Privacy Policy Statement for Users

Privacy Policy Statement for Users

PREMISE: THE ROLE OF ANNOVI REVERBERI S.P.A. AND T-DATA S.R.L. IN THE PROCESSING OF PERSONAL DATA COLLECTED VIA THE WWW.ARXP.COM WEBSITE

The following privacy policy statement is addressed to all purchasers on the www.arxp.com e-commerce website. The proprietor of the website is ANNOVI REVERBERI S.P.A. (“ANNOVI REVERBERI”). The Website is managed, under mandate from ANNOVI REVERBERI, by T-DATA S.R.L. (“T-DATA”), which sells the “ARXP” brand products offered for sale on the website.

T-DATA S.R.L. manages the sales and transactions carried out via the Website (e.g. management of orders, sale and delivery of products, management of returns and the legal warranty, and other activities necessary for the sale of the products via the website). ANNOVI REVERBERI supplies the services which enable access to, browsing of and registration on the website. ANNOVI REVERBERI S.P.A. and T-DATA S.R.L. will use the personal data you contribute when you register on the website and for the conclusion of the purchase contract through the Website, respectively, as independent data controllers (each an “Independent Data Controller” and jointly “Independent Data Controllers”) in accordance with the provisions of Regulation (EU) 679/2016 (the “Regulation”) and Italian Legislative Decree no. 196 of 30 June 2003 (the “Data Protection Code”), as amended.

In particular:

- ANNOVI REVERBERI will process your personal data, as Independent Data Controller, in order to manage access to the Website’s services, to facilitate the online purchase of the products, to enable you to register on the Website and to conclude the purchase contract via the Website and, with your consent, for marketing purposes;

- T-DATA will process your personal data, as Independent Data Controller, to enable you to conclude the purchase contract, for performance of the obligations arising from the contract itself, for fulfilment of all legal, (including fiscal and bureaucratic) obligations relating to the contract and for other purposes related to the said contract and/or the performance of pre-contractual measures, as described in this privacy policy statement;

This privacy policy statement is thus only issued with regard to the processing performed by ANNOVI REVERBERI in its capacity as Independent Data Controller.

1. Data Controller

Annovi Reverberi with registered office at Via Martin Luther King, 3 41122 Modena, VAT number 02207040367 (hereinafter, “Data Controller”), proprietor of the Internet site https://www.arxp.com (hereinafter, the “Website”), in the capacity of independent data controller with regard to the personal data of users who browse and register on the Website (hereinafter the “Users”) hereinafter provides a privacy policy statement pursuant to art. 13 of Regulation (EU) 2016/679 of 27 April 2016 (hereinafter the “Regulation” or “Applicable Law”).

The Data Controller gives the greatest consideration to its Users’ right to privacy and the protection of their personal data. For any information with regard to this privacy policy statement and to exercise their rights, Users may contact the Data Controller at any time by the following means:

• By sending a registered letter with return receipt to the Data Controller’s registered office
• By sending an email to privacy@annovireverberi.it.

1. Purposes of processing

Users’ personal data will be lawfully processed by the Data Controller in accordance with art. 6 of the Regulation for the following processing purposes: 

1. Browsing the Website, with regard to the possible acquisition of Users’ data necessary for technical purposes, such as their IP address, during browsing of the website;
2. Replying to queries which we have received via the contact form provided;
3. Registration on the reserved area of the website;
4. Legal obligations, meaning for compliance with obligations enforced by law, an authority, a regulation or the European regulatory framework;
5. Registration for the extended warranty, for products purchased both via this e-commerce Website and/or from dealers and physical points of sale. Users’ first name, family name, country, email address, product serial number and product date of purchase will be requested for the provision of this service.

The contribution of personal data for the above purposes of processing is optional but necessary, since in case of failure to contribute them the User will be unable to browse or register on the Website, or to use the services offered by the Data Controller on the Website.

