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Informativa e Privacy

Information on the processing of personal data pursuant to art. 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("General Data Protection Regulation")

The entity responsible for the processing of your personal data, collected on our website, accessible at the address https://www.Lasignoradeisaponi.it ("our site"), is DueAlpha srl, with registered office in Via Graziola 16, 48018 Faenza, Ravenna, Italy.

This Personal Data Protection Policy applies to the data we collect when you use Our Website and our application, or when you go to one of our stalls. This policy describes the types of personal data we collect from consumers/users and explains how and for what purposes we use the data we collect and with whom we share it and where we transfer it, as well as the choices consumers have regarding our use of that data. This policy also describes the measures we take to protect the security of this data and how you can contact us about how we process your personal data. Please read this Personal Data Protection Policy carefully. If you do not want your personal data to be used in the manner described in this Privacy Policy, we cannot guarantee that we will respond effectively to all of your requests. Please check this Personal Data Protection Policy regularly in order to be kept up to date with any possible changes to it, in particular those relating to the methods of collection and the conditions for the processing of your personal data.

 

Topics covered

1. Registration on the Site2. Identity and contact details of Duealpha Società Benefit S.r.l. . ("Duealpha") as data controller3. Processing of data by Duealpha for the purposes of access and registration to the Site and for the conclusion and execution of the purchase contract4. Data processing by Duealpha for general marketing/newsletter purposes5. Processing of the e-mail address by Duealpha for soft-spam purposes6. Data processing by Duealpha for profiling purposes for marketing purposes7. Processing of data by Duealpha for assistance/customer care purposes

8. Data processing by Duealpha for administrative, accounting and tax purposes9. Processing of data by Duealpha in order to allow the user to exercise rights10. Processing of data by Duealpha for the purpose of ascertaining, exercising or defending a right11. Processing of health data by Duealpha12. Categories of subjects to whom Duealpha communicates the user's personal data (recipients)13. Right to object14. Right of access15. Right to rectification16. Right to erasure17. Right to restriction of processing18. Right to data portability19. Response times and methods in the event of the exercise of the rights of the data subject20. Right to lodge a complaint with a supervisory authority

1. REGISTRATION ON THE SITE

As specified above, Duealpha srl is the owner of the e-commerce site www.Lasignoradeisaponi.it ("Site") and is the counterparty to the purchase contracts concluded through the Site.

To make purchases through the Site, registration on the Site is required, which implies the activation of a reserved personal area on the Site called "Login" ("Site Registration").

Through the reserved area of the Site called "Login", the logged in user can carry out activities of a general nature (e.g.: modify the personal data provided)

Through the Site Duealpha s.r.l. therefore carries out a plurality of services ("Site Services") and, in particular:

- services related to Site Registration;- services related to the offer and sale of products through the Site;

This information is therefore provided with reference to all the Services of the Site and, therefore, to the processing carried out by La Duealpha s.r.l. in its capacity as data controller:

- in relation to Registration on the Site, including access and navigation on the Site;
- in relation to purchases on the Site;- in relation to the request for assistance and customer care services concerning the Site Services;- subject to the express consent of the data subject, in relation to the pursuit of the marketing and/or profiling purposes better described below.

2. IDENTITY AND CONTACT DETAILS OF DUEALPHA SRL AS DATA CONTROLLER

Duealpha s.r.l. (Duealpha) is the data controller of the personal data of users described in this information and concerning the data collected:

- in relation to Registration on the Site, including access and navigation on the Site;- in relation to purchases on the Site;- in relation to the request for assistance and customer care services concerning the Services of the Site;- subject to the express consent of the data subject, in relation to the pursuit of the marketing and/or profiling purposes better described below.

