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Privacy Policy
1. Introduction
This privacy policy tells you how the VA.ZI.
ITALIA SAS group of companies use your personal data when you visit our
website WWW.ITALICUM.IT®, interact with us, and buy our goods and
services.
It also tells you about your privacy rights and how the law protects you.
It
is important that you read this privacy policy, together with any other
privacy policies we may provide, so that you are fully aware of how and
why we are using your data.
This privacy policy was last updated on 16th of May 2018 and historic versions can be obtained by contacting us.
If
you have any questions, or would like to exercise your privacy rights,
please follow the instructions in this privacy policy. See How to
contact VA.ZI. ITALIA S.A.S. about privacy below.
2. Our website www.italicum.it and the VA.ZI. ITALIA SAS group of companies?
Our
website at www.italicum.it sells typical food product and accessoires,
not every service. This website is not intended for children and we do
not knowingly collect data relating to children.
ITALICUM.IT® is made up of one legal entities:
VA.ZI. ITALIA S.A.S. - Palermo 90147 - Piazza Tommaso Natale, 117 (ITALY)
VA.ZI.
ITALIA S.A.S is the data controller responsible for this website and
any handling of personal data carried out by or on behalf of VA.ZI.
ITALIA S.A.S.
3. Personal data which we collect about you
Personal
data, or personal information, means any information about an
individual from which that person can be identified. It does not include
data where the identity has been removed (anonymous data).
We collect a variety of information about our Customers (you!) and visitors to the ITALICUM.IT® website.
This personal data falls into these categories:
Identity
Data includes title, first name, last name, username or similar
identifier and an encrypted version of your login/password. If you
interact with us through social media, this may include your social
media user name.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes payment card details.
Transaction
Data includes details about payments to and from you and other details
of products and services you have purchased from us.
Profile Data
includes your username and password, purchases or orders made by you,
preferences, feedback and survey responses, as well as any profile data
which we have added (for example, using analytics and profiling).
Technical
Data includes internet protocol (IP) address, your login data, browser
type and version, time zone setting and location, browser plug-in types
and versions, operating system and platform and other technology on the
devices you use to access this website.
Usage Data includes information about how you use our website, products and services.
Tracking
Data includes information we or others collect about you from cookies
and similar tracking technologies, such as web beacons, pixels, and
mobile identifiers.
Marketing and Communications Data includes your
preferences in receiving direct marketing from us and our third parties
and your communication preferences
We also collect, use and share
Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data may be derived from your personal data but is not
considered personal data in law as this data does not directly or
indirectly reveal your identity. For example, we may aggregate your
Usage Data to calculate the percentage of users accessing a specific
website feature. To provide better content and service, ITALICUM.IT®’s
website uses the Google Analytics service. Google Analytics records
mouse actions and scrolling movement, as well as basic interactions with
website forms. Google Analytics does not track your browsing habits
across other third-party websites and all information about you which
reaches Google Analytics contains no personal data about you.
However,
if we combine or connect Aggregated Data with your personal data so
that it can directly or indirectly identify you, we treat the combined
data as personal data which will be used in accordance with this privacy
policy.
We do not collect any Special Categories of Personal Data
about you (this includes details about your race or ethnicity, religious
or philosophical beliefs, sex life, sexual orientation, political
opinions, trade union membership, information about your health and
genetic and biometric data). Nor do we collect any information about
criminal convictions and offences. If you use any of these types of
personal data on products you design or create on moo.com, we will not
be able to tell. We will treat all the personal data included in designs
or products as ordinary personal data.
Remember, if you choose not
to share personal data with us, or refuse certain contact permissions,
we might not be able to provide the products and services you’ve asked
for.
4. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct
interactions. You may give us your Identity, Contact and Financial Data
by filling in forms or by corresponding with us by post, phone, email
or through chat or social media.
This includes personal data you provide when you:
sign up to receive the ITALICUMsletter;
make enquiries or request information be sent to you;
create an account on our website;
create designs for products on our website;
order our products or services;
ask for marketing to be sent to you;
engage with us on social media;
enter a competition, promotion or survey;
contact customer services; or
leave comments or reviews on our products or services (please be kind!).
