INFORMATION ON THE PROCESSING OF PERSONAL DATA
pursuant to articles 13 and 14 of EU Regulation 2016/679
on the protection of individuals with regard to the processing of personal data
Avantgarde S.r.l., company with sole shareholder – Cap. Soc. € 10.300,00 i.v. – registered with the C.C.I.A.A. of Florence n. Rea FI 550960 – VAT number IT05494150484 – Registered Office: Via Tevere, 100/5 – 50019 Sesto Fiorentino (FI) Italy, tel. 055 34116191, owner of the website “www.marlonfirenze.com” and of the registered trademark “MARLON” (hereinafter referred to as the “Company”), as data controller provides you below, pursuant to Arts. 13 and 14 of the European Regulation 679/2016 concerning the protection of personal data (hereinafter referred to as “GDPR”), the information relating to the processing of personal data of all the subjects who purchased, requested or enjoyed services and / or products supplied by the Company or have provided the Company with or without the aid of third parties, including in verbal form, their personal and fiscal data for commercial or trade-related relations (these subjects are then referred to as the “User”).
- Type of data processed
- Purpose of the processing
- Legal basis of the processing
- Methods of processing
- Data retention
- Communication, dissemination and transfer of data
- Transfer of data abroad
- What are the rights of the User
- Changes and updates
- TYPES OF DATA PROCESSED
The personal data processed by the Company include, by way of example and not exhaustively, the following categories of data relating to the User:
(a) identification, personal and company data, contact and access data, such as name, surname, company data, email address, telephone number and credentials for access to web channels provided by the Company * to request and obtain the products of this ‘last;
* (channels intended as websites owned by the Company)
(b) navigation data (in the case of websites owned by the Company), such as IP addresses, log data or domain names and any other parameters relating to computers;
(c) product data, such as data relating to the products and / or services provided by the Company, which the User has requested, to which he / she has access or benefits;
(d) data on preferences, such as data relating to preferences, activities and spending habits of the User;
(e) payment and bank details, such as the account number or IBAN;
(f) data acquired from public sources, such as data of representatives and prosecutors that are collected via, for example, Chambers of Commerce or commercial information services;
(The data listed above will be defined jointly in “Data” later)
You will not be asked to provide, and will not collect sensitive data and / or anyway belonging to the particular categories referred to in art. 9 GDPR.
- PURPOSE OF THE TREATMENT
Data processing is carried out by the Company in carrying out its economic and commercial activities for the following purposes:
a) to allow the User to request information and obtain (even with personal customizations) the products supplied by the Company;
b) to fulfill the obligations deriving from the law, regulations or community legislation (for example, fiscal and accounting obligations);
(the purposes referred to in subparagraphs a) and b) are jointly defined below as the “Contractual Purposes”)
c) to assert and defend their rights, including in the context of debt recovery procedures and assignment of credits, including and possibly through third parties;
d) for the analysis and improvement of services and / or products offered;
e) to carry out a potential merger, sale of assets, transfer of business or business unit divulging and transferring the Data to the third party (s) involved;
(the purposes of letter c) and e) the “Legitimate interests of business interests” are jointly defined)
f) to provide the User, pursuant to article 130 of Legislative Decree 196/2003 (the “Privacy Code”), marketing communications by e-mail on products similar to those supplied by the Company, provided that, at any moment, he will have the possibility to oppose the sending of such communications;
g) with the prior consent of the User, to provide marketing communications relating to the products offered by the Company, through remote communication tools (company emails, telephone application messages, etc.).
(The purposes of letter f) are defined later as the “Marketing Purposes”.)
Your data are not subject to dissemination, profiling, or automated decision-making procedures by the Company.
- LEGAL BASIS OF TREATMENT
Data processing is necessary with reference to the Contractual Purposes as such Data are necessary in order to:
- provide information regarding the Company’s products required in relation to the cases referred to in Section 2, letter a), as well as the entire sale procedure relating to the sale of the same products or other products to the requesting parties;
- comply with the provisions of applicable law as required by Section 2, letter b).
Should the User decide not to provide the Data necessary for the Contractual Purposes, the Company may find it impossible to supply the requested information and products.
