Privacy policy
PRIVACY POLICY – INFORMATION ON THE PROCESSING OF PERSONAL DATA
Information pursuant to and for the purposes of Articles 13-14 of EU Regulation 2016/679
(European Regulation on the protection of personal data)
B 4 LIVING SPA, with registered office in via Direttissima del Conero, no. 51 – Postcode 60021 Camerano (AN), Italy, VAT no. 02595260429, as Data Controller (hereinafter, the “Controller”), informs you pursuant to Articles 13-14 of EU Regulation no. 2016/679 (hereinafter, “GDPR”) that your data will be processed in the manner and for the purposes set out below:
1. Subject of the Processing
The Controller processes personal identification data (for example, first name, surname, company name, address, telephone number, e-mail address, bank and payment details – hereinafter, “personal data” or simply “data”) provided by you either when entering into a contract, when registering on the website www.bontempi.it or during trade fairs and other events. Special categories of data (sensitive data) referred to in Article 9 of the GDPR are excluded from the processing.
2. Purposes of the processing
Your personal data are processed:
A) without your express consent (Article 6 GDPR), for the following Purposes:
- fulfilment of pre-contractual, contractual and tax obligations arising from existing relationships with you;
- compliance with obligations laid down by law;
- exercise of the Controller’s rights, for example the right of defence in court.
B) only with your specific and separate consent (Article 7 GDPR), for the following Marketing Purposes:
- collection, processing and storage of the personal data you have provided to us in order to target and improve all the activities of B 4 Living as much as possible;
- use of the personal data you have provided to us for B 4 Living’s own marketing and promotional purposes (for example market research, promotional, advertising and informative initiatives, by means of e-mail, newsletters, post, text messages, telephone calls, etc.);
- communication of your personal data to B 4 Living’s commercial operators (for example retailers).
E-mail Monitoring and Tracking (Newsletter):
In the context of communications for marketing purposes and the sending of newsletters referred to in point 2.B), the Controller uses electronic monitoring systems known as “tracking pixels” (invisible images embedded in e-mails) to record the total number of message opens and clicks on hyperlinks, as well as basic technical information (device and browser).
- Such data are collected and processed exclusively in aggregated and anonymous form: they are not associated with your e-mail address or your profile, and any elements that could identify you (such as your e-mail address and IP address) are anonymised by the sending platform. The processing is based on the Controller’s Legitimate Interest, for the sole purpose of producing general statistics on the effectiveness of communication campaigns, and does not involve any profiling.
- The Controller does not track your individual reading behaviour (opens and clicks associated with your specific profile or e-mail address). Should it intend to do so in the future, it will first ask for your specific, explicit and optional consent and will provide, at the bottom of each e-mail, a dedicated link to withdraw it at any time while keeping your newsletter subscription active.
Please note that if you are already our customer, we may send you commercial communications relating to services and products of the Controller similar to those you have already used, unless you object.
3. Processing methods
Your personal data are processed by means of the operations listed in Article 4(2) GDPR, both on paper and electronically and/or by automated means.
In compliance with privacy rules and the regulations in force, the Controller retains personal data for 10 years from the last processing.
4. Access to data
For the purposes referred to in Articles 2.A) and 2.B), your data may be made accessible to:
- employees and collaborators of the Controller, in their capacity as persons authorised to process data;
- external data processors carrying out outsourced activities on behalf of the Controller (by way of example, professional firms, consultants, communication agencies, technology platforms for bulk e-mail sending, etc.).
5. Communication of data
Without the need for express consent, the Controller may communicate your data for the purposes referred to in Article 2.A) to public bodies and administrative/judicial authorities by virtue of legal obligations. These parties will process the data as independent data controllers.
Subject to your authorisation as indicated above, your data may be communicated to marketing companies and commercial operators (for example retailers) of B 4 Living.
Your data will not be disclosed to the public.
6. Data transfer
Personal data are stored on servers located within the European Union. It is in any case understood that the Controller, should it become necessary, may move the servers outside the EU as well. In that case, the Controller hereby ensures that any transfer of data outside the EU will take place in accordance with the applicable legal provisions and that an adequate level of protection of personal data is guaranteed, based on an adequacy decision, on standard contractual clauses adopted by the European Commission or on Binding Corporate Rules.
7. Nature of the provision of data and consequences of refusal
The provision of data for the purposes referred to in Article 2.A) is mandatory. Without such data, we will not be able to provide you with the Services referred to in Article 2.A).
The provision of data for the purposes referred to in Article 2.B) is, on the other hand, optional. You may therefore decide not to provide any data or to subsequently refuse/withdraw permission to process data already provided, including via the unsubscribe link at the bottom of each e-mail. Since e-mail monitoring takes place exclusively in aggregated and anonymous form, no action is required on your part to exclude individual tracking. In the event of refusal, you will not be able to receive newsletters, commercial communications and advertising material relating to the Services offered by the Controller. You will nevertheless continue to be entitled to the Services referred to in Article 2.A).
8. Rights of the data subject
As a data subject, you have the rights set out in Article 15 GDPR, namely the right to:
- obtain confirmation as to whether or not personal data concerning you exist, even if not yet recorded, and their communication in an intelligible form;
- obtain information on: a) the source of the personal data; b) the purposes and methods of the processing; c) the logic applied in the case of processing carried out with the aid of electronic tools; d) the identification details of the controller, the processors and the representative designated pursuant to Article 3(1) GDPR; e) the persons or categories of persons to whom the personal data may be communicated or who may become aware of them as designated representative in the territory of the State, processors or persons in charge of processing;
- obtain: a) the updating, rectification or, where you have an interest, the integration of the data; b) the erasure, anonymisation or blocking of data processed unlawfully, including data whose retention is not necessary for the purposes for which they were collected or subsequently processed; c) certification that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disclosed, unless this proves impossible or involves a manifestly disproportionate effort compared with the right protected;
- object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning you, even if relevant to the purpose of collection; b) to the processing of personal data concerning you for the purpose of sending advertising material or direct selling, or for carrying out market research or commercial communication, by means of automated calling systems without the intervention of an operator, by e-mail (including any individual pixel tracking referred to in point 2.B), where activated with your prior consent) and/or by traditional marketing methods by telephone and/or paper mail. Please note that the data subject’s right to object, set out in point b) above, to direct marketing by automated means extends to traditional means, and that the data subject may in any case exercise the right to object also only in part. The data subject may therefore decide to receive only communications by traditional means, only automated communications, or neither type of communication.
Where applicable, you also have the rights set out in Articles 16–21 GDPR (right to rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to lodge a complaint with the Supervisory Authority.
9. How to exercise your rights
You may exercise your rights at any time by sending:
- a registered letter with return receipt to: B 4 LIVING SPA – Registered office: via Direttissima del Conero, no. 51, 60021 Camerano (AN), Italy;
- an e-mail to [email protected].
The Data Controller is B 4 LIVING SPA
The designated DPO is Avv. Enrico MIELE, who can be contacted at: [email protected]
10. Changes
This privacy policy may be subject to changes and updates over time, in line with developments in personal data protection legislation.