in compliance with the obligations under Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (the "Regulation"), we hereby inform you that ShoppingTale S.r.l. ("ShoppingTale" or the "Company") with registered office in Viale Bianca Maria 41, 20122, Milan (MI), Tax Code and VAT No. 09072510960, registered with the Companies' Register of Milan, REA No. MI-2066856, PEC firstname.lastname@example.org, as Data Controller, will process your personal data, which may be collected by us, provided by you and/or communicated to us by other subjects, during the navigation and use of our corporate website http://www.shoppingtale.com/shop/ (the "Website").
The processing of the data you have freely provided or otherwise collected during your navigation on the Website will be carried out in compliance with the personal data protection regulations in force. In particular, the processing will be based on the principles of fairness, lawfulness and transparency. The data will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed and will be collected and recorded only for the purposes indicated in this Policy.
1) What personal data we process?
We will process personal data we collect or you provide when browsing and using the Website, such as:
• User's IP address;
• User's data related to browsing on the Website;
• browser and device information;
• information that you provide, collected via cookies, pixel tags and other technologies, without disclosing your identity;
• demographic and other information that you provide without revealing your specific identity;
• information that has been aggregated in such a way that it no longer reveals your specific identity;
• personal data, tax code, residential and shipping address, e-mail address, telephone number;
• data relating to payment instruments.
2) For what purposes are your data processed?
ShoppingTale will process your personal data for the following purposes:
a. comply with any type of obligation under current legislation;
b. allow you to register on the Website;
c. allow the conclusion, management and execution of an online sales contract with you;
d. to allow you to use the various functionalities offered through the Website, to obtain the information you have requested through our contact form and to allow us to respond to your specific requests of information on products;
e. to inform you via newsletters or other communication channels (e.g. SMS, MMS or other methods) about ShoppingTale's products, promotions and commercial initiatives, organisation and promotion of events, customer satisfaction questionnaires (marketing purposes);
f. carrying out profiling or commercial segmentation activities in order to provide you with advertising offers in line with your interests and through email or other communication channels (profiling or segmentation for marketing purposes). Profiling for marketing purposes is carried out using parameters in such a way that you receive only commercial information that is of interest to you. To do this, the Company will base itself on previous purchases, gender data (male/female), personal data such as age ranges, browsing data (for example, if the User has searched for information on a particular product, the Company may ensure that the User receives information on the same or similar products);
g. send communications aimed at the promotion and/or direct sale of products or services similar to those already purchased/used by you, using the email addresses provided on such occasions, without prejudice to the User's right to object at any time in the manner indicated at the bottom of the communication or at the addresses indicated in paragraph 7.
The Personal Data collected may also be processed in the context of possible corporate events (sale of the Company or business units), due diligence, in the event of the defence of a right in court and in relation to the relevant preparatory activities.
3) Under which legal basis are your data processed?
Without prejudice to the legal obligations referred to in paragraph 2, letter a) (e.g. fiscal obligations), the processing of your personal data, provided by you for the purposes referred to in paragraph 2, letter b), is necessary in order to fulfil the obligations of the pre-contractual relationship at the time you submit your request for registration on the Website. Your refusal to provide the data for this purpose will make it impossible to fulfil your requests.
The processing of your personal data, for the purposes referred to in paragraph 2, letter c), is an essential condition for the conclusion of a contract with ShoppingTale, as well as for the management of the resulting duties, such as those of a fiscal, accounting and administrative nature and the possible recovery of credit. Your refusal to provide such data will make it impossible to enter into a contract with the Company.
The processing of your personal data collected for the purposes referred to in paragraph 2, letter d), is carried out on the basis of a legitimate interest of the Company, whose business is inevitably linked to the quality of the services offered on its Website and the experience of interaction with users and the satisfaction of their expectations.
The processing of your personal data for the purposes referred to in paragraph 2, letter e) is optional, and is subject to your consent. Your refusal to provide such data will make it impossible for the Company to carry out marketing activities, market research and to send you newsletters.
The processing of your personal data for the purposes referred to in paragraph 2, letter f) is optional and is subject to your consent. Your refusal to provide such data will make it impossible to carry out the profiling activity related to your interests. In any case, on the basis of its own legitimate interest, the Company may carry out customer segmentation operations according to non-intrusive logic and criteria and in any case in such a way as not to affect the freedoms and fundamental rights of the Users.
