PRIVACY POLICY

Information on the processing of personal data pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR). Effective from 08/06/2023

PREMISE

Data Controller: Opti Group S.r.l.

This information complies with the GDPR and the Italian Privacy Code (Legislative Decree June 30, 2003, No. 196). The document has also been drafted based on the Privacy Guidelines issued by the Italian Data Protection Authority (especially the Anti-Spam Guidelines issued by the Data Protection Authority on July 4, 2013).

Site to which this privacy policy refers: https://www.centrootticorizzo.com (Site).

The Data Controller has not appointed a Data Protection Officer (DPO). Therefore, you can send any requests for information directly to the Data Controller.

GENERAL INFORMATION

This document describes how the Data Controller processes your personal data provided on the Site. The main processing of your personal data is detailed below. In particular, it explains the legal basis of the processing, whether the provision of data is mandatory, and the consequences of failing to provide personal data. To better describe your rights, we have also specified if and when certain data processing operations are not carried out. On the Site, you have the opportunity to enter personal data of third parties. In such cases, you guarantee that you have obtained the consent of these subjects to provide their personal data. Therefore, you agree to indemnify and hold the Data Controller harmless from any liability.

REGISTRATION ON THE SITE

The information and data requested during registration will be used to allow you to access the reserved area of the Site and to take advantage of the online services offered by the Data Controller to registered users. The legal basis for the processing is the necessity for the Data Controller to take pre-contractual measures at the request of the data subject. The provision of data is optional. However, if you refuse to provide the data, it will be impossible to register on the Site. It is also possible to register on the Site using external services. In this case, your registration data will be shared with these external companies solely for the purpose of allowing registration on the Site. The legal basis for this processing is the legitimate interest of the Data Controller to allow registration on the Site via external services. The provision of personal data for this purpose is optional. Refusal to provide consent for data processing will prevent you from registering via external services.

PURCHASES ON THE SITE

Your personal data will be processed to allow you to make purchases on the Site. If you place an online purchase order, your data will be processed to conclude the purchase contract and to carry out the related operations (and, if necessary, to fulfill fiscal obligations under current law). The legal basis for the processing is the obligation of the Data Controller to execute the contract with the data subject or to comply with legal obligations. Regardless of your consent, the Data Controller may process your data for 'soft-spam' purposes, as regulated by Article 130 of the Privacy Code. This means that the Data Controller may use the email you provided during a purchase to offer similar products/services, unless you object to such processing in the manner described in this policy. The legal basis for this processing is the legitimate interest of the Data Controller to send this type of communication. This legitimate interest can be considered equivalent to the data subject's interest in receiving 'soft-spam' communications. The Data Controller may send reminder emails to complete a purchase. The legal basis for this processing is the legitimate interest of the Data Controller in sending such communications. Through the 'shop updates' option, the Data Controller may process your personal data to send updates via email and/or phone (depending on the options available on the Site) about order status, shipments, and/or inventory. The legal basis for this processing is the legitimate interest of the Data Controller to send these updates, which matches your interest in receiving them. The provision of personal data for this purpose is optional. If you do not provide personal data, the Data Controller will not be able to send these updates.

RESPONDING TO YOUR REQUESTS

Your data will be processed to respond to your information requests. The provision of data is optional, but your refusal will prevent the Data Controller from responding to your inquiries. The legal basis for the processing is the legitimate interest of the Data Controller in responding to the user's requests. This legitimate interest is equivalent to the user's interest in receiving a response to their communications sent to the Data Controller.

GENERIC MARKETING

With your consent, the Data Controller may process your personal data to send you advertising material and/or newsletters related to its own products or third-party products. The legal basis for this processing is your consent. The provision of personal data for this purpose is optional. Refusal to consent to the processing of data for marketing purposes will prevent you from receiving advertising material related to the Data Controller’s products/services or third-party products/services, and the Data Controller will not be able to conduct market research, evaluate user satisfaction, or send you newsletters. These communications will be sent to the email and/or phone number and/or postal address you provided on the Site.

