What categories of Personal Data are collected?
When you register with us, we will collect Personal Data such as your name, street address, email address, telephone number. If you contract to purchase goods or services from us or through this Website, we will collect Personal Data such as payment information, including credit card data. In addition, we collect certain information through cookies and similar electronic devices, as further described in the Cookies section below. We will ask for your consent if we wish to use your data for a purpose materially different than that for which it was collected.
Who determines which Personal Data are collected, how and for which purposes (the data controller)?
The data controller (“us”, “we”, and “our”) will be:
- For products or services contracted offline: the Group Company that contracts with you, as identified in the terms and conditions applicable to the purchase or use of the relevant product or service.
- For products and services contracted online:
- in all events, the Group Company that operates the relevant Website, as identified in its conditions of use; and
- if you are interested in a specific online product or service (other than mere browsing), the Group Company that contracts with you, as identified in the relevant terms and conditions applicable to the purchase or use of the relevant product or service.
How is your Personal Data collected?
- Directly from you, when you are interacting with a Group Company, for example information you give us as requested by phone, email or detailed in the forms you may be asked to complete and also information we collect from your use of our products and services such as online searches you conduct or your interaction with adverts that we place on websites or other media.
Which Personal Data and for which purposes are they used by us?
We collect Personal Data (as detailed in the forms you will be asked to complete) as required to perform the following purposes:
- To evaluate an application regarding the contracting of our products or services. For example, depending on the product or service, this may include verifying whether you are eligible to enter into a competition or to check your credit rating or credit score in credit and solvency files managed by third parties, etc.
- To provide you with a product or service you have requested. For example, to answer your questions or respond to comments submitted to us; to send you information you have requested; to perform and enforce the terms and conditions that govern the product or service (which may include, depending on the product or service, the recording of calls between us and you to evidence the rendering of the product or service or the identification of activities that are prohibited under the terms and conditions that govern the product or service, for accounting, billing and payment verification purposes, to collect debts, to serve notice of unpaid, due and enforceable debts to solvency files which payment has been requested from you); to award a prize if you are the winner of a competition, to post content you have submitted for publication, such as ratings and reviews; to share your Personal Data with payment processing organizations, etc.
If the product or service rendered by us requires us to access or otherwise process on your behalf (e.g, developing, testing, hosting and providing maintenance services for your website) personal data controlled by you (e.g. via your online store or advertising website that we create for you), please refer to its Particular Privacy Terms regarding your and our specific responsibilities.
- To comply with our legal obligations or defend our interests in judicial or administrative proceedings. For example, this includes responding to the requests of governmental and judicial orders of any competent jurisdiction or sharing the Personal Data with other enforcement agencies regarding any mandatory requirement.
- To carry out any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock. For example, this includes a sale of our assets such as our databases, in connection with a bankruptcy proceeding or an intra-group corporate or business reorganization.
- To analyse how our products and service are used by our customers and to improve our business. For example, this includes the analysis of statistical information on the use of our websites by visitors as well as of any feedback on our business or testimonials that you may provide. We may (but we are not obliged to) publish any feedback or testimonials (online or offline) and your name in order to promote our business (your user ID may be published, but your e-mail address and other contact details will not be).
- To honour your preferences on direct marketing and for advert targeting purposes. We (or other third parties, including our affiliates) may send you direct marketing communications in accordance with applicable privacy laws, which may or may not be personalised for you (i.e., tailored to your profile), by any means (e.g., post, phone call, email, text message or other electronic means) and carry out advert targeting. For example, whenever you provide us with any Personal Data (e.g., when you ask for our products or services), we will ask you for your preferences in this respect and provide you with information on the kind of direct marketing available and on whether third party data controllers may send you such direct marketing or carry out the advert targeting. We will not share any Personal Data with affiliates or other third parties for these purposes without meeting the requirements of privacy laws. To discontinue direct marketing or advert targeting, you may send a request as explained in section 9. Furthermore, and regarding direct marketing by electronic means, we will inform you in each of our communications how to unsubscribe in a straightforward way and at no cost (save that related to transmission of your request). We will answer your request as soon as reasonably practicable, and in any case, within the term legally determined (if there is one).
Please note that if you do opt-out of receiving marketing-related messages from us, we will still send messages as necessary to fulfill other purposes (such as administrative messages relating to the operation of the product or service).
Which Personal Data and for which purposes are they shared with third parties?
Personal Data may be used or shared with third parties (including Group Companies) if:
- it is necessary for the following purposes mentioned in section 5 above: (1) to evaluate an application regarding the contracting of our products or services, (2) to provide you with a product or service you have requested, (3) to comply with our legal obligations or defend our interests in judicial or administrative proceedings; (4) to carry out any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock; and (5) to analyse how our products or services are used by our customers and to improve our business;
- it is necessary (6) to honour your preferences on direct marketing and for advert targeting purposes (mentioned in section 5 above), i.e., if you have agreed to receiving marketing and targeted adverts from us and/or certain third parties; or
- these third parties are service providers and work on our behalf to support us in performing any of the abovementioned purposes (e.g., cloud services providers that provide IT infrastructure used by us to provide you with a product or service).
How we keep your Personal Data secure
We take the security of your Personal Data very seriously. We have put in place technology and security policies which are designed to protect the personal information that we hold about you. These cover storing, using and releasing any Personal Data you have provided, and preventing unauthorized access or use. We have put in place technical and organizational measures designed to prevent unauthorized or unlawful processing of Personal Data and designed to prevent accidental access, disclosure, alteration, loss or destruction of, or damage to, Personal Data. These include internal reviews or our data collection, storage, processing and destruction practices. We take steps designed to ensure the reliability of our personnel and subcontractors.
Your responsibilities when you provide us with or allow us access to your Personal Data
You must provide accurate Personal Data and do so only when you are 18 years of age or over and you agree to keep such data up-to-date. You must comply with any data protection and privacy legal requirements applicable to you. You must comply with and not disable any security measure of a Website. If you are acting as a (legal or de facto) representative of any legal entity, you must only provide your professional contact details in respect of that legal entity (and never your private contact details).
Use of the Website by Minors
The Website is not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Data through the Website.
Managing your rights regarding your Personal Data held by us as data controller
You may contact us at email@example.com with written proof of your identity, such as a copy of your photo ID, with signature) (i) to request a copy of your Personal Data; or (ii) to request that your Personal Data be corrected, amended, rectified or deleted if they are inaccurate or incomplete; or (iii) to object to the processing of your Personal Data for certain purposes (such as direct marketing). If you are a registered user of one or more of our Websites, (i) and (ii) may also be managed directly by you in your account management/your profile section. We will answer your request as soon as reasonably practicable, and in any case, within the term legally determined (if there is one) and will comply except where the burden or expense of providing access would be disproportionate to the risk to you, or compliance could result in someone else’s rights being violated.
Last updated 5 August 2014