The processing of your personal data collected for the purposes referred to in paragraph 2, letter g) is carried out on the basis of a legitimate interest of the Company to propose to the Users offers of products similar to those already purchased.
In the event of processing in the context of any corporate events (sale of the Company or business units), due diligence, in the event of the defence of a right in court and in relation to the relative prodromal activities, such processing will be carried out on the basis of the Company's legitimate interests in the continuation of its commercial activities and for the protection of its rights.
4) How are your data processed?
The processing of the personal data referred to in the preceding paragraphs shall be carried out both by means of paper records and with the aid of electronic and computerised tools suitable to grant the security and confidentiality of such data.
5) Who we disclose your data to?
Personal data may be disclosed by the Company solely and exclusively for the purposes indicated and where necessary, to the following categories of subjects: suppliers of services such as website hosting, data analysis, payment processing, order processing, information technology and the use of related infrastructures, customer service, email delivery, auditing and other services; consulting firms, law firms, accountants; companies controlling and/or affiliate to the Company;
Personal data may also be communicated, where requested, to the competent judicial authorities, public administrations and supervisory and control authorities.
Personal data shall not, however, be disclosed to unspecified subjects. The Company, as data controller, also reserves the right to transfer your personal data to third countries. Transfers of data outside the European Economic Area are subject to a special regime under the Regulation, and will only be made to countries that ensure an adequate level of protection of personal data, on the basis of an adequacy decision by the Commission or where adequate safeguards have been adopted (including the standard contractual conditions provided by the European Commission), provided that the data subjects have effective rights of action and remedies.
6) How long do we store your data?
Your data will be stored, in accordance with the provisions of the relevant legislation in force, for a period of time not exceeding that necessary to achieve the purposes for which they are processed. The criteria for determining the period of data retention take into account the period of permitted processing and the applicable regulations on taxation, statute of limitation periods and legitimate interests that constitute the legal basis of the processing. In relation to the processing for marketing purposes, in the absence of specific rules that provide for different retention periods, the Company will take care to use your purchase data for the aforementioned marketing and profiling purposes for a period of time consistent with your interest in the promotional initiatives. In any case, the Company will take every precaution to avoid using your data indefinitely, periodically checking that you are still interested in having the data processed for marketing purposes, as specified above. Subsequently, the data will be deleted, aggregated or anonymised.
7) Which rights do you have?
The Regulation grants to you specific rights, including the right to request from the data controller:
• confirmation as to whether or not your personal data are being processed and, if so, to obtain access to it (right of access);
• the rectification of inaccurate personal data, or the integration of incomplete personal data (right to rectification);
• the erasure of the data, if one of the grounds listed in article 17 of the Regulation applies (right to erasure);
• to restrict the processing of your personal data, if one of the grounds provided for in article 18 of the Regulation applies (right to restriction of processing);
to receive the personal data you have provided in a structured, commonly used and machine-readable format, and to transmit them to another data controller (right to data portability).
You have the right to withdraw your consent to the processing of your personal data for marketing purposes and/or profiling for marketing purposes, at any time, without affecting the lawfulness of the processing based on consent before the withdrawal.
In addition, you have the right to object to the direct marketing activities carried out by the Company, including any profiling for marketing purposes.
To exercise your rights, you can write to ShoppingTale S.r.l. Viale Bianca Maria 41, 20122 Milan or send an email to email@example.com.
According to the Regulation, the Company is not authorised to charge you for complying with any of the requests set out in this paragraph, unless they are manifestly unfounded or excessive, in particular because of their repetitive character. In case you request more than one copy of your personal data or in cases of excessive or manifestly unfounded requests, the Company may (i) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested or (ii) refuse to act on the request. In such cases, the Company will inform you about the costs before processing the request.
The Company may ask for additional information before processing requests if it needs to verify the identity of the individual who submitted them.
Without prejudice to any other administrative or jurisdictional remedy, the User shall also have the right to lodge a complaint with a supervisory authority if he considers that the processing of his personal data is carried out in breach of the Regulation.
The contact details of the supervisory authorities are provided below.
You can find all the information and contact details of the supervisory authorities of each Member State of the European Economic Area at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
In any case, the Company is interested in being informed of any grounds for complaint and invites you to use the contact channels indicated above before referring the matter to the supervisory authority, so that any disputes can be prevented and resolved in an amicable and timely manner, with the utmost courtesy, seriousness and discretion.
Version published on 21.02.2022