PROFILING

With your consent, the Data Controller may process your personal data for profiling purposes, which means analyzing your purchasing choices through the disclosure of the type and frequency of your purchases, in order to send you advertising material and/or newsletters related to products of the Data Controller or third parties that match your specific interests. The legal basis for this processing is your consent. Providing data for this purpose is optional. Refusal to consent to profiling will prevent the Data Controller from analyzing your purchasing preferences or sending you personalized advertising material regarding products from the Data Controller or third parties. These communications will be sent to the email, phone number, or address you provided.

DATA TRANSFER

The Data Controller does not transfer your personal data to third parties.

GEOLOCATION

When accessing the Site, you may receive a notification on your device (desktop and/or mobile) asking for permission to allow or deny the device’s location detection (so-called geolocation). You are free to allow or deny such a setting, without significant changes to the Site's functionality. You can change geolocation settings at any time through your device's settings. The legal basis for this processing is the legitimate interest of the Data Controller in providing services relevant to the user’s location. This legitimate interest is equivalent to the user's interest in receiving services relevant to their location.

CURRICULUM VITAE

You can submit your CV through the Site. Your CV will be reviewed by the Data Controller or its collaborators. The purpose of the processing is the legitimate interest of the Data Controller in reviewing the document to evaluate the possibility of establishing a working or collaborative relationship with you. This interest is equivalent to your interest in being contacted by the Data Controller for this purpose. The data will be retained until the end of the selection process and, in any case, for no more than 6 months after the CV is submitted. The provision of data is optional, but failure to provide it will prevent the Data Controller from contacting you.

APPOINTMENT BOOKING

No third-party appointment booking systems are active on the Site. Therefore, your data will not be processed for this purpose. However, you can always contact the Data Controller using the contact information provided in the preamble.

COMMUNICATION OF PERSONAL DATA

In the course of its ordinary activities, the Data Controller may communicate your personal data to certain categories of subjects. Article 2 contains the list of entities to whom the Data Controller may communicate your personal data. To facilitate the protection of your rights, Article 2 may also specify when your data is not communicated to third parties.

The 'communication' of personal data to third parties is different from 'transfer' (as discussed in the previous section). In the case of communication, the third party receiving the data can use it only for the specific purposes described in the relationship with the Data Controller. In the case of transfer, however, the third party becomes the independent Data Controller of the personal data. Additionally, your consent is always required for transferring your personal data to third parties.

Without prejudice to the above, the Data Controller may still use your personal data to properly comply with the obligations provided for by current laws.

SPECIFIC PRIVACY NOTICE

Art. 1 Processing Methods

1.1 The processing of your personal data will be mainly carried out using electronic or otherwise automated means, in accordance with the methods and tools suitable for ensuring data security and confidentiality in compliance with the GDPR.

1.2 The information obtained and the processing methods will be relevant and not excessive in relation to the services provided. Your data will also be managed and protected in secure IT environments that are appropriate for the circumstances. On the Site, you may create a public profile in which other users can view the content you have published and your personal data (e.g., photos or videos). Therefore, you acknowledge and agree that the Data Controller is not responsible for the use that other users may make of this content and your personal data.

1.3 The Site does not process 'special data.' Special data includes information revealing racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership in parties, trade unions, associations, or organizations of a religious, philosophical, political, or trade union nature, as well as data concerning health or sexual orientation.

1.4 The Site does not process judicial data.

Art. 2 Communication of Personal Data

The Data Controller may communicate your personal data to specific categories of subjects. Below are the subjects to whom the Data Controller reserves the right to communicate your data:

The Data Controller may communicate your personal data to all those subjects (including Public Authorities) who have access to personal data by virtue of legislative or administrative measures.

