Propage S.r.l. cares about the privacy and security of its customers' personal data; it therefore ensures that the personal data collected by the Company will be processed in compliance with EU Regulation 2016/679.
Article 1) Definitions.
"Personal Data": any information relating to an identified or identifiable natural person (the "Data Subject"); an identifiable person is one who can be identified, directly or indirectly, by way of specific reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more distinctive features tied to their physical, physiological, genetic, mental, economic, cultural or social identity;
"Data Subject": the natural person to whom the personal data refers;
"Data Protection Officer" (DPO): an individual designated by the data controller or processor to carry out support, monitoring, advisory, training and informative activities in relation to the application of the Regulation. They cooperate with the Authority and act as the point of contact, including in relation to the data subjects, for matters related to the processing of personal data;
"Data Processor": the natural or legal person, public authority, agency or other body that processes personal data on behalf of the data controller;
"Data Controller": the natural or legal person, public authority, agency or other body that determines the purposes and means of the processing of personal data, whether alone or jointly; where the purposes and means of such processing are determined by the law of the European Union or a Member State, the data controller or the specific criteria for their appointment may be established by the law of the European Union or a Member State;
"Processing": any operation or set of operations performed on personal data or sets of personal data, whether by automatic or other means, including collection; registration; organisation; structuring; storage; adaptation or alteration; retrieval; consultation; use; disclosure by transmission, dissemination or otherwise making the data available; comparison or interconnection; restriction; and erasure or destruction.
Article 2) Data Controller.
The Data Controller is Propage s.r.l., with its registered office at 10 Piazzale Clodio, post code: 00195, Rome, tax code and VAT ID: 07609531004, email address: firstname.lastname@example.org, certified email address: email@example.com.
Article 3) Type of Personal Data, purpose and legal basis of the processing.
Propage s.r.l. is a company that sells consumer goods online and directly at Nuna Lie stores and, as a result, acquires, stores and uses the Personal Data of the Data Subjects in order to properly fulfil the contractual obligations that arise from its sales activities or marketing initiatives to improve the services for its customers.
Propage S.r.l. only acquires, stores and uses the following personal data:
- first and last name or registered name;
- date of birth;
- billing/shipping address;
- email address;
- telephone number;
If payment is made by credit/debit card, the related data is not communicated to Propage S.r.l., but directly to the payment service provider.
Propage S.r.l. shall not, under any circumstances, require, store or process:
- special and judicial data;
- credit card numbers or login credentials for the payment systems used by the customer.
The personal data collected is processed on the following legal bases:
- Article 6, paragraph 1b of EU Regulation 2016/679, for the execution of the contract;
- Article 6, paragraph 1f of EU Regulation 2016/679, for marketing initiatives;
- Article 6, paragraph 1a of EU Regulation 2016/679, for profiling activities aimed at improving services for customers.
Article 4) Data acquisition and storage methods.
The Personal Data is processed in a lawful manner and only used for the purposes indicated in Article 3. The processing will be carried out using tools that guarantee security and confidentiality, employing totally or partially automated tools to store, manage and transmit the data, both on paper and computer. Specific security measures are adopted to prevent data loss and reduce the risks of illegal or improper use and unauthorised access.
The Personal Data is acquired directly from the Data Subject by way of specific online forms, direct contact or telephone communication.
Data acquired in this way is stored electronically on the Propage S.r.l. servers.
Article 5) Obligation and necessity of data provision.
The provision of Personal Data by the Data Subject is obligatory and necessary for the fulfilment of contractual obligations and to respect the mandatory rules in place regarding fiscal, tributary, accounting obligations, and anything else foreseen by the Law.
In the event that the Data Subject refuses to provide said data, Propage S.r.l. may not accept any order or execute any contract.
Article 6) Data storage period.
The personal data of the Data Subject that is acquired on the legal basis of the execution of a contract will be stored for the entire duration of the contract and, after termination, for the period referred to in Article 2220 of the Italian Civil Code for the purpose of fulfilling the associated fiscal and tax obligations.
In the event of judicial or extrajudicial litigation, including potential litigation, the Personal Data will be stored for the entire duration of the litigation and until the time limit for appeals has expired or, more generally, until the time limit for the forfeiture or limitation of rights or claims established by the law has expired.
