PRIVACY POLICY

 

DEIMILLE SRL Data Protection Policy

Last updated: 24/5/18

DATA PROTECTION POLICY

DEIMILLE SRL DEIMILLE SRL ITALY respects your privacy, and is deeply committed to protecting your personal data and empowering you to control how it is used.

This Data Protection Policy (hereafter “Policy”) applies to residents of EU states and certain other customers in states whose governments adopt Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data “General Data Protection Regulation” (“GDPR”). This Policy is intended to ensure that Customer Personal Data (defined as “any information relating to an identified or identifiable natural person”) is collected, maintained and used in accordance with the GPDR and associated data protection and privacy laws.

This Policy describes what kinds of Personal Data DEIMILLE SRL DEIMILLE SRL ITALY will collect from our European Customers, and how DEIMILLE SRL DEIMILLE SRL ITALY maintains and uses our Customers’ Personal Data in connection with the services we provide to them.

This Policy is hereby expressly incorporated into our User Agreements governing the provision of Services by DEIMILLE SRL DEIMILLE SRL ITALY to our Customers residing in states subject to the GDPR (our “European Customers”). This Policy supplements our Contract, and is effective as of 25 May 2018. This Policy shall supersede any directly conflicting data provisions in other DEIMILLE SRL Ltd. agreements, but only for European Customers. The Policy shall have no effect in geographical areas not subject to the GPDR; our existing Privacy Policy will remain in effect for customers in those areas.

Who is responsible for the processing of Customers’ Personal Data?

DEIMILLE SRL DEIMILLE SRL ITALY is the data controller in the sense of the applicable data protection regulations:

DEIMILLE SRL
CORSO SIRACUSA 79
10137 ITALY
Mail: INFO@HARRIDGE.IT

Personal Data DEIMILLE SRL DEIMILLE SRL ITALY may collect from its Customers.

DEIMILLE SRL DEIMILLE SRL ITALY collects Personal Data as described in the Contract, in particular from application forms, contact forms, and/or other interactions with Customer.

Customer should be aware that application fields are mandatory fields, because DEIMILLE SRL DEIMILLE SRL ITALY needs this information to comply with statutory, legal or contractual requirements, internal procedures or to respond to Customer requests.

Fields: DEIMILLE SRL DEIMILLE SRL ITALY may request include but are not DEIMILLE SRL ITALY to: Email, Mobile Phone number, Name, Home address, Date of birth and other. If Customer contacts DEIMILLE SRL DEIMILLE SRL ITALY, DEIMILLE SRL DEIMILLE SRL ITALY will keep a record of that correspondence for the legally required retention period.

Personal Data that Customers provide to DEIMILLE SRL DEIMILLE SRL ITALY should not include any of the following data types, and Customers hereby expressly warrant that they will not provide any of the following:

  • racial or ethnic origin;
  • political opinions;
  • religious or philosophical beliefs;
  • trade union membership;
  • genetic data;
  • biometric data;
  • private health data concerning a Customer;
  • data concerning a natural person's sex life or sexual orientation.

DEIMILLE SRL DEIMILLE SRL ITALY may use Customer Personal Data to send direct marketing to our Customers via e-mail only when Customer has given express prior consent in the relevant contact form. Customer may at any time withdraw approval to receive marketing communications by expressly withdrawing consent via mail at INFO@HARRIDGE.IT or using the newsletter unscribe functionality

DEIMILLE SRL DEIMILLE SRL ITALY will not rely solely on automated Customer onboarding processes or transaction monitoring, including profiling, with respect to its decisions regarding a Customer’s ability to transact business via DEIMILLE SRL

 How does DEIMILLE SRL DEIMILLE SRL ITALY use Customer Personal Data?

Customer Personal Data is collected and handled by DEIMILLE SRL for the following purposes:

  • to deliver DEIMILLE SRL services (including to respond to Customer requests or questions, to investigate or respond to potential incidents and complaints);
  • to comply with applicable statutory, legal and regulatory obligations (including but not DEIMILLE SRL ITALY to the fight against money laundering and terrorist financing).

Lawfulness of our Personal Data processing.

DEIMILLE SRL use of Customer Personal Data as described herein is permitted by applicable data protection law, in particular Article 6(1) of GDPR, on the basis that it is:

  • necessary for the performance of a contract to which the Customer is a party;
  • subject to Customer’s consent, which DEIMILLE SRL DEIMILLE SRL ITALY shall obtain from time to time (for instance, when a Customer opts in (ticking the box) to receive marketing communications via email);
  • in certain cases as necessary to meet DEIMILLE SRL DEIMILLE SRL ITALY’s statutory, legal or regulatory obligations;
  • in certain cases as necessary to safeguard DEIMILLE SRL DEIMILLE SRL ITALY’s legitimate interests in pursuing the purposes set out above, DEIMILLE SRL ITALY in scope such that such interests in each case do not obviate Customer privacy interests.

Sharing Personal Data with third parties.

To facilitate DEIMILLE SRL performance of services and the efficient use of Customer Personal Data, DEIMILLE SRL may disclose Customer Personal Data to identified third parties. However, such disclosure will only occur in the following circumstances:

  • to DEIMILLE SRL subcontractors, suppliers, advisors, agents: from time to time DEIMILLE SRL may cooperate, engage or employ other companies and individuals to perform duties on behalf of DEIMILLE SRL.
    DEIMILLE SRL subcontractors, suppliers, advisors, agents, are based in the following locations: EU/EEA/USA. Such recipients will only have access to Customer Personal Data on a need-to-know basis and as required by them to perform their duties; they are not permitted to use Customer Personal Data for any other purposes. These recipients will be subject to adequate contractual obligations as regards data protection and confidentiality;
  • to other entities belonging to the DEIMILLE SRL (i.e. any companies directly or indirectly controlled by DEIMILLE SRL DEIMILLE SRL ITALY (parent DEIMILLE SRL DEIMILLE SRL ITALY)).
  • to DEIMILLE SRL DEIMILLE SRL ITALY auditors, government or law enforcement authorities if DEIMILLE SRL DEIMILLE SRL ITALY determines in its sole discretion that DEIMILLE SRL DEIMILLE SRL ITALY is under a legal obligation to do so.

