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INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA
(Articles 13 and 14 of Regulation (EU) 2016/679)

Dear Sir/Madam,
We hereby inform you that Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR") entered into force on 25 May 2016 and became fully applicable on 25 May 2018.
Accordingly, Ethimo S.r.l. provides you with this Privacy Notice pursuant to Articles 13 and 14 of the GDPR and informs you that your personal data will be processed in accordance with the principles of lawfulness, fairness and transparency, while ensuring the protection of your privacy and your rights.

1. Data Controller

The Data Controller is Ethimo S.r.l. with registered office in Via Felice Cavallotti, 8 – 20122 Milan (MI), Italy
Contact details:

2. Categories of Personal Data

Following your request for our services, the Company may process your personal data, including:

  • identification data;
  • contact details;
  • accounting and billing information.

In addition, where applicable and within the limits permitted by law, the Company may process the special categories of personal data referred to in Article 9 of the GDPR, particularly when you submit a job application through the "Careers" section of our website.

3. Purposes of Processing

Your personal data will be processed for the following purposes:

  1. management of sales through the website;
  2. logistics activities necessary for the delivery of orders;
  3. administrative and accounting activities strictly connected with the Company's business operations;
  4. sending informational material regarding the Company's products and services, subject to your prior consent;
  5. sending commercial communications and newsletters, in accordance with the subscription methods available on the website, including newsletter performance tracking through pixel technology;
  6. processing job applications submitted through the "Careers" section, recruitment platforms or other communication channels, including the processing of special categories of personal data contained in CVs where applicable;
  7. management of the Company's social media platforms through the tools made available by the relevant social media providers;
  8. sending press releases, catalogues and corporate information to journalists, media professionals and communication specialists, either directly or through the Company's press office.

4. Methods of Processing

Your personal data will be processed in compliance with applicable legislation and with obligations of confidentiality.
The data are stored and protected through appropriate technical and organisational measures designed to ensure their confidentiality, prevent accidental or unlawful destruction, loss, alteration or unauthorised disclosure, and safeguard them against access by unauthorised third parties.
The data are organised in databases and processed using paper-based, electronic and telematic systems, as well as, where applicable, video surveillance systems, exclusively by duly authorised personnel.

5. Provision of Personal Data

The provision of your personal data is necessary for the performance of all activities related to sales, logistics and compliance with legal obligations. With regard to marketing and communication activities, the provision of your consent is entirely voluntary. However, should you decide not to provide your consent, we will be unable to send you commercial communications or information regarding our products and services.

For the purposes set out in Section 3, points a), b), c) and f), the legal basis for processing is Article 6(1)(b) GDPR, as the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

For the purposes set out in Section 3, points d), e), g) and h), the legal basis for processing is Article 6(1)(a) GDPR, namely your freely given consent.

6. Data Retention Period

The personal data provided by you will be retained for the periods indicated below, according to the relevant processing purpose:

Processing Activity Retention Period
a) Sales through the website; 10 years
b) Logistics activities for order delivery; For the time necessary to complete delivery operations
c) Administrative and accounting management; 10 years
d) Sending informational material (subject to consent); 2 years
e) Commercial communications and newsletters, including tracking via pixels; 7 years
f) Processing job applications and CVs; 2 years
g) Management of social media platforms. For as long as users remain followers or fans of the relevant social media page/profile, subject to the policies of each platform
h) Sending press releases, catalogues and corporate information to media and communication professionals. 7 years

7. Categories of Recipients of Personal Data

Your personal data may be disclosed, where necessary, to the following categories of recipients involved in providing services related to the Company's activities:

  1. debt collection agencies;
  2. credit assignment companies;
  3. logistics and shipping providers;
  4. financial institutions;
  5. marketing and communication service providers;
  6. press and public relations agencies.

In addition, your personal data may be accessed by individuals within and outside the Company (including employees and external consultants) who have been duly authorised or appointed as persons authorised to process personal data and/or Data Processors, solely for the performance of the duties and responsibilities assigned to them in connection with the purposes described above.
You may contact the Company at any time to obtain updated information regarding the categories of recipients to whom your personal data may be disclosed. Your personal data will not be disclosed to the public.

8. Transfer of Personal Data Outside the European Union

Ethimo S.r.l. does not intend to transfer your personal data to third countries outside the European Economic Area (EEA).

9. Withdrawal of Consent

You have the right to withdraw your consent to the processing of your personal data at any time, in accordance with Article 7(3) of the GDPR. The withdrawal of consent shall not affect the lawfulness of any processing carried out on the basis of your consent before its withdrawal.

10. Right to Lodge a Complaint with the Supervisory Authority

If you believe that the processing of your personal data infringes your rights under the GDPR, you have the right to lodge a complaint with the supervisory authority in your country of habitual residence or with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali), available at https://www.garanteprivacy.it.

11. Data Subject Rights

You may exercise the rights listed below by submitting a request to the Data Controller using the contact details provided and following the internal procedure established for handling data subject requests (for further information, please refer to the relevant provisions of the GDPR indicated below):

  1. Right of Access (Article 15 GDPR)
    You have the right to obtain confirmation as to whether or not your personal data are being processed, to receive information regarding the processing, and to obtain a copy of the personal data undergoing processing;
  2. Right to Rectification (Article 16 GDPR)
    You have the right to obtain the correction of inaccurate personal data concerning you and to have incomplete personal data completed.
  3. Right to Erasure ("Right to be Forgotten") (Article 17 GDPR)
    Under the conditions set out in the GDPR, you have the right to request the deletion of your personal data;
  4. Right to Restriction of Processing (Article 18 GDPR)
    Under the conditions established by the GDPR, you may request the restriction of the processing of your personal data. In such cases, the Data Controller will process the data only for storage purposes, unless otherwise permitted by law;
  5. Right to Data Portability (Article 20 GDPR)
    You have the right to receive your personal data in a structured, commonly used and machine-readable format and, where technically feasible, to transmit those data to another data controller without hindrance. This right applies where the processing is carried out by automated means and is based on your consent or on a contract to which you are a party, or on pre-contractual measures taken at your request;
  6. Right to Object (Article 21 GDPR)
    You have the right to object, at any time and on grounds relating to your particular situation, to the processing of your personal data;
  7. Right Not to Be Subject to Automated Decision-Making, including profiling (Article 22 GDPR)
    You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

12. How to Exercise Your Rights

You may exercise your rights at any time by contacting Ethimo S.r.l. through one of the following channels:

  1. by registered mail with acknowledgement of receipt to Ethimo S.r.l., Via La Nova 6, 01030 Vitorchiano (VT), Italy
  2. by e-mail to [email protected]
  3. by certified e-mail (PEC) to: [email protected].

13. Data Protection Officer (DPO)

The Data Controller has appointed a Data Protection Officer (DPO) pursuant to Article 37 of the GDPR. The DPO may be contacted by writing to the e-mail [email protected]. The DPO is available to provide assistance and respond to enquiries in English and French.

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