Privacy Policy

DATA CONTROLLER AND GENERAL INFORMATION

Tommaso Giordano, with registered office at Via Concordia 32, 30013 Cavallino-Treporti (VE), VAT number 04570790271, is the data controller for the personal data provided by users.

Tommaso Giordano is committed to protecting users' right to personal data protection.

This Privacy Policy is provided to Users pursuant to and for the purposes of national and European legislation on the protection of personal data, meaning Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), in addition to any other legislation on the protection of personal data applicable in Italy, including the provisions of the Italian Data Protection Authority.

We recommend that you read the following carefully to understand our considerations and practices regarding Personal Data and how it will be processed.

DATA CONTROLLERS

The Data Controller uses data processors to achieve the purposes indicated below and a designatedData Protection Officer(DPO) to oversee the protection of personal data.

We remind you that you can contact theData Protection Officerat any time and send any questions or requests regarding your personal data and respect for your privacy by writing to info@tommasogiordano.com.

TYPES OF DATA COLLECTED

Among the Personal Data collected by this Site/Application, either independently or through third parties, there may be: email address, first name, last name, date of birth, gender, delivery address, postal code, city of delivery, mobile phone number, tax ID or VAT number, Cookies, and Application Usage Data. Where applicable, if the User registers through social media authentication methods, Anagramma Srl will access certain Personal Data (e.g., first name, last name, email, etc.) in the User's social media account based on the applicable terms of use of the specific social media platform.

Personal Data may be directly provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.

Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to provide it, it may be impossible for this Application to provide the Service. In cases where this Application indicates that certain Data is optional, Users are free to refrain from providing such Data, without this having any impact on the availability of the Service or its operation.

Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller.

The use of Cookies – or other tracking tools – by this Application or by the providers of third-party services used by this Application, unless otherwise specified, is for the purpose of providing the Service requested by the User, in addition to the other purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Application and guarantees that they have the right to communicate or disseminate it, freeing the Owner from any responsibility towards third parties.

METHOD AND LOCATION OF DATA PROCESSING

Treatment methods

The Data Controller shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data.

The processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated.

In addition to the Owner, in some cases, other parties involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external parties (such as administrative and accounting service providers, couriers and logistics operators, hosting providers, and system engineering service providers) may have access to the Data. marketing, legal, system administrators) or external parties (such as administrative and accounting service providers, couriers and logistics operators, hosting providers and system 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 Processors can always be requested from the Data Controller. These suppliers only have access to the personal data that is necessary to perform their tasks. We guarantee that they cannot use the Data for other purposes and are also required to process Personal Data in accordance with this Privacy Policy and in accordance with applicable data protection regulations.

Legal basis for processing

The Data Controller processes Personal Data relating to the User if one of the following conditions exists: the User has given consent for one or more specific purposes;

the processing is necessary for the performance of a contract with the User and/or for the implementation of pre-contractual measures;

processing is necessary to comply with a legal obligation to which the Controller is subject;

processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;

processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party.

However, it is always possible to ask the Data Controller to clarify the specific legal basis for each processing operation and, in particular, to specify whether the processing is based on the law, provided for in a contract, or necessary for the conclusion of a contract.

Location

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

Your Personal Data may be transferred to a country other than the one in which you are located, including outside the European Union. When such a transfer occurs, we ensure that it is carried out in accordance with this Privacy Policy and that adequate protection is provided.

If any of the transfers described above take place, the User may refer to the relevant sections of this document or request information from the Data Controller by contacting them at the details provided at the beginning of this document.

Retention period

The Data is processed and stored for the time required for the purposes for which it was collected. In general terms, the data will be stored until:

For Users with addresses in geographical areas served by Tommaso Giordano, the latest date between:

the fifth anniversary after the last use of our Platform or the last active interaction of the User with Tommaso Giordano.

the fifth anniversary after the account closure if the User has taken advantage of a member-get-member promotion or has been identified as participating in a transaction suspected of fraud.

For Users with addresses in geographical areas not served by Tommaso Giordano, the tenth anniversary after registration on the Platform.

The following categories of data may be stored for longer periods:

Financial and accounting data (e.g., invoices, payments, refunds, etc.) are retained for the duration required by applicable tax and accounting laws.

All user-generated content (e.g., products purchased, behavior patterns) is anonymized but remains available for our analysis in aggregate form.

At the end of the retention period, Personal Data will be deleted. Therefore, upon expiry of this period, the right of access, deletion, rectification, and the right to data portability can no longer be exercised.

