ITALIDEA S.R.L., a sole shareholder company – with registered office in Via Giovio, 35 – 22100 – COMO – Italy, Fiscal Code and VAT number 03563650138, REA CO-321264, share capital of Euro 200.000,00 and fully paid-up 123.500,00 (the “Company”) – pursuant to Section 13 of the Legislative Decree 196/2003 (“Privacy Code”), hereby provides the following privacy policy, acting as the controller of the personal data of the users (the “Users“) who visit the website www.Italidea.com (the “Website“) and fill out the online form in order to receive marketing material and commercial communication from the Company.
1. Processing purposes: marketing (sending advertising material, direct sale, commercial communication and market research)
Subject to the User’s optional consent, which can be given by selecting the relevant check-box on the registration form on the Website, the User’s email can be processed by the Company for marketing purposes (e.g. sending advertising material, direct sale, market research and commercial communication). Should the User provide his/her consent, the Company may contact the User by email, in order to propose the purchase of products or services offered by the Company itself or by third parties, offers, promotions or commercial opportunities or propose the User to participated to questionnaires, studies or market researches. The User’s consent to the processing of his/her personal data for marketing purposes is optional and, failing to provide such consent, the possibility for the User to register on the Website and shop online through latter will not be jeopardized. Also in case where the User has given his/her consent, the User may opt-out at any time from receiving further promotional communications by contacting the Company as indicated in paragraph 5 below or by clicking on the relevant opt-out (object the processing) link which will appear in each of those promotional emails.
2. Processing methods
User’s personal data is processed with electronic and non-electronic means, duly taking into account the relevant processing purposes, and in any case ensuring the security and the confidentiality of the data.
3. Persons who may have access to the data
Company’s employees or collaborators entitled to manage the Website and send newsletter may have access to the User’s personal data. Suh individuals, who have been formally appointed by the Company as persons in charge of the processing, will process the Users’ personal data exclusively for the purposes indicated in this policy and in accordance with the provisions of the Privacy Code.
Furthermore, third parties appointed by the Company as external data processors, such as IT and logistic service providers for the operation of the Website, outsourcing and cloud computing service providers, professionals and advisors, marketing companies in charge of sending newsletter on behalf of the Company, may have access to the Users’ personal data. One of the data processor appointed by the Company is Mas Factory, with registered office in Via Copenhagen 26-28 – 20831 Seregno (MB), who manages and optimizes the database of the Company.
Some of the data processors appointed by the Company are established in countries outside the European Economic Area and, therefore, in compliance with the relevant privacy provisions, Users’ personal data may be transferred to countries which do not offer the same level of protection as the one provided for under the Italian and European privacy law. In order to protect the rights of the Users, the Company and such data processor have entered into the model clauses approved by the European Commission with decision 2010/87/EU. Users have the right to obtain copies of the model clauses as well as a list of the data processor appointed by the Company by contacting the Company as indicated in paragraph 5 below.
4. Data communication and dissemination
User’s personal data will not be communicated to autonomous and independent third party data controllers and will not be disseminated in any manner whatsoever.
5. User’s rights
Pursuant to Section 7 of the Italian Privacy Code, the Company hereby informs the Users that they have the right be informed (i) of the source of the personal data; (ii) of the purposes and methods of the processing; (iii) of the logic applied to the processing, if the latter is carried out with the help of electronic means; (iv) of the identification data concerning data controller and data processors; (v) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may have access to said data in their capacity as data processor(s) or person(s) in charge of the processing. Furthermore, Users have the right to obtain a) updating, rectification or, where they have an implied interest, integration of the data; b) deletion, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected. Users have the right to object, in whole or in part, a) on legitimate grounds, to the processing of their personal data, even though they are relevant to the purpose of the collection; b) to the processing of their personal data, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys. The above-mentioned rights can be exercised by contacting the Company by (i) registered mail to: “Italidea s.r.l. via Giovio,35 22100 – COMO (Italy)”, (ii) email at marketing@italidea.com or (iii) fax to the number +39 031 3553215