Automated
technologies or interactions. As you interact with us, including via
the ITALICUM.IT® website, we may automatically collect Technical Data
about your equipment, browsing actions and patterns. We may also collect
Tracking Data when you use our website, or when you click on one of our
adverts (including those shown on third party websites).
Third
parties or publicly available sources. We may receive personal data
about you from various types of third parties, including:
Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers;
Contact, Financial and Transaction Data from providers of payment and fraud prevention services;
Identity and Contact Data from data partners; and
Data
from any third parties who are permitted by law or have your permission
to share your personal data with us, such as via social media or review
sites We will only use your personal data when the law allows us to.
Most commonly, we will use your personal data in the following
circumstances:
5. How we use your personal data
Where
we need to perform the contract we are about to enter into or have
entered into with you. For example, when you purchase our products,
that’s a contract.
Where it is necessary for our legitimate
interests (or those of a third party) and your interests and fundamental
rights do not override those interests. For example, when we carry out
fraud screening as part of the check-out process.
Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.
Generally,
we do not rely on consent as a legal basis for processing your personal
data other than where the law requires it, for example in relation to
sending certain direct marketing communications. Where our legal basis
is consent, you have the right to withdraw consent any time.
See
Explaining the legal bases we rely on to process personal data to find
out more about the types of lawful basis that we will rely on to process
your personal data.
6. Explaining the legal bases we rely on to process personal data
We have also identified what our legitimate interests are where appropriate.
Note
that we may process your personal data for more than one lawful ground
depending on the specific purpose for which we are using your data.
We do not carry out any automated decision making.
If you ever have any questions about this, all you have to do is ask. See How to contact ITALICUM.IT® about privacy below.
7. Advertising, marketing and your communications preferences
We
may use your Identity, Contact, Technical, Tracking, Usage and Profile
Data to form a picture of what we think you may want or need, or what
may be of interest to you. This is how we decide which products,
services and offers may be relevant for you and tell you about them.
This is what we call direct marketing.
We may carry out direct
marketing by email, phone, text or post. For example, you might have the
ITALICUM.IT®sletter hit your inbox or a cool promotion land on your
door mat.
On our website, we always try hard to make it really clear
what we are doing and what communications you will be sent, whether it’s
you deciding to sign up to the MOOsletter or as part of creating an
account or the purchase journey – and you have a right at any time to
change your mind and say no thank you and opt out (but we’d be really
sorry to see you go, so please gives us a chance by fine tuning your
preferences before really leaving us!). The easiest way to opt out is to
use the unsubscribe link at the bottom of the communication.
Of
course, there are lots of different ways you’ll see adverts for
ITALICUM.IT® out and about, and not all of these are based on using
personal data – sometimes we just buy good old-fashioned advertising
space in the real world and websites and social media. If you see
ITALICUM.IT®’s adverts on websites and in social media, these may not be
directed specifically at you, we might just have bid for the space. But
here’s some things we may do that may be specifically directed at you:
emails, for example the ITALICUM.IT® sletter;
text messages, for example with discount codes;
promotions by post, such as great money off shipping offers, or from our trusted retail partners; and/or
phone calls, to tell you something that might be relevant to you and your business.
We
also work with partners to try and promote the reach of our adverts and
use analytics and retargeting for this reason. We use Tracking Data to
deliver relevant online advertising, including via websites and social
media.
Tracking Data, and in particular cookies, help us to deliver
website and social advertising that we believe is most relevant to you
and to potential new customers of ITALICUM.IT®. The cookies used for
this purpose are often placed on our website by specialist organisations
– and this is also why when you’ve been on the moo.com website, you
might see that lovely business card design again. This includes
retargeting.
Cookies can also tell us if you have seen a specific
advert, and how long it has been since you have seen it. This is
helpful, because it means we can control the effectiveness of our
adverts and control the number of times people might be shown our
adverts (you know, before we risk become annoying). Cookies also help us
understand if you’ve opened a marketing email because we don’t want to
send you things you don’t read.
