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Italian Version

GDPR PRIVACY REGULATION

Version 1.1

Updated on May 25th, 2018

 

Dear User,

In this section, you will find information relative to the method of processing your personal data, in case of use of our services on one of K BRAND SRL websites. This information is provided not only to fulfil the statutory obligations regarding the protection of personal data provided for in the European Regulation 2016/679 or GDPR, in the event that you use our services on one of the K BRAND SRL sites, but also because the safeguarding of personal data is considered a fundamental value by our company and it is and will be our priority to supply any information which can help you to protect and monitor the use of your personal data in relation to the browsing experience and the use of our websites and services.

Index

  1. Websites property of K BRAND SRL

  2. Data Controller and Data Processor

  3. Purposes and legal basis of the Processing

  4. Method of data collection

  5. Personal Data Recipient Categories

  6. Personal Data Storage Time Period

  7. Method of Personal Data transfer to EU and non-EU countries

  8. Profiling

  9. User and/or Client Rights

  10. Data Security and Protection

 

  1. Websites property of K BRAND SRL

The Internet sites, property of K BRAND SRL are hosted on the following domains (and relative sub-domains):

 

  1. Data Controller and Data Processor

The Data Controller (he who assumes the decisions regarding the methods and purposes of the processing) for all Sites, Agreements, software and services purchased is K BRAND SRL (hereinafter referred to as “K BRAND”) with headquarters in Corso della Resistenza 23, 20821 Meda (Monza Brianza), Italy. K BRAND SRL utilizes various Data Processors (see subparagraph 5 of this document) to ensure the use and purposes of the Services (see subparagraph 3 of this document).

The Data Controller has also appointed an internal Data Protection Officer, who is the individual responsible for monitoring the compliance with the Regulations, who can be contacted at Questo indirizzo email è protetto dagli spambots. È necessario abilitare JavaScript per vederlo.. Alternatively, it is possible to direct the request, therein including the exercise of the user to:

K BRAND s.r.l.

Corso della Resistenza 23

20821- Meda (Monza Brianza)

Attn. Data Protection Officer for K BRAND

In contacting us, it shall be the care of the data subject to include his/her name, email address, postal address and/or telephone number/s to ensure the proper management of the procedure.

  1. Purposes and legal basis of the Processing

K BRAND collects and uses the Personal Data of Users to achieve the following purposes:

  • a) Allow browsing of the site, improving the user experience, essentially through the use of Cookies.

The collection of Personal Data for the purposes under subparagraph 3, letter a) is governed by the Cookies Information, of which K BRAND recommends the reading of that is available at the following link https://www.kbrand.it/cookie.php.

  • b) Allow Clients to register on K BRAND sites which require the creation of a personal account, useful for the use of the Products and Services.
  • c) Allow Clients the use of request forms, chatbot and connected services (such as automatic notifications) in order to manage the process correctly.
  • d) Provide Services to the Clients, including the management of the administrative and accounting report, generated by the signing of the General Conditions, the Sales Agreement and the dispatch of communications closely related to the implementation of the service of a technical nature (example: information linked to products and services in use, satisfaction surveys) and/or of an administrative nature (example: updates to the present information provision), and/or of an informative character (example: updates to products and services purchased of which information has been requested).

The Personal Data collection for the purposes under letters b), c) and d) is necessary for accessing the Site and/or benefiting from the Services by the Client. The possible refusal prevents the Client from utilizing the connected services.

  • e) By express consent, periodic informative newsletters are sent related to K BRAND Products and Services or linked to them by Profiling.
  • f) By express consent, implement market researches, send invitations to K BRAND initiatives and events, send informative/commercial and marketing material, highlight K BRAND promotional initiatives through Profiling.