The processing of data for the purposes of legitimate business interests is carried out pursuant to Article 6 (f) of the GDPR for the pursuit of the legitimate interests of the Company that is fairly balanced with the interests, rights and freedoms of the User in how much the data processing activity is limited to what is strictly necessary for the execution of the operations indicated therein. The treatment for the purposes of legitimate business interest is not mandatory and the user may oppose the processing under the conditions set out in this information, but if he decides to object to such processing, his data can not be used for purposes of Legitimate Business Interest, unless the Company demonstrates the presence of prevailing legitimate legitimate reasons or the exercise or defense of a right pursuant to Article 21 of the GDPR.
The processing of data for marketing purposes is based on:
- with regard to Section 2 letter f), on Article 130 of the Privacy Code, which allows sending marketing communications by e-mail concerning products similar to those supplied, which the User may object to when data is collected and in any subsequent communication;
- with regard to Section 2, letter g), on the consent of the User.
The processing of data for marketing purposes is not mandatory. Therefore, in case of opposition to marketing communications or refusal to provide the relative consent, or revocation of the same, the User will not receive the marketing communications referred to in Section 2 from letter f). In any case, the User may revoke the consent to the processing of data and oppose the sending of all marketing communications at any time, through the methods provided for in this information.
- METHOD OF TREATMENT
The Data will be processed by the Company with both IT and / or computer systems, and in paper form according to the principles of lawfulness, correctness and pertinence and without exceeding the provisions of the applicable law on the protection of personal data and protecting the confidentiality of the ‘User through technical and organizational security measures to guarantee an adequate level of security.
The processing will also be carried out by authorized parties and members of the Company’s staff and committed to confidentiality as a result of adequate training and / or information.
- DATA CONSERVATION
The Data will be kept for the period of time necessary for the pursuit of the purposes for which such Data were collected, as stated in this statement. In any case, the following retention terms will apply with reference to the processing of the Data for the following purposes:
a) for the purposes of the Contractual and Legitimate Business Interest the Data are kept for a period equal to the duration of the supply of the products requested by the User and for the 10 years following the cessation of supply, except in cases where the storage for a subsequent period is required for any disputes, requests by the competent authorities or pursuant to applicable law;
b) for the Marketing Purposes referred to in Section 2, letters f) and g), the Data are kept for a period equal to the duration of the supply of the requested Products of the User and a period of 24 months following the last contact with the ‘User means, among others, participation in an event of the Company, the use of a product provided by the Company or the opening of a newsletter (jointly defined as the “Last Contact”).
- COMMUNICATION, DIFFUSION AND DATA TRANSFER
For the Contractual Purposes, the Data may be transferred to the following third parties who perform functional activities to those for the supply of the products requested by you located inside and outside the European Union: (a) third party service providers assistance and consultancy for the Company with reference to the activities of the sectors (purely by way of example), technological, accounting, administrative, legal, insurance; (b) in cases where the supply of the products requested by you involves the intervention of our commercial partners, the Company may share some Data with the distributors, resellers and partners in the chain of distribution of the Company’s products; (c) subjects and authorities whose right of access to the Data is expressly recognized by law, regulations or provisions issued by the competent authorities.
For the purposes of legitimate business interests, the data may be transferred to the following categories of recipients, located inside and outside the European Union: (a) third-party suppliers of assistance and consultancy services for the Company with reference the activities of the sectors (purely by way of example) technological, accounting, administrative, legal, insurance, customs, transport and shipping (b) Competent authorities.
For the purposes of marketing, the Data may be transferred to the following categories of recipients, located inside and outside the European Union: (a) third parties responsible for data processing, providing assistance and consulting services for the Company with reference to the activities of sending marketing communications.
These recipients, as the case may be, process the User’s Data in the capacity of data controllers, data processors or processors. The complete and updated list of the parties processing the Data as data controllers is available upon request to the Company, according to the contact methods indicated in this statement.
- TRANSFER OF DATA ABROAD
The Data may be freely transferred outside the national territory to countries located in the European Union.