8. Cookies
You can see from Advertising, marketing and your communications preferences above, that cookies are a tool which we (and everyone one else who operates online) uses for advertising. That is just part of why cookies are used. Generally, they are pretty clever.
Cookies help ITALICUM.IT® work better and provide lots of help in the background to make the process of being a moo.com customer a lot easier. You’d miss a lot of these things if they were gone – like it being easy to log in and move from page to page, and things staying in your cart while you go off and look at other pages.
Other cookies collect information about how visitors use moo.com, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is aggregated and used to improve how moo.com works.
There are also cookies that allow moo.com to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
There are cookies that collect information about your browsing habits in order to make advertising delivered to you more relevant to you and your interests (see Advertising, marketing and your communications preferences above). They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
When you use ITALICUM.IT®, your device or browser may be sent cookies from third parties, for example when using embedded content and social network links. It's important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.
We’ve also included links to the third-party websites where you can go to find out more.
9. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows it.
We may share personal data with the following categories third parties:
Suppliers and service providers (such as technology service providers, payment processing and fraud prevention providers, manufacturers and post and courier services);
auditors and professional advisers like bankers, lawyers, accountants and insurers; and
government, regulators and law enforcement.
We also share data with third parties connected to advertising, retargeting and analytics. Please see Cookies above, including the cookie list, for more information about who those third parties are.
We may also share data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
10. Payment information
ITALICUM.IT® uses third party payment processors PayPal to process payments made for products and services via the ITALICUM.IT® Website. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards (which are high!) and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them. Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors - ITALICUM.IT® and VA.ZI. ITALIA SAS never (ever!) sees your full Permanent Account Number (PAN). This means that the payment form is either off-site or displayed in a frame on the payment page.
11. International transfers
Whenever we transfer your personal data out of the EEA, we will comply with applicable data protection law. Some of the mechanisms we may choose to use when undertaking an international transfer are:
The transfer of your personal data is to a country that has officially been deemed to provide an adequate level of protection for personal data by the European Commission.
We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (called the “EU Model Clauses”).
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. If the provider is not EU-US Privacy Shield certified, we may use the EU Model Clauses.
We share your personal data within the VA.ZI. ITALIA SAS Group, which will involve transferring your data outside the European Economic Area. We do this using the EU Model Clauses.
12. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
13. Third-party links
You can see from Advertising, marketing and your communications preferences above, that cookies are a tool which we (and everyone one else who operates online) uses for advertising. That is just part of why cookies are used. Generally, they are pretty clever.
Cookies help ITALICUM.IT® work better and provide lots of help in the background to make the process of being a moo.com customer a lot easier. You’d miss a lot of these things if they were gone – like it being easy to log in and move from page to page, and things staying in your cart while you go off and look at other pages.
Other cookies collect information about how visitors use moo.com, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is aggregated and used to improve how moo.com works.
There are also cookies that allow moo.com to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
There are cookies that collect information about your browsing habits in order to make advertising delivered to you more relevant to you and your interests (see Advertising, marketing and your communications preferences above). They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
When you use ITALICUM.IT®, your device or browser may be sent cookies from third parties, for example when using embedded content and social network links. It's important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.
We’ve also included links to the third-party websites where you can go to find out more.
You
can set your browser to refuse all or some browser cookies, or to alert
you when websites set or access cookies. If you disable or refuse
cookies, please note that some parts of this website may become
inaccessible or not function properly.
We may share your personal data with the parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows it.
We may share personal data with the following categories third parties:
Suppliers and service providers (such as technology service providers, payment processing and fraud prevention providers, manufacturers and post and courier services);
auditors and professional advisers like bankers, lawyers, accountants and insurers; and
government, regulators and law enforcement.
We also share data with third parties connected to advertising, retargeting and analytics. Please see Cookies above, including the cookie list, for more information about who those third parties are.
We may also share data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require
all third parties to respect the security of your personal data and to
treat it in accordance with the law. We do not allow our third-party
service providers to use your personal data for their own purposes and
only permit them to process your personal data for specified purposes
and in accordance with our instructions.
