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Safe takes the utmost care in the collection and management of the personal data that you will provide to us or that we will automatically acquire in the course of your consultation of the website (Site), taking specific measures to ensure their security, confidentiality and integrity, in accordance with the provisions of Regulation (EU) 679/2016 (Regulations) and any specific local regulations applicable to the protection of personal data.
Whenever, in the sections dedicated to the services of the Site, it will be necessary to provide your personal data, you will be provided with the necessary supplementary information, in addition to the present, designed to allow you to assess whether or not you wish to proceed with the communication of your personal data for the processing purposes indicated from time to time.
1. Data controller
The data controller of your personal data is SAFE S.R.L. (C.F. and P.IVA 08562760960), with registered office in Via Mario Pagano 39, 20145 Milan. If, in relation to certain processing purposes, co-ownership relationships arise with third parties, you will be provided with all the necessary information prior to the provision by you of your personal data.
2. Personal Data
During the consultation of the pages of our Site your personal data will be acquired automatically or, in connection with certain services you will be required to provide additional data.
Data automatically acquired by the Site
Browsing Data - The computer systems and software procedures used to operate the Site acquire, in the course of their normal operation, certain data whose transmission is implicit in the use of Internet communication protocols.
This is information that is not collected to be associated with you, but which by its very nature could, through processing and association with data held by third parties, allow your identification. This category of data includes the IP addresses or domain names of the computers used for navigation and that connect to the Sites, the addresses in URI (Uniform Resource Identifier) notation of the resources requested, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the computer environment.
These data are not disseminated, but are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, and are kept for the time periods defined by the relevant legal regulations. The data could, however, be used to ascertain responsibility in case of hypothetical computer crimes to the detriment of the Site. Save the latter eventuality, such data do not persist for more than fifteen days.
Geo-location data - The Site's internal search system collects, exclusively when used and upon your confirmation, data inherent to your geographical location in order to obtain the appropriate search results.
Data voluntarily provided
In order to enable you to take advantage of the various services offered by the Site, we will ask you, based on the service in question, to provide us with your personal data, such as: personal details, contact data (telephone contacts, e-mail account, home or residence address, etc.), data relating to the method of payment, information on purchases and transactions, etc. The provision of these data is entirely voluntary, but in some cases, failure to provide them will not allow us to be able to provide the relevant service.
Data pertaining to minors
Safe does not intend to collect and does not intend to voluntarily use any personal data of individuals under the age of sixteen (16) years, or under any other limitation imposed by the legislation in force in the country of your residence or domicile.
We therefore ask you to refrain from providing us with any of your personal data if you are under the age of sixteen (16) or under the age of majority in your country of residence or domicile.
3. Purposes of processing and assumptions of lawfulness of processing
Whenever we acquire and process your personal data, this will be done exclusively in accordance with the principles of lawfulness provided by the legislation, in order to:
1. ensure proper navigation to the areas of the Site, due to the necessary nature of such processing to enable navigation on the Site and the fulfillment of legal obligations;
2. process Your requests to purchase Safe's products or to use the services offered by the Site, due to the necessary nature of such processing to execute contractual and/or pre-contractual measures taken at Your request;
3. to follow up on Your contact requests by reason of the necessary nature of such processing to give effect to contractual and/or pre-contractual measures taken at Your request;
4. to conduct marketing activities, by reason of Your explicit consent that may have been given.
Marketing activities may materialize through the sending of newsletters, promotions, discounts, concessions, commercial information and other dedicated services, through paper mail, operator call, direct sales, or through e-mail, pre-recorded calls and sms/mms. In this context, we may also process your personal data in order to invite you to participate in events and demonstrations, to involve you in market research or to notify you of special initiatives dedicated to Safe's customers, in the manner and at the time we deem most effective according to the different initiatives mentioned.
1.To carry out profiling activities, by reason of your explicit consent, if any.
Purposes of profiling
Profiling activities may take the form of the analysis of information regarding your interests and preferences with respect to our products and services and your consumption choices, for example through the detection of the type and frequency of your purchases in order to be able to guarantee you a personalized service during your future visits.
If you have also given consent to the processing of your personal data for marketing purposes, this will allow us to send you promotions and/or invitations to initiatives that are more in line with your profile, preferences and expectations.
We may, in addition, process your personal data in order to fulfill a legal obligation to which we are subject or, finally, for the pursuit of a legitimate interest of ours or of third parties, subject to the conditions and constraints provided by current legislation.
4. Modalities of Processing
The processing will be carried out with the help of telematic, paper and computer tools; this processing will be based on the principles of correctness, lawfulness, transparency and protection of your rights and confidentiality. In particular, the processing of your data, including for profiling purposes, may take place through automated processes, for example through the comparison and comparative analysis of your purchasing choices (types, quantities, frequency, etc.), during a given period and/or season and through the analysis of the type and number of your eventual requests for information on products made over a predetermined time horizon.
The data will be processed in such a way as to minimize the risks of destruction, loss, unauthorized access or processing that is not permitted or not in accordance with the purposes of collection.
5. Scope of communication and dissemination of personal data
Your personal data will not be subject to dissemination.
Your data may, moreover, be accessible to Companies, entities or consortia that carry out, on our behalf, tasks of a technical and organizational nature consistent with the pursuit of the previously described purposes, as well as to Public Authorities that make a lawful and formal request.
If there is a need to transfer any of your personal data outside the European Economic Area, this will only take place if the level of protection of personal data, guaranteed by the Regulations, is not affected.