1. Additional processing purposes: marketing and newsletters (dispatch of advertising material, direct sale and marketing communications)

With the User’s freely given, optional consent, the Data Controller may also process some of the User’s personal data (first name and family name, email address, complete shipping address, etc.) for marketing and newsletter purposes (dispatch of advertising material, direct sale, marketing communications, dispatch of newsletters containing information regarding news of relevance to the Site’s sector of business) or to enable the Data Controller to contact the User via post, email, telephone (landline and/or mobile, with automated call systems or call notifications with and/or without an operator) and/or text messages to offer the User the purchase of products and/or services provided by the Data Controller itself and/or third-party companies, and to submit offers, special offers and commercial opportunities. Users’ ability to register on and browse the Website will be in no way affected if they fail to agree.

If they agree, Users may withdraw their consent at any time by applying to the Data Controller by the procedures set out in point 7 below.

Users may also easily object to further emailing of marketing communications and newsletters by clicking the “unsubscribe” link provided in every marketing and newsletter email. Any User who wishes to withdraw their consent to telephone marketing but still to receive email marketing, or vice-versa, is kindly requested to notify the Data Controller by the procedures set out in point 7 below.

For technical and operational reasons (e.g. preparation of contact lists already completed just before the Data Controller receives the unsubscribe request), Users may still continue to receive some additional marketing messages and newsletters after they have exercised their right to object to the emailing of marketing communications and newsletters. Any User who continues to receive marketing and newsletter messages 72 hours after exercising the right to object is kindly requested to report the problem to the Data Controller using the contacts provided in point 7 below.

1. Legal basis of processing

With reference to the purposes covered by points 2.a, 2.b, 2.c e 2.e, the legal basis for processing is the performance of services provided via the Website which you have requested (in accordance with article 6, para 1, point b of the Data Protection Regulation 2016/679); with reference to the purpose covered by point 2.d of the previous section, the legal basis of processing is the fulfilment of a legal obligation of the Data Controller (pursuant to article 6, para 1, point c of the Data Protection Regulation 2016/679). With regard to the purpose covered by point 3, the legal basis is your freely given consent (pursuant to art. 6, para 1, point a of the Data Protection Regulation 2016/679).

1.  Data processing procedures and data storage times

The Data Controller will process Users’ personal data by means of manual or IT tools, by procedures in strict compliance with the stated purposes, and in all cases in such a manner as to guarantee the security and confidentiality of the data. Website Users’ personal data will be stored for the times strictly necessary for performance of the primary purposes set out in section 2 above, or as necessary for the protection of the interests of both Users and the Data Controller under civil law. Data relating to the warranty extension referred to in point 2.e will be stored for a period of 10 years.

In the circumstances covered by section 3 above, Users’ personal data will be stored for the times strictly necessary for performance of the purposes set out therein, and in all cases within the limits set by the Applicable Legislation.

1. Scope of Communication and Disclosure of Data

Users’ personal data may come to the knowledge of the Data Controller’s employees and/or associates assigned to manage the Website. The said persons, formally designated as “authorised processors” by the Data Controller, will only process Users’ data for the purposes set out in the privacy policy statement and in accordance with the provisions of the Applicable Legislation.

Users’ personal data may also come to the knowledge of third parties who process personal data on the Data Controller’s behalf in the capacity of “External Data Processors” or “Independent Data Controllers”, including, for example, suppliers of outsourcing or cloud computing services, suppliers of logistical and technical management services for the website, professionals and consultants.

Users are entitled to obtain a list of any data processors designated by the Data Controller or by the Independent Data Controllers to whom the data are disclosed, by applying to the Data Controller by the procedures set out in point 7 below.

1. Rights of Data Subjects

Users may exercise their rights under the Applicable Legislation by contacting the Data Controller by the following procedures:

• By sending a registered letter with return receipt to the Data Controller’s registered office
• By sending an email to privacy@annovireverberi.it. 

Any User considering that the processing of their data is in breach of the Regulation has the right to lodge a complaint with a Supervisory Authority (in the Member State where they normally reside or work, or in which the presumed breach occurs). The Italian Supervisory Authority is the Italian Data Protection Supervisory Authority - http://www.garanteprivacy.it/ - protocollo@gpdp.it