Pursuant to Article 13 of EU Regulation 679/2016 (“GDPR” or “Regulation”) and of Legislative Decree No. 196/2003, as amended by Legislative Decree No. 101/2018 (“Privacy Code”)

FOREWORD

This policy is addressed to individuals who make a purchase (with or without simultaneous registration) or who browse the website of Aliena by Faro S.r.l. (“Website“), even if only in consultation (“Data Subjects” or “Users“), activities that presuppose the processing of personal data of the Data Subjects (“Personal Data“).

The processing of Personal Data will be based on the principles of fairness, lawfulness, transparency, purpose limitation and storage, minimization and accuracy, integrity, and confidentiality, in accordance with the provisions of the GDPR.

Personal Data will be entered into the system by the Data Subjects themselves through the use of appropriate forms during registration.

Hereafter, it will be explained the different purposes of processing and how Personal Data is used and stored.

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1. DATA CONTROLLER

The data controller of Personal Data is Aliena by Faro S.r.l. (C.F. 16347711000), with registered office in Rome, Via Piave 55, in the person of the legal representative pro tempore (hereinafter, “Aliena by Faro” or “Controller“) and can be contacted at the e-mail address dafne@aliena.space.

2. PERSONAL DATA PROCESSED

Aliena by Faro receives, collects, and stores all information that the Data Subject enters on the Website or provides in any other way. Specifically, the Personal Data processed are:

• biographical data (first and last name);
• contact information (e-mail, address, and phone number);
• internet browsing and geolocation data (including “IP” addresses): data are used for statistical and analytical purposes, in aggregate and anonymous form only, and are not cross-referenced with any other data;
• banking data (including credit card information), necessary for the management of the contractual relationship;
• photographic images and/or video footage, collected on the occasion of participation in promotions, contests, events, and setups in general (with prior consent, in cases provided by law);
• data directly conferred by the User (“Contributions“) and shared on the pages of social networks dedicated to Aliena by Faro (Instagram, Facebook, ) (“Social Networks“), for the management of which please refer to the third parties that provide such services. Among the data collected through the Social Networks there are, for example, the likes, comments, images and in general any content and information eventually posted by Users on the pages of the Social Networks dedicated to products of the different brands of Aliena by Faro;
• Data related to the User’s interactions with Aliena by Faro (e.g., participation in questionnaires, initiatives, contests, promotions, events even through our social channels).

3. PURPOSE AND LEGAL BASIS OF DIFFERENT PROCESSING ACTIVITIES

The purposes for which Personal Data are processed by the Data Controller and the legal basis on which the Processing is based are listed below:

• Registration via Website: the registration procedure by creating an account is intended to enable the use of the Website as a registered User. The provision of data is optional. The legal basis of the processing is the execution of pre-contractual measures to which the Data Subject is a party.
• Purchase of products through the Website: the User may purchase Aliena by Faro products either as a registered User (and in this case, they will not have to re-enter all the Personal Data on the occasion of each purchase), or as a non-registered User (re-entering from time to time all the data needed to finalize the purchase). Both cases will entail the processing of the User’s Personal Data in order to manage orders and payments, carry out the consequent administrative-accounting fulfilments, as well as to send any communications inherent to the purchases themselves (e.g. information on the progress of orders). The provision of Personal Data is necessary to finalize the purchase order. The legal basis for such processing is the execution of pre-contractual measures and/or the contract to which the Data Subject is a party.
• Handling of requests sent via e-mail and/or Social Networks: Personal Data will be collected to respond to requests that are sent via e-mail and/or via Social Networks. The legal basis for such processing is the legitimate interest of the Data Controller.
• Booking for participation in events, contests, and prize events: Personal Data will be collected to enable participation in events, contests, and prize events. The legal basis for such processing is the execution of pre-contractual measures and/or the contract to which the Data Subject is a party.
• Fulfillment of tax obligations and investigations by judicial authorities in relation to contractual relationships with Data Subjects: Personal Data will be collected to provide information to competent authorities where required by applicable laws or regulations. The legal basis for such processing is a legal obligation.

4. NATURE OF PROVISION

4.1 The provision of Personal Data may be optional or mandatory. In cases where the provision is compulsorily required, failure to provide Personal Data may affect the ability to take advantage of certain services (e.g., to place orders and purchases, to participate in contests and sweepstakes, etc.).

