ASTRA PENCIL 03 Brown

PRIVACY POLICY

INFORMATIVE INFORMATION PRIVACY

Privacy is very important to us. We invite you, therefore, to carefully read the information to know how we treat and protect the data you rely on.

Gargiulo & maiello SpA, Europrogetto Srl and gcube Srl, as Data Controller, informs you in accordance with applicable national law and’art. 13 European Privacy Policy no. 679/2016 (“GDPR”) that your data will be processed as follows.

DATA PROCESSED BY THE COMMISSION

- The data provided during the Registration to the Site or at the Simple Purchase of our products, simply identifying such as: name, surname, identity document, tax code, address, e-mail and telephone number. This is the data you gave us.

- Data related to your preferences and interests, in particular: the use of services, purchases made, functionality used, connection times, traffic data, navigation data on sites and social profiles of the companies of the Group Gargiulo & Maiello Group or of commercial partners or third parties, the IP address, the device identification, devices and connectivity used. This data can also be collected by means of cookies and metadata.

FAIRNESS OF THE PROCESSING

The data provided by you allow us to carry out all the administrative activities related to your contract and to satisfy your requests, on the other hand help us to understand your interests and your preferences to offer you, in this way, better services and personalized to your needs.

In particular, your personal data are processed for the following purposes and legal bases:

a) with your consent for the purpose of service and in particular for:

- allow you to use your sales platform;

- register to the website, manage and maintain your profile;

- provide you with the goods purchased by invoicing them, sending them service communications and assistance;

- improve technical assistance, customer care, our services, content and products;

- carry out any aggregate statistical analysis on an anonymous basis.

The Data Controller will use your data to protect its legitimate interests in the following cases:

- handle complaints and disputes, recover claims, prevent fraud and illegal activities;

- exercise the rights and protection of the legitimate interests of the Data Controller or third parties, such as the right to a fair hearing;

- send commercial communications to the e-mail address provided by you. Each e-mail sent will allow you, by clicking on the appropriate link, to refuse further submissions.

 For the fulfilment of legal obligations your data will be used for:

- comply with the obligations laid down in laws, regulations, Community regulations, orders and requirements of the competent authorities.

b) If you have expressed your separate consent, for other non-service purposes, and specifically for:

- profiling purposes, that is to analyse your preferences and interests (such as your favourite content, your points of sale, your purchases, etc.), and to offer you services, content, personalized initiatives and commercial offers for you (with e-mail, SMS, telephone calls with operator, notifications and newsletters).

TREATMENT OF DATA DATA

Your personal data is used for collection, registration, organization, storage, consultation, analysis, matching, processing, modification, selection, extraction, comparison of databases, use, interconnection, crossing, blocking, communication, deletion and destruction of data.

Your personal data is processed in paper, electronic and automated form and stored in databases.

COMPULSORY DATA AND OPTIONAL DATA

Among the information we collect some are indispensable to the conclusion and administration of your contract, others help us to offer you a better service, day after day. In particular, it shall:

- The provision of your personal data, processed for the purpose of service, is mandatory to purchase products and register you at the site;

- the provision of your personal data, processed for other purposes, is optional. Their non-payment does not prevent the use of the services of the Group gargiulo & maiello, but you will not receive our commercial communications and personalized offers.

TIMING

The Group gargiulo & maiello conserves and uses your personal data for 10 years from the end of the report for the purpose of service and in any case for the time of prescription provided by law, for no more than 3 years from the end of the report for marketing purposes; for the time of your consent and in any case for no more than 36 months from the collection, for profiling purposes. After that, your data will be deleted or anonymised and processed for aggregated and anonymous statistical analysis.

ACCESS TO DATA

your data will be shared only if strictly necessary. Your data are in fact accessible to:

- employees and/or collaborators of the companies of the Gargiulo & Maiello Group, which contribute to the creation, maintain active and improve all services offered in their capacity as controllers and/or internal controllers and/or system administrators;

- companies of the Group Gargiulo & Maiello Group and service providers that carry out outsourcing activities on behalf of Gruppo gargiulo & maiello - in their capacity as external controllers - carrying out related activities, instrumental or support to those of Gruppo Gargiulo & Maiello , for example: technical management and maintenance of the contents of the website, management of information technology systems, tax services, debt recovery, data processing services for invoicing and archiving documentation related to customer relationships, privacy consulting etc.

COMMUNICATION OF THE DATA

Gargiulo & maiello may communicate your data without your express consent for service purposes:

- to the judicial and/or supervisory authorities at their request,

-to the companies of the Gargiulo & Maiello Group and to all other persons who are subject to this Privacy Policy or to procedures that provide similar safeguards to those described in this Privacy Policy, to which it is necessary to communicate them, by law or by contract, to allow the accomplishment of the purposes described above (such as credit institutions, professional studies).

In any case, we want to reassure you that your data will not be released.

TRANSFER OF DATA

Data transfer outside the European Union is not currently planned. If, in the future, for reasons exclusively related to the provision of the service (e.g. location of cloud servers in non-European countries by the providers in charge, sale of goods located in non-European countries etc.) should your data be subject to these transfers, Gruppo gargiulo & maiello will adopt appropriate guarantees, including adequacy decisions and standard contract terms approved by the European Commission.

