E-COMMERCE PLATFORM PRIVACY POLICY

Information document pursuant to and for the purposes of Article 13 of Regulation (EU) 2016/679 (GDPR)

E-COMMERCE PLATFORM PRIVACY POLICY

Information document pursuant to and for the purposes of Article 13 of Regulation (EU) 2016/679 (GDPR)

WHY THIS INFORMATION?

Pursuant to Regulation (EU) 2016/679 (hereinafter "GDPR"), this page describes the methods used to process the personal data of users (customers and prospects) who use Sent Retail Srl's e-commerce platform for the sale of Como 1907 branded products. This information is provided pursuant to Art. 13 of the GDPR. This information does not apply to other third-party websites that may be accessible via links on this website, for which Sent Retail Srl assumes no responsibility.

Processable personal data

Personal data : any information relating to an identified or identifiable natural person (' data subject '); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (C26, C27, C30 GDPR).

Browsing data

The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of internet communication protocols. This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of computers used by users connecting to the site, the URI (Uniform Resource Identifier) ​​addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), and other parameters relating to the user's operating system and IT environment.

Data communicated by the interested party

The optional, explicit, and voluntary sending of messages to the contact addresses listed on this site and/or the completion of data collection forms entails the subsequent acquisition of the sender's address, which is necessary to respond to requests, as well as any other personal data entered.

Specific information

Specific information will be present on the Site pages in relation to particular services or processing of the data provided.

Cookies. What are cookies? What are cookies used for?

Cookies are small text files that websites send to users' terminals, where they are stored before being re-sent to the same websites on subsequent visits. So-called "third-party" cookies, on the other hand, are set by a website other than the one the user is visiting. This is because each website may contain elements (images, maps, sounds, specific links to web pages on other domains, etc.) that reside on servers other than the one being visited. Cookies are used for various purposes: performing computer authentication, monitoring sessions, storing information on specific configurations regarding users accessing the server, storing preferences, etc. For more information on the cookies used by this website, see the cookies policy in the website footer and at the following link .

  1. WHO IS THE DATA CONTROLLER? HOW TO CONTACT THEM
  2. When two or more Data Controllers jointly determine the purposes and means of processing, the following companies are defined as Joint Data Controllers pursuant to art. 26 GDPR for the purposes C ), D ), and F ), referred to in this policy:

Sent Entertainment Italy Srl , with registered office in Via Alessandro Volta 70, 22100, Como (CO) Italy, in the person of its legal representative pro tempore, e-mail: privacy@sent.tv 

Sent Retail Srl with registered office in Via Alessandro Volta 70, 22100, Como (CO) Italy, in the person of its legal representative pro tempore, email: privacy@sentretail.com

Como 1907 Srl with registered office in Via Alessandro Volta 70, 22100, Como (CO) Italy, in the person of its legal representative pro tempore, e-mail: privacy@como1907.net  

Pursuant to Article 26, paragraph 1 of the GDPR, the parties have signed an appropriate joint controllership agreement aimed at regulating their respective responsibilities for compliance with the obligations of the Regulation.

The essential content of the joint controllership agreement is available at the following link: https://_____________. The joint controllers have identified the email address privacy@sent.tv as the contact point for data subjects, without prejudice to the right of the data subject to exercise their rights towards each joint controller.

For the remaining purposes indicated in the information, the Data Controller will be solely Sent Retail Srl .

2. HAS A DATA PROTECTION OFFICER BEEN APPOINTED? WHAT ARE HIS CONTACT DETAILS?

Sent Retail Srl and the other joint controllers have appointed their own Data Protection Officer (DPO) pursuant to Articles 37, 38, and 39 of the GDPR. The DPO can be contacted at the Controller's office indicated above and by email: dpo.sent@dpoprofessionalservice.it 

3. PURPOSE OF THE PROCESSING, LEGAL BASIS, DATA RETENTION PERIOD AND NATURE OF THE PROVISION

PURPOSE OF THE PROCESSING LEGAL BASIS RETENTION PERIOD NATURE OF THE CONTRIBUTION
Browsing this website. The data required to use web services is also processed for the following purposes: •obtaining statistical information on the use of services (most visited pages, number of visitors per time slot or day, geographical areas of origin, etc.); •monitoring the proper functioning of the services offered. The data will be used to ascertain liability in the event of hypothetical cybercrimes against the site. Processing is necessary for the pursuit of the legitimate interests pursued by the joint controllers or by third parties, provided that the interests or fundamental rights and freedoms of the data subject which require the protection of personal data do not prevail, taking into account the reasonable expectations of the data subject and the activities strictly necessary for the functioning of the site and navigation itself (Art. 6, par. 1, letter f and C47 of the GDPR). You have the possibility to obtain, upon request, information on the balancing test carried out Browsing data will be retained for the duration of the browsing session. For more information, please consult the cookie policy.










Providing your data is necessary to navigate the website.

















