THE HOLDER OF THE TREATMENT Following consultation of this Site, data relating to identified or identifiable persons may be processed. The data controller is Bros S.r.l. with registered and administrative office in Via degli Acaya 2, 73100 Lecce (LE).
RESPONSIBLE FOR THE PROTECTION OF PERSONAL DATA
Contact details of the Data Protection Officer. The Company has appointed Andrea Buccoliero as the Data Protection Officer. You can be contacted by writing to: email@example.com
PLACE OF DATA PROCESSING
The processing operations connected to the web services of this Site take place at the administrative and tax office of the company Bros s.r.l., or in via degli Acaya 2, 73100 Lecce (LE).
OPTIONAL PROVISION OF DATA
The User is free to provide the personal data necessary in order to execute his specific requests. Personal data means any information relating to a person that allows the identification of such a person, such as his name, telephone number, e-mail and postal address, etc. Failure to provide such data may make it impossible to obtain what is requested.
TYPE OF DATA PROCESSED AND PURPOSE OF THE TREATMENT
a) in order to allow Bros to fulfill its contractual obligations, in the event of a purchase order being made;
b) for post-sales assistance;
c) other personal data requested are optional (such as a landline phone number, mobile phone number, etc.) but if provided, they will allow the interested party to be contacted for service communications related to his order, to verify his satisfaction with the products, or, with your consent, will allow you to propose commercial offers, also based on the detection of your personal consumption preferences, commercial information on the products and news of Bros, promotional offers, also through marketing activities carried out in automated mode, by ordinary mail , via SMS / MMS, by landline and / or mobile and also to the e-mail address provided.
The data of third parties
In the area of the Site dedicated to the purchase of Bros products, the User can be given the possibility to send the purchased products to third parties; in this case the User is required to indicate the personal details and the complete postal address of the recipient, to whom the chosen products should be sent.
Data storage and access
The personal data processed are also processed through the creation of a centralized database, with IT and electronic tools. The database, containing the personal data of the interested parties, is accessible only by the authorized parties. Individuals specifically appointed as employees or other collaborators may become aware of the data in the treatments necessary or connected to the sending of advertising material and to the execution of the order and, if necessary, third-party suppliers of services strictly functional to the execution of the contractual relationship, such as: a) data entry, personalization and mailing company;
b) call center;
c) carriers for the delivery of the package;
d) companies that provide payment services;
e) central offices of supervisory institutions.
Specific instructions regarding the processing of data are given to each respionsible. Bros s.r.l. confirmation that any personal data communicated by the interested party is not intended for purposes other than those indicated here.
Data retention period based on purpose The personal data of each interested party are kept for the time strictly necessary to carry out those processing operations carried out in relation to each interested party, depending on his choices, preferences and indications. The storage of personal data for the purposes of direct marketing purposes relates to a maximum period of 24 months.
The personal data, subject to profiling treatment, for this purpose are used for 12 months. Personal data related to contractual relationships with Bros.’s customers are kept in accordance with the law for civil, fiscal, accounting, administrative purposes, to make possible means of proof in the event of litigation and to meet specific requests by the competent Authority.
Bros uses user data, in accordance with their free consent only in the presence of an express authorization from the User, Bros proceeds to use its data. It clarifies that user data is controlled by the User, through communication and public communication techniques for sending advertising material, for carrying out direct sales activities, marketing research or commercial communication. Exactly like, an exit front of the User, Bros you can send to the User customized offers based on his consumption habits. The data have been communicated to the sector companies: home and office furniture, textiles, clothing, cosmetics and wellness, floriculture, publishing, hobby and generalists for marketing purpose.
From the applicability of the GDPR. The legal basis of the processing is constituted by the obligations arising towards the Interested party as part of the contractual relationship of sale (“treatment necessary for the execution of a contract” – GDPR Article 6, paragraph 1, letter b)); for treatments for direct marketing purposes, the legal basis is the legitimate interest of the company (“treatment necessary to pursue a legitimate interest of the data controller” GDPR art. 6, paragraph 1, letter f) and “Can be considered legitimate interest to process personal data for direct marketing purposes “Cons. n. 47); for all other treatments performed by the Data Controller, the legal basis is the consent of the interested party (RGPD art. 6, paragraph 1, letter a)).
Users’ data are never disclosed, with the exception of those that the User voluntarily makes available on any publicly accessible areas of the site. Bros invites Users not to provide special categories of personal data (ex sensitive data) within the site, reserving the right to delete such data or make it anonymous according to the protection directives contained in art. 9 of the GDPR 2017/679. The data can, finally, be communicated to the public authority in the presence of a legitimate order given by the same and eventually could be used to ascertain responsibility in case of hypothetical information crimes against the Site. SAFETY
Security is the fundamental technical element for the protection of the right to the protection of personal data, it is clear that the setting of security measures must be considered as an obligation for the Data Controller.
Specific security measures are observed to prevent the loss of data, illicit use, unauthorized access or processing that is not permitted or does not comply with the purposes of collection.
Bros is aware that the Site and the Services could interest a minor public. Bros encourages parents to monitor their children’s use of the Internet, for safe and filtered use of its contents, including through the use of parental control tools. In addition to guaranteeing an online environment suitable for minors, these tools can prevent the disclosure of personal data by children or young people who do not have the consent of their parents. For children under 18 years. Are you a minor but are you already 16? Bros, starting from May 25th 2018, will be happy to accept your orders made on the Site. Your personal data collected in this way (name, surname, address, date of birth) will be processed only for all purposes related to the order fulfillment product delivery; will not be communicated to other companies nor will any profiling treatment be done. The newsletter will be sent to you if you have requested it and other commercial communications as well, but you can unsubscribe at any time through the relative function. For any clarification on the processing of your data, do not hesitate to contact us: firstname.lastname@example.org.
RIGHTS OF THE INTERESTED PARTIES
All changes to the Website Policy will be published in this document.