Copy of Privacy Policy
PRIVACY POLICY
This page describes the characteristics of the processing of personal data of users (the “Users”) of the website https://www.davidhalfon.com/it/ (the “Site”). Users of the Site may be simple visitors, or they may sign up for the newsletter service, register and create an account or, again, purchase on the e-commerce and/or use the customer service.
This is the information provided pursuant to European Regulation 2016/679 (the “GDPR”) and Legislative Decree 196/2003 - Personal Data Protection Code (the “Privacy Code”) to those who interact with the web services of Almavida SA Halfon (David Halfon).
INFORMATION
The Information is provided only for this Site and not for other websites, apps and/or third-party content of any kind, possibly consulted by the User via links accessible from the Site. In these cases, the provisions on data protection of such third parties may be applicable, which may be different from those reported in this Information and which we recommend consulting before communicating any data.
This Policy describes the methods, timing and nature of the information that the Owner (as defined below) must provide to Users when processing their personal data.
THE DATA CONTROLLER
For the purposes of this Policy, the data controller is Almavida SA Halfon, with registered office in Via Attilio Friggeri 129, 00136 – Rome (RM), VAT number 17291931008 (“Almavida” or the “Data Controller”).
To resolve any doubts about how the Data Controller processes personal data, it is always possible to contact him at the addresses indicated in the “Rights of interested parties” section of this Policy.
DATA PROCESSED
DATA COLLECTED BY THE OWNER - BROWSING DATA
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.
This information is not collected to be associated with identified interested parties, but by its very nature could, through processing and association, allow Users to be identified.
This category of data includes the IP addresses or domain names of the computers used by Users who connect to the Site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the User's IT environment (the "Navigation Data").
These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Site: except for this eventuality, at present the data on web contacts do not persist for more than seven days.
COOKIES
The Site uses cookies and similar technological tools to collect and store data relating to the use, access or interaction through the Site. For further information relating to the use of cookies, please refer to the additional and specific EXTENDED INFORMATION published on this Site and drawn up in accordance with the provisions of the Provision of 10 June 2021 issued by the Italian Data Protection Authority, which integrates and completes this document.
DATA PROVIDED VOLUNTARILY BY THE USER – personal data, contact data and purchase data
Users within the Site have the possibility to:
forward messages and requests to Almavida addresses. Any optional, explicit and voluntary sending of messages and requests entails the subsequent acquisition of personal data of the Users necessary to respond to them, as well as any additional personal data possibly included in the communications; sign up for the newsletter service, create your own account and make a purchase on the e-commerce.
In the context of the above activities, Users must provide Almavida with the necessary and requested personal data through the various forms on the Site. The data marked with an asterisk (*) are mandatory and necessary to complete the action and failure to provide them does not allow Users to proceed and conclude the procedures.
In particular, Almavida collects the following personal data:
name, surname, residential address, country of residence, nationality and date of birth (the “Personal Data”);
telephone number, email address (the “Contact Data”).
data relating to purchases such as the products purchased, location, date, time, purchase history, delivery data, payment and billing methods, as well as any personal data present in communications between the interested party and the Data Controller, and relating to the products purchased or of interest to the customer (the “Purchase Data”).
The Browsing Data, the Personal Data, the Contact Data and the Purchase Data are jointly defined as the “Data”.
PURPOSE OF THE PROCESSING AND RELATED LEGAL BASIS
ACCOUNT
The Data communicated by Users during registration on the Site (including shipping and payment data) will be processed to allow the User to register an account on the Site, insert products into the wishlist, complete the purchase of the desired products, manage their reserved area.
The Owner may receive the User's identification and contact data from Facebook or Google, in the case of User login through Facebook and Google+. The personal account requires the use of authentication credentials that are known only to the User, and that the latter must keep carefully and under his/her full and exclusive responsibility.
Registering on the Site allows you to benefit from some advantages, such as invitations to exclusive promotions, birthday discounts and a simpler check-out procedure in the case of online purchases. Creating an account is not necessary to make online purchases, which can also be made in simple visitor mode of the Site.
The legal basis for such processing is the need to execute a contract to which the User is a party and/or pre-contractual measures adopted at the request of the same, and to comply with related legal obligations.
Any refusal by Users to provide their personal data will make it impossible to complete the account registration.
RESPONSES TO USER REQUESTS
The Data will be processed to respond to requests sent by Users to the contact details, or by filling in the forms available on the Site, such as the online form "Contact us", including communications forwarded to Customer Service.