The identification details and contact details of Duealpha s.r.l. are as follows:

- DueAlpha s.r.l. with registered office in Faenza (RA), via Graziola 16 (48018), share capital of € 30000.00 fully paid-up, R.E.A. n. 222657, registered in the Ravenna Business Register, with registration number, VAT number and Tax Code 02677030393- e-mail: info@lasignoradeisaponi.it- telephone: +39.349 7159218 (from Monday to Friday,  from 9.00 to 12.30 and from 14.30 to 17.00, excluding Saturdays and Sundays, as well as public holidays in Italy),

3. PROCESSING OF DATA BY DUEAPLHA FOR THE PURPOSES OF ACCESS AND REGISTRATION TO THE SITE AND CONCLUSION AND EXECUTION OF THE PURCHASE CONTRACT

Duealpha will process the user's personal data to:

- allow registration on the Site and the use of services reserved for registered users, including the possibility of purchasing online through the Site;

- to allow the conclusion of the purchase contract through the Website and the correct execution of the obligations arising from this contract, such as, by way of example, the delivery and payment, including online, of the products and/or services purchased;

- to execute the pre-contractual requests sent by the user. The legal basis for this processing is the fulfilment of the contract or, as the case may be, the execution of pre-contractual measures adopted at the request of the data subject (Article 6.1.b) of the Regulation). For this purpose, Duealpha will process the user's data for the time strictly necessary to carry out the individual processing activities (e.g.: registration data will be processed until the account is closed, taking into account the technical time necessary for the same; the data necessary for the execution of the purchase contract will be processed until the delivery of the product or, in the event of non-delivery,  until the termination of the contract), it being understood that, after this term, Duealpha may retain the data for the purposes and for the maximum retention periods referred to in the other sections of this policy, if relevant, and/or, in any case, in the cases established by the Regulation and/or by law.

Further Information

In particular, as part of this purpose, Duealpha will process users' personal data, among other things, to:

- allow the user to access the Site, even as a non-logged in user, and to browse the Site;

- to allow the user to register on the Site, by creating an account, and to use the services reserved for registered users, including, in particular, the possibility of purchasing through the Site, and/or exercising the right of withdrawal online;

- maintain and manage your account;

- store data and information in the user's account, such as, by way of example, the user's personal data, the history of his/her orders and any returns, his/her preferred delivery and/or billing addresses, the preferences expressed in relation to the processing of personal data for general marketing purposes and/or for profiling purposes for marketing purposes;

- to allow the user to put the products in the shopping cart and to conclude the purchase contract through the Site;

- to allow the user to make online payment for purchases made on the Site;

- to execute the purchase contract concluded by the user with Duealpha through the Site, making the delivery of the products purchased.

The provision of data for the purpose in question is optional: that is, there is no legal or contractual obligation to communicate the data; however, since their processing is necessary to allow access to the Site and/or navigation on the Site and/or Registration on the Site and/or the provision of management and maintenance services of the Site Registration account as well as the conclusion and execution of the purchase contract through the Site or to respond to pre-contractual requests made by the user in relation to the Site, failure to provide data will make it impossible for the user to access and/or browse the Site and/or to register on the Site and to use the services reserved for registered users and/or to conclude a purchase contract through the Site and/or to receive a response to the pre-contractual requests made.

4. PROCESSING OF DATA BY DUEALPHA FOR GENERAL MARKETING/NEWSLETTER PURPOSES

Subject to the express consent of the user, Duealpha will process the user's personal data to send him/her commercial communications, including a happy birthday email, newsletter, discount coupons and promotions, referring to products and services of the same or of third parties as well as for the purpose of carrying out market research (customer satisfaction),  by e-mail, text message, post and/or telephone.

The legal basis for this processing is the express consent of the data subject (art. 6.1.a) of the Regulation). The user may revoke the consent given at any time and/or object, at any time, to the processing of his data for marketing purposes:

- by contacting Duealpha at the following addresses:telephone: +39.349 7159218 (Monday to Friday, from 9.00 to 12.30 and from 14.30 to 17.00, excluding Saturdays and Sundays, as well as public holidays in Italy); e-mail: info@lasignoradeisaponi.it- by accessing the "Personal Information" section on the "Login" page of the Site, if the user is registered on the Site.

The opposition expressed in these ways also extends to the sending of communications by postal service and/or by telephone.
The provision of data for general marketing purposes is optional: there is no legal or contractual obligation on the part of the user to provide such data for this purpose and/or to give consent to the processing of his/her personal data for this purpose.For marketing purposes, Duealpha will process the user's data until the withdrawal of consent and/or the exercise of the right to object and, in any case, no later than three years from the collection of the data, reserving the right, before the expiry of this term, to ask the user to renew consent and/or update the data.