PURPOSE OF THE PROCESSING OF COLLECTED DATA

User Data is collected to enable the Owner to provide and optimize its Services, and in particular to:

the identification of the User necessary for access to the Application and to the dedicated products and services, as well as to allow the correct development of User support activities;

completing the order and managing payment collection with the necessary control and security measures for the transaction;

order preparation and delivery;

order invoicing management and completion of related administrative and tax processes;

after-sales service and management of support and contact requests;

the development of marketing activities relating to its Services, as well as to analyze and understand our customers in order to improve our service (including the user interface experience) and optimize the selection of products offered.

For further information and details on the Personal Data specifically relevant to each purpose, the User may request information from the Data Controller by contacting them at the details provided at the beginning of this document.

USER RIGHTS

Users may exercise certain rights with regard to the Data processed by the Data Controller. In particular, the User has the right to:

withdraw consent at any time. The User may withdraw consent to the processing of their Personal Data previously expressed.

object to the processing of their Data. The User may object to the processing of their Data when it is carried out on a legal basis other than consent. Further details on the right to object are provided in the section below.

access their Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing, and to receive a copy of the Data processed.

verify and request rectification. The User may verify the accuracy of their Data and request that it be updated or corrected.

obtain restriction of processing. Under certain conditions, the User may request the restriction of the processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than storage.

obtain the deletion or removal of their Personal Data. Under certain conditions, the User may request the deletion of their Data by the Data Controller.

receive their Data or have it transferred to another data controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to have it transferred without hindrance to another controller. This provision is applicable when the Data is processed by automated tools and the processing is based on the User's consent, on a contract to which the User is party, or on contractual measures related to it.

file a complaint. The User may file a complaint with the competent data protection supervisory authority or take legal action.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public powers vested in the Data Controller, or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that they may block the receipt of newsletters from the Data Controller at any time and without providing any reason. To do so, Users are invited to visit the "Preferences" subsection within the "Profile" section of the Website.

How to exercise your rights

To exercise their rights, Users may send a request to the contact details of the Data Controller indicated in this document. Requests are processed by the Data Controller as quickly as possible, and in any case within one month.

COOKIE POLICY

This Application uses Cookies. To learn more and to view the detailed information, the User can consult the Cookie Policy.

FURTHER INFORMATION ON PROCESSING

Legal defense

The User's Personal Data may be used by the Data Controller in court or in the preparatory stages of any legal proceedings to defend against abuse in the use of this Application or related Services by the User.

The User acknowledges that the Data Controller may be required to disclose the Data by order of public authorities.

Specific information

At the User's request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For operational and maintenance purposes, this Application and any third-party services it uses may collect system logs, i.e., files that record interactions and may also contain Personal Data, such as the User's IP address.

Any information not contained in this policy

Any further information regarding the processing of Personal Data may be requested at any time from the Data Controller using the contact details provided.

Response to“Do Not Track” requests

This Application does not support"Do Not Track" requests.

To find out whether any third-party services used support them, the User is invited to consult the respective privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page. Please therefore consult this page regularly, referring to the date of the last modification indicated at the bottom. If you do not accept the changes made to this privacy policy, you must stop using this Application and may request the Data Controller to remove your Personal Data. Unless otherwise specified, the previous privacy policy will continue to apply to Personal Data collected up to that point.

LEGAL REFERENCES

This privacy policy has been drafted in accordance with Regulation (EU) 2016/679 and Directive 2009/136/EC on cookies.

DEFINITIONS USED

Personal Data (or Data)

Personal data is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, identifies or makes identifiable a natural person.

Usage Data

This is information collected automatically through this Application (including from third-party applications integrated into this Application), including: the IP addresses or domain names of the computers used by the User connecting to this Application, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various products added to the shopping cart and possibly purchased, the various time characteristics of the visit (for example, the time spent on each page) and details of the route taken within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the User's operating system and IT environment.

User

The individual who uses this Application, who, unless otherwise specified, coincides with the Data Subject.

Interested

The natural person to whom the Personal Data collected refers.

Data Processor (or Processor)

The natural person, legal entity, public administration, and any other entity that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Controller)

The natural or legal person, public authority, service, or other body that, individually or jointly with others, determines the purposes and means of personal data processing and the tools used, including the security measures relating to the operation and use of this Application. Unless otherwise specified, the Data Controller is the owner of this Application.

This Application

The hardware or software tool through which Users' Personal Data is collected and processed, either through the website or any Tommaso Giordano applications for mobile devices, if applicable.

Service

The Service provided by this Application as defined in the relevant terms (if any) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document shall be understood to extend to all current member states of the European Union and the European Economic Area.

Cookies

Small portion of data stored within the User's device.

Unless otherwise specified, this privacy policy applies exclusively to this Application.

Last modified: July 1, 2021