The legal basis for such processing is the need to execute a contract to which the User is a party and/or pre-contractual measures adopted at the request of the same, and to comply with related legal obligations.
The processing of the Data as described above is necessary; in its absence, it will not be possible to respond to User requests.
ONLINE SHOPPING
The Data will be processed to manage purchase orders (including sending information and service communications via email on the status of the order; carrying out the related shipments; pre- and post-sale customer support) and to allow Almavida to fulfill legal obligations.
The legal basis for the processing is the need to execute a contract to which the User is a party and/or pre-contractual measures adopted at the request of the same, and to comply with the related legal obligations.
The processing of User Data is necessary to complete the purchase procedure, in case of refusal by the User, the same will not be able to complete the purchase of products on the Site.
Customer Satisfaction surveys
Within 48 days of purchase and/or 30 days of request to our customer service, Users will receive customer satisfaction surveys and polls via email to ask Users to evaluate Almavida (David Halfon) products and/or their experience with customer service.
Participation in customer satisfaction surveys is optional and the data collected may be used to improve the products and services offered by Almavida.
The legal basis for this processing is Almavida's legitimate interest in keeping its Users satisfied with the products and customer service offered. This interest is balanced with that of the Users, as it is reasonable to believe that the customer is interested in finding and purchasing quality and non-defective products and in being able to ask for assistance from a qualified customer service.
“Soft marketing” communications
The Data (and, in particular, the e-mail address provided by the User at the time of registration on the Site and finalization of the purchase) will also be processed to send commercial, promotional and advertising communications via e-mail exclusively regarding David Halfon branded products, similar to those already purchased or used by the User.
Pursuant to art. 130 co. 4 of the Privacy Code, this processing finds its legal basis in the legitimate interest of Almavida to keep its customers constantly informed and updated on the offer of new products and services available from time to time on the Almavida website (www.davidhalfon.com), as well as on the promotions and/or initiatives promoted by the same. This legitimate interest is balanced and compatible with the interest of the User, as it is reasonable to believe that those who purchase a David Halfon brand product or use a service through the Site are interested and expect to receive updates on the catalog of David Halfon products and services.
At any time, the interested party has the possibility to oppose the processing carried out for the purposes described above, easily (following the procedure indicated in each commercial communication or using the contact details of the Data Controller indicated below) and at no cost.
Any opposition to the processing by the interested party will not affect the lawfulness of the processing carried out up to that point, nor will it have any effect on the future purchase of David Halfon branded products.
Newsletter – Marketing
The Data will be processed to allow Users to register and use the David Halfon newsletter service. In the event of a request to register for the newsletter service, the Data will be processed to respond to the request and allow the sending, via email and/or SMS, of messages containing informational, promotional, commercial, advertising material relating to David Halfon products and invitations to events and communications of any extraordinary openings/closures of stores, catalogs and invitation postcards to events and special promotions of David Halfon.
The processing of Data for the purpose of sending the newsletter will be possible only with the explicit, free and informed consent of the User, which may be given by ticking the relevant box in the registration forms (i.e. account, contact us) or by filling out the explicit request for registration in the "Newsletter Subscription" section. Failure to give consent does not prevent the User from completing online purchases, browsing the David Halfon website, sending requests for information, or receiving non-profiled communications.
If the User intends to revoke the consent given, he/she may at any time oppose the processing described here by writing to David Halfon at the addresses indicated in the section “Rights of the Interested Parties”. In any case, any opposition will not affect the lawfulness of the processing activities carried out up to that point by Almavida.
Profiling
Subject to consent collected when completing the purchase procedure, the Data relating to the products purchased, preferred and/or included in the wishlist will be processed - with automated methods - also for profiling purposes, i.e. to analyse the User's consumer choices and consequently personalise the commercial and promotional communications sent by the Data Controller, and to better assist the User in their purchases, both online and in David Halfon stores, suggesting products that may interest them.
This profiling does not involve the adoption of automated decisions that produce legal effects on Users.
The processing is possible only with the explicit, free and informed consent of the User, which may be given by ticking the relevant boxes on the Site. Failure to give consent does not prevent the User from making online purchases, browsing the David Halfon site, sending requests for information, or receiving non-profiled communications.
