Under EU Regulation 2016/679 concerning the protection of individuals with regard to the processing of personal data
In compliance with the obligations established by EU Regulation 2016/679 concerning the protection of individuals with regard to the processing of personal data (the “Regulation”), we hereby intend to inform you that ADV Deal Srl (“ADV Deal” or the “Company”) with its registered office in Via Amedeo Modigliani 41, 20090, Segrate (MI), Tax Code and VAT number 07223170965, registered in the Milan Company Register, REA N. MI-1944453, Certified email firstname.lastname@example.org, as the Data Controller, will process your personal data, which may be collected by us, given by you and/or by other informed subjects, during the navigation and use of our company website http://www.advdeal.com (the “Site”).
The processing of data freely provided by you or otherwise collected while browsing the Site will be carried out in compliance with the ongoing rules on the protection of personal data.
In particular, processing will be based on compliance with the principles of correctness, lawfulness and transparency. The data will be relevant, complete and not excessive in relation to the purposes they are processed for and will be collected and recorded only for the purposes indicated in this Policy.
1) Which data is processed?
Personal data collected or provided by you while browsing and using the Site will be processed, such as:
- User’s IP address;
- User’s browsing data on the site;
- Browser and devide information;
- Information collected through cookies, pixel tags and other technologies, provided by the User, without revealing their specific identity
- Demographic information and other information provided by the User, without revealing their specific identity
- Information that has been aggregated in such a way as to no longer reveal the specific identity of the User
- personal data, tax code, residential and shipping address, email address, telephone number;
- data relating to payment instruments.
2) Which purposes is your data processed for?
ADV Deal will process your personal data for the following purposes:
- fulfill any type of obligation required by current regulations;
- allow you to register on the Site;
- allow the conclusion, management and execution of an online sales contract with you;
- allow you to take advantage of the Site’s functions, obtain the information you requested through our contact form and also allow you to respond to any specific requests for information on the products;
- to inform you via newsletters or other communication channels (for example SMS, MMS or other methods) about ADV Deal products, promotions and commercial initiatives, organisation and promotion of events, customer satisfaction questionnaires (marketing purposes);
- carry out profiling or commercial segmentation activities to propose advertising offers in line with your interests and via email or other communication channels (profiling or segmentation for marketing purposes).
Profiling for marketing purposes is carried out using parameters so that you only receive commercial information relating to your interests. To do this, the Company will rely on the purchases made previously, on gender data (male/female), personal data (age groups), navigation data (for example if the User has searched for information on a particular product, the Company may ensure that the User receives information on identical or similar products).
The Personal Data collected could also be processed in the context of any corporate events (divestment of the Company or company branches), due diligence, in defence of a right in court or in relation to the related prodromal activities.
3) On what basis is your data processed?
Notwithstanding the legal obligations referred to in Paragraph 2, Letter a) (for example of a fiscal nature), the processing of your personal data, provided by you for the purposes referred to in Paragraph 2, Letter b), it is necessary to fulfil the obligations of the pre-contractual relationship you initiated when you submit the request for registration on the Site. Your refusal to provide data for this purpose will make it impossible to follow up on the requests you have made.
The processing of your personal data, provided by you for the purposes referred to in Paragraph 2, Letter c), constitutes an indispensable condition for the purpose of stipulating a contract with ADV Deal, as well as the management of the obligations that follow, such as those of a fiscal, accounting and administrative nature and any credit recovery activities. Your refusal to provide such data will make it impossible to enter into the contract with the Company.
The processing of your personal data collected for the purposes referred to in Paragraph 2, Letter d), is carried out on the basis of a legitimate interest of the Company, whose business is inevitably linked to the quality of the services offered by its Site and the experience of interaction with users and the satisfaction of their expectations.
The processing of your personal data, for the purposes referred to in Paragraph 2, Letter e), is optional, and is subject to the provision of your consent. Your refusal to provide such data will make it impossible for the Company to carry out marketing, market research or send you newsletters.
The processing of your personal data for the purposes referred to in Paragraph 2, Letter f) is optional, and is subject to the provision of your consent. Your refusal to provide such data will make it impossible to carry out the profiling activity of your interests. In any case, on the basis of its legitimate interest, the Company may carry out customer segmentation operations according to non-intrusive logic and criteria and in any case in such a way as not to affect the fundamental rights and freedoms of Users.
