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DATA PRIVACY PROTECTION POLICY

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General

Roberto Petroli owns and operates this website.  This document governs your relationship with Stefania Verità (“www.stefaniaverita.com”). Access to and use of this website and the products and services available through this website (collectively, the "Services") are subject to the following terms, conditions and notices. By using the Services, you are agreeing to all of the Terms of Service, as may be updated by us from time to time. You should check this page regularly to take notice of any changes we may have made to the Terms of Service.

Access to this website is permitted on a temporary basis, and we reserve the right to withdraw or amend the Services without notice. We will not be liable if for any reason this website is unavailable at any time or for any period. From time to time, we may restrict access to all or some parts of this website.


WIX

This website was created on the online website builder platform WIX (www.wix.com). WIX has its own privacy policy according to GDPR regulations and are outlined on its website: https://www.wix.com/about/privacy. By agreeing to the terms of services outlined by Stefania Verità, you are also agreeing to the terms of service of WIX. Please refer to this document if you have any questions regarding their privacy or cookie policies.


External Links

This website may contain links to other websites (the "Linked Sites"), which are not operated by Stefania Verità. Stefania Verità has no control over the Linked Sites and accepts no responsibility for them or for any loss or damage that may arise from your use of them. Your use of the Linked Sites will be subject to the terms of use and service contained within each such site.

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Personal Information Privacy

How is your personal information collected?

We may collect and process your personal information or your personnel through the following various means:

  • You have filled out forms for creating a login membership or communication requests;

  • A correspondence was conducted with us via phone, e-mail, online chat or otherwise;

  • Information was exchanged at a networking event (e.g. dance exhibitions, product demonstrations, school visits);

  • Sharing information on all social media;

  • Filling out an information form during the purchase of our products online or in person;

  • Your personal data is given by filling out a form to receive newsletters and promotions via e-mail or other means.

Your personal data may also be automatically collected when you visit our website by third-party marketing platforms, such as Google, Twitter, Facebook, Youtube, Instagram, and providers of analytics services (Google Analytics). Google Analytics may collect your personal information to tailor the content you see when visiting our website.  These marketing platforms may combine information they collect on our website with data on their platforms and data they collect from other websites or through other sources in order to conduct targeted advertising.  The activities of these third-party marketing platforms are governed by their own privacy policies, not this Privacy Policy.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your data relating to the use of our website to calculate the percentage of users accessing a specific website feature. Aggregated Data may also be used for research and data analysis with the aim of improving the services we offer and may be shared with third parties. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

 

The personal data you give us may include:

  • Your name and title

  • Contact information: phone number, cell number, postal address, billing address, delivery address, e-mail address

  • Information regarding your company’s location, preferences and/or interests

  • Please note that financial details such as your bank account number, paypal account information, credit card number requested on purchase will be provided to our payment service provider WIX when purchasing through our website.This information is collected and stored by a payment service providing company operated by WIX, who is governed by its own data privacy policy as per GDPR requirements and not by this policy.

  • If payments are done via bank transfer, we will need banking specific information such as your IBAN or SWIFT numbers including the information of your bank.

  • Username and password when you create a login for our website.

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How will your personal information be used?

We may use your information for the following purposes:

  • Fulfill order requests and purchases made through our online Website, via e-mail or in-person;

  • To respond to any query or requests that you may submit to us;

  • To maintain a database of clients and suppliers for administrative, accounting and relationship management purposes;

  • to carry out any relevant conflict checks, anti-money laundering and sanctions checks and fulfilling our obligations under relevant anti-money laundering law or regulation (including Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations of 2017);

  • To send you information about our latest offers and services using the e-mail or postal address you have provided but only if you have agreed to the receipt of our newsletter and promotional communications;

  • To provide you with better service and tailor our products to better suit your needs.