Your personal data may also be communicated to all public and/or private entities, natural and/or legal persons (e.g., legal, administrative, and tax consultants, judicial offices, Chambers of Commerce, Labor Offices, etc.), when such communication is necessary or functional to the proper fulfillment of legal obligations.

The Data Controller employs staff and/or collaborators of any kind. For the proper functioning of the Site, the Data Controller may communicate your personal data to these employees and/or collaborators.

The Data Controller does not employ companies, consultants, or professionals for the installation, maintenance, updating, and overall management of the Data Controller’s hardware and software. Therefore, your data will not be communicated to these categories of subjects.

For sending its communications, the Data Controller relies on external companies tasked with sending this type of communication (CRM platforms). Your personal data (particularly your email) may therefore be communicated to these companies.

The Data Controller does not use external companies for customer care services.

The purchaser's personal data may be communicated to postal offices, couriers, or shipping companies in charge of delivering products purchased through the Site.

The Data Controller reserves the right to modify the above list based on its ordinary operations. Therefore, you are invited to regularly review this privacy policy to check to whom the Data Controller communicates your personal data.

Art. 3 Retention of Personal Data

This article describes how long the Data Controller reserves the right to retain your personal data.

For marketing purposes, personal data will be retained until the consent is revoked. For inactive users, personal data will be deleted one year after the last email viewed.

As provided by Article 2220 of the Civil Code, invoices, as well as all accounting records in general, are kept for a minimum of ten years from the date of registration to be presented in case of an audit.

Through the Site (or by requesting it from the Data Controller), it is possible to delete the user account. In this case, all stored personal data will be deleted and will not be retained by the Data Controller for any purpose.

For the purpose of executing the sales contract, data will be retained for 10 years from the date of receipt of the purchase order. This allows the Data Controller to exercise its right of defense and demonstrate the correct execution of the contract.

Without prejudice to the provisions of Article 3.1, the Data Controller may retain your personal data for the time required by specific regulations, as amended from time to time.

Art. 4 Transfer of Personal Data

The Data Controller is based within the European Union. Therefore, the processing of your data is safe from a regulatory point of view, as it is governed by the GDPR. If your personal data is transferred to a non-EU country for which the European Commission has issued an adequacy decision, the transfer is considered safe from a regulatory perspective. Article 4.1 will indicate the countries to which your personal data may be transferred and where the European Commission has issued an adequacy decision.

You are invited to regularly check this article to verify whether your personal data is transferred to a country with these characteristics.

Notwithstanding the provisions of Article 4.1, your data may also be transferred to non-EU countries for which the European Commission has not issued an adequacy decision. You are invited to regularly check this article to determine in which of these countries your data may be transferred.

This article indicates the countries in which the Data Controller may specifically direct its activity. This may imply the application of both the relevant national laws and the GDPR.

Upon request, the Data Controller will apply the user’s national legislation if it offers greater protection for personal data processing.

Art. 5 Data Subject's Rights

Pursuant to Article 13 of the GDPR, the Data Controller informs you that you have the right to:

request access to your personal data, as well as their rectification, erasure, or restriction of processing, or to object to the processing, in addition to the right to data portability

withdraw consent at any time, without prejudice to the lawfulness of the processing based on the consent given before its withdrawal

lodge a complaint with a supervisory authority (e.g., the Italian Data Protection Authority).

The above rights may be exercised by submitting a request informally to the contacts indicated in the Preamble.

Art. 6 Changes and Miscellaneous

The Data Controller reserves the right to make changes to this privacy policy at any time, providing appropriate notice to users of the Site and ensuring that the personal data is adequately and similarly protected. To review any changes, you are invited to regularly consult this privacy policy. If there are substantial changes to this privacy policy, the Data Controller may also notify you via email.

7Pixel S.r.l., represented by its legal representative, is appointed as the data processor for the management of user comment requests within the Trusted Program of the website www.trovaprezzi.it (info@centrootticorizzo.com).