The Data Controller(s), i.e. the subject(s) establishing the purposes and means of data processing during your browsing or your purchasing experience on eral55.com, are Eral55 s.a.s. Piazza XXV Aprile 14, Cap 20124, Milan, Italy (hereinafter together referred as “we”, “us”, “our”).
Eral55 having subscribed specific agreements, will act as joint controller within the limit of the abovementioned agreements.
PERSONAL DATA PROCESSED
Which personal data are processed?
We process the following categories of personal data:
Data that you provide when you conclude an order and purchase goods (e.g. Name, Surname, email address, shipping and billing address);
Data that you provide when you accept to receive marketing communications from Us (e.g. Name, Surname, email address, country of residence, preferences);
Personal data under the above section shall be processed for the following purposes:
to conclude and execute the purchase agreement for the products offered on eral55.com. When you complete your purchase, we ask you for the personal data necessary for the execution of the agreement, such as payment, anti-fraud checks if you choose to pay by credit or debit card, billing, shipping of the product and possible management of the return;
to provide you with the services offered on eral55.com. For this purpose, in relation to each service and its characteristics, we need to collect the personal data necessary for the performance of the service requested by you;
management of requests to our Customer Service, which uses the personal data you provide to deal with your requests for assistance;
Sending commercial and promotional communications following (i) the purchase of one of our products or (ii) the intention to purchase one of our products (abandoned cart), so-called soft spam. We will send you communications containing our business proposals and related products and services to the e-mail address that you provided;
Subject to your express consent, we may use the contact details you have provided for commercial communications on our products and services, in order to update you on news, new arrivals, exclusive products, our offers and promotions. In addition, always with your consent, we will be able to use your contacts as part of market research and surveys for the detection of satisfaction in order to improve our services and the relationship with our users. Based on your consent we can send you marketing communications based on your browsing and purchasing experience.
Which are the legal bases of the processing?
We process your personal data only in the presence of one of the conditions provided for by the law in force, and specifically:
a) for the conclusion and execution of a contract of which you are part.
When we process your data for the conclusion of the purchase agreement of which you are a part, we ensure that we only use the minimum information necessary for the execution of this. This basis legitimises the processing of personal data that takes place in the following activities:
- conclusion and execution of a purchase agreement for the products offered on eral55.com;
- registration on the website and use of services reserved for registered users;
- provision of services offered on eral55.com;
- management of your requests by our Customer Care.
The contribution of your personal data for these activities is a contractual obligation. You are free to communicate your data or not, but in the absence of the requested data, we will not be able to execute the agreements and your requests. This means that you will not be able to purchase the products and you will not be able to use Our services, and We will not be able to handle your requests;
b) to comply with a legal obligation.
In the event of the conclusion of an agreement for the purchase of goods on eral55.com, the processing of the user's data will take place in order to fulfil the legal obligations to which We comply with in accordance with the tax provisions and other regulations to which We are subject. You are free to decide whether to conclude an agreement and whether or not to disclose your data, but if you conclude it, your data will be necessary and will be processed to effect the aforementioned legal obligations to which We are required.
c) for our legitimate interest.
If you purchase products on our website by credit or debit card, some of your personal data may be processed to carry out anti-fraud activities: we have a legitimate interest in carrying out this activity to prevent and pursue any fraudulent activity.
d) based on your consent.
We will carry out carry out marketing activities and opinion polls and market research only if you have given us your express consent.
Providing your personal data for these activities is absolutely optional. You are free to provide us with your data for these purposes, but without it, it will not be possible for Us to carry out marketing activities, opinion polls and market research, and to analyse your habits.
With whom will your personal data be shared?
Personal data provided shall be disclosed to:
Our employees trained and authorised for the processing;
Third-party companies that help us in performing our operations on eral55.com (such us Banking operators, Internet Providers, companies specialised in IT, Couriers, Companies specialized in Marketing activities) that act on Our behalf. In these cases, there are specific agreements with such third parties to guarantee that the processing of your personal data is properly carried out.