  • For internal operations, including troubleshooting, data analysis, testing, research, statistical and survey response analysis;

  • To measure the effectiveness of our marketing strategies and methodologies;

  • Occasionally, we seek customer comments on our products and/or services. These comments allow us to determine which products and/or services our customers should be made aware of based on their specific needs;

  • Personal information is used for record keeping, site management, activities on the site, the fulfillment of requested transactions, and marketing only to members who have consented to such marketing;

  • To comply with any other professional, legal and regulatory obligations which apply to us or policies that we have in place.

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Legal grounds for processing your personal information

We will rely on the following legal basis under European Data Protection Legislation for processing your personal data:

  • Performance of, or entry into, a contract. The personal data that we are required to collect in order to comply with any other professional, legal and regulatory obligations which apply to us must be provided to us in order for us to perform this contract – we would not be able to act for you without this personal data.

  • It is necessary to comply with a legal obligation to which we are subject.

  • We have a legitimate interest in doing so as a services provider (and where our legitimate interests are not overridden by your (or the relevant individual’s) own interests or fundamental rights or freedoms). These legitimate interests will include our interests in managing our relationship with our clients, administering visits to our offices and ascertaining achievement of proper standards/ compliance with policies, practices or procedures, as well as to prevent fraud.

  • Where processing of ‘special category data’ is necessary in the context of the establishment, exercise or defence of legal claims.

  • It is necessary for our legitimate interests (to ensure all staff are appropriately trained and responsive, to ensure great customer service and to develop and grow our business).
     

Sharing your information

  • We may share your details with carefully selected third parties. These may include service providers, support services and organizations that help us to market our services or enable us to fulfill our contractual obligations to you and/or our clients in the course of business.

  • If we share your information with third parties, we will only share your personal data in compliance with the European Data Protection Legislation.

  • We may disclose your information to third parties:
    • if you specifically request to disclose your information or it is necessary to provide our services to you (i.e. when we need to instruct service providers in another jurisdiction to provide advice which you have requested);
    • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
    • if our Website or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
    • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property or safety of our Website, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

  • The third parties include:
    • our bank (as required by The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 which, for the purposes of preventing money laundering or terrorist financing, may require us to disclose your personal data on request to our bank from time to time);
    • our Payment service provider WIX;
    • our insurers;
    • our auditors, including external accreditation bodies;
    • other professional advisors or third parties with whom we engage as part of our work for our clients or who our clients separately engage in the same context;
    • our regulators;
    • our data processors providing catering, security, email security, data governance, archiving and other IT and business support services;
    • our e-mail marketing platform provider and our Website platform provider;
    • selected partner digital agencies and online job application provider;
    • analytics and search engine providers that assist us in the improvement and optimization of our Website (Google Analytics);
    • any third party you ask us to share your data with.

  • We will not rent or sell our users’ or other contacts’ details to any other organization or individual.

 

 

Storage and retention of your personal data

  • We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Unfortunately, the transmission of information via the internet is not completely secure and although we do our best to protect your personal data, we cannot absolutely guarantee the security of your data.

 

  • We will keep your information stored on our systems for as long as it takes to provide the services to you. We may keep your data for longer than our stated retention period if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research, preventing conflicts of interests or statistical purposes. If we do, we will ensure that appropriate safeguards are in place to protect your privacy and only used for those purposes. Any third-party we engage to provide services on our behalf will keep your data stored on their systems for as long as is necessary to provide the services to you.

 

  • Any contact details stored on our client relationship management database will be removed from our mailing lists if they do not interact with our emails (i.e. open emails or click on links within them) for a certain period following which they will be moved to an archive folder before being deleted permanently. By law, we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.

 

  • Roberto Petroli operates with a SSL certificate as indicated by the "s" in https://.  This certificate is a type of encryption that allows for secure connections between our server and browser. Data exchanges will be better secured and protected.

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Sending your information outside of the EEA

  • If we need to share your personal data with a recipient outside the European Economic Area (“EEA”) (e.g. a professional advisor or third party engaged by us or you as part of our work under an engagement letter) we will ensure we do so in compliance with European Data Protection Legislation, including where applicable by ensuring that the transfer is necessary to perform a contract in place with you.