Once the aforementioned time limits have expired, the personal data of the Data Subject will be deleted according to the technical procedures laid out for this purpose.
The personal data of the Data Subject that is acquired on the legal bases of the Data Controller's legitimate interest and consent will be stored for 10 years from the end of the last customer contact with Nuna Lie.
Article 7) Independent Data Controllers, Data Processors and Recipients of Personal Data.
In addition to the Data Controller and its staff, who have been formally authorised, the Personal Data of the Data Subject may be processed by external parties operating as independent Data Controllers, including, but not limited to, companies that offer goods transport and shipping services.
Additionally, the Personal Data may be processed on behalf of the Company by external parties that have been authorised and designated as Data Processors of the Personal Data, to whom appropriate operating instructions shall be given, including, but not limited to, the Companies affiliated with Propage s.r.l. under the Nuna Lie brand. A complete and up-to-date list of these parties can be obtained by contacting the Company via certified email or registered letter with return receipt at the addresses indicated in Article 2, attaching a signed copy of an identity document.
Finally, the Data Subject's Personal Data may be disclosed to the Judicial or Administrative Authorities, or to parties who have been specifically designated and authorised by law and to whom it must be communicated in order to fulfil specific legal obligations.
Article 8) Loyalty Card.
If the Data Subject has decided to join the loyalty card programme by filling out the online form or paper form at a Nuna Lie store, their Personal Data, as listed in Article 3, may be used for marketing activities—such as sending communications, newsletters and offers, and earning points for discounts on purchases, etc.—both by the Data Controller and parties designated for this purpose, according to the legal basis of legitimate interest.
The Nuna Lie Shop Card allows registered customers to earn points on their purchases in order to receive discounts on subsequent purchases, receive exclusive promotions, access collection previews and early sales, and receive discounts on products from other companies reserved for Nuna Lie customers. The Shop Card is free of charge and valid in all Nuna Lie stores.
In order to provide the best possible service to customers who register for a Shop Card, computer profiling of the Data Subject is carried out, with the consent of the latter, analysing their purchases to recommend specific offers and products. This information can also be viewed by the affiliates of Propage s.r.l., allowing them to better assist Shop Card holders that physically visit Nuna Lie stores. The provision of Personal Data is optional; however, failure to provide the data will make it impossible to carry out the activities indicated here.
Article 9) Work with us.
If the Data Subject has submitted their CV to work for Propage s.r.l. or other affiliated companies under the Nuna Lie brand, the personal data contained therein will be stored electronically for a maximum period of 2 years. The processing of such data is carried out on the legal basis of consent (as per Article 6, paragraph 1a of the GDPR) in order to evaluate and possibly employ the data subject. Propage s.r.l. may forward the Data Subject's CV to the other affiliated companies under the Nuna Lie brand.
Article 10) Rights of the Data Subject and lodging complaints with the Supervisory Authority.
In accordance with Articles 15,16,17,18,19,20 and 21 of EU Regulation 679/2016, the Data Subject has the right to:
- Obtain confirmation as to whether personal data concerning them is being processed, obtain access to the data concerning them, obtain a copy of the data concerning them, and obtain information about the processing;
- Rectify any inaccurate data concerning them;
- Obtain the deletion of personal data concerning them;
- Obtain the restriction of the processing of personal data concerning them in the specific cases listed in Article 18 of EU Regulation 2016/679;
- Obtain the portability of personal data concerning them;
- Object to the processing of personal data concerning them on the legal bases of consent and public interest.
The point of contact to exercise these rights is firstname.lastname@example.org.
The Data Subject is also entitled to lodge a complaint with the competent Supervisory Authority in the Member State in which they normally reside or work, or in the State in which the alleged breach occurred.
If the Data Subject has registered on the www.nunalie.it website, they can also view and/or rectify their Personal Data by logging in to their account, in addition to deleting their account.
Article 12) Personal Data Security.
The Data Controller has adopted specific security measures to prevent the loss of the Data Subject's Personal Data, illegal or improper use, and unauthorised access. However, the Data Subject must also use devices equipped with suitable tools (for example, up-to-date antivirus software and an internet connection that ensures the transmission of data through firewalls, spam filters, etc.).
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