RIGHTS OF THE PERSON CONCERNED

We explain now what your rights are, in order to always have control of your privacy and your information. If you do not have recourse to the limitations provided by law, you have the right to:

- RIGHT OF ACCESS, or to have confirmation of the existence or otherwise of your personal data, even if not yet recorded, and to request that such data be made available to you in a clear and comprehensible way, under this right it is your right to ask for directions and, if so, copy:

a) the origin and category of your personal data;

b) the logic of use, in case your information is processed by electronic means;

c) the purposes and modalities of processing;

d) the identification details of the Owner and those responsible;

e) the subjects or categories of subjects to whom your personal data may be communicated or who may become aware of it;

f) the period in which your data is stored or the criteria that are used to determine that period, whenever possible;

g) the existence of an automated decision-making process, including profiling. In this case you can request the used logics, the importance and the expected consequences for you;

h) the existence of adequate safeguards in case of transfer of your data to a non-EU country or international organisation;

- NEGOTIATING - obtaining, with a justifiable delay, the updating of the change, the incorrect modification or the integration of the non-compulsory element, if it is of interest to you,

CANCELLATION RIGHT– it is your right to obtain the deletion, the blocking of data or, where applicable, the form:

a) if treated unlawfully;

b) if no longer necessary in relation to the purposes for which they were collected or subsequently treated;

c) in case of withdrawal of the consent on which the processing is based and in case there is no other legal basis;

d) if you are opposed to the processing and there are no further legitimate reasons to continue using your data;

e) if required by law;

f) in case they are referred to minors.

The Owner may refuse to delete your data in the case of:

a) exercise of the right to freedom of expression and information;

b) fulfilment of a legal obligation, performance of a task in the public interest or exercise of official authority;

c) reasons of public health interest;

d) archiving in the public interest, scientific or historical research or for statistical purposes;

e) establishment, exercise or defence of a right in the courts;

- RIGHT TO LIMITATION you can obtain the limitation of treatment in the case of:

a) contesting the accuracy of personal data, if you did not prefer to ask for the modification, updating, modification or correction of your data;

b) unlawful treatment of the Owner to prevent its cancellation;

c) exercise of your right in court;

d) verification of the possible prevalence of the legitimate reasons of the Data Controller over those of the data subject;

- RIGHT TO PORTABILITY. You are entitled to receive, if the processing is carried out by automatic means, without hindrance and in a structured format, of common and readable use, the personal data concerning you, that you have provided us with prior consent or on contract to transmit them to another Owner or– if technically feasible– to obtain direct transmission by the Owner to another Holder;

RIGHT OF OPPOSITION, you have the right to object at any time in whole or in part:

a)      for legitimate and prevailing reasons, related to your particular situation, the processing of personal data concerning you;

b)     the processing of personal data concerning you for marketing and/or profiling purposes where carried out (e.g. you can object to the sending of advertising or direct sales material or to the completion of market research or commercial communication, through the use of automated call systems without the intervention of an operator, with e-mail and traditional marketing methods, with telephone and paper mail).

For all the cases mentioned above, if necessary, Gruppo gargiulo & maiello, as controller, will inform third parties to whom your personal data is communicated of the possible exercise of rights by you, except in specific cases (e.g. where such fulfilment proves impossible or involves the use of means which are manifestly disproportionate to the protected right).

We remind you that you can at any time modify and revoke the consents given in the Personal Area of the sites: www.ideabellezza.it wwww.gargiuloemalo.com wwww.g-cube.it and exercise your rights by sending an email request to: Group gargiulo & maiello Function DPO – Avv. Marco Sergio marco.sergio@leverup.it or by registered mail to/r at the operating headquarters of the organisation - Interporto di Nola Lotto A1-A6 - 80035 Nola (Na).

Finally, for the processing referred in this policy, you have the right to submit a complaint to the Guarantor for the Protection of Personal Data (www.garanteprivacy.it ).

DPO (Data Protection Officer

The processing of personal data is required by Gargiulo & Maiello SpA, in the person of the CEO doctor. Alessandro Maiello, registered office in Naples at Via Posillipo 69/30. Data Protection Officer DPO Avv. Marco Sergio - 1° telephone N. 3897853044, 2° telephone N. 081.3158411 email marco.sergio@leverup.it or at the operating headquarters of organization - Interporto di Nola Lotto A1-A6 - 80035 Nola (Naples) .  The updated list of our data controllers is available from the offices of Gruppo gargiulo & maiello s.r.l. and can be consulted at.

MEASURES OF SECURITY

Whenever you use our services, Gargiulo & Maiello Group and third parties who work for us take appropriate security measures to prevent unauthorized access, unauthorised disclosure, modification or destruction of your data, in accordance with applicable national law and the GDPR.

In particular, access control systems for the network, servers and programs are used to prevent the disclosure of data to unauthorised external users, firewall and antivirus systems are adopted to protect against viruses and malaware that could erase, disclose or render unusable data, encryption techniques and pseudonymisation of data are implemented, physical and logistical measures of protection of the informatic infrastructures are implemented, procedures of business continuity and disaster recover are implemented, let alone of Data brunch in case of violations.

DATA OF MINORS

Gargiulo & maiello allows young and old to enjoy the services offered in tranquility. For this reason we remind you that children under 18 years of age can use the service only with the assistance of a parent or of those who exercise the parental authority, which will provide the personal data and the necessary privacy consents.

Gargiulo & Maiello Group does not knowingly use the service to process personal data relating to children under 14 for profiling purposes.

This information may be modified. For every update, we invite you to consult our websites made available by Gargiulo & Maiello Group.