Last updated: January 25th, 2021
The Data Controller is d’Avossa S.r.l. with registered seat in Rome (RM), Italy, Via Borgognona 26 – 00187, owner of the website.
We invite you to read the following policy for more information about the collection, processing, diffusion and transfer of data you provided through the Site, by visiting a d’Avossa boutique, by telephone contacts, whatsApp or interactions through the d’Avossa social pages.
You can contact d’Avossa to know the complete list of data processors by sending an email to: firstname.lastname@example.org.
- TYPE OF DATA PROCESSED AND PROCESSING PURPOSE
The following data are collected and processed by d’Avossa to manage contractual relations with the customers and to fulfill obligations contemplated by law, authorities, regulation or EU laws:
- name, surname, address, identification;
d’Avossa may collect and process the data mentioned above and additional data indicated below, only subject to the prior express consent of the interested User:
- for profiling purposes or statistical activities, also through third parties, to identify the Users’ tastes and consumption habits and to create commercial offers appropriate to the profiles defined.
- for providing personalized services (for example: free customer assistance services, personal shopping services, personalization services) and manage customers’ questions and requests.
- for sending (by post – email – fixed or mobile telephone, with automated call systems or with an operator – SMS – MMS- WhatsApp) different types of communications, advertising material and newsletters regarding: our products, direct or reserved sales, commercial opportunities, events and projects organized by d’Avossa or in which d’Avossa is a guest, including any invitations to such initiatives or satisfaction questionnaires about the d’Avossa’s services.
In relation to the purposes described in points b), c) and d), d’Avossa may collect and use additional data than those strictly essential for the management of the contractual relationship and the fulfillment of legal obligations, as shown below by way of example only:
- photograph, gender, language, nationality, telephone/mobile number, email address;
- birthdate, age range, family events’ date, education’s level, professional position, interests, hobbies;
- how to use the Site, including information collected through cookies or similar technologies;
- types of preferred products, included in the so-called “Wish List”, purchases history and statistical expenditure levels, measure, price, discount percentage, products selected for purchase but not purchased, answer to contacts/initiatives in which the customer has taken part.
- PROVISION OF DATA AND CONDITIONS APPLICABLE TO CONSENT OF MINORS
While the provision of data of paragraph 1 letter a) is mandatory and in case of refusal, d’Avossa will not be able to carry out the contractual services requested, for the purposes of paragraph 1 letters b), c), d) the provision is free and optional and the use of data by d’Avossa is subject to consent; in case of refusal to provide data, d’Avossa will not be able to pursue the purposes indicated.
The minors’ data processing is allowed provided they are at least 16 years of age. In the event that the minor is under this age, the data processing is permitted only if and to the extent that such consent is granted or authorized by the parental responsibility’s holder. In case of no- authorization from the parental responsibility’s holder, d’Avossa will promptly delete any data involuntarily collected relating to subjects under the age of 16.
- WITHDRAWAL OF CONSENT
The consent given by the User to collect and use their data can be revoked, by this one, at any time (without any prejudice to the legitimacy treatment based on the consent acquired before the revocation) and may make it impossible to pursue the purposes indicated above.
- DATA PROCESSING METHODS AND CRM SYSTEM
d’Avossa will process data collected using IT tools and/or through manual processing and/or using automated mechanisms, with logic strictly related to the purposes described above and, in any case, in order to guarantee the data security and confidentiality.
The insertion of collected data in the CRM system (Customer Relationship Management) is optional and it happens only in case there is the consent release for the purposes of paragraph 1 letters b), c), d ). The CRM system is used by d’Avossa, and by its employees designated as data processors, to offer higher quality services and to improve the management (administrative and IT) of customer data.
- DATA PRESERVATION
The data collected for the purposes described in paragraph 1 letter a) will be kept by d’Avossa for a time period necessary for the realization of the contract, for the provision of legal or conventional guarantees or in accordance with the data retention’s terms indicated by law. After this deadlines, the collected data will be deleted or made anonymous.
The data collected for the purposes of paragraph 1 letters b), c), d) will be kept by d’Avossa until the customer requests the consent revocation to the processing of their data. Upon this request, this data will be deleted or made anonymous.
Moreover the customer can request to stop receiving direct marketing communications. In this event, d’Avossa will record this request and the related contact details to ensure compliance with what is expressly requested.
- DIFFUSION OF DATA AND TRANSFERS ABROAD
The personal data is processed by d’Avossa personnel authorized for this purpose, appointed as data processor and each according to their respective area of duties. In addition to d’Avossa’s personnel authorized for this purpose or appointed as data processor, collected data may be processed by companies that perform: customer care services; services for sending newsletters/advertising material/promotional communications; shipping/delivery services of catalogs / brochures / products; market research company; companies that maintain IT systems.
The data collected by d’Avossa may also be processed by independent third-party data controllers, such as, for example: people, associations, companies or professional that provide assistance and consultancy of various kinds (by way of example only: legal, economic, commercial, strategic); companies that manage credit card payment service and tax free.
In the event that d’Avossa share the personal data with data processors working on behalf of d’Avossa, in EU or non-EU member countries, ensuring always an adequate protection level of the data processed, the transfer will be limited to what is necessary, restricted to purposes for which the data were collected.
In no case the data collected will be diffused and transferred to third-party companies for purposes other than d’Avossa’s ones, described in paragraph 1 letters b), c), d), for which they were collected.
The complete list of third parties authorized to process the data collected by d’Avossa can be found by writing to email@example.com.
- RIGHTS OF THE DATA SUBJECT
The data subject has the right to ask at any time: the information on the data processing that may concern him and on any recipients to whom the collected data can be communicated; the communication of collected data in intelligible form and information about their origin; the data modification and e correction; the cancellation of the collected data or the limitation of processing if this is unlawful or the data subject has expressly opposed to their processing or he has revoked the consent.
d’Avossa must correct inaccurate data and integrate incomplete data. Furthermore, if expressly requested by the data subject, d’Avossa must delete the data, restrict its use and/or stop its processing. Finally d’Avossa must respond to requests received, regarding the collection and the data processing, within the deadlines provided by applicable regulations.
To exercise own rights, request more information or to report any problems or violations, data subject can send an email to firstname.lastname@example.org or, if the response obtained by d’Avossa is not considered exhaustive, data subject can contact the Italian Data Protection Authority
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