Privacy Policy

**Privacy Policy in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR). Effective from 08/02/2022**

**PREAMBLE**

This privacy policy takes into account what is indicated by the GDPR and the Privacy Code (Legislative Decree 30 June 2003, No. 196). The document is also drafted in accordance with the Guidelines of the Privacy Guarantor (especially the Guidelines for combating spam issued by the Privacy Guarantor on 4 July 2013).

**Data Controller:** La Dispensa S.r.l., VAT Number 06263700962, Via Circonvallazione 67, Bellusco (MB), Email: info@saponiflorinda.it

**Website to which this privacy policy refers:** https://saponiflorinda.it/ (Site).

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

**GENERAL INFORMATION**

This document describes how the Data Controller processes your personal data provided on the Site.

Below are described the main processing activities of your personal data. In particular, the legal basis for processing, whether the provision is mandatory, and the consequences of not providing personal data are explained. To best describe your rights, if necessary, we have specified whether and when a particular personal data processing is not carried out. On the Site, you have the possibility to enter personal data of third parties. In this case, you guarantee that you have obtained the consent of these individuals to enter this personal data. Therefore, you commit to indemnify and hold harmless the Data Controller from any liability.

**Registration on the Site**

The information and data requested in case of registration will be used to allow you both to access the reserved area of the Site and to use the online services offered by the Data Controller to registered users. The legal basis for processing is the necessity of the Data Controller to carry out pre-contractual measures at the request of the data subject. The provision of data is optional. However, your refusal to provide the data will make it impossible to register on the Site.

**Purchases on the Site**

Your personal data will be processed to allow you to make purchases on the Site. In the case of placing an online purchase order, to enable the conclusion of the purchase contract and the proper execution of the operations connected thereto (and, if necessary, to fulfill tax obligations). The legal basis for processing is the Data Controller’s obligation to perform the contract with the data subject or to fulfill legal obligations. Regardless of the above (and therefore without your consent), the Data Controller may process your data for the purpose of so-called “soft-spam,” regulated by Article 130 of the Privacy Code. This means that, limited to the email provided by you in the context of a purchase through the Site, the Data Controller will process the email to allow direct offers of similar products/services, provided that you do not object to such processing in the manner provided in this notice. The legal basis for processing is the Data Controller’s legitimate interest in sending this type of communication. This legitimate interest may be considered equivalent to the data subject’s interest in receiving “soft-spam” communications. The Data Controller may send emails to remind the user to complete a purchase. The legal basis for this processing is the Data Controller’s legitimate interest in sending this type of communication.

**Responding to Your Requests**

Your data will be processed to respond to your requests for information. The provision is optional, but your refusal will make it impossible for the Data Controller to respond to your questions. The legal basis for processing is the Data Controller’s legitimate interest in responding to user requests. This legitimate interest is equivalent to the user’s interest in receiving responses to communications sent to the Data Controller.

**Generic Marketing**

With your prior consent, the Data Controller may process personal data provided by you 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 purely optional. The failure to consent to the processing of your data for marketing purposes will make it impossible for you to receive advertising material related to products/services of the Data Controller and/or third parties, as well as for the Data Controller to conduct market research, also aimed at assessing the degree of user satisfaction, and to send you newsletters. These communications will be sent to the email address you provided on the Site.

**Profiling**

With your prior consent, the Data Controller may process your personal data for profiling purposes, i.e., for the analysis of your consumption choices through the detection of the type and frequency of purchases made by you, in order to send you advertising material and/or newsletters related to products of its own or third parties, of specific interest to you. The legal basis for this processing is your consent. The provision of data for this purpose is purely optional. The failure to consent to the processing of your personal data for profiling purposes will make it impossible for the Data Controller to create your commercial profile, by detecting your choices and purchasing habits, and to send you advertising material related to products of the Data Controller and/or third parties, of specific interest to you. These communications will be sent to the email address you provided on the Site.

**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 (fixed and/or mobile) that will allow you to enable or disable the identification of your device (so-called geolocation). You are free to consent or refuse this setting, without substantial changes to the functionality of the Site. You can change geolocation settings on your device at any time. The legal basis for processing is the Data Controller’s legitimate interest in providing services relevant to the user’s location. This legitimate interest is equivalent to the user’s interest in receiving services as relevant as possible to their location.

**Communication of Personal Data**

As part of its ordinary activities, the Data Controller may communicate your personal data to certain categories of subjects. In Article 2, you can find the list of subjects to whom the Data Controller communicates your personal data. To facilitate the protection of your rights, Article 2 may specify in some cases when your data is not communicated to third parties.

The “communication” to third parties of personal data is different from “transfer” (governed by the preceding point). In fact, in communication, the third party to whom the data is transmitted can only use it for specific purposes described in the relationship with the Data Controller. In the case of transfer, the third party becomes an autonomous Data Controller of personal data. In addition, the consent of the data subject is always required to transfer your personal data to third parties.

Notwithstanding the above, the Data Controller may use your personal data to fulfill legal obligations as required by current laws.

