Owner and Data Controller

Tiziana De Falco c/o Primi Mesi - Viale 3 Marzo 1970 n. 185 - 86170 Isernia (Italia)

Owner contact email: clienti@primimesi.com

Types of Data collected

Among the types of Personal Data that primimesi.com collects, by itself or through third parties, there are: email address, Cookies, Usage Data, phone number, various types of Data, Videos, Data communicated while using the service and geographic position.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using primimesi.com.
Unless specified otherwise, all Data requested by primimesi.com is mandatory and failure to provide this Data may make it impossible for primimesi.com to provide its services. In cases where primimesi.com specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by primimesi.com or by the owners of third-party services used by primimesi.com serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through primimesi.com and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of primimesi.com (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User, Managing contacts and sending messages, Analytics, Advertising, Social features, Interaction with live chat platforms, Location-based interactions, SPAM protection, Remarketing and behavioral targeting, Platform services and hosting and Hosting and backend infrastructure.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Advertising

  This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on primimesi.com, possibly based on User interests.
  This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
  Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside primimesi.com. For more information, please check the privacy policies of the relevant services.
  In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

  Google AdSense (Google Inc.)

  Google AdSense is an advertising service provided by Google Inc. This service uses the “Doubleclick” Cookie, which tracks use of primimesi.com and User behavior concerning ads, products and services offered.
  Users may decide to disable all the Doubleclick Cookies by clicking on: google.com/settings/ads/onweb/optout.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

• Analytics

  The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

  Google Analytics (Google Inc.)

  Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of primimesi.com, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

• Contacting the User

  Mailing list or newsletter (primimesi.com)

  By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning primimesi.com. Your email address might also be added to this list as a result of signing up to primimesi.com or after making a purchase.

  Personal Data collected: email address.

  Contact form (primimesi.com)

  By filling in the contact form with their Data, the User authorizes primimesi.com to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

  Personal Data collected: email address.

  Phone contact (primimesi.com)

  Users that provided their phone number might be contacted for commercial or promotional purposes related to primimesi.com, as well as for fulfilling support requests.

  Personal Data collected: phone number.

• Hosting and backend infrastructure

  This type of service has the purpose of hosting Data and files that enable primimesi.com to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of primimesi.com. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  iubenda Consent Solution (iubenda srl)

  iubenda Consent Solution is a service provided by iubenda srl to facilitate the collection and management of proofs of consent.

  Personal Data collected: Data communicated while using the service.

  Place of processing: Italy – Privacy Policy.

• Interaction with live chat platforms

  This type of service allows Users to interact with third-party live chat platforms directly from the pages of primimesi.com, for contacting and being contacted by primimesi.com support service.
  If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

  Smartsupp (Smartsupp.com, s.r.o.)

  The Smartsupp Widget is a service for interacting with the Smartsupp live chat and session recording platform provided by Smartsupp.com, s.r.o.

  Personal Data collected: Cookies, Data communicated while using the service, Usage Data, various types of Data as specified in the privacy policy of the service and Videos.

  Place of processing: Czech Republic – Privacy Policy.

• Location-based interactions

  Non-continuous geolocation (primimesi.com)

  Primimesi.com may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by primimesi.com.
  The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.

  Personal Data collected: geographic position.

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  SendinBlue Email (SendinBlue SAS)

  SendinBlue is an email address management and message sending service provided by SendinBlue SAS.

  Personal Data collected: Cookies, email address and Usage Data.

  Place of processing: France – Privacy Policy.

• Platform services and hosting

  These services have the purpose of hosting and running key components of primimesi.com, therefore allowing the provision of primimesi.com from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  PrestaShop (PrestaShop S.A.)

  PrestaShop is a platform provided by PrestaShop S.A. that allows the Owner to build, run and host an e-commerce website.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: France – Privacy Policy.

• Remarketing and behavioral targeting

  This type of service allows primimesi.com and its partners to inform, optimize and serve advertising based on past use of primimesi.com by the User.
  This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
  In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

  AdWords Remarketing (Google Inc.)

  AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of primimesi.com with the Adwords advertising network and the Doubleclick Cookie.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out.

• Social features

  Inviting and suggesting friends (primimesi.com)

  Primimesi.com may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.

  Personal Data collected: various types of Data.

• SPAM protection

  This type of service analyzes the traffic of primimesi.com, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

  Google reCAPTCHA (Google Inc.)

  Google reCAPTCHA is a SPAM protection service provided by Google Inc.
  The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

Further information about Personal Data

• Selling goods and services online

  The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
  The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by primimesi.com depends on the payment system used.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of primimesi.com or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, primimesi.com may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, primimesi.com and any third-party services may collect files that record interaction with primimesi.com (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

Primimesi.com does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within primimesi.com and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.