The purpose of this document is to inform Users with regard to Personal Data collected from the website www.prosacalwaysmile.com (hereinafter, the Application).
1. Personal Data collected by the Application
The Data Controller shall collect the following categories of Personal Data:
A. Voluntary contents and information provided by the User
- Contact, payment and shipping details for correct order fulfillment
- Name and e-mail address for subscription to the newsletter
- Name, e-mail address and sizes for requests and orders of customized items
If the User does not communicate Personal Data, for which there is a legal or contractual obligation, will be impossibile to the Data Controller to provide, in whole or in part, its services. It will be impossible also in case that Personal Data is necessary requirement for the use of the service or for the contract conclusion.
The User who communicates to the Data Controller third parties Personal Data, is directly and exclusively liable for their origin, collection, processing, communication or disclosure.
B. Data and contents automatically acquired while using the Application
Technical Data: the computer system and the software procedures functional to this Application may acquire, in the course of their ordinary activity, any Personal Data whose communication is implicit in the use of internet communication protocols. Such information is not collected to be associated with identified Users, however, those Data, due to its nature, may identify Users in the Processing and through the association with Data held by third parties. This category includes IP addresses or domain names used by Users who connect to the Application, addresses of Uniform Resource Identifier (URI) of the requested resources, time of the request, method used submitting the request to the server, size of the file obtained, etc.
Usage Data: Data may be collected relating to the use of the Application by the User, such as the pages visited, the actions performed, the features and services used by the User.
Geolocation Data: the Application may collect location Data, which may be accurate or inaccurate. The precise location Data may consist in GNSS Data (Global Navigation Satellite System, such as GPS), as well as in Data which identify the nearest repeater, Wi-Fi hotspots and bluetooth, communicated when you enable products or features based on the location.
C. Personal Data collected through cookies or similar technologies
2. Purposes of the processing
Collected Personal Data may be used for the performance of contractual and pre-contractual obligations, legal obligations, for the pursuit of Data Controller legitimate interest and for the following purposes:
- Registration and authentication of the User
- Support and contact with the user, logistics management for shipments and home delivery services for the User communicating Data to Brt S.p.A., https://www.brt.it/it/privacy.do - DHL, https://ecommerce.dhl.it/privacy-policy/
- Personalizationof User experience
- Handling of external payment tools through credit card, bank transfer or other tools (using Paypal, Stripe, Braintree, etc.) communicating Data to PayPal Holdings Inc., https://www.paypal.com/it/webapps/mpp/ua/privacy-full - Stripe, Inc., https://stripe.com/it/privacy - Amazon Payments S.C.A, https://pay.amazon.com/it/help/201751600
- Storage, hosting and management of backend infrastructure communicating Data to SiteGround, https://it.siteground.com/privacy? scid=3〈=it_IT - Amazon.com Inc. (Amazon Web Services /Amazon CloudFront CDN), https://www.amazon.it/gp/help/customer/display.html?nodeId=201909010
- Handling of Users database
- Statistic using only anonymous data (i.e. Google Analytics with anonymized IP) communicating Data to Google Inc., https://privacy.google.com/intl/it/index.html# - Hotjar Ltd, https://www.hotjar.com/legal/policies/privacy
- Monitoring, analysis and tracking of User behavior communicating Data to Google Inc., https://privacy.google.com/intl/it/index.html# - Hotjar Ltd, https://www.hotjar.com/legal/policies/privacy - Facebook Inc., https://it-it.facebook.com/policy.php
- Technical monitoring of the infrastructure for maintenance, fixing and performance improvement communicating Data to Google Inc., https://privacy.google.com/intl/it/index.html# - Hotjar Ltd, https://www.hotjar.com/legal/policies/privacy - SiteGround, https://it.siteground.com/privacy?scid=3〈=it_IT
- Sending of e-mails or newsletter and handling of mailing list communicating Data to MailChimp, https://mailchimp.com/legal/privacy/
3. Personal Data processing methods
The Processing of Personal Data is performed with paper, IT and/or digital tools, with methods of organizations and with logics strictly related to the indicated purposes.
