Policy on personal data processing based on REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 (GDPR)

Introduction

This privacy policy refers to the website “www.indabwetrust.com” (Sito). The data controller of your personal data is Emanuele Milazzo, with registered office in Messina, registered with the Companies Register of with VAT number 03567180835; (Company).

Purchasing through the Website

The Company shall acquire and process your personal data to process your request to purchase through the Website.

Profiling

If you provide your explicit consent, the Company shall process your personal data for the analysis of your consumer choices and purchasing habits (known as “profiling”), through a study of the type and frequency of your online purchases, in order to send newsletter and/or advertising material of the Company or third-parties that may be of particular interest to you.

Soft Spamming

The Company is entitled to sale its products and / or services using the email that you communicated during your first purchase on the Website, if this product and / or service is similar of the first sale (soft spamming). You may at any time notify the Company of your refusal to receive this type of communication.

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Pursuant to the GDPR, the Seller shall process the personal data provided by you as indicated in this privacy policy.

Article 1. Purpose of the processing. Legal basis. Mandatory or optional nature of data provision and consequences of any refusal.

The Company shall process the personal data provided by you for the following purposes:

a. for administrative/accounting purposes. The legal basis for the processing is Company’s commitment to be compliance with a legal obligation or to take steps at the request of the data subject prior to entering into a contract, as the case may be;

b. in the case of the execution of an online purchase order, to allow the conclusion of the purchase contract and the proper execution of transactions related to the same (and, where necessary, to fulfill tax obligations). The legal basis for the processing is is Company’s commitment to be compliance with a legal obligation or to perform a contract to which the data subject is party;

c. limited to the email address provided by you when purchasing a products and / or services offered on the Website, to enable the direct sale of similar products and / or services (soft spamming), without requiring your express and prior consent and provided that you do not exercise your right to object. The legal basis for the processing is the Company's legitimate interest to perform these activities. This legitimate interest is equal to the user's interest to riceve "soft-spam" comunication;

d. if you provide your explicit consent, if you provide your explicit consent, for the analysis of your consumer choices and purchasing habits (known as “profiling”), by the Company, through a study of the type and frequency of your online purchases, in order to send informative and/or advertising material about products and / or services of the Company and / or third-parties, that may be of particular interest to the user, (profiling purposes). The legal basis for the processing is your consent;

e. to respond to your requests through the customer care service. The provision of data is purely optional. However, as the said processing is necessary in order to respond to your request, your refusal to provide the relevant data will prevent you from obtaining answer from the customer care of the Company. The legal basis for the processing is the Company's legitimate interest to perform these activities. This legitimate interest is equal to the user's interest to use the customer care service of the Website;

f. in order to answer to your requests by email, by telephone. The provision of data is purely optional. However, as the said processing is necessary in order to respond to your request, your refusal to provide the relevant data will prevent you from obtaining answer from the customer care of the Company. The legal basis for the processing is the Company's legitimate interest to perform these activities. This legitimate interest is equal to the user's interest to receive answer by the Company.

The provision of data for the purposes set out in at Point b) is purely optional. However, as the said processing is necessary in order to enable you to register with the Website and to provide the online purchasing your refusal to provide the relevant data will prevent you from registering with the Website andfrom completing an online purchase.

Consent to profiling purposes is purely optional. Failure to consent will have the following consequences.

Failure to consent to the processing of personal data for profiling purposes will prevent the Company from studying the type and frequency of your online purchases, in order to send to you newsletter and/or advertising material that may be of particular interest to you regarding products and / or services of the Company and/or third-parties.

It is understood that the Company may use your personal data to comply with legal obligations and to perform the purchase contract.

Payment Card Data

In order to make a payment through one of the payment cards offered on the Website, you shall enter the data of the payment card directly on a page that will communicate through secure encryption protocol with the payment service provider (which will act as an independent data controller). These data will not pass through the server of the Company which, therefore, will not process such data in any way.

To provide the above-indicated data is necessary to make purchases on the Website.

