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Privacy Policy

Privacy notice as required by the EU Regulation 2016/679

Dear Sirs, we are glad to share the present notice, as required by the EU Regulation 2017/679, related to the protection of natural persons considering the processing and the free flow of personal data (hereunder ‘’GDPR’’).

Giovanardi SpA (hereunder “Giovanardi”) will use the personal data provided by the customer for the on-line purchase of Giovanardi products branded “Lettera G” (hereunder “products”), in compliance with the data protection legislation. The processing of data will have as object the operations or the complex of operations (such as data collecting, registration, organization, storage, processing, communication, amendment, selection, use, deletion, destruction) concerning the personal data supplied by the customer during the compilation and the on-line sending of the purchase order of the products.

1. Responsibility
The Controller is Giovanardi SpA – Via Ozanam 35 Concorezzo, MB. Any request concerning the present Privacy Policy, the protection of personal data and the information security may be forwarded to Giovanardi, by e-mail to the address info@letterag.it 2. Personal data
Giovanardi processes, in compliance with the present Privacy Notice, the data supplied by the customers, including: a. The data provided during the creation of the account on the website (e.g. name, surname, invoicing address, e-mail address, telephone number, payment method)
b. The data concerning the purchases done through the website (e.g. purchased products, date, time of the purchases, living address)
c. The data supplied in case of information request or assistance.
Further personal data may be processed in accordance to the terms of the cookies notice, available at the section ‘notice cookies’

The data mentioned above are processed only to the extent of the purposes described in paragraph 4 of the present notice. In order to provide the most reliable on-line payment service, Giovanardi selected payment methods (e.g. PayPal) which are recognized to be among the main players in the e-commerce and financial world. With these services the on-line payment procedure is done on a secured page to which you will automatically be addressed. Moreover, the data sent to this server gets encrypted before being transmitted. In any case neither Giovanardi nor any other player will have access to the credit card information. In particular, Giovanardi does not have access to the secured page, nor to the credit card information.

3. Modalities for data processing
The data processing will be done in such a way to ensure an appropriate protection of personal information, through specific technical and organizational means, from illegal or not authorized procedures and from the loss, the destruction or accidental damages (“integrity and confidentiality”). The data gets processed by Giovanardi with manual, hard-copy, computer and electronic procedures strictly necessaries to the extent of the purposes mentioned in the present notice and gets processed only by official employees and under detailed instructions received by the company owner. For certain activities, Giovanardi uses trustworthy subjects who perform tasks of a technical or organizational nature on his behalf, acting under the direction and control of the owner.
Giovanardi considers the security of information, including personal data, an indispensable factor.

4. Purposes of the processing
a. For the management and implementation of the procedure of the purchase order transmission and of the Contract (“Contractual Purposes”).
b. To enable the customer to register himself on the website by creating a personal account and to perform the regular activities within the General Conditions of the website, including the purchases on the website, to provide the services available through the website, including the before and after sale services of customer care, and enforce and defend the rights of the customers and of third parties (“Contractual Purposes”).
c. To observe any legal obligation or regulation (“Legal Purposes”), including any possible communication related to the safety of the purchased products.
d. Prior consent of the user, to send newsletters, commercial communications and updates on the possible events organized by Giovanardi through the means of traditional communication (at distance), including regular mail, e-mail, SMS, instant message, telephone, for the promotion and /or the sale of products and /or services offered by Giovanardi, and for the survey of the satisfaction level (“Marketing purposes”).

5. Legal basis for the processing
a. The provision of personal data for the Contractual Purposes, point 4 a), b), c), is necessary to the purposes of the registration on the website and of the on-line purchase of products.
In case the customer does not want his data to be processed for these purposes, it won’t be possible for him to access to the abovementioned services through the website.
b. The processing of personal data for Marketing Purposes, point 4 d), is optional and subject to prior consent of the customer.
The event of absence of consent makes it impossible for Giovanardi to keep the customer informed and updated on the new products or services, promotions, personalized offers, or to carry out market surveys and send communications or other informative material.

6. (Area of) Data communication and dissemination
Giovanardi, within the purposes mentioned in paragraph 4, will be allowed to communicate the customers information strictly necessary for each kind of treatment, to the following player categories:
a. To all the subjects that are legally allowed to access to these data.
b. To employees, contractors and suppliers of Giovanardi, within each specific task and/or within possible contractual commitments with them, concerning the commercial relationship with the customer.
c. To post offices, shippers or carriers for the shipment of the products purchased by the customer and/or of other material related to the implementation of the services offered by Giovanardi.
d. To legal, administrative and fiscal consultants according to necessary or functional extent in relation to the activity of Giovanardi, in the procedure and for the purposes mentioned above; to banks for the management of collections and payments deriving from the execution of the contracts with the User. The User’s personal data will not be disclosed beyond the purposes for which they are collected.

7. Personal data transfer abroad
Personal data may be transferred outside the national area to Countries located in the European Union. The eventual transfer of User’s personal data in Countries located outside the European Union, in any case, will be managed in compliance with the appropriate and suitable guarantee regulating such transfer in accordance with the applicable legislation and in particular with the articles 44, 45 and 46 of EU Regulation 679/2016.

8. Personal data retention period
Giovanardi will process personal data for the period necessary to satisfy the purposes for which they are collected in accordance with paragraph 4 mentioned above. In any case, the following retention periods apply to the processing of personal data for the following purposes:
i. Data collected for the Contractual Purposes mentioned in paragraph 4, lett. a) and b) are stored for the entire duration of the Contract and for 3 additional years following the expiration of the same Contract for defense purposes and / or to allow Giovanardi to claim a right in court and / or out-of-court in case of disputes related to the execution of the Contract;
ii. Data collected for the Law Purposes mentioned in paragraph 4, lett. c) are stored for a period equal to the duration determined by Law for each type of data;
iii. Data collected for the Marketing Purposes of Giovanardi mentioned in paragraph 4, lett. d) are stored for a period equal to the entire duration of the User’s registration to the Website through their personal account and for 3 additional years following the deactivation and / or cancellation of the same; In Giovanardi S.p.A we care about the minimization of the personal information we collect and, for this reason, we have decided to cancel the accounts of the Users who have not dealt with the Website since more than 3 years. Once deleted, all data contained therein will be stored according to the information in the previous paragraph. At the expiry of the time limit set above, the User’s data may be deleted, anonymized and / or aggregated.

9. Users under 18
The Website is not addressed to Users below the age of 18 and Giovanardi S.p.A does not consciously collect personal data of Users below the age of 18.

10. Rights of the data subject
It is your right to know, at any time, which of your data are available to the controller and how they are used; it is also your right to have them updated, completed, corrected or cancelled, to request their portability or limitation of processing, according to law provisions, and to oppose to their processing except in the case of a legitimate interest of the owner. For the application of your rights, as well as for more detailed information about the subjects or categories of subjects to whom the data are communicated and / or transferred or who become aware of them as managers or agents, you can contact Giovanardi SpA, Via Ozanam 35, Concorezzo MB, email info@letterag.it. With the mentioned methods you can, at any time, withdraw the consent given without the revocation affecting the legitimacy of the previous processing.

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