  • When working abroad (including from jurisdictions outside the European Economic Area), we will use our systems and access any personal data in accordance with all the usual policies and procedures.

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Withdrawal of consent

  • In cases where we process your data on the basis that you have provided your consent for us to do so for the purposes set out in this Policy when you submitted your personal data to us, you may withdraw your consent at any time by contacting us at daffymu@libero.it.

 

  • In the case where you do withdraw your consent, we may still be able to process some of the data that you have provided to us on other grounds and will notify you of these at such time.

 

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Your information rights

  • European Data Protection Legislation gives you the right to request access to your personal data (known as a “data subject access request”). This request enables you to receive a copy of the personal data that is in our possession as well as to check that we are lawfully processing this information.

    You can access the personal information we hold on you by contacting us via e-mail at daffymu@libero.it. We may also ask you to provide proof of identity before we show you your personal information – this is to prevent unauthorized access.

  • You have the right to request rectification (correction) of the personal data that is in our possession.

  • You have the right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • You have the right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • You have the right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

  • You also have the right to complain to your data protection regulator, such as the EDPS (https://edps.europa.eu) in Europe.

 

 

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Google Analytics

 

This Website uses Google Analytics, a web analytics service provided by Google Inc. ("Google") Google Analytics uses so-called "cookies", text files that are stored on your computer and that allow an analysis of your use of the Website. The information generated by the cookie about your use of this Website (including your IP address) is transmitted to and stored by Google on servers in the United States. Google will use this information to evaluate your use of the Website, to compile reports on Website activity for Website operators and to provide other services related to Website activity and internet usage. Google may also transfer this information to third parties if required by law or as far as third parties process this data on behalf of Google.

 

Google will in no case associate your IP address with other Google data. You can prevent the installation of cookies by setting your browser software accordingly; however, please note that in this case you may not be able to use all features of this Website to the fullest extent.

 

By using this Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. The data collection and storage can be contradicted at any time with effect for the future. In view of the discussion about the use of analysis tools with complete IP addresses, we would like to point out that this Website uses Google Analytics with the extension "anonymizeIp" and therefore IP addresses are only shortened to exclude a direct personal reference.

 

Roberto Petroli will only pass on personal customer data to third parties that are necessary for the execution or payment of the order (e.g. to the post office for delivery, to a collection agency for non-payment, etc.) for customer information. Our partners delete the personal data of the customers as soon as they are no longer needed and in any case after expiry of the statutory maximum retention period. All personal data is kept strictly confidential.

 

Contact

If you have any additional questions about our privacy policy, want to exercise any of the aforementioned rights or make a complaint, we encourage you to contact our privacy liaison at daffymu@libero.it.

 

Prohibitions

You must not misuse this Website. You will not: commit or encourage a criminal offense; transmit or distribute a virus, trojan, worm, logic bomb or any other material which is malicious, technologically harmful, in breach of confidence or in any way offensive or obscene; hack into any aspect of the Service; corrupt data; cause annoyance to other users; infringe upon the rights of any other person's proprietary rights; send any unsolicited advertising or promotional material, commonly referred to as "spam"; or attempt to affect the performance or functionality of any computer facilities of or accessed through this Website. Breaching this provision would constitute a criminal offense and Stefania Verità will report any such breach to the relevant law enforcement authorities and disclose your identity to them.

We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of this Website or to your downloading of any material posted on it, or on any Website linked to it.

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Intellectual Property, Software and Content

The intellectual property rights in all software and content (including photographic images) made available to you on or through this Website remains the property of Roberto Petroli or its licensors and are protected by copyright laws and treaties around the world. All such rights are reserved by Stefania Verità and its licensors. You may store, print and display the content supplied solely for your own personal use. You are not permitted to publish, manipulate, distribute or otherwise reproduce, in any format, any of the content or copies of the content supplied to you or which appears on this Website nor may you use any such content in connection with any business or commercial enterprise.

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