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Privacy Policy

 

 

 

This Privacy Policy  refers exclusively to the  PA.REO Site, and does not concern any third party website referred to within the pages of the Site.

 

  1. Which data we process:

  • With reference to the processing purpose indicated in point 2 below, Pa.Reo processes various types of personal data concerning you, including:

  • your identification data (such as name and surname), your contact details (such as email and telephone number), shipping address and billing address, payment data(such as the payment method used, the holder, the number of the card used). These data are processed with reference to the online sale of Pa.Reo products and the related activities connected to it (such as the conclusion and execution of the contract, the payment, the issuance of the invoice, the shipment of the product: any management of the right of withdrawal, return and legal guarantees: customer assistance, the control and prevention of fraud and abusive behaviour, even by third parties in conflict with current regulations, applicable contractual provisions, rules of fairness and good faith), as well as for the services offered through the Site and related to online sales (not active in all countries): return of products purchased online at Pa.Reo. For the customer assistance activity, thin formation you chose to provide in your communication is also processed.

  • In case of your registration on the Site (My Account), your identification data, your email address and your password, as well as the data necessary to provide you with the services reserved to the registered users.

  • Your identification and contract data are also used by Pa.reo to manage your requests for information relating to the products as well as to provide youth any online product booking service (requested by you and offered through the website).

  • Your geographical position, used by your consent by Pa.Reo for any service (requested by you and offered through the website).

  • Your identification and contact data may be processed when you have consented to receive, by telephone, email or other means, marketing communications from or on behalf of Pa.Reo, in compliance with this Privacy Policy.

  • Your name, surname and postal address, as well as any contact details (such as email address and telephone number) when a user of the Site provides us with your data to deliver certain products purchased on the Site. Your data is only processed to fulfil, at our user’s request and never for other purposes(for example marketing). When you provide us with third party personal data, you must do what is necessary so that the communication of the data to Pa.Reo and our subsequent processing for the purposes specified in this Privacy Policy takes place in compliance with the applicable legislation, for which, for example, before providing us with the personal data of third parties, you must inform them and obtain the consent to treatment when required.

Furthermore, when you browse the Site, data relating to your navigation is collected, in particular to verify the regular functioning  of the site to guarantee the best navigation and increase the quality of our services. For more information on the technology used (cookies and similar tools) you are invited to consult our cookie policy.

 

2.Why your data is processed and on what legal bases.

2.1 Purposes related to the online sale of products

Pa.Reo as data controller, processes your personal data for online sales Pa.Reo products and related activities. In particular for:

  • the conclusion and execution of the purchase contract of the Site of one or more products, for payment, shipment of the product, any management of the right of withdrawal, return and legal guarantee. this treatment is necessary for execution of a contract of which you are a part (purchase agreement). The provision of your personal data is mandatory; failing that, it will not be possible for you to make a purchase on the Site or manage any request relating to the right of withdrawal, return and legal guarantee to receive assistance dedicated to customers.

  • Customer support. The treatment is necessary for the execution of a contract of which you are part (supply of assistance). The provision of your personal data is mandatory, failing that you will not be able to make a purchase on the Site.

  • The prevention and repression of the fraud and abusive behaviour (also by third parties) in conflict with current regulations, the applicable contractual provisions, the rules of correctness and good faith. The lawfulness of this processing is based on the legitimate interest in carrying out security checks and activities for the purpose of prevention and protection against fraudulent activities and abusive behaviour. Upon your request, you will be provided with the information of detail on the aforementioned legitimate interesting on the related so called balancing test.