The collection of Personal Data for the purposes under letters a) and f) is necessary for accessing the Services which, by their nature, entail the processing of Personal Data for commercial and periodic information purposes (see commercial offers and newsletters). The possible refusal by the User prevents the latter from benefiting from Marketing Services (commercial offers and newsletters). Said processing are based on the User’s free, specific, informed and unequivocal consent, expressed through declaration or positive action (example: flag) on one of the K BRAND sites. The revocation of the consent may be exercised at any time, following the indications set out in subparagraph 9 of this Information.

  • g) Perform statistical analyses, market researches, improve the presentation of the Services and the use of Sites, Products and Services by the Users. Where possible, to accomplish these purposes, K BRAND utilizes Anonymous Personal Data (Personal Data which does not identify or make Users identifiable).

The Processing under letter g) is founded on the legitimate interest of K BRAND, consisting of the benefit which it can obtain in being able to present Users an offer more akin to the preferences established while browsing the Sites or the use of Products with the purpose of benefiting from customized services. For this reason, K BRAND deems that the legitimate interest of developing and improving Sites, Services, Software and connected Apps, justifies the Processing of Users Personal Data (albeit anonymously). Opposition to this Processing (in case of Personal Data which is not anonymous) may be exercised at any time by writing to Questo indirizzo email è protetto dagli spambots. È necessario abilitare JavaScript per vederlo.. Alternatively, one can submit one’s request to:

K BRAND s.r.l.

Corso della Resistenza 23

20821- Meda (Monza Brianza)

Attn. Data Protection Officer for K BRAND

In contacting us, it shall be the care of the data subject to include his/her name, email and postal addresses and/or telephone number to ensure the proper management of the procedure.

  1. Methods of Data Collection

K BRAND collects Personal Data with the following methods:

  • a) Personal Data entered on the Sites by Users and/or Clients is Personal Data provided, including but not limited to, for browsing, registering, using the support/information Service and accessing Services through K BRAND Sites or its software/Apps. Personal Data collected during marketing campaigns (Marketing SMS/Marketing emails, etc.) is included.
  • b) Personal Data expressly communicated to K BRAND by Users and/or Clients in an offline mode: this is Personal Data provided, purely be way of example, to K BRAND Customer Service (in case of a request to be contacted) or collected at the time of events and/or initiatives organized by K BRAND or communicated to K BRAND at the time of subscription of the General Conditions.
  • c) Data automatically collected by the Sites: this is Personal Data automatically collected by the Sites through, but not only, the use of Cookies (for further information, K BRAND recommends reading the Cookies Policy available on the Websites at the following link https://www.kbrand.it/cookie.php).
  • d) Social Plugins: K BRAND Sites, software and Applications may use the Social Plugins of various Social Networks (Facebook, LinkedIn, Instagram, Pinterest, Twitter, Google Plus, WhatsApp). Through their use, it is possible to access the Services, share content, updates, express opinions or suggest Products/Services. In case of activation of the Social Plugins, the Social Networks receive information related to the browsing on K BRAND Sites. If actions are taken, such as clicking on “Like” or you post a comment, the information shall be communicated from the browser directly to the Social Network. In case of use of the function “Access with Facebook” or “Register via Facebook”, the Social Network informs Users about the Data that shall be transmitted to K BRAND which, including but not limited to, is: public profile, email address, current address. Data communicated are used to simplify registration procedures, access for the posting of opinions or comments and in particular for the creation of the Client’s account.

Detailed information on entities, methods and processing of Data by the Social Networks may be viewed by accessing the information on the protection of data on the Social Networks portals.

In the case of use of K BRAND Services and Products or in case of browsing on K BRAND Sites, having the location detection activated, it could be possible that K BRAND collects and processes the information about the approximate location. In this case, Data is processed in an anonymous manner and the personal identification of the Users is not allowed. The purpose of the Processing is to facilitate and improve the benefiting from some Services features based on the location. It is possible to activate/deactivate the location feature at any time by accessing the settings of the browser and/or the device used.

