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Information on the processing of personal data pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR). Effective from 18/06/2023

INTRODUCTION

This policy takes into account the provisions of the GDPR and the Privacy Code (Legislative Decree No. 196 of 30 June 2003). The document has also been drawn up in accordance with the Guidelines of the Privacy Authority (in particular the Guidelines on combating spam issued by the Privacy Authority on 4 July 2013).

Data Controller: MARIA CHIARA LEONARDI

Website to which this privacy policy refers: www.lessinterior.it (Website).

The Data Controller has also appointed a Data Protection Officer (DPO), who is responsible for monitoring the Data Controller's compliance with the GDPR.

GENERAL INFORMATION

This document describes how the Data Controller processes your personal data provided on the Website.

The main processing of your personal data is described below. In particular, the legal basis for the processing is explained, whether the provision of data is mandatory and the consequences of not providing personal data. In order to best describe your rights, where necessary, we have specified if and when a particular processing of personal data is not carried out. On the Website, you have the option of entering personal data of third parties. In this case, you guarantee that you have obtained the consent of these parties to enter their personal data. Therefore, you undertake to indemnify and hold harmless the Data Controller from any liability.

Registration on the Website

The information and data requested during registration will be used to allow you to access the reserved area of the Website and to use the online services offered by the Data Controller to registered users. The legal basis for the processing is the Data Controller's need to carry out pre-contractual measures taken at the request of the data subject. The provision of data is optional. However, your refusal to provide data will make it impossible to register on the Website. You can also register on the Website using external services. In this case, your registration data will be shared with the companies providing these external services for the sole purpose of allowing you to register on the Website. The legal basis for this processing is the legitimate interest of the Data Controller in allowing registration on the Website through external services. The provision of personal data for this purpose is purely optional. However, failure to consent to the processing of data will make it impossible to register through external services.

Purchases on the Website

Your personal data will be processed to enable you to make purchases on the Website. In the case of an online purchase order, this is to enable the conclusion of the purchase contract and the correct execution of the operations connected with it (and, if necessary under sector regulations, to fulfil tax obligations). The legal basis for the processing is the Data Controller's obligation to perform the contract with the data subject or to comply with legal obligations. Notwithstanding the above (and therefore your consent), the Data Controller may process your data for so-called "soft-spam" purposes, governed by Article 130 of the Privacy Code. This means that, limited to the email address you provided in the context of a purchase through the Website, the Data Controller will process the email address to allow the direct offering of similar products/services, provided that you do not object to such processing in the manner provided for in this policy. The legal basis for the processing is the legitimate interest of the Data Controller in sending this type of communication. This legitimate interest can be considered equivalent to the interest of the data subject in receiving "soft-spam" communications. The Data Controller may send emails to remind the user to complete a purchase. The legal basis for this processing is the legitimate interest of the Data Controller in sending this type of communication. Through the "follow on shop" option, the Data Controller may also process your personal data to send updates by email and/or telephone (depending on the options available on the Website from time to time) on the status of orders, shipments and/or supplies. The legal basis for this processing is the legitimate interest of the Data Controller in sending this type of communication. This interest is equal to your interest in receiving this type of update. The provision of personal data for this purpose is optional. However, if personal data is not provided, it will not be possible for the Data Controller to send this type of communication.

Responding to your requests

Your data will be processed in order to respond to your requests for information. The provision of data is optional, but your refusal will make it impossible for the Data Controller to respond to your questions. The legal basis for the processing is the legitimate interest of the Data Controller in responding to user requests. This legitimate interest is equivalent to the user's interest in receiving a response to communications sent to the Data Controller.

Generic marketing

With your consent, the Data Controller may process the personal data you provide in order to send you advertising material and/or newsletters relating to its own or third-party products. The legal basis for this processing is your consent. The provision of personal data for this purpose is purely optional. Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to the products/services of the Data Controller and/or third parties, as well as making it impossible for the Data Controller to carry out market surveys, including those aimed at assessing user satisfaction, and to send you newsletters. These communications will be sent to the email address you provided on the Website.