 

2.2 Marketing Purposes

 

With your consent, which is optional, Pa.Reo uses your personal data for marketing purposes. In fact Pa.Reo will be able to send you promotions, commercial or advertising communications about its products, services and events. Marketing activities may include carrying out market research and surveys to measure your satisfaction or to carryout statistical analysis, even with anonymous data organised in aggregated form. The processing of your data is based on your freely expressed consent and the provision of your data is optional, in case of refusal. In fact, there will be no consequences on the possibility purchasing our products. With your consent, which is optional, Pa.Reo uses the data collected online, through this Site, to collect information relating to your preferences, habits, lifestyle as well as the details of the purchases made. The data is used for creation of group/individuals profiles(profiling) which allows us to send you personalised communications and in line with your interests, or to carry out market research statistical analysis, even with anonymous data, organised in aggregate form. The processes of your data is based on your freely expressed consent and the provision of your data is optional, in case of refusal, in fact, there will be no consequences on the possibility on the possibility to purchasing our products online.

To send you marketing communications or personalised offers, channels such as email, newsletters, telephone calls via operator , SMS, MMS, chat, instant messaging, social networks and traditional mail are used, including sending invitations to events organised by Pa.Reo or to which Pa.Reo participates. You can unsubscribe from the newsletters through the appropriate section of your personal account or by clicking on the relevant link at the bottom of each commercial communication.

 

2.3 Additional Purposes

 

Your personal data are processed by the owner, as far as he is responsible also of

  • the management of requests to exercise rights regarding the protection of personal data (more information at point 6). This processing is necessary to fulfil a legal obligation to which the controller is bound.

  • other obligations regarding the protection of personal data. Under certain circumstances, the legislation on the protection of personal data obliges the data controller to use your data details to provide you with specific information on the processing of your data such as, for example, to inform you of any security breaches that have affected your data, and of the measures taken to deal with it(so called data breach), as well as to communicate any significant updates to this privacy statement. this treatment is, therefore, necessary to fulfil a legal obligation to which the data controller is bound.

 

3. Who will process your data.

 

Your personal data may be processed by Pa.Reo personnel (collaborators) who offer a suitable guarantee of compliance with the rules of the processing of personal data.

Furthermore your personal data may be disclosed to third parties in the following cases:

  • when the communication is required by applicable laws and regulations with respect to legitimate third parties recipients of communications, such as authorities and public bodies that process your data as independent data controllers for their respective institutional purposes

  • In the event of extraordinary transactions

You can request the uploaded list to whom you communicate your data by contacting us at the Site email address.

 

4. How long your data is stored.

 

We keep your personal data for a limited period of time, strictly related to the purpose for which it was collected and in compliance with applicable legal or regulatory obligations. At the end of the retention period established, your personal data will be irreversibly deleted or, in any case, rendered anonymous, except in the case in which Pa.Reo is required to keep your data for a further period to fulfil legal or regulatory obligations or to exercise or defend a right in court.

The retention period is different depending upon the purpose of the processing, in particular:

  • for the online sale of products and the related activities connected to it (point2.1), your personal data will be kept for the entire duration of the contractual relationship and for ten years after the termination of the same, except for the registration to the Site (my account) and the use of service reserved for registered users, in relation to which your personal data will be kept until you request cancellation of your account; for profiling or personalised marketing  purposes, your data is kept for a period of seven years from the time you give your consent for the aforementioned purposes, following the impact assessment on data protection conducted by Pa.Reo, with the participation of our Data Protection Officer;

  • for generic marketing activities, your data is kept by Pa.Reo until the request of cancellation, withdrawal of consent or opposition to the processing; Pa.reo also wants to protect your data and make sure you want to continue to receive its communications, therefore it deletes your data when four years are passed since your last interaction with the Pa.Reo site.

  • to fulfil the legal obligations regarding the processing of personal data (point2.4), your personal data will be processed by each owner, to the extent of their competence, for the period necessary to manage your request to exercise the rights recognised  by the GDPR or to fulfil a legal obligation the data controller is bound. The data necessary to demonstrate compliance with the legal obligations to which the owner is bound will be kept for ten years;

  • In the event of a judicial or administrative dispute, your data will be kept for the period necessary for Pa.Reo or a third party  to protect a  right in court or within the limits imposed by the judicial or administrative authority.

