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Privacy Policy

Privacy Policy

The purpose of this document is to inform the natural persons (hereinafter “Interested Party”) with relation to the treatment of their personal data (hereinafter “Personal Data”) collected by the holder of the treatment, VARIETY DISTRIBUTION S.R.L., registered office at Corso Trieste 42, 00198 Rome (Italy), Tac Code/VAT Code 15178651004, 1573114, e-mail sales@varietydistribution.it, (hereinafter “Holder”), through https://shop.varietydistribution.it/ (hereinafter  “Application”).

Any change and update shall be binding as soon as published on the Application. In case the changes brought to the Privacy Policy are not accepted, the Interested Party shall be required to cease use of this Application and shall be allowed to ask the Holder for deleting their Personal Data.

Categories of the treated Personal Data

The Holder treats the following types of Personal Data provided voluntarily by the Interested Party:

Contact Details: name, surname, address, e-mail, phone, images, authentication credentials, any further personal information provided by the Interested Party, etc.

The Holder treats the following types of Personal Data collected in an automated way:

Technical Data: Personal Data produced by the devices, applications, tools and protocols used, such as information on the device used, IP addresses, type of browser and Internet provider (ISP). This Personal Data can leave traces which, especially if combined with unique identifiers and other information received from the servers, can be used to create natural persons’profiles.

Browsing and Application usage data: data such as pages visited, click count, performed actions, duration of user sessions, etc.

Failure for the Interested Party to provide this Personal Data in compliance with a legal and contractual  obligation,  or because it is a needed requirement for entering the contract with the Holder, shall entail the Holder’s inability to establish or ccontinue the relationship with the Involve Party.

In case the Interested Party provides the Holder with Personal Data of a third party, the Interested Party shall be responsible for the source, collection, treatment, communication and dissemination of this data.

Cookie and similar technologies

The Application uses cookies, web beacons, unique identifiers and other similar technologies to collect Personal Data of the Interested Party, of visited web pages and other actions performed when the Interested Party uses the Application. This data is recorded in order to be provided again at the following visit of the Interested Party. The complete Cookie Policy is available at the following address: https://www.iubenda.com/privacy-policy/34463709/cookie-policy?an=no&s_ck=false&newmarkup=yes

 

Legal basis and purpose of the treatment

The treatment of the Personal Data is necessary

  • for the execution of the contract with the Interested Party and specifically:
    • fulfillment of any obligation deriving from the the pre-contractual or contractual relationship with the Interested Party
    • registration and authentication of the Interested Party: to let the Interested Party register with the Application, access and be identified even by external platforms
    • support and contact with the Interested Party: to respond to the Interested Party’s requests
    • payment management: to manage the payment by credit card, bank transfer or other means

 

  • for legal obligation and specifically:
    • the fulfillment of any obligation required by current legislation, laws and rules, in particular referring to tax and fiscal matters
  • on the basis of the legitimate interest of the Holder, for:
    • email marketing purposes related to the Holder’s products and/or services: to sell the Holder’s products or services directly using the email provided by the Interested Party in a sale context of a product or service similar to the one object of the sale
    • technical infrastructure management, optimization and monitoring: to identify and solve possible technical problems, to enhance the Application’s performances, to manage and organize the information in a computer system ( server, database, etc.)
    • security and anti-fraud: to guarantee the security of the Holder’s property, infrastructure and networks
    • statistics with anonymous data: to make statistical analysis on aggregated and anonymous data in order to analyse the Interested Party’s behaviours, to improve the products and/or the services provided by the Holder and better meet the Interested Party’s expectations
  • on the basis of the Interested Party’s consent, for:
    • profiling the Interested Party for marketing purposes: to provide the Interested Party with information about the Holder’s products and/or services through an automated treatment aimed at collecting personal information with the purpose of predicting or considering their preferences or behaviours
    • retargeting and remarketing: to reach through a customised advertisement the Interested Party who has already visited or has shown interest in the products and/or services offered by the Application, by using their Personal Data. The Interested Party can opt-out by visiting the Network Advertising Initiative
    • marketing purposes for the Holder’s products and/or services: to send commercial and/or promotional information and material, to conduct direct sales activities of the Holder’s products and/or services or to perform market research through traditional or automated procedures
    • communication of Personal Data for marketing purposes of third parties: to communicate Personal Data to third parties operating in the Entertainment sector in order for them to use it to send their commercial and/or promotional information and material or to conduct direct sales activities of their products and/or services or to perform market research through traditional or automated procedures
    • detection of the Interested Party’s exact position: to detect the Interested Party’s presence, accesses, times and position in a specific place, etc.