If the User intends to revoke the consent given, the same may at any time oppose the processing of personal data by writing to Almavida at the addresses indicated in the section "Rights of the Interested Parties". In any case, any opposition will not affect the lawfulness of the processing carried out on the basis of the consent before the revocation.
In the event that the preference in relation to consent is given more than once (for example, because multiple purchases are made or because an account is created and a purchase is made), the choice made last will prevail.
Right of defense
When necessary, the Data may be used to allow the Owner to fulfill legal obligations incumbent on the same; as well as to guarantee the right of defense of the Owner in court or arbitration with reference to any disputes relating to the execution of contracts concluded with the same.
The legal basis for such processing is the need to fulfill the related legal obligations incumbent on the Data Controller; as well as the legitimate interest of the Data Controller in defense in court. Legitimate interest which, in the balancing of the interests of the parties, does not entail a violation of the rights and freedoms of the User, since judicial defense is a right guaranteed by the legal system.
DATA PROCESSING METHODS
The Data will be processed, on the basis of adequate operating instructions provided by the Data Controller, exclusively by the personnel and collaborators of the same or of the companies expressly appointed as data controllers. Among these:
companies affiliated with the Almavida SA Halfon commercial network that manage the David Halfon franchise stores. The latter will be given the data of those who have created an account on the Site and/or who have made an online purchase, to support Users who go to David Halfon stores both in relation to purchases and for requests for assistance and warranty.
The affiliated companies, where not present in Italy, are all based in States belonging to the European Union and/or which benefit from an adequacy decision of the European Commission and, in the absence of this, have signed the standard contractual clauses approved by the European Commission as an appropriate measure for the transfer of personal data abroad.
Specific and adequate security measures are adopted to prevent the loss of Data, illicit or incorrect use and unauthorized access.
DATA COMMUNICATION
Where necessary for the pursuit of the specific purposes of the processing, the Data may be communicated to third party suppliers of ancillary services (e.g. communication agencies for the preparation and sending of commercial and promotional communications; shippers and carriers for the management of deliveries of products purchased on the e-commerce). These parties will process the Data, depending on the case, as independent controllers, or as data processors by virtue of a specific written assignment conferred to them by the Data Controller.
TRANSFERS TO THIRD COUNTRIES
The Data may be transferred abroad only if the User requests to deliver the products purchased on the e-commerce outside of Italy: in this case, the transfer will take place (if towards countries that do not benefit from an adequacy decision of the European Commission and which, therefore, do not offer an adequate level of protection for personal data) by virtue of the derogation constituted by the need to execute a contract between the Owner and the User.
Retention Period
The Data will be retained only for the period necessary to achieve the purposes for which they are processed. In particular:
for the performance of the activities necessary for the execution of the contract with the User in relation to the purchase of the products, the Data will be retained according to the limitation period established by law;
to guarantee the right to defense, the Data will be stored for 10 years starting from the termination of the contractual relationship established between Almavida and the interested party;
for sending commercial and promotional communications (including personalized ones, if consented to) and the newsletter for a maximum period of 48 months from registration to the newsletter service; this period may be extended by the same duration each time the User renews his/her consent by responding to a specific request sent by Almavida before the expiry of the retention period;
for soft marketing (or soft spam) activities, the Data will be processed in a form that allows the identification of the User only for the period strictly necessary to achieve the purposes for which they were collected and, in particular, for a maximum period of 48 months from collection;
for customer satisfaction surveys, the Data will be processed and stored for a maximum period of 48 months after each individual purchase; and
for profiling activities, the Data will be processed for a maximum period of 48 months from collection.
Please note that the Data may be stored for a longer period if necessary to comply with legal or regulatory obligations and/or for protection.
RIGHTS OF INTERESTED PARTIES
Users have the right at any time to:
obtain access to data;
obtain rectification, erasure or, where applicable, limitation of processing;
object to processing;
revoke consent;
where applicable, receive in a structured, commonly used and machine-readable format, the Data provided to Almavida, as well as transmit such Data to another data controller without hindrance from Almavida; and
lodge a complaint with the Personal Data Protection Authority, or appeal to the Judicial Authority.
At any time, Users may also request the complete list of recipients of the Data.
The rights referred to in this section, and any requests for clarification on the characteristics of the Data processing, may be exercised by writing to the following addresses:
by email, to: shop@davidhalfon.com;
INTEGRATIONS
In the event of substantial changes to this Policy, the Owner will send a notification via email and/or publish a notice on the Site to report the changes and collect any requests to exercise the rights described above.