4.2 The mandatory or optional nature of the provision will be indicated from time to time either explicitly or through the use of symbols (e.g., “*”) placed alongside the information whose provision is mandatory to pursue the respective purpose. 

5. METHODS OF PROCESSING

5.1 Personal Data will be processed in accordance with the requirements of the GDPR and the Privacy Code, by means of mainly computerized tools, but also possibly on paper, with logic strictly related to the purposes of the processing, through the databases, electronic platforms managed by Aliena by Faro or third parties (appointed Data Processors), the integrated computer systems of Aliena by Faro and the aforementioned third parties, and/or the Website.

5.2 Personal Data collected are processed in ways that provide adequate security measures to ensure maximum confidentiality and to prevent data loss, illicit or incorrect use and unauthorized access.

5.3 Personal Data are processed mainly at the offices of the Data Controller and at the locations of the Data Processors.

6. DATA PROCESSORS AND OTHER RECIPIENTS OF PERSONAL DATA

6.1 Personal Data may be transferred to companies controlled by, or affiliated with, Aliena by Faro and/or companies linked to it by a contractual relationship, located in or outside the EU, which will act as data processors (“Processors“).

6.2 The constantly updated list of Processors can be made available to Data Subject by contacting the Controller at the e-mail address dafne@aliena.space.

6.3 Personal Data may be made accessible, for the above purposes, to employees and associates of Aliena by Faro (“Persons in charge of the processing“), who are properly trained in their processing.

6.4 Personal Data may be transmitted to the Judicial Authority where necessary and in the cases provided for by law.

7. DATA RETENTION PERIOD (DATA RETENTION)

7.1 The Personal Data conferred directly by the User are kept for the duration of the registration (or, in the absence thereof, for the duration of the browsing), for the performance of the fulfillments inherent and consequent thereto, for compliance with applicable legal, contractual and regulatory obligations (and, in any case, for the fulfilment of the purposes referred to in point 3 of this policy) and, in any case, are stored in the database of Aliena by Faro for a period of time proportional to the purpose of processing, after which the data will be deleted or anonymized.

7.2 This is without prejudice to defensive needs that may require retention for an additional period, such as but not limited to, settlement of pre-litigation and/or litigation initiated prior to the expiration of the retention period and compliance with public authority requests received/notified to the Controller prior to the expiration of the retention period.

7.3 The browsing data of Users accessing the Website are stored by the hosting provider without the Company having control over the retention time.

8. DATA OF MINORS

8.1 Aliena by Faro does not intend to collect Personal Data from minors or intentionally establish communication with them. For this reason, we encourage parents to actively monitor the online activities of children under the age of 18 (eighteen).

8.2 Nonetheless, should Aliena by Faro process data of a minor under the age of 18, the consent of the parents, parental guardians, or legal guardians will be required.

9. RIGHTS OF THE DATA SUBJECT

9.1 Each Data Subject may at any time exercise against the Controller the rights provided for in Articles 15-22 of the GDPR, including:

1. a) the right to obtain access, rectification, deletion, restriction of processing, and portability of personal data (e.g., biographical data);
2. b) the right to object to the processing at any time.

9.2 The Data Subject has the right to revoke the consent given in relation to the purposes of the processing at any time. Revocation of consent will not affect the lawfulness of any processing based on consent and carried out by Aliena by Faro prior to revocation.

9.3 Requests made to exercise rights should be forwarded to the Controller’s e-mail address dafne@aliena.space.

9.4 If the Data Subject considers that the processing of data concerning them does not comply with the provisions in force, or if the response to a request by which they exercise one or more of the rights provided for in Articles 15-22 of the GDPR does not reach them within the specified timeframe or is unsatisfactory, the Data Subject may appeal to the Judicial Authority or the Data Protection Authority, in the latter case by means of a complaint pursuant to Article 77 of the GDPR in the manner described on the Authority’s website: https://www.garanteprivacy.it/. 

10. AMENDMENTS TO THIS POLICY

10.1 Aliena by Faro may amend or simply update this policy, in part or in full, as a result of changes in the laws and regulations governing the subject matter as well.

10.2 Such changes will be publicized by posting on the Website.

10.3 Aliena by Faro invites the Data Subject to regularly visit the Website to become aware of the most recent and updated version of this policy.

Policy updated to 14/03/2023