Pursuant to art. 12, 13, 14 and ss. of the General Data Protection Regulation No. 2016/679 (hereinafter GDPR), concerning the protection of individuals with regard to the processing of personal data, Russo Daniela, Data Controller, provides the following information:

1. The user’s personal data will be processed for purposes related to the provision of the services provided on the Site (thus the website absoleg.it and/or the identical Apps, iOS and Android systems), for commercial activities, of direct sales, marketing, promotions, statistics, for the disclosure of consumption preferences, as well as for the execution of inherent contractual obligations (including the purchase of online products and order management; the management of customer care activities, those of verification and investigation of reports, complaints and disputes; for the execution of the activities preliminary to the contract and contractual obligations; for the fulfillment of administrative-accounting duties).

With specific and separate consent, the Data will be processed for the following purposes:

a) advertising, promotional and marketing activities (including the sending of newsletters and advertising material on products and services offered by Russo Daniela);

b) definition of the profile or personality of the person concerned and analysis of his habits and / or consumption choices, also by means of electronic processing.

2. The legal basis of the processing consists of the obligations assumed by the Data Controller towards the User if the processing is necessary for the execution of a contract (such as, for example, the sale of goods) and/or for pre-contractual relationships relating to the sale or other services offered. For treatments for direct marketing purposes, on the other hand, the legal basis is the legitimate interest of the Data Controller (“processing necessary to pursue a legitimate interest of the data controller”), in the same sense as the legitimate interest of processing personal data, again for direct marketing purposes. For all other treatments possibly carried out by the Data Controller, the legal basis is the consent of the User concerned.

3. The data controller is Russo Daniela, C.F. RSSDNL65T65L174W, Via Paoli 17, 38068 Rovereto – russo@assoleg.it. The Data Controller can be contacted by email at the address: russo@assoleg.it.

4. The Personal Data Protection Officer (DPO) can be contacted at the address of the registered office or at the e-mail address: russo@assoleg.it.

5. To register on the Site, enter the reserved area of the Site, obtain purchase assistance from the Owner, it is necessary to provide the following data: name, surname and e-mail address. With the User’s consent, the aforementioned data will allow Russo Daniela to send their newsletters (with commercial and promotional information). In case of refusal to communicate the personal data indicated (name, surname and e-mail address), the User will not be able to access the services offered by the Site.

6. The provision of data relating to the personal details of the interested party (name, surname, email and complete postal address) is necessary:

a) to allow Russo Daniela to fulfill its contractual delivery obligations in the event of a purchase order;

b) for after-sales assistance and customer service activities;

c) for the issue of the invoice;

d) for the management of job requests.

7. Other personal data requested – such as landline phone number, mobile phone number – are optional but, if provided, will allow the Data Controller to contact the interested party for communications relating to the purchase order, to verify the satisfaction of the services. or, subject to consent, to receive presentations of commercial offers, also based on preferences and through marketing activities, including by ordinary mail or by email or SMS.

8. The data may be disclosed to companies in the IT security sectors: for security purposes. Personal data are also processed through the creation of a centralized database, with IT and telematic tools. The database containing the personal data of the Users is accessible only by authorized parties. Subjects specifically appointed, such as employees or other collaborators, may become aware of the data in the processing necessary or related to the execution of the purchase order and marketing activities. In addition to the Data Controller, in some cases, other subjects involved in the organization of the Site (administrative, commercial, marketing, legal, system administrators) or external subjects (such as suppliers of administrative and accounting services, couriers and operators) may have access to the Data. logistics, hosting providers and systems engineering service providers, collection service providers, IT and online marketing companies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of subjects can always be requested from the Data Controller. These subjects will only have access to the personal data necessary to perform their duties and will not be able to use the same data for other purposes. They are also required to process Personal Data in accordance with this Privacy Policy and in accordance with applicable regulations on the protection of personal data. Each appointee is given specific directives regarding the processing of data that the appointees are required to comply with in order not to incur disciplinary sanctions and / or judicial initiatives. Russo Daniela confirms that any personal data communicated by the interested party is not intended for purposes other than those indicated here.

9. Data retention period based on the purposes.
The data are processed and stored for a period of time not exceeding the achievement of the purposes for which they are processed. The data relating to the detail of purchases with reference to identifiable customers will be kept for profiling or marketing purposes for a period not exceeding, respectively, twelve and twenty-four months from their registration, except for the actual transformation into anonymous form that does not allow, even indirectly or by connecting other databases, to identify the data subjects. Personal data (personal data, contact details, contractual and pre-contractual) connected to contractual relationships with Russo Daniela’s customers are kept in accordance with the law for civil, fiscal, accounting, administrative purposes, to make possible means of proof in the event of litigation and to meet specific requests from the competent Authority. At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

10. The User, by accessing the Home Page or other pages of the Site, initially views the pop-up banner with a brief information on cookies, with a request for consent to the use of cookies. The User then has access to the Site Privacy Policy, as well as to the extended information relating to the Cookie Policy. By continuing to browse, the User gives his consent to the use of cookies. By accessing the Cookie Policy, the User can deny consent to cookies.

11. By monitoring the User’s navigation on the Site, with the integration of the use of cookies, Russo Daniela will be able to:

a) count the visitors of a web page or a service provided by the Site;

b) elaborate aggregate statistics also regarding the functioning of the Site and the services present;

c) improve the performance of the Site, also making User searches more effective;

d) collect data relating to User traffic to identify trends;

e) store information on Users’ preferences and then customize the Site according to them;

f) avoid the repetition of advertising messages;

g) recognize the computer when the User accesses the Site again;

h) store the products already purchased and placed in the User’s cart;

i) evaluate the satisfaction, always anonymously, of the services available on the Site, including those of an advertising nature;

l) improve the User’s browsing experience by suggesting the best products and promotions based on the browsing performed;

m) perform, with the consent, revocable at any time, of the registered Users, the identification and detection of personal consumption preferences, with recording of the monitored data in view of targeted offers and promotions;

n) collect anonymous statistical data concerning the percentage of e-mail delivery with respect to those sent, reading, opening the message, forwarding to third parties, “click” numbers, etc.

Pursuant to Articles 15 to 22 of the GDPR, the User concerned has the right:

a) to have access to their personal data, to receive information on the data processed and to receive a copy (Article 15);

b) to obtain the correction of inaccurate personal data concerning him (Article 16);

c) to obtain the cancellation of personal data concerning him without undue delay under the conditions indicated in (Article 17);

d) to limit the processing of their data in the presence of the conditions referred to in (Article 18);

e) to object at any time to the processing of their personal data processed for direct marketing purposes and to profiling processing, insofar as it is connected to such direct marketing (Article 21);

f) in the event that the processing has its legal basis in the consent, to withdraw the consent at any time, without any prejudice to the lawfulness of the processing based on the consent before the revocation;

g) to the portability of their data (Article 20), or to receive their personal data provided to the Data Controller, in a structured format, commonly used and readable by an automatic device and to transmit them to a different Data Controller without impediments by the Data Controller of the treatment to which he provided them. In exercising their rights relating to data portability, the interested party also has the right to obtain the direct transmission of personal data from one Data Controller to another, if technically feasible;

h) to lodge a complaint with the data protection supervisory authority or to take legal action.

These rights may be exercised by the Data Subject, at any time, by writing to the Data Controller Russo Daniela, for the attention of the company Privacy Office, or by sending an e-mail to the inbox: russo@assoleg.it who will provide you as soon as possible.

Pursuant to art. 77 of the GDPR, however, without prejudice to the right of the interested party to contact the Guarantor Authority for the protection of personal data.