Privacy Policy

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INFORMATION ON THE PROCESSING OF PERSONAL DATA
Pursuant to article 13 of the general Regulation (EU) 2016/679 on data protection ("Regulation"), Gioielleria Zamberlan Riccardo s.a.s hereinafter called COMPANY, provides the following information with reference to the personal data provided by the contractual counterparty - who undertakes to transfer said information to the interested parties -, as well as to the personal data collected for the marketing purposes indicated in the this Information.

1. Data Controller
Gioielleria Zamberlan Riccardo s.a.s, VAT number 04468360278 with registered office in Via d. Manin 18 - 30020 La Salute di Livenza (VE)

2. CATEGORIES OF DATA OBJECT OF PROCESSING

2.1 Data processed during the contractual relationship
The object of processing is the personal data provided by the contractual counterparty hereinafter called INTERESTED SUBJECT, at the time of collection of the information, hereinafter called PERSONAL DATA or simply DATA, from the website www.gioielleriazamberlan.it such as for example:

• the personal data
• the place of birth
• of residence
• tax code
• VAT number
• tax code
• unique code
• telephone number
• e-mail address
• bank details

and their subsequent changes, as well as further data that will be provided by the INTERESTED PARTY or acquired by the COMPANY during the contractual relationship ("PERSONAL DATA" or "DATA").

All such information is to be be considered Personal Data pursuant to the applicable legislation to the extent that it refers directly or indirectly to identified or identifiable natural persons (for example, directors, employees, managers, collaborators, consultants of the contractual counterparty).

For example, the VAT number of a legal person does not fall within the definition of Personal Data.


2.2 Data processed in the performance of marketing activities
The object of processing is the personal data ("Personal Data" or "Data") provided by the user ("INTERESTED SUBJECT") or collected by the COMPANY during navigation on the Site.

• Data provided by the INTERESTED SUBJECT: this is mainly the Data collected during interactions with the COMPANY through the forms on the website or by subscribing to the Newsletter. This Data includes the name, surname, e-mail address and telephone number;
• Other Data processed: this is mainly the Data collected during the INTERESTED SUBJECT's browsing on the Site, such as the IP address, the operating system of the browser used, the contents clicked and the web pages visited.


3. PURPOSE OF THE PROCESSING, LEGAL BASIS AND CONSEQUENCES OF FAILURE TO PROVIDE DATA

3.1 Data processed during the contractual relationship
Personal Data are processed by the COMPANY for the following purposes:

• fulfill the legal and administrative obligations to which the COMPANY is subject. Any refusal to provide Personal Data for the pursuit of the indicated purposes will result in the impossibility of establishing and continuing the contractual relationship with the COMPANY;

• stipulating and managing the contractual relationship with the COMPANY. For the aforementioned purpose, Personal Data will also be processed in the context of the activities of: administration, accounting, contract management, services, invoicing/payments, auditing and mandatory/optional balance sheet certification, assignment or advance of credits, as well as to fulfill specific requests and comply with other obligations deriving from the Contract with the COMPANY. The provision of Personal Data is necessary for the establishment and performance of the Contract. Any refusal to provide Personal Data forpursuit of the indicated purposes, will result in the impossibility of establishing and continuing the contractual relationship.

3.2 DATA PROCESSED IN CARRYING OUT MARKETING ACTIVITIES

The Data is processed by the COMPANY for the following purposes:
• to allow interested parties to be updated on the COMPANY's products, through the direct marketing of goods and services, the receipt of the newsletter, the distribution of information material, the organization and promotion of events and the sending of questionnaires relating to the degree of customer satisfaction;

• send personalized information based on the specific profile and interests of the INTERESTED SUBJECT;

The processing of the Data for the purposes is optional, and is subject to the provision of consent by the INTERESTED SUBJECT.

Any refusal to provide such Data will make it impossible to communicate to the INTERESTED PARTY any commercial initiative and offer of the COMPANY Gioielleria Zamberlan Riccardo S.a.s, as well as to receive commercial information deemed relevant to his profile.

The processing of Personal Data could also take place in the context of carrying out management operations of any dispute. Any such processing could be carried out on the basis of a legitimate interest of the COMPANY, which intends to protect its interests and rights as recognized by current regulations.


4. METHOD OF PROCESSING AND DATA STORAGE PERIOD

4.1 Data processed during the contractual relationship
Personal Data is mainly processed at the COMPANY with the aid of electronic and manual means suitable to guarantee its security and confidentiality. In particular, they may be processed in the following ways:

• collection of data from the interested party;
• collection of data from registers, lists of documents or public documents;
• recording and processing on paper support;
• recording and processing on IT support;
• organization of archives in both automated and non-automated form

Personal Data will be stored in compliance with the provisions of current legislation on the subject, for a period of time not exceeding that necessary to achieve the purposes for which they are processed.

The criteria for determining the retention period of the Data take into account the permitted processing period and the applicable regulations regarding taxation, prescription of rights and the nature of the legitimate interests where they constitute the legal basis of the processing.

In compliance with the provisions of current legislation, the Personal Data may be retained for a period subsequent to that originally envisaged, in the event of any disputes or requests from the competent Authorities.
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4.2 DATA PROCESSED IN THE CARRYING OUT OF MARKETING ACTIVITIES
Communications for the purposes indicated in paragraph 3.2 may be made via e-mail, text message, Whatsapp, Telegram, paper mail as well as any other present and future means of communication, without prejudice to the fact that the interested party may object to the processing carried out through one or all of these means of communication.

