Alajmo S.p.A. (“Alajmo”), having its registered office in via Liguria n. 1, Sarmeola di Rubano, (PD) (tax code/VAT number 04384890283) is the Data controller of the personal data which you will share by registering to the Alajmo+ Club through the website www.alajmo.it (the “Website”). In this Policy we will also refer to you as the “Data subject”, that is the person to whom the personal data relate.
The Data controller has appointed a DPO (“Data Protection Officer”), which you may contact at email@example.com, if you have any doubt regarding the processing of your data or if you want to exercise your rights.
Which personal data do we collect?
Through the Website, we collect the following data:
- Browsing data: the computer systems and software procedures used to operate the Website collect some personal data, whose transmission is an integral part of Internet communication protocols. We cannot directly identify you through such data, but this could still be possible in the event that they are elaborated and associated with other sets of data provided elsewhere. We collect in particular information about:
- your IP address;
- the URI (Uniform Resource Identifier) of the requested sources;
- the time and date in which you use the Website;
- the operating system, the browser used, the screen resolution and other information relating to the device environment.
- Data provided on a voluntary basis (e.g., name, surname, e-mail address): Alajmo will process these data, in accordance with the applicable law, to achieve the purposes specified in each form and in this Policy. The indication of certain data is compulsory in order to ensure the correct performance of the services required to the Data Controller. We presume that the data you communicate refer to you or to third parties who have authorised you to provide them. In this case, you assume all relevant obligations and responsibilities.
How do you process my data? On which legal basis?
Your personal data will be processed through informatic and/or telematic instruments, with organizational arrangements and procedures strictly related to the purposes listed hereunder.
Alajmo has adopted specific security measures in order to prevent the loss of personal data or illicit or incorrect uses thereof or unauthorised access.
In all the cases in which Alajmo processes your data, it is allowed to do so pursuant to a specific legal basis which legitimates the processing.
Sometimes we need your consent to process your personal data, for example in order to use analytics or profiling cookies or to send you a newsletter.
Other times, to the extent of governing laws and subject to your rights, Alajmo may process your data without asking for your consent. We are allowed to do so when we process your data to comply with a legal obligation or to reply to a request that you made by contacting Alajmo or by requiring services through the Website.
Any refusal to provide data which are indicated as “necessary” may prevent Alajmo from replying to your requests or from complying with legal obligations to which Alajmo is subject.
At the end of the data retention period, the collected personal data will be irreversibly anonymised or deleted.
PERSONAL DATA SUBJECT TO PROCESSING, PURPOSES, LEGAL BASIS/RETENTION PERIOD
1) to collect anonymized statistics information on the use of the Website and to verify its correct functioning;
2) to ascertain responsibilities for suspected cyber-crimes committed through the Website, against it or against the Data controller, following the request of surveillance authorities.
6.1.b GDPR– Contract (Purpose n.1)
6.1.c GDPR – Legal obligation (Purpose n. 2)
For the time that is technically required to execute the functions for which the data are collected and for a maximum of 6 months. The Data controller could be obliged to retain the personal data for a longer period in accordance with legal obligations or with the order of authorities.
Data provided to Alajmo’s addresses per e-mail or per chat:
1) to respond to your requests
6.1.b GDPR – Contract or steps prior to entering into a contract (Purpose n.1)
6.1.c GDPR – Legal obligation (Purpose n.1)
For the duration necessary to respond to your requests. For the period necessary for the establishment, exercise or defence of legal claims or for executing legal obligations
Data provided through the form for the creation of a new account Alajmo+ Club (name, surname, birth date, e-mail address, telephone number):
1) to participate in the collection of points and to grant the prize for the fidelity program;
2) for checks and evaluations on the offered services and products and on the risks connected to them (e.g., on the validity of the shared information);
3) for direct marketing purposes;
4) with your previous consent, for profiling purposes. More specifically, by processing your personal data we will be able to gain information regarding your interests and preferences related to the offered products and services and we will use this in order to customize your experience and to suggest you in advance offers which align with the expressed preferences, by sending customized commercial communications.