DEIMILLE SRL DEIMILLE SRL ITALY endeavors to take all reasonable steps to ensure that Customer Personal Data is treated securely and in accordance with this Policy and applicable laws.

Data retention.

DEIMILLE SRL DEIMILLE SRL ITALY will retain Customer Personal Data for as long as (i) necessary for the respective purpose, (ii) necessary to deliver services and carry out DEIMILLE SRL DEIMILLE SRL ITALY business relationship with Customer in accordance with the Contract, (iii) Customer has consented to, and/or (iv) required by applicable retention laws.

Data Security.

Although DEIMILLE SRL DEIMILLE SRL ITALY will do its best to protect Customer Personal Data, every Customer should be aware and is hereby informed that the transmission of information via the internet is not inherently secure. CRIMINAL HACKERS AND OTHER BAD ACTORS WILL ATTEMPT TO STEAL YOUR DATA AND DIGITAL ASSETS! DEIMILLE SRL DEIMILLE SRL ITALY cannot guarantee the security of Customer Personal Data transmitted to DEIMILLE SRL DEIMILLE SRL ITALY or any third party; for this reason, ANY TRANSMISSION IS AT CUSTOMER’S OWN RISK.

DEIMILLE SRL DEIMILLE SRL ITALY will use industry standard (or better) technical and organizational security measures safeguard against unauthorized access, change, transmission or deletion of Customer Personal Data.

Customer rights: How can a Customer access, object, rectify, and delete its Personal Data?

Under applicable data protection laws, Customer has the following rights:

  • Right to access and obtain a copy of Customer Personal Data: Customer is entitled to request confirmation if and when DEIMILLE SRL DEIMILLE SRL ITALY processes your Customer Personal Data. Customer may have access to Personal Data and learn details upon request about how it is maintained and used. In some cases, Customer can ask DEIMILLE SRL DEIMILLE SRL ITALY to provide Customer with an electronic copy of Personal Data.
  • Right to object to marketing: if Customer expressly objects to DEIMILLE SRL DEIMILLE SRL ITALY’s use of Customer Data for marketing purposes, DEIMILLE SRL DEIMILLE SRL ITALY will put Customer personal contact information (name, address, telephone number, fax number, e-mail address) on a specific list to ensure that Customer no longer receives this material. The Customer Data will be maintained and used for non-marketing purposes unless and until Customer expressly withdraws the objection to marketing in writing.
  • Right to rectify Personal Data: If evidence can be provided that Personal Data DEIMILLE SRL DEIMILLE SRL ITALY holds about Customer is inaccurate, or needs to be updated, Customer can update this data via the DEIMILLE SRL wallet interface.
  • Right to be forgotten/Personal data erasure: In certain circumstances Customers have the right to have their personal data deleted. Customer may make such a request at any time in writing and DEIMILLE SRL DEIMILLE SRL ITALY will evaluate if Customer’s request should be granted.
    However, this right is subject to overriding legal rights or obligations; DEIMILLE SRL DEIMILLE SRL ITALY may be legally required to retain European Customer data, including in cases of suspicious transactions as to which DEIMILLE SRL DEIMILLE SRL ITALY is legally obligated to retain all relevant records, or to conduct internal investigations, or to use European Customer data (while safeguarding a specific identity) for purposes of general data security. For situations where, in accordance with the law, DEIMILLE SRL DEIMILLE SRL ITALY determines that a Customer’s data deletion request must be granted, DEIMILLE SRL DEIMILLE SRL ITALY will do so without undue delay. To exercise this deletion right, Customer must submit a request to DEIMILLE SRL DEIMILLE SRL ITALY via DEIMILLE SRL’s support service, and thereafter respond to any legitimate inquiries regarding the deletion request.

To the extent DEIMILLE SRL DEIMILLE SRL ITALY’s retention or use of European Customer Personal Data is based on Customer consent, the Customer also has the right to withdraw consent at any time. Withdrawal of Customer consent pursuant to this Policy will not affect the lawfulness of any processing based on Customer consent before the receipt of such withdrawal.

DEIMILLE SRL DEIMILLE SRL ITALY will only send marketing communications to European Customers via email . Customer may opt out of any further marketing communications using the un-scribe right at any time by contacting DEIMILLE SRL at INFO@HARRIDGE.IT  and providing the following information: Customer name, email address, the marketing communications to unsubscribe.

Otherwise the unscribe option will be always available in every marketing communications in the bottom panel of the emails

Changes to this Policy.

The terms of this Policy may be amended from time to time in accordance with DEIMILLE SRL DEIMILLE SRL ITALY’s internal rules and/or change in law or regulation. DEIMILLE SRL DEIMILLE SRL ITALY shall publish any material changes to this Policy either on its Website or contacting Customer using other communication channels

Questions, comments and requests regarding this Policy are welcomed and should be addressed to DEIMILLE SRL DEIMILLE SRL ITALY at the following e-mail address: INFO@HARRIDGE.IT SRL

 


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