**SPECIFIC PRIVACY NOTICE**

**Article 1 Processing Methods**

1.1 The processing of your personal data will mainly be carried out using electronic or automated means, according to methods and with tools suitable to ensure their security and confidentiality in compliance with the GDPR. If the automatic chatbot service is active, your personal data will also be processed to enable the activation of this service, through which the user can contact and be contacted by the Data Controller, with your prior consent. The legal basis is the Data Controller’s legitimate interest

in responding to user requests via the chatbot service. This legitimate interest can be considered equivalent to the data subject’s interest in using the automatic chatbot service.

1.2 The information obtained and the processing methods will be relevant and not excessive with respect to the type of services provided. Your data will also be managed and protected in secure computer environments suitable for the circumstances.

1.3 “Special data” is not processed through the Site. Special data are those that can reveal racial or ethnic origin, religious, philosophical, or other beliefs, political opinions, membership of parties, trade unions, associations, or organizations of a religious, philosophical, political, or trade union nature, as well as personal data concerning health and sexual life.

1.4 Judicial data is not processed through the Site.

**Article 2 Communication of Personal Data**

The Data Controller may communicate your personal data to certain categories of subjects. The subjects to whom the Data Controller reserves the right to communicate your data are indicated below:

– The Data Controller may communicate your personal data to all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative measures.
– Your personal data may also be communicated to all those public and/or private subjects, individuals and/or legal entities (legal, administrative, and tax consulting firms, Judicial Offices, Chambers of Commerce, Labor Chambers, etc.), if communication is necessary or functional to the correct fulfillment of legal obligations.
– The Data Controller uses employees and/or collaborators in any capacity. For the proper functioning of the Site, the Data Controller may communicate your personal data to these employees and/or collaborators.
– In the ordinary course of managing the Site, the Data Controller uses companies, consultants, or professionals entrusted with the installation, maintenance, updating, and, in general, management of the hardware and software used by the Data Controller or for the provision of its services. Therefore, only for these purposes, your data may also be processed by these subjects.
– For the sending of communications, the Data Controller uses external companies entrusted with the sending of this type of communication (CRM platforms). Your personal data (in particular, your email) may therefore be communicated to these companies.
– For customer support purposes, the Data Controller uses one or more companies tasked with providing customer care services. Only for this purpose, your personal data may be communicated to these companies.
– The Data Controller reserves the right to modify the above-mentioned list based on its ordinary operations. Therefore, you are invited to regularly access this notice to check which subjects the Data Controller communicates your personal data to.

**Article 3 Storage of Personal Data**

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

– Your personal data will be kept only for the time necessary to ensure the proper provision of services offered through the Site.
– For marketing purposes, personal data will be kept until consent is revoked. For inactive users, personal data will be deleted one year after the last email sent and possibly viewed.
– For customer care purposes, data will be deleted once the assistance service is completed.
– For the purpose of executing the sales contract, data will be kept for 10 years from the date of receipt of the purchase order. This is to allow the Data Controller to exercise its right to defense and to demonstrate that it has correctly executed the contract.
– As provided for by Article 2220 of the Civil Code, invoices, as well as all accounting records in general, are kept for a minimum period of ten years from the date of registration, so that they can be presented in case of an audit.
3.2 Notwithstanding what is provided in Article 3.1, the Data Controller may keep your personal data for the time required by specific regulations, as may be amended from time to time.

**Article 4 Transfer of Personal Data**

4.1 The Data Controller is headquartered within the European Union. Therefore, the processing of your data is safe from a regulatory perspective, as it is governed by the GDPR. If the transfer of your personal data takes place to a non-EU country for which the European Commission has expressed an adequacy decision, the transfer is considered safe from a regulatory perspective. Article 4.1 lists from time to time the countries in which your personal data may be transferred and where the European Commission has expressed an adequacy decision.

Therefore, you are invited to regularly access this Article to check whether the transfer of your personal data is made to a country with these characteristics.

4.2 Notwithstanding what is indicated in Article 4.1, your data may also be transferred to non-EU countries for which the European Commission has not expressed an adequacy decision. Therefore, you are invited to regularly view this Article 4.2 to determine in which of these countries your data is possibly transferred. To allow the proper functioning of the Site, your personal data may be transferred to the United States. In these cases, the Data Controller will adopt all suitable contractual measures to ensure an adequate level of personal data protection, including, among others, the Standard Contractual Clauses approved by the European Commission on 4 June 2021.

4.3 In this article, the Data Controller indicates the countries to which it specifically directs its activities. This circumstance may imply the application of the legislation of the reference country, together with that of the GDPR.

At the request of the user, the Data Controller will apply to the processing of personal data the more favorable legislation provided by the national legislation of the user.

**Article 5. Data Subject Rights**

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

– ask the Data Controller for access to your personal data and to rectify or delete them or limit their processing concerning you or to oppose their processing, as well as the right to data portability
– withdraw your consent at any time without affecting the lawfulness of the processing based on the consent given before the withdrawal
– lodge a complaint with a supervisory authority (e.g., the Guarantor for the protection of personal data).
The above rights can be exercised by making a request to the contacts indicated in the Preamble without formalities.

**Article 6. Changes and Miscellaneous**

The Data Controller reserves the right to make changes to this policy at any time, giving adequate notice to the users of the Site and guaranteeing in any case adequate and equivalent protection of personal data. To view any changes, you are invited to regularly consult this policy. In case of substantial changes to this privacy policy, the Data Controller may also provide notice via email.

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