INFORMATION ON THE PROTECTION OF PERSONAL DATA – TERMS AND CONDITIONS
INFORMATION ON THE PROTECTION OF PERSONAL DATA
The protection of your personal data is important for Smarty Comm Srls – to which SmartyStore belongs – which has adopted strong principles valid for all the services offered, principles recalled in its Information on Data Protection available on all the sites of our Company.
This Information on Data Protection provides you with detailed information regarding the protection of your personal data by Smarty Comm Srls, VAT number and Tax Code IT02304850569, with registered office in Strada Teverina, 5H, 01100, Viterbo, (VT), as the data controller (“We”).
We are responsible, as owners, for the collection and processing of your personal data in relation to our activities. The purpose of this Data Protection Notice by Smarty Comm Srls is to allow you to know what personal data we collect about you as our customer or visitor to one of our websites (whether you are our customer or employee of a company that is our client) or as a representative of a company that is our client, the reasons why we use and share such data, how long we keep them, what are your rights and how you can exercise them.
Further information may be provided, where necessary, at the time of requesting a specific product or service.
- WHAT OF YOUR PERSONAL DATA DO WE PROCESS?
We collect and use your personal data to the extent necessary in the context of our activities and to achieve high quality standards of personalized products and services.
We may collect various categories of personal data concerning you, including:
identification data (for example, name, driving license, nationality, place and date of birth, gender, IP address)
contact details (for example, postal address and e-mail address, telephone number)
tax situation (for example, tax code, tax regime)
banking, financial and commercial transaction data (for example, your bank account details, data relating to payments made)
data relating to the purchase order of a product and / or service (for example, customer identification number, order number, buyer data, recipient data)
data concerning your person, your habits and your preferences:
data concerning your use of our products and services as well as data relating to concluded commercial transactions;
data deriving from your interactions with us: our offices (contact relationships), our websites, our applications, our social media pages, meetings, calls, chats, emails, interviews, telephone conversations
video surveillance (including CCTV) and geolocation data (for example, location data to show you the location of service providers or for the provision of specific services such as printing services, delivery services, installation services).
We never ask for personal data relating to your racial or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, genetic data or data relating to your sexual orientation, unless required by law.
Your data that we use can be provided directly by you or obtained from the following sources, in order to verify or enrich our databases:
publications / databases made available by official authorities (for example, the Official Journal)
our corporate clients and / or their subsidiaries and related entities (e.g. your employer) or their service providers
third parties such as advertising and marketing agencies, consulting companies, installation companies of our products and other intermediary companies that purchase products and / or services from our Company with direct delivery to your address
websites / social media pages containing information made public by you (for example, your website or social media page)
databases made publicly accessible to third parties
- SPECIFIC CASES OF COLLECTION OF PERSONAL DATA, INCLUDING INDIRECT COLLECTION
In certain circumstances, we may collect and use personal data of individuals with whom we have, may have or have had a direct relationship such as:
For some reasons, we may also collect information about you even though you do not have a direct relationship with us.
This can happen for example when your employer provides us with information about you or your contact details are provided to us by one of our clients if you are, for example:
Recipient of one of our products / services
Legal representative (attorney)
Effective owner of the good / service provided
Representative of a legal person (which can be a customer or a seller)
Personnel of service providers and business partners
- WHY AND ON WHAT BASES DO WE USE YOUR PERSONAL DATA?
- A) To fulfill legal and regulatory obligations
We use your personal data to comply with a number of legal and regulatory obligations, including the following:
banking and financial regulations in compliance with which We:
we put in place security measures in order to prevent fraud and abuse
we detect transactions that deviate from normal patterns
We monitor and report the risks to which We may expose ourselves
we record, where necessary, telephone calls, chats, emails, etc.
