Privacy Policy

Privacy policy pursuant to art. 13 of the European Regulation 679/2016 and consent

Pursuant to and for the purposes of the legislation cited in the subject, afterlabel, registered trademark Golden Season Srl, hereby wishes to inform you in advance of both the use of your personal data and your rights, informing you as follows:

Data Controller and Data Protection Officer

The owner of the treatment is afterlabel, is a registered trademark of Golden Season Srl; P.iva:03233670987 and the responsible of the treatment is the DPO Paolo Baldassare has been appointed and can be contacted by e-mail at privacy@paolobaldassare.it.

Type of data processed and collected

Among the personal data collected by this application, either independently or through third parties, there are

Cookie, usage data, name, surname, telephone number, company name, email and city.

Full details of each type of data collected are provided in the dedicated sections of this privacy policy or by means of specific information texts displayed prior to the collection of the data itself.

Personal data may be freely forged by the user or, in the case of usage data, automatically collected during the use of this application.

Unless otherwise specified, all the data requested by this application is mandatory. If the user refuses to communicate 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 this having any consequence on the availability of the service or its operation.

Users who are unsure of what data is required are encouraged to contact the owner.

Any use of cookies or other tracking tools by this application or the owners of third party services used by this application, unless otherwise specified, is for the purpose of providing the service requested by the user, in addition to the other 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 he/she has the right to communicate or disseminate them, releasing the owner from any liability towards third parties.

Purpose and obligatory or optional nature of processing

Your data that you indicate will be processed in order to:

1) The collection and processing of personal data will be carried out exclusively for purposes strictly connected and instrumental to the fulfilment of the obligations inherent to the relationship with our company and/or to fulfil the requests promoted by e-mail and to allow you to purchase our products       as well as, if necessary, for fulfilments and obligations provided for by laws, regulations and community norms or by provisions given by authorities legitimated by law and by supervisory and control bodies and for anonymous and aggregate statistical purposes.

2) Direct and/or indirect marketing purposes: for example, the sending, by automated contact methods (such as SMS or e-mail) and traditional methods (telephone calls with operator or traditional mail) of promotional and commercial communications relating to services/products offered by the Company Golden Season Srl as well as the carrying out of market studies and statistical analysis, advertising, remarketing and behavioral targeting, display of content from external platforms, tag management, content commenting, interaction with live chat platforms, management of user databases.

3) analyze your usage, preference and consumption data of our services to improve our approach to you and our customers in general, through automated processing including profiling. We do this so that we can make better decisions in relation to services, advertising, products and content that are based on a  greater awareness of how our customers use our services and to provide you with a more personalized

experience. For this purpose, we may also collect your mobile device’s Identifier for Advertising (IDFA – for iOS devices

and AAID – Google Advertising ID – for Android devices) to enable us to always provide you with targeted and relevant ads based on your preferences and interests.

Persons authorized to process data

The data may be processed by employees and collaborators of the company departments responsible for pursuing the above-mentioned purposes, who are expressly authorized to do so and have been adequately trained.

Treatment modes

The controller shall take appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of personal data.

The treatment is carried out by means of computer and/or telematic instruments, with organizational methods and logics strictly related to the indicated purposes. In addition to the owner, in some cases, may have access to data from other subjects involved in the organization of this application (administrative staff, sales, marketing, legal, system administrators) or external parties (with third party technical service providers, couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, data processors by the owner, The updated list of managers can always be requested from the owner of the treatment.

Location

The data are processed at the operational headquarters of the owner and in any other place where the parties involved in the processing are located. For further information, please contact the Data Controller. The user’s personal data may be transferred to a country other than the one where the user is located. To obtain further information on the location of the processing, the user may request information directly from the data controller.

You have the right to obtain information about the legal basis for the transfer of data outside the European Union to an international organization under public international law or consisting of two or more countries, such as the UN, as well as about the security measures taken by the data controller to protect the data.

Conservation period

Data are processed and stored for the time required by the purposes for which they were collected. Therefore:

◦ Personal data collected for purposes related to the performance of a contract between the controller and the user will be retained until the performance of that contract is completed.

◦ Personal data collected for purposes attributable to the legitimate interest of the owner will be retained until such interest is satisfied. The user can obtain further information about the legitimate interest pursued by the holder in the relevant sections of this document or by contacting the holder.

◦ In the specific case of marketing purposes, the retention time is 24 months from data collection; in the case of a contract in progress, the retention time is 24 months from its termination.

The controller may be required to retain personal data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the personal data will be deleted. Therefore, at the end of this period the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Legal basis of processing

The controller processes personal data relating to the user 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 the execution of pre-contractual measures;

◦ The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the holder;

◦ The processing is necessary for the pursuit of the legitimate interest of the owner or third parties. However, it is always possible to ask the data controller to clarify the concrete legal basis of each processing operation and in particular to specify whether the processing is based on law; provided for by a contract or necessary to conclude a contract.

Data transfer abroad

Your personal data may be transferred to countries that are members of the European Union and to countries outside the European Union, always within the scope of the purposes indicated in this information notice and in compliance with the regulations and international agreements in force.

Rights of the interested party

Your rights under the GDPR include the rights to:

– to request access to your personal data and to the information related to the same; the correction of inaccurate data or the integration of incomplete  data; the  cancellation  of  personal data concerning  you (if one of the conditions indicated in art. 17, paragraph 1 of the GDPR occurs); the limitation of the processing of your personal data (if one of the hypotheses indicated in art. 18, paragraph 1 of the GDPR occurs);

– request and obtain – in cases where the legal basis of the processing is the contract or consent, and the same is carried out by automated means – your personal data in a structured and machine-readable format, including for the purpose of communicating such data to another data controller (so-called right to portability of personal data);

– to object at any time to the processing of your personal data in the event of special situations concerning you;

 -withdraw consent at any time, limited to cases where processing is based on your consent for one or more specific purposes and concerns common personal data (e.g. date and place of birth or place of residence), or special categories of data (e.g. data revealing your racial origin, political opinions, religious beliefs, state of health or sex life). The processing based on consent and carried out prior to the revocation of the same retains, however, its lawfulness;

– propose a complaint to a supervisory authority (Autorità Garante per la protezione dei dati personali is www.garanteprivacy.it.

You may request the execution of these rights at any time at the address of the data controller, or at your e-mail address indicated above. Requests will be processed free of charge by the data controller as soon as possible, and in any case within one month of the request.