Data Subjects under the age of 16 are not allowed to provide Personal Data. In some cases, where expressly indicated, the age limit is raised to 18 years of age. K BRAND shall not take any ownership of possible untruthful statements or contact requests received from Users who shall not respect said limitations. In the event that K BRAND notices the existence of untruthful statements or, after email or telephone contacts it becomes aware of the non-observance of these limitations, it shall be the care of K BRAND to proceed with the immediate deletion of any Personal Data acquired.

  1. Personal Data Recipient Categories

Personal Data that is processed by K BRAND and/or by third parties, selected for their integrity and competence and to which said Data may be communicated for the implementation of the Services and the proper operation of the Products requested by the Clients and/or to carry out anonymous statistical surveys (including but not limited to, Google Analytics, Google Tag Manager, Yandex.Metrica).

In particular, K BRAND informs Users that Personal Data may be processed by and/or communicated to:

K BRAND employees and/or collaborators closely connected to K BRAND and operatives working on the Product and Service requested by the Client.

Third party suppliers of services necessary to ensure the operation of Sites, Applications, Software and Services (example: Company who takes care of Cloud services, market researches and analyses).

Third party suppliers of services necessary for the enjoyment of the Services (example: payment processors).

Administrative Authorities where provided by the Services requested by the Client (example: participation to events).

Third parties (K BRAND partners/suppliers) which supply analyses services of the Sites’ browsing data.

By express consent of the User and/or Client, third parties (K BRAND partners/suppliers) which provide services of automatic newsletters delivery and/or any other types of commercial communications, marketing services, promotions, analysis of habits and consumption choices.

In NO EVENT, K BRAND releases or sells Personal Data to third parties.

The relationship between K BRAND and third-party subjects (K BRAND partners/suppliers appointed jointly responsible for the Processing of Personal Data) shall be governed by a regular contract, with prior verification of compliance with the principles of the EU Regulation.

  1. Personal Data Storage Time Period (or criteria for the determination of this period)

K BRAND stores Users and/or Clients Personal Data for the time strictly necessary for the attainment of the purposes for which it was collected, as indicated in subparagraph 3 of this Information. In particular, except in the exercise of the right of withdrawal of the consent/opposition referred to in subparagraph 9 of this Provision of Information and if there are rules or laws obliging a data retention exceeding the indicated times:

for the use of the Products (Services, Apps, platforms), K BRAND stores Personal Data for the duration strictly necessary to the provision of the Service/Product and for two additional years (2 years) from the conclusion, interruption of the Service/Product, without prejudice to the right to withdraw consent and the right to be forgotten. The objective is to allow an optimal benefit of the requested Services and to allow Users an easy repeated Log-in to the Services, without loss of the historical activities.

For the fruition of the information services and the commercial purposes, K BRAND stores Personal Data from the time of relative consent to the Agreement and up to two (2) years, without prejudice to the right to withdraw consent and the right to be forgotten. The objective is to keep Clients informed on new products (services, software, apps, platforms) or complementary products to those already in use by the Client as well as maintaining the history on the communication between K BRAND and the User for a better customization of the Service or of the proposal.

For invoices, accounting records and data relative to the transactions, K BRAND stores Personal Data for the duration of the Agreement and for additional 10 years in compliance with the law (included the tax obligations).

Such terms having passed, K BRAND shall proceed with the automatic deletion of the collected Personal Data and/or with its transformation into anonymous form in an irreversible method.

  1. Method of Personal Data Transfer to EU and non-EU Countries

Personal Data collected by K BRAND for the purposes set up under subparagraph 3 of this Information may be transferred by K BRAND, in compliance with the Regulation, to organizations located in non-EU Countries. All the organizations and K BRAND partners are bound to the Data Processing in compliance with the European principles established by the Regulation. In particular, K BRAND Sites may share some of the data collected with companies such as Google, Facebook and Microsoft (LinkedIn) via social plugins and the Google Analytics service. The transfer is authorized on the basis of specific decisions of the European Union and the Italian Data Protection Authority (Garante) for the protection of Personal Data, in particular decision 1250/2016 (Privacy Shield – link to the informative page of the Italian Garante), for which no further consent is required.