respond to an official request from a duly authorized public or judicial authority (for example, for the purpose of a tax audit)
prevention of money laundering and terrorist financing
compliance with the legislation on sanctions and embargoes
fight against tax fraud and fulfillment of tax verification and notification obligations
- B) To execute a contract of which you are a party or to take pre-contractual measures at your request before concluding a contract with you
Applicable in your capacity as our individual client
We use your personal data to conclude and execute our contracts, including for:
evaluate if we can offer you a product or service and under what conditions
provide you with information regarding our products and services
plan and manage the delivery, return, maintenance and repair of purchased products, manage the resolution of disputes (for example, for debt recovery) and assist you as well as respond to your requests and complaints
ensure and facilitate your needs, allowing you to easily access certain services directly on your smartphone through our mobile applications
manage billing, reporting and recovery activities
- C) To pursue our legitimate interest
We use your personal data in order to implement and develop our products and services, to manage our contractual relationships with our client companies that you may be dependent on, including the following:
proof of transactions
launch of promotional campaigns, for example to raise awareness of new products / services placed on the market by our Company
IT systems management, including infrastructure management (for example, shared platforms), business continuity and IT security
creation of statistics, tests and aggregate models, for research and development, in order to improve our products and services or to create new ones
training of our staff by recording telephone calls to our switchboard
personalization of our offers, through the improvement of the quality of our products and services (also through surveys on the degree of customer satisfaction);
advertising of products and services that correspond to your situation and profile
The above can be achieved:
segmenting our prospects and customers
analyzing your habits and preferences in the different channels (visits to our websites, emails or messages, phone calls, etc …)
by matching the products or services you already own or use with other data we hold about you
Applicable to employees of our client companies
evaluate if we can offer you a product or service and under what conditions
provide you with information regarding our products and services
plan and manage the delivery, return, maintenance and repair of the product sold, value-added services (for example, loyalty cards, discount codes, etc.)
manage dispute resolution (for example, for debt collection) and assist you and respond to your inquiries and complaints
provide a digital platform that allows you to easily access the consultation of the products / services offered by our Company, as well as the consultation of your personal data for any corrections
provide information on the status of your order and consult past orders already defined
Your data may be aggregated into anonymized statistics which could be offered to professional clients to assist them in the development of their businesses. In this case, your data will never be disclosed and the subjects who will receive such anonymized statistics will not be able to trace your identity.
- D) To respect your choice if we have requested your consent for a specific treatment
In some cases, we need to ask for your consent to process your data, for example:
where the aforementioned purposes lead to automated decisions, which produce legal effects or which significantly affect you. At that point, we will inform you separately on the logic used, as well as on the meaning and expected consequences of such processing
if we need to carry out further processing for purposes other than those indicated above in Article 3, we will inform you and, where necessary, we will acquire your consent
- WHO DO WE SHARE YOUR PERSONAL DATA WITH?
In pursuit of the aforementioned purposes, we disclose your personal data only to:
service providers who may process data on our behalf
independent agents, intermediaries, banking and commercial partners with whom we have relationships; financial or judicial authorities, state agencies or public bodies, upon request and within the limits permitted by law
regulated professionals such as accountants, lawyers, notaries and auditors
Transport companies such as post offices, express couriers, national and international couriers
- TRANSFER OF PERSONAL DATA OUTSIDE THE EEA
In the case of international transfers originating from the European Economic Area (EEA), where the European Commission has recognized that a country not belonging to the EEA is able to guarantee an adequate level of data protection, your personal data may be transferred on that basis.
For transfers to non-EEA countries whose level of protection has not been recognized by the European Commission, We will rely on an exemption applicable to the specific situation (for example, if the transfer is necessary to perform our contract with you such as when you make an international payment) or we will implement one of the following measures to ensure the protection of your personal data:
standard contractual clauses approved by the European Commission
binding corporate rules, where applicable
To obtain a copy of these measures or details on where they are available, you can send a written request as indicated in Article 9.
- HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will retain your personal data for as long as necessary to comply with applicable laws and regulations or for a different period having regard to our operational requirements, such as proper account maintenance, facilitating customer relationship management and responding to legal disputes or regulatory requests. For example, most of the customer’s information is kept for the duration of the contractual relationship and after the end of the contractual relationship for the period of time necessary to ensure the exercise or defense of rights.
Cookies and other connection and tracking data stored on your device are kept for a maximum period of 24 months from the date of their collection.
- WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?