Profiling

With your consent, the Data Controller may process your personal data for profiling purposes, i.e. to analyse your consumption choices by revealing the type and frequency of your purchases, in order to send you advertising material and/or newsletters relating to its own or third-party products that are of specific interest to you. The legal basis for this processing is your consent. The provision of data for this purpose is purely optional. Failure to consent to the processing of your personal data for profiling purposes will make it impossible for the Data Controller to process your commercial profile by detecting your choices and purchasing habits, as well as to send you advertising material relating to products of the Data Controller and/or third parties that may be of specific interest to you. These communications will be sent to the email address you provided on the Website.

Transfer of data

The Data Controller does not transfer your personal data to third parties.

Geolocation

When accessing the Website, you may receive a notification on your device (fixed and/or mobile) giving you the option to allow or deny the identification of your device (known as geolocation). You are free to accept or decline this setting without any substantial changes to the functionality of the Website. You may change your geolocation settings at any time via your device settings. The legal basis for the processing is the legitimate interest of the Data Controller in providing services relevant to the user's location. This legitimate interest is equal to the user's interest in receiving services that are as relevant as possible to their location.

Curriculum Vitae

It is not possible to send CVs via the Website. Therefore, your data will not be processed for these purposes.

Appointment booking

There are no third-party systems on the Website for booking appointments with the Data Controller. Therefore, your data will not be processed for this purpose. In any case, you can always contact the Data Controller at the addresses indicated in the epigraph.

Communication of personal data

As part of its ordinary activities, the Data Controller may disclose your personal data to certain categories of subjects. In Article 2, you will find a list of the subjects to whom the Data Controller discloses your personal data. To facilitate the protection of your rights, Article 2 may specify in some cases when your data will not be disclosed to third parties.

The "communication" of personal data to third parties is different from "transfer" (regulated in the previous point). In fact, in communication, the third party to whom the data is transmitted may only use it for the specific purposes described in the relationship with the Data Controller. In transfer, on the other hand, the third party becomes the independent Data Controller of the personal data. Furthermore, your consent is always required to transfer your personal data to third parties.

Without prejudice to the foregoing, it is understood that the Data Controller may in any case use your personal data to correctly fulfil the obligations provided for by the laws in force.

SPECIFIC PRIVACY POLICY

Art. 1 Processing methods

1.1 Your personal data will mainly be processed using electronic or automated means, in accordance with methods and tools that guarantee security and confidentiality in compliance with the GDPR. If the automatic chatbot service is operational, your personal data will also be processed to enable the activation of this service, through which the user can contact and be contacted by the Data Controller, subject to consent. The legal basis is the legitimate interest of the Data Controller in responding to user requests via the chatbot service. This legitimate interest can be considered equivalent to the interest of the data subject in using the automatic chatbot service.

1.2 The information acquired and the methods of processing will be relevant and not excessive in relation to the type of services provided. Your data will also be managed and protected in secure IT environments that are appropriate to the circumstances.

1.3 No "special categories of data" are processed through the Website. Special categories of data are those that may reveal racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organisations of a religious, philosophical, political or trade union nature, health status and sex life.

1.4 No judicial data is processed through the Website.

Art. 2 Communication of personal data

The Data Controller may disclose your personal data to specific categories of subjects. The subjects to whom the Data Controller reserves the right to disclose your data are indicated below:

  • The Data Controller may disclose your personal data to all those entities (including Public Authorities) that have access to personal data pursuant to regulatory or administrative provisions.
  • Your personal data may also be disclosed to all those public and/or private entities, natural and/or legal persons (legal, administrative and tax consultancy firms, judicial offices, chambers of commerce, chambers and offices of labour, etc.), if such disclosure is necessary or functional to the proper fulfilment of the obligations arising from the law.
  • The Data Controller employs employees and/or collaborators in any capacity. For the proper functioning of the Website, the Data Controller may communicate your personal data to these employees and/or collaborators.
  • In its ordinary management of the Website, the Data Controller uses companies, consultants or professionals responsible for the installation, maintenance, updating and, in general, management of the Data Controller's hardware and software or that which the latter uses to provide its services. Therefore, only with reference to these purposes, your data may also be processed by these subjects.
  • The Data Controller uses external companies responsible for sending this type of communication (CRM platforms) to send its communications. Your personal data (in particular your email address) may therefore be disclosed to these companies.
  • The Data Controller does not use external companies to provide customer care services.
  • The purchaser's personal data may be disclosed to post offices, couriers or shippers responsible for delivering the Products purchased through the Website.

The Data Controller reserves the right to modify the above list based on its ordinary operations. Therefore, you are invited to regularly access this policy to check which entities the Data Controller communicates your personal data to.

Art. 3 Retention of personal data

3.1 This article describes how long the Data Controller reserves the right to retain your personal data.

  • Your personal data will be stored only for the time necessary to ensure the proper performance of the services offered through the Website.
  • For customer care purposes, the data will be deleted once the assistance service has been completed.
  • As stipulated in Article 2220 of the Civil Code, invoices, as well as all accounting records in general, must be kept for a minimum period of ten years from the date of registration, so that they can be presented in the event of an audit.
  • Through the Website (or by submitting a request to the Data Controller), it is possible to delete the user's account. In this case, all personal data stored will be deleted and will not be retained by the Data Controller for any purpose.
  • For the purpose of executing the sales contract, the data will be stored for 10 years from the date of receipt of the purchase order. This is to allow the Data Controller to exercise its right of defence and to demonstrate that it has correctly executed the contract.

3.2 Without prejudice to the provisions of Article 3.1, the Data Controller may retain your personal data for the time required by specific regulations, as amended from time to time.

Art. 4 Transfer of personal data

4.1 The Data Controller is based within the European Union. Therefore, the processing of your data is secure from a regulatory point of view as it is governed by the GDPR. If your personal data is transferred to a non-EU country for which the European Commission has issued an adequacy ruling, the transfer is considered secure from a regulatory point of view in all cases. This Article 4.1 indicates the countries to which your personal data may be transferred and where the European Commission has issued an adequacy ruling.

  • Users are therefore invited to regularly access this article to check whether their personal data is being transferred to a country with these characteristics.

4.2 Without prejudice to the provisions of Article 4.1, your data may also be transferred to countries outside the EU for which the European Commission has not issued an adequacy ruling. You are therefore invited to regularly review this Article 4.2 to ascertain to which of these countries your data may be transferred.

4.3 In this article, the Data Controller indicates the countries in which it specifically conducts its business. This circumstance may imply the application of the legislation of the country in question, together with that of the GDPR. 

  • At the user's request, the Data Controller will apply the most favourable legislation provided for by the user's national legislation to the processing of personal data.

Article 5. Rights of the data subject

Pursuant to Article 13 of the Privacy Regulation, the Data Controller informs you that you have the right to:

  • request the Data Controller to grant you access to your personal data and to correct or delete it or limit its processing or to object to its processing, in addition to the right to data portability
  • withdraw consent at any time without prejudice to the lawfulness of processing based on consent given prior to withdrawal
  • lodge a complaint with a supervisory authority (e.g. the Data Protection Authority).

The above rights may be exercised by sending a request to the contacts indicated in the Introduction.

Article 6. Amendments and Miscellaneous

The Data Controller reserves the right to make changes to this policy at any time, giving appropriate notice to users of the Website and ensuring, in any case, adequate and similar protection of personal data. In order to view any changes, you are invited to consult this policy regularly. In the event of substantial changes to this privacy policy, the Data Controller may also notify you by email.

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