 

 

5. What are your rights

 

You can contact each data controller or the respective Data Protection Officer to exercise your rights recognised by the GDPR and, in particular:

  • have confirmation as to whether or not personal data concerning you is being processed and, if so, to obtain access to and a copy of such personal data (“right of access”);

  • rectification of your personal data, i.e. to obtain the correction, modification or updating of any inaccurate or no longer correct data as wells to obtain the integration of incomplete personal data, also by providing a supplementary declaration(“right of rectification”);

  • withdraw your consent(r”right to withdraw consent”): you can withdraw in at any time the consent you have given for the processing of your personal data, also in relation to any activity for marketing purposes, including profiling. In this regard, sending  commercial and promotional communications, the carrying out of market research and surveys to measure satisfaction and personalisation of commercials offers based on your interest are considered marketing activities. Upon receipt of your request, it will be the owners responsibility to promptly cease the processing of your data based on this consent while different treatments on other assumption will continue to be carried out in full compliance with the provisions in force.

  • request the deletion of your personal data when these, in particular, they are no longer necessary with respect for the purposes for which they were collect or processed, or they have been processed unlawfully, or they must be cancelled to fulfil a legal obligation, or finally, you oppose their treatment (see below “right of opposition”) and there is no prevailing legitimate reason which allows the owner to proceed with the treatment in any case (“right of cancellation” or “right to be forgotten”).

  • obtain the limitation of the processing of your personal data, i.e. that the owner keeps such data without being able to use them without prejudice to any requests and the exceptions provided by law. This right can be exercised only when, in particular, you dispute the accuracy of the personal data, for the period necessary for the owner to verify the accuracy of such personal data, or the data processing is unlawful and you request the limitation of their use, rather than cancellation, or although the owner no longer needs them for processing purposes, the personal data are necessary for you to ascertain, exercise or defend a right in court, or you have objected to the processing (see “right to object” below), pending verification of whether the legitimate reasons of the owner prevail over those of the interested party (right to limitation).

  • request your data or transfer it to a person other than the owner (“right to data portability”). you can request to receive the data processed the basis of your consent or on the basis of a contract stipulated with you, in a structured format, commonly used and readable by an automatic device. If you wish, where technically possible, we will be able to transfer your data at your request directly to a third party indicted by you;

  • forward a complain to the competent supervisory authorities for compliance with the rules of the protection of personal data, if you believe that the processing your personal data has been carried out unlawfully (“right to lodge a complain”). In Italy the complain can be presented to “Garante per la Protezione dei Dati Personali (http://garanteprivacy.it). Furthermore, as an interested party, you have the “right of opposition”i.e.

  • object, at any time, for reasons connected to your particular situation, to the processing of your personal data carried out for the pursuit of a legitimate interest of the owner or for marketing purposes. The owner will refrain from further processing your personal data unless the owner demonstrates the existence of compelling legitimate reasons to proceed with the processing, which prevail over the interests, right and freedom of the interested party, or for the assessment, exercise or defence of a right in court. To ensure full compliance with the right described above and that the data of our users are not subject to violations and illegitimate access by third parties, before accepting your request to exercise one of the right indicated, we may ask you for some information to ascertain your identity or for clarification of the request..

 

6. Changes to the Privacy Policy

 

The features, functions and services offered by the Site may undergo changes in the future, consequently this Privacy Policy may undergo changes and additions over time. You are therefore invited to periodically check the contents.You will be promptly notified of any significant changes made to this Privacy Policy.

 

8. Data Security

 

Pa.Reo adopts specific technical and organisational security measures in order to safeguard the confidentiality of the personal data of the Site users and to prevent their personal data from being used illegitimately or fraudulently.

You are invited to take precautions in using the Site, such as keeping your login credentials strictly confidential or changing them periodically.

Contact details of the data controller responsible for Pa.Reo Site is Paola Antonia Reoli and is available at paolareoli@gmail.com

For any clarification, question or requirement related to your privacy or to exercise your right recognised by GDPR (see point 5) you can contact us by sending a request to the email paolareoli@gmail.com

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