6.1.b GDPR – Contract (Purpose n. 1)
6.1.a GDPR – Consent (Purpose n. 4)
6.1.f GDPR – Legitimate interest (Purposes no. 2, 3)
For 15 (fifteen) days after the deletion of the account, or until the Data subject has withdrawn its consent or has objected to the data processing
Data collected through cookies:
1) as regards technical cookies, to allow the correct functioning of the Website;
2) as regards analytics cookies, with your previous consent we will process your data to track your visits to the Website and how you have used it, in order to improve our services;
6.1.a GDPR – Consent (Purposes no. 2, 3)
6.1.b GDPR – Contract or steps prior to entering into a contract (Purpose n.1)
The services of the Website are offered only to persons who are not underage. If you are under the age of 18, you should not give your personal data to the Data controller and you cannot take advantage of the offered services. If we find out that you are an underage user, we will immediately and irreversibly delete your personal and non-personal data and your accounts.
Will my data be shared with other subjects?
Alajmo will not disseminate your personal data nor will communicate them to unspecified subjects. Nevertheless, your data may be communicated to identified subjects for established purposes. These subjects may be appointed as Data processors, when necessary. The subjects who may have access to the data include but are not limited to:
- subjects authorised by Alajmo to process personal data, that are committed to, or under, an appropriate statutory obligation of confidentiality;
- subjects in charge of the maintenance of the Website and our legal or tax consultants, who will act as data processors or data controllers;
- public authorities, according to applicable laws.
You can always ask for an updated list of the Data processors by writing an e-mail to: firstname.lastname@example.org.
More specifically, if you register to the Alajmo + Club, your data will be processed by HubSpot Inc. (having its registered seat in the USA) and by Think Design Ltd, which have been appointed as Data processors.
On the Website you find some links which lead to the social network pages of Alajmo, to allow easy access to those contents. Such links do not send your personal data to the social networks as long as you are on our Website and do not click on them. The cookies of the social networks can be activated only through their pages. If you navigate on our Website after having logged in to a social network, you have already expressed your preferences for the cookies. In any case, the processing of personal data by social network platforms is regulated by their own privacy policies, to which you should refer for more precise information.
How can I delete my personal data?
If you create an account on our Website, you may delete it at any time by sending an e-mail to: email@example.com. Consider that if you have bought anything on the e-commerce, the data which are necessary for the execution and the invoicing of the orders may be retained by Alajmo for a longer period, as specified above.
Which rights do I have as Data subject?
You will always keep control of your personal data.
More specifically, you have the right:
- to request information about the personal data processed by Alajmo and to receive in a structured, commonly used and machine-readable format the personal data concerning you;
- not to be subject to a decision based solely on automated processing, unless you have provided your explicit consent;
- to ask the Data Controller for the rectification or the erasure of your personal data or the restriction of their use only for certain purposes;
- to change your idea and ask us to stop processing your data, for example by deleting your account;
- to withdraw your consent.
If you gave your consent to profiling, you could withdraw it at any time by writing to: firstname.lastname@example.org .
If you want to withdraw your consent to the newsletter, you can also use the link “unsubscribe” which you can find in all the e-mails.
In some limited cases, we may not be able to comply with your requests, as long as it is forbidden by law provisions or by the act of a public authority.
The requests to exercise your rights shall be sent to the DPO: email@example.com .
In any case, you have the right to lodge a complaint with the relevant supervisory authority (Data Protection Authority) if you believe that the processing of your personal data is against the applicable law.
Where do you store my data?
However, the Data Processors declare that the third countries guarantee an adequate level of protection of data subjects’ rights by virtue of compliance with one or more of the conditions set out in Articles 45-47 of the GDPR.
In any case, United States authorities may have access to the data collected by US companies, under the conditions established by US law.