PRIVACY POLICY
Dear User, Soffass respects your privacy and protects your personal data. Please find below the policy, drafted pursuant to Articles 13 and 14 of European Regulation No. 679/2016, on the protection of personal data (for brevity, referred to as the ‘Regulation’ or ‘GDPR’), regarding the processing of any personal data that you provide when you browse our websites and/or use the services contained therein. Below we describe the general rules of data processing, the rules on cookies and how it is always possible for you to withdraw your consent to certain processing of your personal data. Your personal data shall be processed by Soffass in accordance with the principles of law and the Regulation. Please note that processing of personal data means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.1. DATA CONTROLLER AND DATA PROTECTION OFFICER
The Data Controller is Soffass S.p.A., with registered office in Via Fossanuova n. 59 – 55016 Porcari (LU), Italy (hereinafter, ‘Data Controller’ or ‘Soffass”), who can be contacted at [email protected]. The Data Controller has appointed a Data Protection Officer (‘DPO‘) who can be contacted at [email protected].2. CATEGORIES AND TYPES OF PERSONAL DATA PROCESSED
By using the sites www.nicky.eu, www.nicky.ie, www.nickytissue.co.uk, www.nicky.us, www.cosynel.be, www.kittensoft.com, www.letrefle.fr, www.thelyckefamily.com, www.nalyspapier.com/be, www.softis.de, www.sopalin.fr, www.regina.eu, www.regina.uk.com, www.sofidelshop.com (hereinafter for brevity referred to as the ‘Websites’), the Data Controller may collect and process the following personal data:- Browsing data
- Data voluntarily provided by the user
- Data processed as a result of services rendered online
- Cookies
3. PURPOSE OF PROCESSING
Your personal data shall be processed, if necessary with your consent, for the following purposes, where applicable:- to allow you to browse the Websites and to receive services, such as participating in the prize competition, in the prize draw as per the competition rules duly published by the Data Controller on the relevant site, including the management of security profiles;
- with reference to the site www.sofidelshop.com for the management of online sales services, billing, returns, verification of the status of orders placed as well as to respond to requests made by you to the Data Controller in relation to after-sales, information relating to product returns, shipments.
- to respond to any requests you submit using the appropriate forms available on the Websites or through the customer service email addresses published on the Websites;
- with your consent, to send you promotional and marketing communications, including newsletters, promotional offers, commercial initiatives, advertising material, direct sales and market research, on the products and services of the Data Controller and/or of Business Partners, as well as invitations to events and initiatives organised by the Data Controller or by companies in the Group, by automated means (text message, multimedia message, email, automated call systems without an operator, use of social networks, push notifications, WhatsApp, fax) and non-automated means (paper mail, telephone with operator);
- with your consent, to analyse your purchasing choices and behavioural preferences, in order to better structure personalised commercial communications and offers, to carry out general analyses for strategic orientation and commercial intelligence purposes and for profiling activities in general;
- for statistical evaluation and monitoring purposes; this purpose involves analysis of aggregate information that does not relate to identified or identifiable natural persons and, therefore, does not constitute personal data and thus does not allow the Data Controller to trace your identity in any way;
- to fulfil any obligations under applicable laws, regulations or EU legislation, or to comply with requests from the authorities;
- in the event that it is necessary to ascertain, exercise or defend a legal claim.
4. LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF THE PROCESSING
The legal basis for processing personal data for the purposes referred to in points a), b) and c) is Article 6(1)(b) of the Regulation, since the processing is necessary for the provision of the services you have requested. Providing your personal data for these purposes is optional, but failure to do so would make it impossible to activate the Services provided by the Website or respond to requests. The processing carried out for the marketing and profiling purposes described in points d) and e) is based on your giving consent pursuant to Article 6(1)(a). Your consent can be withdrawn at any time. Providing your personal data for these purposes is therefore entirely optional and does not affect the use of other services offered by the Websites. With regard to marketing purposes, it should be noted that the Data Controller collects a single consent for the marketing purposes described herein, pursuant to the General Provision of the Italian Data Protection Authority ‘Linee guida in materia di attività promozionale e contrasto allo spam’ (Guidelines on promotional activities and combating spam) of 4 July 2013. If, in any event, you wish to object to the processing of your data for marketing or profiling purposes, you may do so at any time by contacting the Data Controller at the addresses indicated in the ‘Contacts’ section of this policy. Finally, it should be noted that the processing referred to in point f), not being personal data, does not fall under the scope of the legislation on the data protection and can therefore be freely carried out by the Data Controller. The purpose referred to in point g) constitutes lawful processing of personal data within the meaning of Article 6(1)(c) of the Regulation. Data processing carried out for the purposes referred to in point h) is based on the legitimate interest of the Data Controller pursuant to Article 6(1)(e) of the Regulation.5. RECIPIENTS OF PERSONAL DATA
Your personal data may be shared, for the purposes indicated, with the following recipients:- Persons who typically act as Data Processors pursuant to Article 28 of the Regulation on behalf of the Data Controller, in particular: persons in charge of providing the Services (for example, hosting providers or providers of email platforms); persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communication networks), etc. The complete list of Data Processors is available by sending a written request to the Data Controller at the addresses indicated in the ‘Contacts’ section of this policy.
- Persons authorised by the Data Controller to process personal data necessary to carry out activities strictly related to the provision of services, who have committed to maintaining confidentiality or are under an appropriate legal obligation of confidentiality.
- Persons, entities or authorities to whom it is compulsory to communicate your personal data pursuant to the provisions of the law or orders by the authorities.
- Your data may be accessible to other companies of the Sofidel Group for the same purposes as above and/or for administrative and accounting purposes pursuant to Art. 6(1)(f) and Recitals 47 and 48 of the Regulation.