In the case of treatment in the context of any corporate events (sale of the Company or of company branches), due diligence, in defence of a right in court or in relation to the related prodromal activities, these treatments will be carried out on the basis of legitimate interests of the Company in the continuation of its commercial activities and for the protection of its rights.
4) How is your data processed?
The processing of personal data referred to in the previous points will be carried out both with the use of paper supports and with the aid of electronic and IT tools suitable for guaranteeing the data’s security and confidentiality.
5) Who do we communicate your data to?
Personal data may be disclosed by the Company solely and exclusively for the purposes indicated and where necessary, to the following categories of subjects:
service providers such as website hosting, data analytics, payment processing, order fulfillment, information technology and use of related infrastructure, customer service, email delivery, auditing and other services;
- consulting firms, law firms, accountants;
- parent companies and/or associated with the Company;
- where required, the relevant legal authorities;
- where required, public administrations and supervisory and control authorities.
Personal data will not, however, be disclosed to indeterminate subjects.
The Company, in its capacity as data controller, also reserves the right to transfer your personal data to third countries. Data transfers outside the European Economic Area are subject to a special regime pursuant to the Regulation, and are carried out only towards countries that ensure an adequate level of protection of personal data, based on an adequacy decision of the Commission, or where adequate guarantees have been adopted (including the standard contractual conditions provided by the European Commission), provided that the interested parties have enforceable rights and effective means of appeal.
6) How long do we keep your data?
Your data will be kept, in accordance with the provisions of relevant current legislation, for a period not exceeding that necessary to achieve the purposes for which they are processed. The criteria for determining the data retention period take into account the permitted processing period and the applicable laws on taxation, prescription of rights and legitimate interests that constitute the legal basis of the processing.
In relation to the processing for marketing purposes, in the absence of specific rules that provide for different storage times, the Company will use your data for the aforementioned marketing and profiling purposes for a reasonable time with respect to the interest expressed by you towards promotional initiatives and equal to 3 years. In any case, the Company will take every precaution to avoid the use of the data for an indefinite period, proceeding periodically to adequately verify the effective persistence of your interest in having the processing carried out for marketing purposes, as specified above.
Subsequently, the data will be deleted, aggregated or anonymised.
7) What are your rights?
The Regulation confers the exercise of specific rights, including those to ask the data controller:
- confirmation that a personal data processing is currently underway and, in this case, obtaining access (right of access);
- the correction of your inaccurate personal data, or the integration of your incomplete personal data (right of rectification);
- the cancellation of the data, in the presence of one of the reasons, provided for by Article 17 of the Regulation (right of cancellation);
- to limit the processing of their personal data, in the presence of one of the reasons provided for by Article 18 of the Regulation (right of limitation);
- to receive the personal data in a structured format, commonly used and readable by an automatic device, and to transmit them to another data controller (right to portability).
You have the right to withdraw consent to the processing of your personal data for marketing purposes and/or for profiling for marketing purposes, at any time, notwithstanding the lawfulness of the processing based on the consent given prior to revocation.
Furthermore, you have the right to object to the direct marketing activities carried out by the Company, including any profiling for marketing purposes.
To exercise your rights, you can write to ADV Deal Srl Via Amedeo Modigliani 41, 20090 Segrate MI or send an email to [•].
Pursuant to the Regulations, the Company is not authorised to charge costs to fulfil one of the requests set out in this paragraph, unless they are manifestly unfounded or excessive, and in particular, are repetitive. In cases where you request more than one copy of your personal data or in cases of excessive or unfounded requests, the Company may (i) charge a reasonable fee, taking into account the administrative costs incurred to process the request or (ii) refuse to satisfy the request. In these cases, the Company will inform you of the costs before processing the request.
The Company may request additional information before processing requests if it needs to verify the identity of the individual who submitted it.
Notwithstanding any other administrative or legal appeal, the User will also have the right to lodge a complaint with a Supervisory Authority (for Italy: the Guarantor for the protection of personal data), if they consider that the processing that concerns them is carried out in violation of the General Data Protection Regulation. Further information is available at http://www.garanteprivacy.it.
In any case, the Company is interested in being informed of any reasons for complaint and invites you to use the contact channels indicated above before referring to the supervisory authority, to prevent and resolve any disputes in a friendly and timely manner, with the utmost courtesy, seriousness and discretion.