PayPal

You may make purchases using PayPal. In this event, you will be directed to a page outside the Website, where you must indicate the personal data requested by PayPal to complete the purchase process (PayPal will act as a data controller). These data will not pass through the server of the Company which, therefore, will not process such data in any way. To provide the above-indicated data is necessary to make purchases on the Website.

Wire Transfer

If you choose to pay by bank transfer, the Company may ask to you your bank details in order to make reimbursement in your favor.

Special Categories of Personal Data. Judicial Data.

The Company does not process special categories of personal data nor judicial data.

Article 2. Methods of Processing Personal Data

The processing of your personal data will be carried out by electronic or automated means, in the manner and with the appropriate tools to ensure the security and confidentiality in accordance with the GDPR.

The information and methods of processing will be relevant and not excessive in relation to the type of services provided. Data will be managed and protected in environments where access is under constant control.

Article 3. Data Disclosure

For the purposes described in this privacy policy, the personal data provided by you may be disclosed or communicated to the following parties:

• to all those parties (including Public Authorities) that have access to the data by virtue of regulatory or administrative measures
• to third parties in charge of printing, enveloping, shipping and/or delivery and/or collection of products purchased through the Website
• to forwarding agents and to parties responsible for the delivery and/or collection of the products purchased
• to parties who process online payment transactions
• to companies, consultants or professionals in charge of the installation, maintenance, updating and the management of the Company's hardware and software or which the Company uses for the provision of its services
• to the company in charge of the customer care service
• companies managing online payment transactions
• third parties in charge of for repairing damaged products or products subject to the legal guarantee of conformity
• to all those public and/or private parties, natural and/or legal persons (legal, administrative and tax consultancy firms), where the communication is necessary or of practical use for the correct fulfilment of contractual obligations undertaken in relation to the services provided through the Website, and of legal obligations.

Your data may be disclosed only in anonymous and aggregated form for statistical or research purposes.

Article 4. Data Controller

You can contact the Company, as Data Controller, at the following addresses:

Via Ghibellina 88
By telephone, calling: 0031685401944
By email, writing to: info@indabwetrust.com
By selecting the contact form on the Website.

You may address requests relating to the processing of your personal data to both the Data Controller and the Data Protection Officer.

Article 5. Data Storage

 

Your personal data will be stored only for the period of time required to ensure the correct provision of the services offered, in any case not beyond the legal limits.

In any case, it is understood that personal data will be stored and processed for profilingpurposes for the period of time allowed by law and the provisions of the Italian Data Protection Authority. At the end of this period, the Company may ask you to renew your consent to the processing of your data or to make them anonymous and keep them only for statistical or historical purposes.

 

Article 6. Transfer of Personal Data to Third Countries

The Company will transfer your personal data to to Netherlands. With reference to this country the European Commission has established that the protection of personal data is inadequate. Therefore, you acknowledge that the transfer of personal data is risky due to the lack of an adequacy decision by the European Commission and appropriate safeguards.

Article 7. Transfers Subject to Appropriate Safeguards

Your personal data may be transferred to one or more third countries as the Company has provided appropriate safeguards.

You have enforceable data subject rights and effective legal remedies in the third countries.

The appropriate safeguards are the followings: a legally binding and enforceable instrument between public authorities or bodies.

You may obtain a copy of your personal data:

• by contacting the Company (as Data Controller) and/or the Data Protection Officer, if any .

 

Article 8. Rights of the Data Subject

Purstuant to GDPR (Article 13), you have the right to:

• request access to and rectification or erasure of personal data or restriction of processing or object to their processing, in addition to the right to data portability
• withdraw consent at any time without prejudice to the lawfulness of processing based on consent given prior to the withdrawal
• lodge a complaint before a supervisory authority (for instance, the Italian Data Protection Authority).

The above-mentioned rights may be exercised by making a request to at the contacts indicated above.

 

Article 9. Amedments

The Company reserves the right to change this privacy policy at any time, giving suitable notice to users and ensuring in any case an adequate and similar protection of personal data. In order to view any changes, you are invited to regularly consult this privacy notice.