Use of cookies and similar technologies. Please see the cookies policy available in the footer of the site or via the hyperlink in this policy. For cookies and similar non-technical technologies, processing is based on consent to the processing of personal data (Article 6, paragraph 1, letters a and C42 and C43 of the GDPR). Consent is provided through the banner and the website's cookie policy. See the cookies policy in the footer of the site See the cookies policy in the footer of the site

In addition to browsing, personal data will be processed for

PURPOSE OF THE PROCESSING

LEGAL BASIS

RETENTION PERIOD

NATURE OF THE CONTRIBUTION

a. Purchase of products and management of related services. The personal data provided is necessary to complete the purchase, to enter the billing and delivery address, and to send you all communications related to the order (including sending service information related to the shopping cart, order confirmation, or shipping, for the purpose of providing you with customer support).

Contractual and pre-contractual measures (Article 6, paragraph 1, letter b), GDPR): implementation of contractual and/or pre-contractual measures adopted at the request of the data subject.

The Data is stored for 10 years from the date of purchase and/or the termination of the contract.

Providing your data is necessary to ensure the fulfillment of the Data Controller's contractual and/or pre-contractual obligations towards the interested party, which are necessary to process the purchase, invoicing, and shipping of the purchased goods.

  • Shipping/Returns Policy : Common data is processed to ensure a package tracking system and shipment status, as well as to open reports or tickets and manage return requests according to the policies in use available on the e-commerce platform.

Contractual measures (Article 6, paragraph 1, letter b) of the GDPR): execution of contractual measures adopted at the request of the data subject.

Data is retained for 10 years from the date of purchase and/or the termination of the contract.

The provision of data is necessary to ensure the execution of the contractual obligations of the Data Controller towards the interested party for the correct exercise of his right of withdrawal.

  1. Direct marketing, for sending promotional communications relating to the joint controllers' products or services, invitations to initiatives/events or for carrying out market research, commercial communications, via automated contact methods (with tools such as: text messages, email, social networks, instant messaging apps, push notifications) and traditional methods (such as telephone calls with an operator and traditional mail).

Consent ( C42, C43)

art. 6 par. 1 lett. a) GDPR )

Until consent is revoked

(or opt-out)

The provision is optional.

Failure to provide the necessary data will result in the inability to receive direct marketing communications from the co-owners.

  • User profiling for sending promotional communications regarding activities/products/services more in line with your interests.

Consent ( C42, C43)

art. 6 par. 1 lett. a) GDPR )

3 years, unless consent is revoked (Opt-out), if earlier

Providing data is optional.

Failure to provide the necessary data will make it impossible to perform analyses and send targeted promotional communications.

  • Direct marketing, automated "soft-spam" via email : The joint data controllers will use, for the direct sale of their products or services, the email address provided by the data subject in the context of the sale of a product or service, without requesting the data subject's consent, for promotional and commercial communications and newsletters on services similar to those being sold, provided that the data subject, having been adequately informed, does not object to such use, initially or in subsequent communications. The data subject, at the time of collection and at the time of sending each communication carried out for the purposes referred to in this paragraph, is informed of the possibility to object to the processing at any time, easily and free of charge.

  • Legitimate interest of the Data Controller (art. 6, par. 1, lett. f) GDPR) :

    Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data (C47-C50)

    Art. 6 PAR. 1 lett. f) GDPR

    And

    Art. 130, paragraph 4 of Legislative Decree 196/2003

    Until opposition

    Providing data is optional.

    Failure to provide the necessary data will make it impossible to receive direct marketing communications by email (soft-spam).

  • Disclosure of data to third parties (third-party companies, partners of the joint controllers) for their direct marketing purposes.

  • Consent ( C42, C43)

    art. 6 par. 1 lett. a) GDPR )

    Until consent is revoked.

    Please refer to the privacy policy of these third-party companies, which act, in this case, as independent Data Controllers.

    Providing data is optional.

    Failure to provide the necessary data will make it impossible to communicate personal data to third-party companies.

  • Registration in the reserved area of ​​the site

  • Contractual measures (Article 6, paragraph 1, letter b) of the GDPR): execution of contractual measures adopted at the request of the data subject.

    For the entire duration of the relationship and, following its termination, for 10 years

    The transfer is necessary.

    Failure to provide the required data will prevent you from registering for the reserved area. Failure to provide this information will not affect other purposes, including purchases, which can be made without registering by purchasing in "guest" mode.

  • Prevention and management of disputes and other legal matters and for defense in the event of a lawsuit

  • Legitimate interest of the Data Controller ( C47-C50)

    Art. 6 PAR. 1 lett. f) GDPR )

    10 years, unless objected to and except for the time necessary for legal defense

    Providing the data is necessary and, without it, it will not be possible to satisfy the legitimate interest of the indicated Data Controller.

    The refusal must be balanced against the legitimate interest of the Data Controller indicated in the indicated purpose.

    1. Management of your requests and requests from other interested parties , pursuant to art. 15 et seq. of the GDPR (rights of the interested party)

    Legal obligation to which the data controller is subject ( C45)

    Art. 6 par. 1 lett. c) GDPR )

    5 years from the closure of the request, barring disputes

    The provision of personal data is mandatory, as it is essential to comply with legal obligations.