T.G.S. TRADITIONAL GOODS&SERVICES S.R.L. with registered office at Via Meda 7 – 20136 Milan is the data controller for the personal data provided by users.

T.G.S. TRADITIONAL GOODS&SERVICES S.R.L. is committed to protecting users’ rights to personal data protection.

This Privacy Policy is provided to users pursuant to and for the purposes of national and European regulations on personal data protection, meaning the Regulation (EU) 2016/679 of the European Parliament and Council of April 27, 2016, regarding the protection of individuals with regard to the processing of personal data, as well as the free movement of such data (GDPR), in addition to any other applicable personal data protection laws in Italy, including the measures of the Data Protection Authority.

It is advisable to carefully read the following to understand our views and practices regarding Personal Data and how it will be processed.

DATA PROCESSORS

The data controller uses data processors to achieve the purposes indicated below and a designated Data Protection Officer (DPO) to oversee the protection of personal data.

Please remember that you can contact the Data Protection Officer at any time and send any questions or requests regarding your personal data and your privacy rights by writing to info@smarthalal.it.

TYPES OF DATA COLLECTED

Among the Personal Data collected by this Application, either independently or through third parties, there may be: email, first name, last name, delivery address, postal code, city of delivery, mobile phone number, tax code or VAT number, Cookies, and Application Usage Data.

The Personal Data may be provided directly by the User or, in the case of Usage Data, collected automatically during the use of this Application.

Unless otherwise specified, all data requested by this Application is mandatory. If the User refuses to provide them, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain data as optional, Users are free to refrain from communicating such data, without any consequence on the availability of the Service or its operation.

Users who have doubts about which data is mandatory are encouraged to contact the Data Controller.

The potential use of Cookies – or other tracking tools – by this Application or by third-party service providers used by this Application, unless otherwise specified, aims to provide the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Application and guarantees that they have the right to communicate or disseminate them, releasing the Data Controller from any liability towards third parties.

METHODS AND LOCATION OF DATA PROCESSING COLLECTED

Processing Methods

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, alteration, or destruction of Personal Data.

The processing is carried out using IT and/or telematic tools, with organizational methods and logics strictly related to the stated purposes.

In addition to the Data Controller, in some cases, other parties involved in the organization of this Application (administrative, commercial, marketing, legal staff, system administrators) or external parties (such as providers of administrative and accounting services, couriers, and logistics operators, hosting providers and system engineering service providers, collection service providers, IT and online marketing companies) may also have access to the Data, designated, if necessary, as Data Processors by the Data Controller. An updated list of the Data Processors can always be requested from the Data Controller. These providers have access only to the personal data necessary to perform their tasks. We guarantee that they cannot use the data for other purposes and are also obliged to process Personal Data in accordance with this Privacy Policy and under applicable personal data protection regulations.

Legal Basis for Processing

The Data Controller processes Personal Data relating to the User only if one of the following conditions is met:

• The User has given consent for one or more specific purposes;
• The processing is necessary for the execution of a contract with the User and/or for the implementation of pre-contractual measures;
• The processing is necessary to comply with a legal obligation to which the Data Controller is subject;
• The processing is necessary for the performance of a task carried out in the public interest or in the exercise of public authority vested in the Data Controller;
• The processing is necessary for the pursuit of legitimate interests of the Data Controller or third parties.

It is always possible to request the Data Controller to clarify the specific legal basis of each processing and in particular to specify whether the processing is based on the law, provided for in a contract, or necessary to conclude a contract.

Location

The Data is processed at the operational offices of the Data Controller and in any other place where the parties involved in the processing are located.

The User’s Personal Data may be transferred to a country other than the one in which the User is located, even outside the European Union. When such a transfer occurs, we ensure that it is carried out in accordance with this Privacy Policy and guarantees adequate protection.

If one of the above-described transfers takes place, the User may refer to the respective sections of this document or request information from the Data Controller by contacting them at the contact details provided at the beginning.

Retention Period

The Data is processed and stored for the time required by the purposes for which it was collected. In general terms, data will be retained until the tenth anniversary after registration on the Platform.

The following categories of data may be stored for longer periods:

• Financial and accounting data (e.g., invoices, payments, refunds, etc.) are retained for the duration required by applicable tax and accounting laws;
• All content generated by users (e.g., purchased products, behavior patterns) is anonymized but remains available for our analysis in an aggregated manner.

At the end of the retention period, Personal Data will be deleted. Therefore, upon the expiration of that term, the rights of access, deletion, rectification, and the right to data portability can no longer be exercised.

 

PURPOSES OF DATA PROCESSING COLLECTED

User Data is collected to allow the Data Controller to provide and optimize its Services and, in particular, for:

• The identification of the User necessary for access to the Application and dedicated products and services, as well as to enable the proper development of User support activities;
• The completion of the order and the management of the collection with the necessary control and security measures for the operation;
• The preparation and delivery of orders;
• The management of order invoicing and the completion of related administrative and tax processes;
• Post-sales assistance and the management of support and contact requests;

The development of marketing activities regarding its Services as well as analyzing and understanding our customers to improve our service (including the user interface experience) and optimize the selection of products offered.

To obtain further information about the Personal Data relevant to each purpose, the User may request information from the Data Controller by contacting them at the contact details provided at the beginning.

USER RIGHTS

Users can exercise certain rights regarding the Data processed by the Data Controller. In particular, the User has the right to:

• Withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously expressed.

• Object to the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are provided in the section below.

• Access their Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing, and to receive a copy of the Data processed.

• Verify and request rectification. The User can verify the accuracy of their Data and request its update or correction.

• Obtain the limitation of processing. When certain conditions are met, the User can request the limitation of processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than its storage.

• Obtain deletion or removal of their Personal Data. When certain conditions are met, the User can request the deletion of their Data by the Data Controller.

• Receive their Data or have them transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to obtain its transfer without hindrance to another controller. This provision applies when the Data is processed using automated tools and the processing is based on the User’s consent, on a contract to which the User is a party, or on related contractual measures.

• File a complaint. The User can file a complaint with the competent data protection authority or take legal action.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public authority vested in the Data Controller, or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that they may, at any time and without providing any justification, block the receipt of newsletters from the Data Controller by sending an email to info@smarthalal.it indicating their wish.

How to exercise rights

To exercise the User’s rights, Users can direct a request to the contact details of the Data Controller indicated in this document. Requests are processed by the Data Controller as quickly as possible, in any case within a month.