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Privacy policy

Privacy Policy

Information on the processing of personal data pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR)

Foreword

This information is related to the website www.florwine.com(Site) and is provided by ALWAYS ON SRL, registered office Via Vigevano 6 Milan 20144, share capital 10,000 euros i.v., CF/P.IVA 10926660969, Cam.Com MI REA 2567041, as the Data Controller of personal data (hereinafter referred to as Florwine).

The Site is owned by Florwine, which is also the owner of the corresponding domain name.

In this policy, the definitions in the singular also include those in the plural, and vice versa.

Purchases on the Site

Subject to your prior consent, your personal data will be processed to allow you to make purchases on the Site.

Registration

The information and personal data requested in the event of registration on the Site will be used to allow you to access the reserved area of the Site and to use the online services offered by Florwine to registered users.

Marketing

Subject to your consent, Florwine may process the personal data provided by you in order to send you advertising material regarding its own products and/or services or those of third parties.

Profiling

Subject to your consent, Florwine may process your personal data for profiling purposes, i.e. for the analysis of your consumption choices by revealing the type and frequency of purchases made by you, in order to send you advertising material of Florwine or third parties of your specific interest, as well as to present you on the Site with products of your specific interest.

Soft spamming

Florwine may use, for the purposes of the direct sale of the products offered for sale through the Site, the e-mail coordinates provided by you in the context of a purchase on the Site, even without your consent, provided that it concerns a product similar to that subject of the previous sale (so-called soft spamming). You may however refuse this processing at any time by communicating your opposition to Florwine in the manner indicated in art. 4 below.

In compliance with the GDPR, with this information we intend to inform you that Florwine will process the personal data provided through the Site under the following conditions.

Art. 1. Purpose and legal basis of processing. Compulsory or optional conferment. Consequences of refusal to treatment.

The processing of personal data is aimed at achieving the following purposes:

  1. To allow registration on the Site and access to services reserved for registered users as well as to allow compliance with obligations arising from the law or regulations in force, in particular, in the administrative, accounting, public security. The legal basis of the processing is your consent to the processing of your data in order to register on the Site and access services reserved for registered users;
  2. in the case of an online purchase order, to allow the conclusion of the purchase contract and the proper execution of transactions related to the same (and, if necessary under the sector legislation, to fulfill tax obligations). The legal basis of the processing is the existence of a purchase contract;
  3. limited to e-mail coordinates provided by you in the context of a purchase through the Site, to allow the direct offer by Florwine of similar products (so-called soft spamming), unless you object to such treatment in the manner provided by this policy. The legal basis of the treatment is the legitimate interest of Florwine to send this type of communication;
  4. with your consent, for sending newsletters and for carrying out market surveys, also aimed at assessing the degree of user satisfaction, and sending advertising material relating to products and/or services of Florwine and/or third parties, by means of automated systems, such as e-mail, fax, SMS or MMS, or by traditional means (e.g. paper mail or telephone): paper mail or telephone)(marketing purposes); subject to your consent, for the processing of your commercial profile, through the detection and processing of your choices and buying habits on the Site, in order to monitor the degree of customer satisfaction to ensure better satisfaction of the needs of the same, and to send you advertising material on products and/or services of Florwine and/or third parties, of your specific interest, by means of automated systems, such as e-mail, fax, sms or MMS, or by traditional means (eg. paper mail or telephone)(profiling purposes). The legal basis of the treatment is the legitimate interest of Florwine to carry out this type of activity;
  5. to respond to your requests through the customer care service. The conferment is optional, but your refusal will make it impossible for Florwine to answer your questions through this service. The legal basis of the processing is the legitimate interest of Florwine to respond to your requests;
  6. to answer your requests by phone and/or email or to inform you that one or more products of your possible interest are available on the Site. The conferment is optional, but your refusal will make it impossible for Florwine to respond to your requests. The legal basis of the processing is the legitimate interest of Florwine to respond to your requests.

The provision of data for the purposes referred to in points 1) and 2) is merely optional. However, since such processing is necessary to allow registration on the Site as well as to make a purchase on the Site, your refusal to provide the data in question will make it impossible to register on the Site and to make such a purchase through the Site.

Consent to the processing of your data for marketing and profiling purposes is purely optional. Failure to consent will only imply the consequences described below.

Failure to consent to the processing of your data for marketing purposes will make it impossible for you to receive advertising material regarding Florwine and/or third party products and/or services, as well as making it impossible for Florwine to carry out market surveys, also aimed at assessing the level of user satisfaction, and to send you newsletters.

Failure to consent to the processing of your personal data for profiling purposes will make it impossible for Florwine to process your commercial profile, through the detection of your choices and purchasing habits on the Site (also in order to ensure greater satisfaction of customer needs), as well as to send you advertising material, related to goods and/or services of Florwine and/or third parties, of your specific interest.