In certain cases, subjects other than the Data Controller who are involved in the organization of the Data Controller (such as personnel management, sales personnel, system administrators employees, etc.) or who are not (as IT companies, service providers, postal couriers, hosting providers, etc.) may access to Personal Data. These subjects, will be appointed, where necessary, as Data Processors by the Data Controller and will have access to Users Personal Data whenever required, and shall be contractually obliged to keep it confidential.
The updated list of Data Processors may be requested via email at the email address firstname.lastname@example.org.
4. Legal basis for the processing
The Data Controller processes Personal Data regarding the User whether one of the following applies:
- The User has given consent for one or more specific purposes;
- Processing is necessary for the performance of a contract with the User and/or for the performance of pre-contractual measures;
- Processing is necessary to comply with a legal obligation to which the Data Controller is subject;
- Processing is necessary for the performance of a task carried out in the public interest or for the exercise of public authority vested in the Data Controller;
- Processing is necessary for the purposes of the legitimate interest pursued by the Data Controller or by a third party.
It is always possible to ask the Data Controller to clarify the concrete legal basis of each processing.
Personal Data are processed in the operative offices of the Data Controller and in any other place in which the parties involved in the Data processing are located. For further information, you may contact the Data Controller at the following email address email@example.com.
Personal Data may be transferred to Countries outside the EU: USA.
With respect to these Countries, an adequacy decision by the European Commission exists or, in the absence of such decision, it is possible to request further information to the Data Controller regarding any adopted appropriate safeguards as well as the means to obtain a copy of Data or the exact location where they have been stored.
6. Security of processing
The Data Processing is performed through adequate methods and tools to ensure the Personal Data security and confidentiality, as the Data Controller has implemented appropriate technical and organizational measures which guarantee, in a provable way, that the Processing complies with the applicable law.
7. Period of storage of Data
The Data Controller will store Personal Data for the necessary time to perform the purposes connected with the performance of the agreement in force between the Data Controller and the User and Data shall not be stored beyond the duration of years 10 after the end of the relationship with the User. In any case Data could be stored within the limitation term prescribed by the current regulations.
When the Processing of Personal Data is necessary for the purposes of the legitimate interests pursued by the Data Controller, Personal Data shall be stored until the performance of the relevant interest.
When the Processing of Personal Data is based on the User consent, the Data Controller may store Personal Data until the withdrawal of the User.
Personal Data may be stored for a longer period of time in order to perform a legal obligation or public Authority order.
All Personal Data shall be deleted at the end of the period of storage. At the expiration of such period, the rights of Data access, rectification, erasure and portability must not be exercised.
8. Automated individual decision-making
All collected Data shall not be subject to automated individual decision-making, including profiling, which may produce legal effects concerning the User or may significantly affect the User.
9. Rights of the User
The Users may exercise specIfic rights with respect to Personal Data processed by the Data Controller. In particular, the User has the right to:
- withdraw its consent at any time;
- object the Processing of its Data;
- access its Data;
- monitor and request the rectification of Data;
- obtain a restriction of Processing;
- obtain the erasure or remotion of its Personal Data;
- receive its Data or obtain the transfer to a different Data Controller;
- lodge a complaint before the supervisory authority for the protection of personal data or start legal proceedings.
In order to exercise their rights, the Users may send a request to the contact information of the Data Controller indicated in this document. These requests are free of charge and performed by the Data Controller in the shortest possible time, in any case no later than 30 days.
10. Data Controller
The Data Controller is Prosac Alwaysmile Srl, with registered office in Via XX Settembre, 50 - 06034 - Foligno (PG), Tax Code/VAT Code 03485850543, PG - 292547
e-mail firstname.lastname@example.org, phone 0742/352680.