible for processing. No transfer of ownership and/or availability for the Head and/or for appointed third parties, named as responsible for processing. No transfer of data to extra-EU countries is carried out and your personal data will not be distributed.
(e) Period of conservation of personal data
Personal data gathered for the purposes indicated in the previous paragraph (a) section (i) will be processed and kept for the whole necessary duration of the execution of the established juridical relationship.
Starting from the date of the end of said relationship, for whatever reason or cause, the data will be kept for the duration of the ex lege applicable prescribed periods.
Personal data gathered for the purposes indicated in the previous paragraph (a), sections (ii, iii, iv, v) will be processed and kept for the time necessary to carry out them out, in the respect of the terms set down by law for that type of activity and in any case until the annulment of consent or until the right to opposition is exercised.
(f) Rights that can be exercised
In compliance with what is provided for in Point III, Section I, GDPR, you can exercise the rights therein indicated and in particular:
• Right of access – To obtain confirmation that there is/isn’t an existing processing of personal data that concerns you, and in that case, receive information regarding, among others: reasons for the processing, categories of personal data being processed and period of conservation, and to whom these data can be communicated (article 15, GDPR),
• Right to correct – to obtain, without unjustified delay, the correction of incorrect personal data that regards you and the integration of incomplete personal data (article 16, GDPR),
• Right to cancellation – to obtain, without unjustified delay, the cancellation of personal data that regards you, in the cases provided for by the GDPR (article 17, GDPR),
• Right to limitation - to obtain the limitation of the processing, in cases provided for by the GDPR (article 18, GDPR)
• Right to portability – to receive in a structured, commonly used format, that can be read from an automatic device, the personal data that regards you that was given to the Head, and to obtain that these be transmitted to another Head without any problems, in the cases provided for by the GDPR (article 20, GDPR)
• Right to opposition – to oppose the processing of personal data that regards you, unless there are legitimate reasons for the Head to continue to deal with them (article 21, GDPR)
• Right to present a complaint to the controlling authority – to present a complaint to the Guarantor Authority for the protection of personal data, Piazza di Montecitorio n. 121, 00186, Rome (RM).
You can exercise these rights by simply sending a request by e-mail to the e-mail address of the Head of processing, indicated above.
(g) Mode of processing
Processing of your personal data is carried out by means of the operations indicated in article 4, n. 2, GDPR – carried out with or without the help of information systems – and precisely: gathering, registration, organization, structuring, updating, conservation, adapting or modifying, extraction and analysis, consultation, use, communication by transmission, comparison, interconnection, limitation, cancellation or destruction of data.
In any case, the logical and physical security of the data will be guaranteed, and in general, also the confidentiality of the personal data processed, by putting into play all the necessary technical and organizational measures adequate to guarantee their security.
(h) Cookies Policy
Cookies are text files that contain small quantities of information that are downloaded on your computer or mobile device when you visit a website or a mobile application. They are used to recognize your computer when you navigate the pages of a website or when you return to visit a website or a mobile application you have visited previously. Cookies are used a lot to allow platforms to function, or to make them function more efficiently, apart from giving information to the owners of the platform.
There are two large categories of cookies:
• Owners’ cookies, sent directly by the Controller to your computer or mobile device. The Owner only uses them to recognize your computer or mobile device when you access our website again.
• Third party cookies, that are sent to the Owner by a third party service provider to recognize your computer or mobile device when they access other platforms. Third party cookies are usually used for platform analytics or for advertising.
Cookies can remain on your computer or mobile device for variable lengths of time. The Owner uses both “session cookies” and “permanent cookies”. Session cookies appear exclusively when the browser is open and they cancel out automatically when you close the browser. Permanent cookies survive also after the browser is closed down, and can be used to recognize your computer or mobile device when you open your browser again and navigate on the internet.
In particular, the Owner only sends the following type of cookies to your computer or mobile device:
• Cookie that are necessary for essential purposes. These cookies are essential to give you the services available on the website and to use some of its functions, as for example access to secure areas. Without these cookies, it would not be possible to give you the services you have asked for, for example the pages on transactions and the secure login accounts.
• Function cookies: these cookies are necessary for various ends connected to the presentation, activity and function of our Platforms. However, their overall aim is to give visitors a better experience and usage of the Platforms. For example, some of these cookies allow visitors to specify their preferences as to language, products or other preferences.
• Performance cookies: these cookies are used to gather information on how visitors use the Platforms. The information gathered does not identify any single visitor and is aggregated. It includes the number of visitors to our Platforms, the platforms through which they arrived and the pages they visited on our Platforms. We use this information to improve our Platform function, to gather ample demographic information and to monitor the level of activity on our Platforms.
• Advertising cookies: when you visit our Platforms or click on advertisements or on promotional areas on our Platforms, these cookies are used to offer advertisements that correspond more to your interests. They are also used to limit the number of times an advertisement is shown, as well as to evaluate how effective the advertisement or promotion is. Usually, these cookies are placed by advertising networks with our permission. They remember you have visited a platform and this information is shared with other organizations, as for example the advertisers.
• Social cookies: these cookies make it possible for users to share pages and contents through third party social platforms and other platforms. The companies that send these cookies can also use your information to send focused advertising to other platforms.
We use the non-essential cookies on the basis of your consent. You have the right to revoke your consent and refuse the use of the cookies at any time. However, if you choose not to consent to cookies it is possible you wouldn’t be able to use all the functions of our Platforms. You can choose your preferences for cookies by changing your browser’s settings, so that the cookies from our Platforms can’t be installed on your computer or mobile device. To do this, follow the instructions given by your browser (you can usually find them under “Guide”, “Instruments” or “Modify”). For further information on cookies, as well as on how to see which cookies have been installed on your computer or mobile device, and on how to manage and cancel them out, go to www.allaboutcookies.org and www.youronlinechoices.eu.
Besides, we gather information on your computer or mobile device (including the IP address if it’s available), on your operational system, on when you access and on the type of browser. We use this information to understand better how visitors use our Platforms and for internal reporting. We will make this information anonymous, and could share it with advertisers, sponsors or other partners.
We would like to point out that platforms use third parties, for example networks of advertisers and ad exchanges, to show advertising on third party platforms after you have left our Platforms. We use analytics from third party partners and from other service suppliers to evaluate and procure for us or for third parties information on the use of the Platforms and on visualization of advertising and of our contents. The networks of advertisers are third party partners who show advertisements, which can be based on your visits to the Platforms, on other apps and websites you have visited. Sending you advertising from third parties allows us to personalize the advertising for you on the basis of the products and services that could interest you.
As to receiving the advertising, you can choose. You can choose the right to opt-out of receiving specific types of behavioristic advertising by visiting the websites of third parties. We are not responsible for the effectiveness of, or conformity with, any choice of opt-out from third parties.
Finally, some of the services we provide are able to use the information on your position. For these services, which are generally available on mobile devices or applications, you are given the possibility to give your consent to the use of localization, which for example processes the information from GPS, sensors, beacons or Wi-Fi access points to allow you to benefit from a more personalized service. Should you choose not to use them further, your device has settings that allow you to disactivate these services.