Privacy Policy in accordance with art. 13 GDPR

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 communicate by using the shop and the e-commerce on 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 privacy@alajmo.it, 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:

Personal data: name, surname, address, telephone number, e-mail address, tax code, VAT number, credit card number and name of its holder, CVV code, details about other means of payment, notes and messages

Data belonging to special categories: only if voluntarily communicated by the Data subject in the messages sent with the orders. Such data will not be used by the Data controller and will be immediately deleted.

The indication of the required personal 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.

The personal data which are spontaneously communicated by the Data subject will be accessible to the Data controller and to subjects authorised by him.

The data collected for the use of the online shop will be processed only in an anonymized and aggregated form for statistical purposes.

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 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

Browsing data:

1) To collect essential information for the correct functioning of the Website;

2) to collect anonymized statistics information on the use of the Website and to verify its correct functioning; 

3) 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.f – Legitimate interest (Purpose n. 2)

6.1.c GDPR – Legal obligation (Purpose n. 2)

Retention period:

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)

Retention period:

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 collected for the creation of a new account and for purchases as a registered user:  

1) to allow your purchases through the e-commerce; 

2) to save data for the invoicing and shipping addresses;

3) if you buy through the online shop, for the compliance with our legal obligations, especially with tax law; 

4) to store information related to your previous orders; 

5) to contact you in case there are problems with the orders (especially for products which are not available or for the communication of incorrect information);

6) for direct marketing purposes.

6.1.b GDPR – Contract (Purposes no. 1, 2, 4, 5)

6.1.c GDPR – Legal obligation (Purpose n. 3)

6.1.f GDPR – Legitimate interest (Purpose n.6)

Retention period:

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. When necessary, for the duration required to execute legal obligations or for the establishment, exercise or defence of legal claims. 

Data collected if you purchase as a non-registered user: 

1) to allow your purchases through the e-commerce;

2) for the compliance with our legal obligations, especially with tax law; 

3) to contact you in case there are problems with the orders (especially for products which are not available or for the communication of incorrect information);

4) with your previous consent, to send you marketing communications related to Alajmo’s products, services and offers. 

6.1.a GDPR – Consent (Purpose n. 4)

6.1.b GDPR – Contract (Purposes no. 1, 3)

6.1.c GDPR – Legal obligation (Purpose n. 2)

Retention period:

Until the execution of the order or, only for strictly necessary data, for the duration required for the execution of legal obligations or for the establishment, exercise or defence of legal claims. The data processed for marketing communications will be processed until the withdrawal of the consent.

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;

3) as regards profiling cookies, the data collected with your previous consent may be processed to show you targeted advertisements on this and on other websites; if you do not accept them, you will still see advertisements, but they will not be based on your interests. For more information, see the Cookie Policy.

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)

Retention period:

Until the end of each browsing session or for the retention period indicated for each specific cookie, unless you previously withdraw your consent. For more information, see the Cookie Policy.

Underage users

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: privacy@alajmo.it

More specifically, if you buy anything on the e-commerce, the data which you will communicate to create your account and/or for the purchase will be processed by Shopify Inc, having its registered seat in Canada, which has been appointed as Data processor.

Data for the payments will be processed by PayPal, Google and by the other subjects indicated on the Website, which act as Data controllers in accordance with their privacy policies and/or as Data processors.  

If you accept third parties’ cookies, your data will be shared with the subjects indicated in our Cookie Policy .

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: privacy@alajmo.it. 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. 

To know how to delete cookies, read our Cookie Policy.

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 for marketing communications, you could withdraw it at any time using the function “unsubscribe” which you can find in all the e-mails or writing to: privacy@alajmo.it

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: privacy@alajmo.it .

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?

Your personal data may be transferred outside the European Union by the Data processors. Data collected by third parties’ cookies may be transferred to Third countries as provided for in our Cookie Policy and in such third parties’ privacy policies.

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.

Will you amend this Privacy Policy?

Alajmo reserves the right to amend or update the content of this Privacy Policy whenever necessary. In the event of substantial amendments, especially referring to the purposes of the processing, we will inform you by sending an e-mail to the provided e-mail address. If you do not agree with the amendment, you will be free to quit using our services, by deleting your account on the Website and/or by avoiding the communication of additional data.