Politique de confidentialité

INFORMATION ON THE PROCESSING OF PERSONAL DATA pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR)

Premise

This information is provided for the site “cbp.esta.support” (Site) owned by NAPO GROUP SRL, with registered office in Via Gaetano Filangieri 21, Naples (NA) CAP 80121, registered with the Chamber of Commerce of Naples, with VAT no. . 11278790966, share capital of €10,000.00 iv (Data Processor), as Data Processor pursuant to the GDPR and as Data Controller, subject to your consent, for the following activities: Registration; Profiling; Marketing; Soft spamming; sending of newsletters. The Data is given by you to the Seller, as defined in the General Conditions of Sale published on the Site (Data Controller).

Purchases on the Site

Upon your conferment, your personal data will be processed to allow you to request services on the Site.

Registration

The information and data requested in the event of registration will be used to use the online services offered by the Data Controller to registered users.

Marketing

Subject to your consent, the Data Controller and the Data Processor may process the personal data you provide in order to send you advertising material and/or newsletters relating to their own products or those of third parties.

Profiling

Subject to your consent, the Data Controller and the Data Processor may process your personal data for profiling purposes, i.e. for the analysis of your consumption choices by revealing the type and frequency of purchases you make, in order to send you advertising material and/or newsletters relating to its own products or those of third parties, of specific interest to you.

Soft spamming

the Data Controller and the Data Processor may use, for the purpose of direct sale of services or products offered for sale through the Site, the e-mail coordinates provided by you in the context of a purchase on the Site, even without your consent, provided that it is a product similar to that of the previous sale (so-called soft spamming). However, you may refuse this treatment at any time by communicating your objection to the Data Controller.

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In compliance with the GDPR, we hereby inform you that the Data Controller will process your personal data under the following conditions.

Art. 1. Purpose and legal basis of the processing. Compulsory or optional provision. Consequences of refusal to treatment.

The processing of personal data is aimed at achieving the following purposes:

  1. to allow registration on the Site and access to services reserved for registered users as well as to allow compliance with the obligations deriving from the law or regulations in force, in particular, in the administrative, accounting and public safety fields. The legal basis of the processing is the need for the Data Controller and/or the Data Processor to carry out pre-contractual measures adopted at the request of the interested party or to fulfill a legal obligation;
  2. in the case of placing an online purchase order, to allow the conclusion of the purchase contract and the correct execution of the operations connected to the same (and, if necessary according to sector legislation, to fulfill tax obligations). The legal basis of the processing is the obligation of the Data Controller and/or the Data Processor to execute the contract with the interested party or to comply with legal obligations;
  3. limited to the e-mail coordinates provided by you in the context of a purchase through the Site, to allow the direct offer by the Data Controller and/or the Data Processor of similar products (so-called soft spamming), provided that you do not oppose this treatment in the manner provided for by this information. The legal basis of the processing is the legitimate interest of the Data Controller and/or the Data Processor to send this type of communication. This legitimate interest can be considered equivalent to the interested party’s interest in receiving “soft-spam” communications;
  4. subject to your consent, for sending newsletters and for carrying out market surveys, also aimed at assessing the degree of user satisfaction, and for sending advertising material relating to products of the Data Controller and/or third parties , by means of systems such as email (marketing purposes); subject to your consent, for the development of your commercial profile, through the detection and processing of your choices and purchasing habits, in order both to monitor the degree of customer satisfaction and to send you advertising material relating to the products of the Data Controller and/or third parties, of your specific interest, by means of systems such as email (profiling purposes). The legal basis of the processing is the consent of the interested party;

And. to respond to your requests through the customer care service. The provision is optional, but your refusal will make it impossible for the Data Controller and/or the Data Processor to answer your questions through this service. The legal basis of the processing is the legitimate interest of the Data Controller to follow up on the user’s requests. This legitimate interest is equivalent to the user’s interest in receiving a response to communications sent to the Data Controller;

  1. to reply by email, telephone to your requests. The provision is optional, but your refusal will make it impossible for the Data Controller and/or the Data Processor to respond to your requests. The legal basis of the processing is the legitimate interest of the Data Controller to respond to user requests. This legitimate interest is equivalent to the user’s interest in receiving a response to communications sent to the Data Controller.

The provision of data for the purposes referred to in points a) and b) is purely optional. However, since this processing is necessary to make a purchase on the Site, your refusal to provide the data in question will make it impossible to make this purchase through the Site.

The consent to the processing of your data for marketing and profiling purposes is purely optional. Failure to consent will only imply the consequences described below.

Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to products of the Data Controller and/or third parties as well as the impossibility for the Data Controller and/or the Data Processor to carry out market surveys, also aimed at assessing the degree of user satisfaction, as well as send you newsletters.

Failure to consent to the processing of your personal data for profiling purposes will make it impossible for the Data Controller and/or the Data Processor to process your commercial profile, by detecting your choices and purchasing habits as well as sending you material advertising, relating to products of the Data Controller and/or third parties, of your specific interest.