Where do we transfer personal data?
Some of the third parties mentioned in the previous paragraph may be located in countries outside the European Union that nevertheless offer an adequate level of data protection, as established by specific decisions of the European Commission (http://www.garanteprivacy.it/home/provvedimenti-normativa/normativa/normativa-comunitaria-eintenazionale/trasferimento-dei-dati-verso-paesi-terzi#1).
The transfer of your personal data to countries that do not belong to the European Union and that do not ensure adequate levels of protection will be performed only after conclusion between Us and said subjects of specific agreements, containing safeguard clauses and appropriate safeguards for the protection of your personal data which are so-called "standard model clauses", also approved by the European Commission, or if the transfer is necessary for the conclusion and execution of an agreement between you and Us (for the purchase of goods offered on our site, for registration on the website or the use of services on the website) or for the management of your requests.
For how long do we process personal data?
Your personal data is stored in compliance with the following terms and criteria:
a) data collected to conclude and execute agreements for the purchase of goods on eral55.com: until the administrative and accounting formalities have been completed. The billing data will be kept for ten years from the billing date;
b) data of the registered user: the data will be stored until you request cancellation of your profile;
c) data relating to the payment: up to the certification of the payment and the conclusion of the related administrative and accounting formalities resulting from the expiration of the right of withdrawal and the terms applied for the contestation of the payment;
e) data related to user requests to our Customer Care: the data used to assist you will be kept until your the request is met;
g) data used for commercial communication activities towards users who purchase products on eral55.com (soft spam): this data will be stored until the service is terminated or the user withdraws his or her registration;
h) data provided for commercial communications activities, opinion polls and market research: up to the request by the user to interrupt the activity and in any case within two years from the last interaction of any kind of user with Us.
In any case, for technical reasons, the termination of the processing and the subsequent cancellation or irreversible anonymisation of the related personal data will be final within thirty days of the terms indicated above.
Your privacy rights
In accordance with the rules and regulations applicable to data protection, you have the right to: a) Access your data and modify it: you have the right to access your personal data and to request that it be correct, modified or integrated with other information. If you wish, we will provide you with a copy of your data in our possession.
b) Revoke your consent: you can revoke a consent you have given for the processing of your personal data in relation to any activity for marketing purposes at any time. In this regard, we remind you that marketing activities are considered the sending of commercial and promotional communications, the conduct of market research and surveys for the detection of satisfaction for the customisation of the website and commercial offers according to your interests. Once we receive your request, it will be our duty to promptly cease to process your personal data based on this consent, while different processing or that which is based on other assumptions will continue to be carried out in full compliance with the provisions in force.
c) Opposition to the processing of your data: you have the right to object at any time to the processing of your personal data made on the basis of our legitimate interest, explaining the reasons that justify your request, before accepting it, we will have to evaluate the reasons for your request.
d) Delete your data: you may request the cancellation of your personal data in the cases provided for by current legislation. Once your request has been received and examined, and if it is legitimate, it will be our duty to timely cease to process your personal data and to delete it.
e) Request of restriction of the processing: in this case, we will continue to keep your personal data but we will not process it, unless it is subject to your different request and the exceptions established by law. Processing of your personal data can be limited when you dispute the accuracy of your personal data, when the processing is illegal, but you oppose the cancellation of your data, when we no longer need your personal data but you need to exercise your right in court and when you oppose your processing, in the period in which we evaluate the reasons for your request.
f) Request of data transfer to other party than Us ("right to data portability"). You can ask to receive your data that we process based on your consent or on the basis of an agreement with you in a standard format. If you wish, where technically possible and at your request, we may transfer your data directly to a third party that you indicate. You may exercise your rights by writing to firstname.lastname@example.org
If you believe that the processing of your personal data has been carried out illegally, you can file a complaint with one of the supervisory authorities responsible for compliance with the rules on personal data protection. In Italy, the complaint can be presented to the Italian Data Protection Authority. More information on the presentation methods are available on the website of the Italian Data Protection Authority, at http://www.garanteprivacy.it
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