PRIVACY POLICY

the processing of personal data by The Brave s.c.

Latest update: 06/08/2018

 

This Privacy Policy is provided pursuant to Regulation (EU) 679/2016 and the subsequent national adaptation legislation in accordance with article 13 of EU Regulation 2016/679 ("GDPR") and describes how the companies of the The Brave s.c. (referred to in the "Data Controllers" section below, jointly in this Privacy Policy "The Brave s.c.") collect and process the personal data of users or customers through their website www.clickfoods.it or more generally every time that express reference is made to this Privacy Policy.

The term "personal data" means any information concerning an identified or identifiable physical person. For example, personal data is the name, an identification number, location data, an online identifier.

The Brave s.c. may amend, supplement or periodically update this information, also in consideration of possible regulatory changes which are applicable or provisions from the Guarantor for the Protection of Personal Data. The changes and substantial updates to the Privacy Policy will be applied and brought to the attention of the interested parties as soon as they are adopted by updating the link to the Privacy Policy in the Site footer.

 

Data Processer

The Brave s.c. with registered office in Menfi, via Dante Alighieri 67, VAT number IT 02781460841. If you have doubts or if you want more information about the relevant data controller, contact us by the mail support@clickfoods.it .

 

Access to personal data

Your data may be made accessible for the purposes mentioned above:

- to employees and collaborators of the Owner, in their capacity as designated subjects

- to any other subjects (internal or external) identified by the owner for the implementation of the purposes referred to in this statement.

 

PURPOSES OF PROCESSING AND LEGAL BASIS

 The data are processed for the following purposes.

a) Based on the contractual need in order to:

- manage orders and perform related activities (ex: sales and after-sales customer assistance, communications with the customers on the status of their orders, responses to their information requests, management of payments, etc.);

- managing user accounts when registered with the Site;

- manage product shipments and create waybills;

 b) Based on the consent expressed by the user, specifically collected each respective time, in order to carry out market research, as well as to contact the user and send commercial communications and promotional offers, in addition to sending the Newsletter described below, with regard to products, services and/or events of The Brave s.c., through SMS, telephone, paper mail or other means, including through a prior analysis of consumer behaviour aimed at customising commercial messages.

 In any case, the user may exercise his right to object to such processing in the manner indicated above.

 c) Based on the legitimate interest of The Brave s.c., specifically:

- for the analysis and improvement of its services;

- for statistical and/or research and development activities, also by analysing data deriving from the use of services and products or consumer behaviour;

- in order to defend their rights in the course of court, administrative or extrajudicial proceedings, and in disputes arising in connection with the services offered;

- in the case of extraordinary transactions, merger, sale of a business unit, acquisitions, etc.

 d) Based on the need to fulfill the legal obligations to which The Brave s.c. is subject.

The provision of data for the purposes referred to in paragraph (a) above is mandatory, as it is necessary to process the sale and delivery of products and services purchased, or for registration at the sites. Refusal to provide personal data for processing makes it impossible to perform the services required for the purchase of goods and services on the Site.

 

CATEGORIES OF DATA PROCESSED BY THE BRAVE S.C.

 Below is a description of the categories of data we deal with:

- Data supplied directly by the interested party: all personal data entered on the Site (to proceed with online purchases or to register), or in any case provided to The Brave s.c. in any manner. Examples of data provided directly by the interested parties are: name; address and telephone number; fiscal code. More generally, all the data provided to allow the execution of a purchase order, the carrying out of research of products on the Site, the compilation and use of the profile on the Site, the facilitation of the delivery of products with the communication data relating to numbers or contact addresses (eg telephone, email, addresses) etc.

- The data provided by third parties constitute all the personal data The Brave s.c. collects from other sources (postal service companies, couriers, data entry companies, etc.) to perform its services. Examples of data provided by third parties are the data related to updates or corrections received during delivery by couriers, transport partners or third parties, the data on web pages visited that we may receive from other commercial operators with whom The Brave s.c. collaborates for certain initiatives, the names of the recipients of the orders, if different from the buyer.

- Data collected automatically: these are browsing data and/or collected using the so-called "cookies". During their normal operation, the computer systems and software procedures used to operate this Site acquire certain personal data whose transmission is implicit in the use of internet communication protocols. This information is not collected with the aim of linking it to identified users, although, by its nature, it might enable user identification through processing and linking with data held by third parties. This category of data includes IP addresses or domain names of computers used by persons who connect to the site, the URI (Uniform Resource Identifier) of requested resources, the time of request, the method used to submit the request to the server, the size of the file received in reply, the numerical code indicating the status of the reply provided by the server (successful, error, etc.) and other parameters regarding the user's operating system and computer environment.

 

 

DATA RECIPIENTS OR CATEGORIES OF RECIPIENTS

 The data may be processed by third parties, carefully selected in terms of reliability and competence, who, as data controllers, act in the name and on behalf of The Brave s.c. on the basis of contractual agreements and specific instructions. This is necessary or appropriate in order to carry out activities, including instrumental or ancillary, related to the purposes of data processing indicated in this Privacy Policy, the main one of which consists in the supply of goods or services requested by the interested party (e.g.: postal service companies, couriers, data entry companies, companies that manage marketing and newsletters, etc.).

In any other case, except as required by applicable law, personal data are not transferred and/or disclosed to third parties.

 

TRANSFER OF DATA TO NON-EU COUNTRIES

 If personal data are transferred to countries outside the European Union, the transfers will take place in compliance with the provisions established by the GDPR in order to ensure an adequate level of protection. In particular, the transfers will take place through the conclusion of Standard Contractual Clauses approved by the European Commission, a copy of which can be obtained through a specific request to be sent to the contact data contained in this Privacy Policy.

 

DATA RETENTION PERIOD

 As soon as the personal data are no longer necessary for the purposes for which they were collected, The Brave s.c. will delete them, unless the law requires further storage, or the user has not consented to the processing for a longer time, or when they are archived. In particular, following the deactivation of the account or, for unregistered users, of the completion of the order, The Brave s.c. will retain the personal data that are necessary to: - fulfill the requests of the authorities within their competence;

- defend or assert any existing or potential claim;

- handle any complaint regarding contracts or orders concluded.

The data retention period necessary to achieve the aforementioned purposes is linked to the limitation period of a claim that in many cases is equal to 10 years. The Brave s.c. will retain personal data after such time has elapsed only when required to comply with legal obligations or in the event of disputes and extraordinary claims that reasonably require the retention of personal data.

 

 

RIGHTS OF THE DATA SUBJECT

 Under the GDPR, each user has the right to access their personal data and to obtain confirmation of the existence or otherwise of his personal data, even if not yet registered, and to their communication in intelligible form.

In particular, each user has the right to obtain access to his data from The Brave s.c., as well as any information regarding the methods and characteristics of the processing.

 In addition to the above, the user, in the cases provided by law, has the right to receive his personal data in a structured, plain and readable format, as well as the right to transmit this data to another data controller without impediments. Furthermore, each user has the right to obtain updates, rectification or integration of their data from The Brave s.c.. The user also has the right to erase his personal data as well as to limit the processing in cases provided by law.

 Finally, each user has the right to object, in whole or in part, to the processing of personal data concerning him if the processing is based on the legitimate interest of the controller, as well as for direct marketing purposes.

 The requests referred to in the previous points should be addressed to the data controller's contacts indicated in the "Data Controller" section below. The requests must be addressed to the relevant controller for the relevant activities. If you have doubts or if you want more information about the relevant data controller, contact us by mail support@clickfoods.it .