- WHAT ARE THE CUSTOMER’S RIGHTS
In relation to the processing of the Data described in this statement, the User can exercise at any time the rights established by the GDPR (articles 15-21), including:
- receive confirmation of the existence of the Data and access their contents (access right);
- update, modify and / or correct the Data (right of rectification);
- request the deletion or limitation of the processing of data processed in violation of the law including those that do not need to be kept for the purposes for which the data were collected or otherwise processed (right to be forgotten and the right to limitation) ;
- oppose the treatment (right of opposition);
- revoke the consent, where provided, without prejudice to the lawfulness of the treatment based on the consent given prior to the revocation;
- propose a complaint to the Supervisory Authority (Guarantor for the protection of personal data www.garanteprivacy.it) in case of violation of the regulations regarding the protection of personal data;
- receive an electronic copy of the Data concerning him, to transfer them to himself or to a different service provider, in the event that the Company processes these Data on the basis of his consent or on the basis that the processing is necessary for the supply of the requested products or information on the requested products and the Data are processed using automated tools (right to data portability).
To exercise these rights, the User can contact the Company, which can be contacted by sending a request to the address firstname.lastname@example.org, or by sending the communication by registered mail to:
( Via Tevere n. 100/5
50019 – Sesto Fiorentino (FI) Italy)
c.a .: Data controller
When contacting us, you must ensure that you include your name and surname, email and postal addresses and / or telephone number (s) to make sure that your request can be handled correctly.
- CHANGES AND UPDATES
This information may be subject to changes also as a result of any changes and / or regulatory additions. The changes will be notified in advance and the constantly updated information will be uploaded to make it available on the sites owned by the Company.
What are cookies?
According to Regulation (EU) 2016/679 on the protection of personal data, cookies constitute personal data when they can be associated with a device and, therefore, to an identifiable person.
Types of cookies
There are different types of cookies that contain different information and perform different functions (eg execution of computer authentication, monitoring of sessions, storage of preferences for sending targeted advertising messages, etc). Each cookie, in turn, contains different data (eg the name of the server it came from, a numerical identifier, etc.). This data can remain in the user’s device for different time periods – a browser session, a few hours, several days or for longer periods.
Third-party analytical cookies used as technical cookies
Cookies that are used to browse or provide a service requested by the user. They are not used for further purposes.
The analytical cookies of third parties can be assimilated to technical cookies only if used for the purpose of optimizing the site by the owner of the site, to collect information in aggregate form on the number of users and how they visit the site.
Cookies used to track user navigation on the web and create profiles on his tastes, habits, choices, etc. With these cookies, advertisements can be transmitted to the user’s terminal in line with the preferences expressed by the user in his online navigation.
Need to install on the user’s device
Technical cookies are necessary for the proper functioning of the site. Without the use of these cookies, some operations could not be performed or would be more complex and / or less secure. Therefore, technical cookies are indispensable.
When used as technical cookies and when anonymisation measures are required by the Guarantor, analytical cookies are necessary to allow the site owner to improve the functioning of the site and the user experience on the site.
Profiling cookies are not strictly necessary for the proper functioning of the site and, therefore, the user can decide whether to install such cookies or not.
User consent required?
Technical cookies do not require user consent, as they are necessary for the proper functioning of the site.
For the installation of analytical cookies, the user’s consent is required, which can be expressed or revoked by the user
For the installation of profiling cookies, user consent is required, which can be manifested or revoked by the user
How to express your choice regarding the cookies used by the site
- Google Analytics (Third-party analytical cookies used as technical cookies)
If you do not want your data to be used by Google Analytics, you can install the browser add-on in the manner described by Google at the following addresses:
- Third-party profiling cookies
These cookies are activated by clicking “Accept” on the information banner that appears when you start browsing the site (or closing the banner or “skipping” the banner, selecting another element of the site).
In addition, you can also disable cookies by adjusting your browser settings. We remind you, however, that disabling technical or navigation cookies may cause the site to malfunction or may render some features unavailable. Each browser has different procedures for managing settings. Here are the links to the instructions for the most common browsers:
Social network widgets
The social icons are present on the Company’s website that depict social networks (eg Facebook, Instagram, etc.) and that allow you to interact with a “click” directly with the Company’s account profiles active on social platforms. Through the use of these buttons are therefore not installed on the site third-party cookies.