In accordance with the applicable regulations, you are the owner of the following rights:
Access: you can obtain information in relation to the processing of your personal data, and a copy of such personal data
Rectification: where you believe that your data is inaccurate or incomplete, you can request that such data be modified accordingly
Cancellation: you can request the cancellation of your personal data, within the limits permitted by law
Limitation: you can obtain the limitation of the processing of your personal data
Opposition: you can oppose the processing of your personal data, for reasons related to your particular situation. You have the absolute right to object to the processing of your personal data for direct marketing purposes, including profiling connected with such direct marketing.
Withdrawal of consent: where you have given your consent for the processing of your personal data, you have the right to withdraw it at any time
Data portability: in the cases provided for by law, you have the right to obtain the return of the data you have provided us, and where technically feasible, to obtain its transfer to a third party
If you wish to exercise the rights listed above, you can send an e-mail to email@example.com. Please attach a scan / copy of your ID for identification purposes.
In accordance with current legislation, in addition to the aforementioned rights, you also have the right to lodge a complaint with the competent supervisory authority.
- HOW CAN YOU KEEP UP TO DATE ON CHANGES TO THIS DATA PROTECTION POLICY?
In a world of constant technological change, we may need to periodically update this Notice.
We invite you to check the latest version of the information online and we will inform you of any substantial changes through our website or through our usual communication channels.
- HOW CAN YOU CONTACT US?
If you have any questions in relation to our use of your personal data pursuant to this Notice, please send a letter to the following address Smarty Comm Srls, Strada Teverina 5H, 01100, Viterbo (VT) or contact us by writing an e-mail at firstname.lastname@example.org, which will process your request.
We also inform you that the data protection officer (DPO) can be reached at email@example.com.
If you want to know more about cookies and security, please contact us by writing an e-mail to firstname.lastname@example.org
The information is provided only for the sites mentioned above and not for other websites that may be consulted by the user through appropriate links.
Smarty Comm Srls guarantees compliance with the legislation on the protection of personal data.
Type of data processed and purpose of the processing
1) Navigation data
The computer systems and software procedures used to operate this site acquire, in normal operation, some personal data which are then implicitly transmitted
in the use of Internet communication protocols.
This is information that is not collected to be associated with identified data subjects, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s IT environment.
These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning and are deleted immediately after
processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the site: except for this possibility, the data on web contacts are not
persist for more than seven days.
2) Data provided voluntarily by users / visitors
If users / visitors, connecting to this site, send their personal data to access certain services, or to make requests via e-mail, this involves the acquisition by Smarty Comm Srls of the sender’s address and / or of others any personal data that will be processed exclusively to respond to the request, or for the provision of the service. The personal data provided by users / visitors will be disclosed to third parties only if the communication is necessary to comply with the requests of the users / visitors themselves.
To allow the use of our site and the provision of our services, we make use of both so-called persistent cookies (i.e. cookies that remain in memory until they are manually deleted by the user or for which a scheduled removal is planned for a long time. term) and so-called session cookies, which are not permanently stored on the visitor’s computer and disappear when the browser is closed. Through cookies we cannot access other information stored on your device, even if this is where the cookies are downloaded. Cookies cannot load codes of any kind, carry viruses or malware and are not harmful to the user’s terminal.
4) Processing methods
Personal data are processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected.
Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access.
5) Optional supply of data
Apart from what has been specified for navigation data, users / visitors are free to provide their personal data. Failure to provide them may only make it impossible to obtain what is requested.
6) Place of data processing
The treatments connected to the web services of the aforementioned sites take place at the company headquarters and / or at the headquarters of the hosting and / or management company of the website and are only handled by technical staff of the Office in charge of processing, or by any persons in charge of occasional maintenance operations.
No data deriving from the web service is communicated or disseminated. The personal data provided by users who submit requests to send information material are used only to perform the service or provision requested and are disclosed to third parties only if this is necessary for this purpose.
7) Rights of interested parties
The subjects to whom the personal data refer have the right at any time to obtain confirmation of the existence or otherwise of the same data and to know its content and origin, verify its accuracy or request its integration or updating, or rectification.
Pursuant to the same article, one has the right to request cancellation, transformation into anonymous form or blocking of data processed in violation of the law, as well as to oppose in any case,
for legitimate reasons, to their treatment.
8) Data Controller
The data controller for the website www.smartystore.it is Smarty Comm Srls with registered office in Strada Teverina, 5H 01100 Viterbo