On the basis of the Holder’s legitimate interest, the Application allows to interact with external platforms or social networks whose Personal Data treatment is ruled by the respective privacy policies to which it is recommended to refer. The interactions and information acquired by this Application are in any case subject to the privacy settings that the Intereste Party has selected on these platforms or social networks. In case of absence of a specific consent to the treatment for further purposes, this information  shall be used with the only purpose of allowing the use of the Application and providing the information and the services required.

The Interested Party’s Personal Data can be also used by the Holder to protect itself against claims with the competent courts.

Treatment modalities and recipients of Personal Data

 

The treatment of Personal Data is processed on paper and through computerised systems with management procedures strictly related to the purposes mentioned and through the adoption of appropriate security measures.

The Personal Data shall be treated exclusively by:

  • people authorized by the Holder of the treatment of Personal Data who committed themselves to confidentiality or have an adequate legal obligation to confidentiality;
  • individuals operating autonomously as separate holders of the treatment or individuals appointed by the Holder as data processing managers in order complete all the treatment activities necessary to fulfil the purposes of this privacy policy (such as business partners, consultants, computer companies, service providers, hosting providers);
  • individuals or bodies that must acquire Personal Data in compliance with law or by order of authorities

The above mentioned parties are obliged to adopt the appropriate guarantees to protect the Personal Data and are allowed to access only the data necessary to perform the tasks  they are assigned.

The Personal Data shall not be discloded indiscriminately in any way.

Territory

Personal Data shall not be object of any transfer outside the territory of the European Economic Area (EEA).

Personal Data retention period

Personal Data shall be retained for the period of time required to fulfil the purposes for which it is collected, in particular:

  • for purposes related to the execution of the contract between the Holder and the Interested Party, the data shall be stored for the entire duration of the contractual relationship and, after expiry, for the ordinary limitation period of 10 years. In case of legal dispute, over the entire duration of it, until the expiry of the time limits of admissibility of appeal
  • for purposes related to the Holder’s legitimate interest, data shall be stored until the accomplishment of such interest
  • for the fulfilment of a legal obligation, for an authority’s order and protection in court, data shall be stored in compliance with the timing provided by such obligations, laws and in any case until the completion of the limitation period provided by the legislation in force
  • for purposes based on the Interested Party’s consent, data shall be stored until the withdrawal of consent. For marketing purposes for a period not exceeding 24 months.

At the end of the preservation period, all Personal Data shall be deleted or stored in a form which shall not allow the identification of the Intereste Party.

 

Interested Party’s Rights

The Interested Parties can exercise certain rights with reference to the Personal Data treated by the Holder. In particular, the Interested party shall have the right to:

  • be informed on the treatment of their own Personal Data
  • withdraw their consent any time
  • limit the treatment of their Personal Data
  • oppose the treatment of their Personal Data
  • access their Personal Data
  • verify and ask for correction of their Personal Data
  • obtain limitation of treatment of their Personal Data
  • obtain deletion of their Personal Data
  • transfer their Personal Data to another Holder
  • address a complaint to the control authority supervising protection of their Personal Data and/or engage in a judicial procedure.

To exercise their own rights, the Interested Parties can address a request to the following email address sales@varietydistribution.it. The requests shall be immediately taken over by the Holder and processed as soon as possible, in any case within 30 days.

Last updating: 21/03/2022