In the event that it becomes necessary to transfer your personal data from outside the European Economic Area (EEA), to third parties who perform on our behalf, tasks of a technical and organizational nature consistent with the pursuit of the purposes for which your data have been collected and processed, this will only take place if a level of data protection equivalent to that of the EU can be guaranteed. In fact, we ensure that the transfer of your personal data will only take place against the implementation of at least one of the following security measures, as required by the Regulation:
You can contact us for more information about the specific mechanism used to transfer personal data outside the European Economic Area. Adequate information on the safeguards to protect your personal data that may be transferred outside the European Economic Area is available by contacting Our Data Protection Officer (DPO) at the contact details below.
In any case, your data will only be processed by persons duly trained and able to provide adequate technical and organizational safeguards, as well as bound to the utmost confidentiality by the Data Controller.
6. Duration of Processing
Your personal data will be processed by Safe for varying periods of time depending on the different purposes of processing. We will, in any case, retain your personal data only for the period of time strictly necessary to achieve the purposes for which the data were collected and processed, without prejudice to the need for further retention in the face of specific legal provisions.
7. Rights of data subjects
We would like to remind you that at any time you have the right to know what personal data we hold about you and its ongoing processing, to request that it be updated or corrected, as well as, in the cases provided for by the regulations in force, to obtain its deletion, limitation of processing or to oppose its processing. If you wish, you may also receive your personal data in electronic format for the purpose of their transfer to a third party indicated by you. In the event that the processing is based on your explicit consent, you may revoke that consent at any time.
Rights of data subjects
At any time, by writing to our Data Protection Officer (DPO), at the e-mail address: email@example.com, you may exercise the rights recognized by the Regulation, with reference to the specific processing operations carried out by us:
1. Request to access your personal data as well as receive information regarding the purpose of the processing, categories of data processed, recipients or categories of recipients to whom your personal data may be disclosed, expected retention period, application or non-application of profiling mechanisms and automated decision-making processes;
2. Request to rectify your personal data. This right allows you to correct or complete the data concerning you, although in some cases a prior verification of the correctness of the new data you have provided is necessary.
3. Request to delete your personal data. This right allows you to request the deletion or removal of your personal data if there are no valid reasons for the continuation of processing. You also have the right to request the deletion or removal of your personal data if you have exercised your right to object to the processing and there is no other legal basis for us to keep it, or if we have processed your information in violation of the law or if we are required to delete your personal data to comply with a specific regulatory provision. Please note that any requests for deletion may not be able to be fulfilled or may be fulfilled only partially; this is due, for example, to legal, juridical or fiscal constraints, which are beyond our control, that prevent us from deleting all or part of your personal information. The reasons underlying our total or partial inability to fulfill your request will be promptly communicated to you.
4. Request to object to the processing of your personal data. By exercising this right you may obtain the cessation of the processing of your personal data in relation to the purpose(s) you have indicated. Please note that our granting of your request for objection may or may not take place on the basis of the assumption of lawfulness of the processing itself.
If the processing is carried out against your explicit consent, we will, within the timeframe provided by the Regulations, execute your request, ceasing the processing in question.
We remind you that you may revoke any consent you may have given for "marketing" and/or "profiling" purposes by writing to the e-mail account indicated above. The exercise of this right does not affect the legitimacy of the processing carried out before your revocation of consent.
Please note that the revocation of consent, may result in our inability to continue providing certain services or products, provided by both the Site and Safe. If this is the case, we will notify you of this when revoking consent in order to allow you to fully assess the effects of the revocation.
1. Should the processing be carried out on the basis of a legitimate interest, either ours or that of a third party, we reserve the right to assess the grounds for your request. If the reasons underlying the processing are found to be legitimately overriding your interests, rights and freedoms, or if it is necessary for us to process such data in order to initiate, execute legal actions or defend ourselves in court, we will be compelled to refuse your request, stating the reasons for the refusal.
2. Request for restriction of the processing of personal data. This right allows you to request the suspension of the processing of your personal data in the following cases:
1. Request for transfer of your personal data to a third party. We will provide you or a third party specified by you with your personal data in a structured, commonly used and machine-readable format. This will be done, if technically feasible, only for personal data whose processing is carried out by automated means and where the processing is based on consent or performance of a contract.
When exercising the aforementioned rights, we reserve the right to ask you, in such ways as we deem appropriate, for specific information to help us confirm your identity, in order to be reasonably certain that only you can dispose of your personal data and that they are not disclosed to third parties not entitled to receive them.
We undertake to respond and act on your request, where well-founded, within one month of receiving your request to exercise one or more of your rights. Occasionally, always within the time limits granted by the regulations, we may take longer if the request is particularly complex or if you have submitted numerous requests. In such cases, we will notify you and keep you updated.
The exercise of your rights is completely free of charge.
Finally, we remind you that at any time you may decide to lodge a complaint with the Supervisory Authority in the event of a violation of data protection regulations and/or if you believe that one or more of your rights have been violated.
These rights may be exercised by simple written notice to be sent to our Data Protection Officer (DPO), at the e-mail address: firstname.lastname@example.org.
Revocation of Consent
You may exercise your right to revoke the consent given to us to process your personal data for marketing and/or profiling purposes at any time by writing to email@example.com.
You may, in addition, contact the DPO to receive further information or clarifications or to have indication of the persons authorized to access your personal data.
8. Changes to this Policy