Without prejudice to the above, it is understood that Florwine may nevertheless use your personal data only for the purpose of correctly fulfilling the obligations laid down by the laws in force and the obligations deriving from the contractual relations established between you and Florwine.

We remind you that you can object to the processing of your personal data by sending an e-mail to Florwine at info@florwine.com or by using the link at the bottom of any promotional e-mail sent by Florwine. The opposition manifested in these ways also extends to the sending of communications through the postal service.

Payment Card Information. Use of PayPal

To make a payment through one of the payment cards offered on the Site, the user must enter the confidential data of the payment card directly on a page that will communicate through secure encryption protocol with the provider of the payment service (which will act as autonomous owner of the treatment), without passing through the server of Florwine that, therefore, will not treat such data in any way. The data will be acquired in encrypted format.

On the Site you can also buy through the PayPal payment tool. In this case, you will be directed to a page outside the Site, where you must indicate the personal data required by PayPal - which will act as independent data controller - to complete the purchase process. The personal data will not transit from the Florwine server which, therefore, will not process such data in any way.

With reference to the processing of payment card data and those required by PayPal, it is specified that the processing of your personal data is necessary to allow the conclusion of the online purchase contract with Florwine. Failure to provide this data, therefore, will not allow you to complete the online purchase process.

Sensitive/judicial data

Florwine does not process sensitive or judicial data.

Art. 2. Methods of treatment

The processing of personal data concerning you will be mainly carried out with the help of electronic or automated means, according to the methods and with the tools necessary to ensure the security and confidentiality of the data in accordance with the GDPR. In particular, all the necessary technical, IT, organizational, logistical and procedural security measures will be adopted so that the minimum level of data protection required by law is guaranteed, allowing access only to the persons in charge of processing by Florwine or the Data Processors designated by Florwine.

The information acquired and the methods of treatment will be relevant and not excessive in relation to the type of services rendered. The data will also be managed and protected in environments whose access is under constant control.

Art. 3. Communication and dissemination of data

Your data may be communicated

  • to all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative measures;
  • to companies or third parties in charge of printing, enveloping, shipping and/or delivery and/or collection services of the products purchased through the Site;
  • post offices, couriers or shippers responsible for the delivery of products purchased through the Site;
  • banks and companies that manage national or international payment circuits through which online payments for products purchased through the Site are made;
  • to companies, consultants or professionals in charge of the installation, maintenance, updating and, in general, the management of Florwine's hardware and software or which it uses to provide its services;
  • to external companies in charge of sending advertising communications on behalf of Florwine;
  • to the employees and/or collaborators of Florwine;
  • to subjects who manage online payment transactions;
  • to subjects in charge of repairing the products purchased in execution of the legal guarantee of conformity or in any case of damaged products;
  • to all those public and / or private individuals and / or legal entities (legal, administrative and tax consulting firms, Judicial Offices, Chambers of Commerce, Chambers and Offices of Labor, etc..), if the communication is necessary or functional to the proper fulfillment of contractual obligations assumed, as well as obligations under the law.

The data concerning you will not be disclosed, except in anonymous and aggregate form, for statistical or research purposes.

Art. 4. Data Controller

Florwine, as Data Controller of personal data can be contacted at the following addresses:

Address: ALWAYS ON SRL - Via Vigevano. 6 milan 20144

Phone: +39 3288559576 (Mon-Fri 9.30-13.30 and 15.00-18.00).

Email: info@florwine.com.

Art. 5. Storage of personal data

Florwine will keep your personal data for no longer than is necessary to fulfill the purpose for which they were collected. Florwine will keep your personal data for profiling and marketing purposes for 5 years from the last conferment. After this period of time Florwine will proceed to cancel your personal data, or to ask for the renewal of your consent.

In any case, Florwine will keep your personal data for 10 years from the last conferment for the needs of defense in court.

Art. 6. Rights of the interested party

Pursuant to art. 13 of the GDPR, Florwine informs you that you have the right to:

  • ask Florwine for access to your personal data and the rectification or cancellation thereof or the limitation of processing concerning you or to object to their processing, in addition to the right to data portability;
  • withdraw consent at any time without affecting the lawfulness of the processing based on the consent given before the withdrawal;
  • to lodge a complaint with a supervisory authority (e.g.: the Italian Data Protection Authority).

The above-mentioned rights can be exercised with a request addressed without formalities to Florwine at the contacts indicated in art. 4 above.

In particular, Florwine informs you that the right to portability implies that you have the right to receive in a structured, commonly used and machine-readable format the personal data concerning you provided to Florwine and you have the right to transmit such data to another data controller without impediment from Florwine.

Art. 7. Changes

Florwine reserves the right to make changes to this information at any time, giving suitable publicity to the users of the Website and guaranteeing in any case an adequate and similar protection of personal data. In order to view any changes, you are invited to regularly consult this information.

In any case, should Florwine make any substantial modifications to this information (e.g.: processing of personal data for different and additional purposes), it will inform the parties concerned by e-mail.

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