ITALICUM.IT® uses third party payment processors PayPal to process payments made for products and services via the ITALICUM.IT® Website. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards (which are high!) and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them. Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors - ITALICUM.IT® and VA.ZI. ITALIA SAS never (ever!) sees your full Permanent Account Number (PAN). This means that the payment form is either off-site or displayed in a frame on the payment page.
For
PayPal we only store the tokens required to identify the transaction
with PayPal, issue refunds and identify transactions made using PayPal.
Whenever we transfer your personal data out of the EEA, we will comply with applicable data protection law. Some of the mechanisms we may choose to use when undertaking an international transfer are:
The transfer of your personal data is to a country that has officially been deemed to provide an adequate level of protection for personal data by the European Commission.
We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (called the “EU Model Clauses”).
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. If the provider is not EU-US Privacy Shield certified, we may use the EU Model Clauses.
We share your personal data within the VA.ZI. ITALIA SAS Group, which will involve transferring your data outside the European Economic Area. We do this using the EU Model Clauses.
Many of our external
third-party providers are based outside the EEA, so their processing of
your personal data will involve a transfer of data outside the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with
any suspected personal data breach and will notify you and any
applicable regulator of a breach where we are legally required to do so.
This
website may include links to third-party websites, plug-ins and
applications (for example, the ability to sign in with Facebook,
Twitter, Google+, Pinterest, Linkedin). Clicking on those links or
enabling those connections may allow third parties to collect or share
data about you. We do not control these third-party websites and are not
responsible for their privacy statements. When you leave our website,
we encourage you to read the privacy policy of every website you visit.
14. Data retention
We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers for tax purposes.
We also make a promise to you that you can come back at any time in the future and re-print products you have ordered from us in the past. So, unless you actively delete this information, we keep it, so we can keep our promise to you.
In some circumstances you can ask us to delete your data; see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers for tax purposes.
We also make a promise to you that you can come back at any time in the future and re-print products you have ordered from us in the past. So, unless you actively delete this information, we keep it, so we can keep our promise to you.
In some circumstances you can ask us to delete your data; see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
15. Your legal rights
If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:
The right to be informed – that’s an obligation on us to inform you how we use your personal data (and that’s what we’re doing that in this privacy policy);
The right of access – that’s a right to make what’s known as a ‘data subject access request’ for copy of the personal data we hold about you;
The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate;
The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);
The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data;
The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making.
These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner’s Office website.
If you wish to exercise any of the rights set out above, please contact us (see How to contact ITALICUM.IT® about privacy).
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details in How to contact ITALICUM.IT® about privacy below.
You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:
The right to be informed – that’s an obligation on us to inform you how we use your personal data (and that’s what we’re doing that in this privacy policy);
The right of access – that’s a right to make what’s known as a ‘data subject access request’ for copy of the personal data we hold about you;
The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate;
The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);
The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data;
The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making.
These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner’s Office website.
If you wish to exercise any of the rights set out above, please contact us (see How to contact ITALICUM.IT® about privacy).
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details in How to contact ITALICUM.IT® about privacy below.
You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
16. How to contact ITALICUM.IT® about privacy
If you have any questions about this privacy policy, or would like to exercise any of your rights, please email us at [email protected] or write to us with your letter addressed to: Data Privacy Manager, VA.ZI. ITALIA SAS - Palermo 90147 Piazza Tommaso Natale, 117 (Italy)
If you need help about our products and services, or this website generally, please contact us on [email protected]
If you have any questions about this privacy policy, or would like to exercise any of your rights, please email us at [email protected] or write to us with your letter addressed to: Data Privacy Manager, VA.ZI. ITALIA SAS - Palermo 90147 Piazza Tommaso Natale, 117 (Italy)
If you need help about our products and services, or this website generally, please contact us on [email protected]
17. A little request from ITALICUM.IT® to you
It
is important that the personal data we hold about you is accurate and
current. Please keep us informed if your personal data changes during
your relationship with us. You can do this by updating your account.
Thank you.