The Data is mainly processed by the COMPANY with the aid of electronic and manual means suitable to guarantee its security and confidentiality. In particular, they may be processed in the following ways:
• collection of data from the interested party;
• recording and processing on paper support;
• recording and processing on IT support;
• organization of archives in both automated and non-automated form.

The Data will be stored in accordance withas provided for by current legislation on the matter, for a period of time not exceeding that necessary to achieve the purposes for which they are processed.
In the absence of specific rules that provide for retention times for the purposes indicated in this Information, the COMPANY will take care to use the Personal Data for the aforementioned marketing purposes for a time appropriate to the interest expressed by the INTERESTED PARTY towards the promotional initiatives, estimated at 5 years.

In any case, the COMPANY will take every precaution to avoid using the data indefinitely, proceeding periodically to appropriately verify the actual continuation of the INTERESTED PARTY's interest in having the processing carried out for marketing purposes, as specified above.


5. SCOPE OF COMMUNICATION AND TRANSFER OF DATA

Personal Data will be made available to subjects authorized to process them within the COMPANY only where necessary and for the purposes for which processing is permitted.

5.1 Data processed during the contractual relationship
Personal Data may be communicated by the COMPANY, only and exclusively for the purposes indicated, as well as to the competent Judicial Authorities where necessary, to the following categories of subjects:

• banking and credit institutions;
• insurance companies;
• legal consultants;
• tax consultants, auditors and accountants;
• debt collection companies;
• companies that detect financial risks and carry out fraud prevention activities;
• public administrations and supervisory and control authorities;
• car rental companies;
• travel agencies;
• companies that provide IT services;
• companies that provide security and surveillance services;
• companies controlling and/or connected to the COMPANY.

With reference to the Personal Data communicated to them, the subjects belonging to the above categories may operate, depending on the case, as data controllers (and in this case they will receive appropriate instructions from the COMPANY) or as separate data controllers. In the latter case, the Personal Data will be communicated only with the express consent of the interested parties, except in cases where the communication is mandatory or necessary by law or for the pursuit of purposes for which the consent of the interested party is not required by law.

If this is instrumental to the pursuit of the purposes indicated in paragraph 3.1, the Data may also be transferred abroad to COMPANY having headquarters both within and outside the European Union.
Some of these jurisdictions may not guarantee the same level of data protection as the country in which the interested party resides. In this case, the COMPANY undertakes that the Data will be treated with the utmost confidentiality by stipulating, if necessary, agreements that guarantee an adequate level of protection and/or adopting the standard contractual clauses provided for by the European Commission.

5.2 DATA PROCESSED IN THE CARRYING OUT OF MARKETING ACTIVITIES

The Data may be communicated by the COMPANY, only and exclusively for the purposes indicated, as well as to the competent Authorities Judicial where necessary, to the following categories of subjects:
• companies that provide IT services;
• consultants of the Company;
• suppliers of marketing services;
• companies controlling and/or connected to the COMPANY.

If this is instrumental to the pursuit of the purposes indicated in paragraph 3.2, the Data may also be transferred abroad to a COMPANY based both within and outside the European Union.
Some of these jurisdictions may not guarantee the same level of data protectionguaranteed by the country in which the interested party resides. In this case, the COMPANY undertakes that the Data will be treated with the utmost confidentiality by stipulating, if necessary, agreements that guarantee an adequate level of protection and/or adopting the standard contractual clauses provided by the European Commission.

6. EXISTENCE OF AN AUTOMATED DECISION-MAKING PROCESS
There is no automated decision-making process in relation to the Data.

7. Rights of the interested party
At any time, the interested party will have the right to:
• obtain confirmation from the COMPANY whether or not their Personal Data is being processed and in this case, to obtain access to the information referred to in the art. 15 of the Regulation;
• obtain the rectification of inaccurate Data concerning him, or, taking into account the purposes of the processing, the integration of incomplete Personal Data;
• obtain the cancellation of his Personal Data, in the presence of one of the reasons referred to in the art. 17 of the Regulation, where applicable;
• revoke consent at any time in cases where it has previously been provided. The revocation of consent does not affect the lawfulness of the processing based on the consent previously given;
• obtain the limitation of the processing of your Data if one of the hypotheses referred to in the art. 18 of the Regulation;
• object to the processing of your Personal Data, for reasons connected to your particular position, where applicable;
• receive the Personal Data concerning you provided in a structured, commonly used and machine-readable format as well as transmit such Data to another data controller, in the cases and within the limits set out in art. 20 of the Regulation.
The COMPANY may request further information before processing requests, if it needs to verify the identity of the natural person who submitted them.

Pursuant to the GDPR, the COMPANY is not authorized to charge costs to fulfill one of the requests reported in this paragraph, unless they are manifestly unfounded or excessive, and in particular are repetitive in nature.

In cases where an INTERESTED SUBJECT requests more than one copy of their personal data or in cases of excessive or unfounded requests, the COMPANY may (i) charge a reasonable fee, taking into account the administrative costs incurred to process the request or (ii) refuse to satisfy the request. In these cases, the COMPANY will inform the interested party of the costs before processing the request.

These rights may be exercised by sending:
- a communication by e-mail to the address zamberlanoreficeria@gmail.con
Without prejudice to any other administrative or jurisdictional appeal, the interested party also has the right to lodge a complaint with a Supervisory Authority (for Italy: the Guarantor for the protection of Personal Data), if he/she believes that the processing concerning him is carried out in violation of the General Data Protection Regulation. Further information is available on the website http://www.garanteprivacy.it.

The COMPANY undertakes to comply with all the obligations set out in this information. Interested parties who decide to propose the above appeals or complaints are invited to contact us.

Gioielleria Zamberlan Riccardo s.a.s

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