In NO EVENT shall K BRAND release or sell Personal Data to third party subjects.

  1. Profiling

  • a) Subject: collection of Users/Clients Personal Data on the Sites (example: registration, questionnaires, forms compilation), during the participation to organized events or with the participation of K BRAND and in the registration stage and use of K BRAND applications/software.
  • b) Purposes: optimize the experience of use, implementing and improving developments, promote complementary Services by sending commercial communication in line with the Users Personal Data (including the Clients) collected on the Sites, the possible sending of holiday greeting cards and the reporting of events organized by K BRAND (for example, trade shows). Thus, Profiling is aimed at defining the profile or personality of the Users (including the Clients) or at forecasting of future choices, or at monitoring the use of electronic communication services.
  • c) Effects for Users/Clients: receipt of commercial/informative communication in line with the preferences established by Users/Clients while browsing the Sites and in the use of the Services.

In NO WAY, does the Profiling by K BRAND:

  • constitute an automated decision from which legal or similarly significant effects are derived for Users/Clients;
  • prejudice the behavior and the choices of the Services completion by the Users/Clients;
  • have a prolonged and permanent impact, considering that Personal Data collected by K BRAND may be automatically updated at any time by Users/Clients;
  • determine any discrimination of Users/Clients, due to the type of Services offered by K BRAND and the category of Users/Clients affected by this Processing.
  1. User and/or Client Rights

For the purposes and the effects of the Regulation, for the time period referred to in subparagraph 6 of this Information, each User/Client shall have the right to:

With reference to the Processing under subparagraph 3, letters d), e) and f), revoke the consent at any time without prejudice to the lawfulness of the Processing, by exercising the opt-out from K BRAND commercial communications or by deleting the account directly on the Sites where a profile of the User/Client is present (see art. 7 of the Regulation).

Request Questo indirizzo email è protetto dagli spambots. È necessario abilitare JavaScript per vederlo. the access to Personal Data and to the information of the relative Processing and eventual copy in electronic format, unless otherwise specifically requested by the User/Client (see art. 15 of the Regulation).

Request Questo indirizzo email è protetto dagli spambots. È necessario abilitare JavaScript per vederlo. the rectification and/or update of Personal Data, without undue delay (see art. 16 of the Regulation).

Request the removal of Personal Data, for specific reasons (for example, unlawful Processing, withdraw of the consent, no overriding legitimate grounds for the Processing), without undue delay (see art.17 of the Regulation).

Request the restriction of Processing for specific reasons (for example, inaccuracy of Personal Data, unlawful Processing, exercise of a right in judicial proceedings). See art. 18 of the Regulation.

Object to, at any time the Processing of Personal Data by sending an email to Questo indirizzo email è protetto dagli spambots. È necessario abilitare JavaScript per vederlo., with reference to the Processing referred to in subparagraph 3, letters d), e) and f) (see art. 21 of the Regulation).

Be informed by K BRAND without undue delay, on any infringement or unauthorized accesses by third parties to its own systems containing Personal Data (example: data breach – see art. 34 of the Regulation).

Lodge a complaint with a supervisory authority (Garante Privacy) of the EU Country in which the data subject resides, works or in which the data subject holds for the violation of his/her rights took place (see art. 77 of the Regulation).

For further information, it is possible to consult the text of the 2016/67 European Regulation (link) or contact K BRAND by the methods provided in subparagraph 2 of this Information. (link to https://eur-lex.europa.eu/legal-content/IT/TXT/?uri=uriserv:OJ.L_.2016.119.01.0001.01.ITA&toc=OJ:L:2016:119:TOC)

  1. Data Security and Protection

Data collected by K BRAND must comply with the Regulations, with particular regards to the security measures provided for by the GDPR (art. 32 and 33 of the Regulation).