Without prejudice to the foregoing, it is understood that the Data Controller and/or the Data Processor may in any case use your personal data for the sole purpose of correctly fulfilling the obligations established by the laws in force and the obligations deriving from the contractual relationships existing between you and the Data Controller.

We remind you that you may also object to the processing of your personal data via the appropriate link at the bottom of any promotional email sent by the Data Controller and/or the Data Processor.

Data provided as part of the service

On the Site you will have the possibility to give one or more products to a person by entering the personal data requested from time to time. You are aware that the Data Controller and/or the Data Processor will keep such personal data for the time strictly necessary to document that they have processed your request. To use this service, you must be able to demonstrate, if requested by the Data Controller and/or by the Data Processor, that you can legitimately use the personal data of your friends/contacts.

Payment card data

To make a payment using one of the payment cards offered on the Site, the user must enter the confidential data of the payment card directly on a page which will communicate via secure encryption protocol with the payment service provider (who will act as autonomous Data Controller), without passing through the server of the Data Controller who, therefore, will not process such data in any way. The data will be acquired in encrypted format.

With reference to the payment card data, it should be noted that the processing of your personal data is necessary to allow the conclusion of the online purchase contract with the Data Controller. Failure to provide this data, therefore, will not allow you to complete the online purchase process.

Particular or judicial data

The Data Controller does not process particular or judicial data.

Art. 2. Processing methods

The processing of your personal data will mainly be carried out with the aid of electronic or automated means, according to the methods and with the tools suitable for guaranteeing security and confidentiality in accordance with the GDPR.

The information acquired and the methods of treatment will be pertinent and not excessive with respect to the type of services rendered. The data will also be managed and protected in environments whose access is under constant control.

Art. 3. Communication and dissemination of data

Your data may be communicated:

  • to all those subjects (including the Public Authorities) who have access to personal data by virtue of regulatory or administrative provisions
  • to companies or third parties responsible for printing, enveloping, shipping and/or delivery and/or collection of products purchased through the Site
  • to post offices, couriers, suppliers (e.g. drop shipping sales) or shippers in charge of delivering the products purchased through the Site
  • to banks and companies that manage the national or international payment circuits through which online payments are made for products purchased through the Site
  • to companies, consultants or professionals possibly in charge of the installation, maintenance, updating and, in general, the management of the hardware and software of the Data Controller or which the latter uses for the provision of its services
  • to external companies responsible for sending advertising communications on behalf of the Data Controller
  • to employees and/or collaborators of the Data Controller
  • to the company in charge of carrying out the customer care activity
  • to subjects who manage online payment transactions
  • to persons responsible for the repair of damaged products or products subject to the legal guarantee of conformity
  • to all those public and/or private subjects, natural and/or legal persons (legal, administrative and tax consultancy firms, Judicial Offices, Chambers of Commerce, Chambers and Labor Offices, etc.), if the communication is necessary or functional to the correct fulfillment of the obligations deriving from the law.

The data concerning you will not be disclosed, except in anonymous and aggregated form, for statistical or research purposes.

Art. 4. Data Processor

The Personal Data Processing Manager can be contacted at the following addresses:

NAPLES (NA) VIA G.FILANGIERI 21 – 80121 NAPLES (NA) ITALY

Telephone: +1 (786) 4542382

Email: info@esta.support

Through the contact form on the Site.

Art. 5. Retention of personal data

Personal data will be stored and processed for marketing purposes for a period of 24 months and for profiling purposes for a period of 12 months. At the end of this period, the Data Controller and/or the Data Processor may ask the user to renew the consent to the processing of his data for these purposes or to make them anonymous and keep them only for statistical or historical purposes.

For all the remaining purposes set out in the privacy information, personal data will be kept only for the time necessary to guarantee the correct provision of the services offered.

In the event of closure of the Site account on the user’s initiative, the data contained therein will be kept for administrative purposes for a period not exceeding 90 days, without prejudice to any specific legal obligations on the conservation of accounting documentation or for public purposes. safety.

Art. 6. Rights of the interested party

Pursuant to art. 13 of the Privacy Regulation, the Data Controller and the Data Processor inform you that you have the right to:

  • ask the Data Controller and/or the Data Processor to access your personal data and correct or cancel them or limit their processing or to oppose their processing, in addition to the right to data portability
  • revoke the consent at any time without prejudice to the lawfulness of the treatment based on the consent given before the revocation
  • propose a complaint to a supervisory authority (e.g.: the Guarantor for the protection of personal data).

The above rights may be exercised with a request made without formalities to the Data Processor at the contacts indicated above or to the Data Controller at the contacts indicated from time to time for each Seller.

Art. 7. Modifications

The Data Processor reserves the right to make changes to this information at any time, giving suitable publicity to the users of the Site and guaranteeing in any case adequate and similar protection of personal data. In order to view any changes, you are invited to regularly consult this information.