Further information

The user is informed of the following:

- for general marketing purposes, Duealpha uses personal data initially collected for other purposes and, in particular, for the purpose of registering on the Site and/or concluding and/or executing the purchase contract through the Site; such further processing is permitted, as it is based on the consent of the data subject;

- the withdrawal of consent does not affect the lawfulness of the processing based on the consent given before the withdrawal;

- in the event that you object to the processing of your data for general marketing purposes and/or withdraw your consent to the processing for general marketing purposes, your data will no longer be processed by Duealpha for this purpose and will only be kept by Duealpha in the event that there is another legal basis (such as,  for example, the establishment, exercise or defence of a right in court or administrative proceedings);

- failure to provide data for general marketing purposes and/or failure to provide consent to such processing and/or the revocation of such consent and/or the exercise of the right to object do not have any consequence on the user's ability to register on the Site and/or make purchases on the Site.

5. PROCESSING OF THE E-MAIL ADDRESS BY DUEALPHA FOR SOFT-SPAM PURPOSES

Duealpha will process the e-mail coordinates (i.e. the e-mail address) provided by the user in the context of the purchase of a product through the Site, to allow Duealpha to sell similar products directly (and therefore to send the user promotional communications concerning such products by e-mail) without the need for express and prior consent of the data subject, as provided for by art. 130, paragraph IV, of the Privacy Code, and provided that the user does not exercise the right to object in the manner indicated below (so-called soft-spam). The legal basis for this processing is art. 130, paragraph IV, of the Privacy Code which expressly allows the processing in question. The user can object to receiving soft-spam communications:

- by contacting Duealpha at the following addresses:telephone: +39.349 7159218 (Monday to Friday, from 9.00 to 12.30 and from 14.30 to 17.00, excluding Saturdays and Sundays, as well as public holidays in Italy); e-mail: info@lasignoradeisaponi.it- by accessing the "Personal Information" section on the "Login" page of the Site.

For the purpose of soft-spam, Duealpha will process the user's data until the exercise of the right to object and, in any case, no later than 3 years from collection, except for the details of purchases which will be stored and processed for soft-spam purposes for a period of 24 months from collection.

Further information

The provision of data for the purpose in question is optional: there is no legal or contractual obligation on the part of the user to provide such data for this purpose. Failure to provide data for the purpose of soft-spam or opposition to such processing will not have any consequence on the user's ability to register on the Site and/or make purchases on it.

The user is informed of the following:

- for the purpose of soft-spam, Duealpha uses personal data initially collected for other purposes and, in particular, for the purposes of registration on the Site and the conclusion and execution of the purchase contract through the Site; such further processing is permitted, as it is based on Article 130, IV, paragraph, of the Privacy Code;

- in the event that the user objects to the processing of his/her data for soft-spam purposes, his/her data will no longer be processed by Duealpha for this purpose and will be kept by Duealpha only in the event that there is another legal basis (such as, for example, the establishment, exercise or defense of a right in court or administrative proceedings).

6. PROCESSING OF DATA BY DUEALPHA FOR PROFILING PURPOSES FOR MARKETING PURPOSES Subject to the

explicit consent of the user, Duealpha will process the personal data of users, in an automated manner, to:

- monitor and track the behavior of users on the Site, collecting and recording data relating to navigation (e.g.: pages visited, products viewed, whether the user has purchased or has not purchased,  abandoned carts, access device, dwell time) and purchase data (e.g.: type of product purchased, frequency of purchases, amounts spent, payment methods);

- analyse and process such data, together with other information relating to users (such as, by way of example, gender, postal code, date of birth, IP address, etc.), in order to identify correlations between user behaviour and include them in various "clusters" or sets of types of customers that may have common characteristics;

- sending, by e-mail or text message, post or telephone, and/or displaying personalized offers on the Site to users, i.e. combined with the cluster in which the user has been included and, therefore, of presumed specific interest. All stages of the processing, including the final decision on the promotional communication to be sent or displayed to the user based on the cluster(s) to which the user belongs, take place in a fully automated manner, without any human intervention, on the basis of an algorithm whose parameters have been previously set by Duealpha.La decision based solely on automated processing,  including profiling produces legal effects concerning the data subject (i.e. the limitation of his or her freedom of choice) and is allowed by the cause of exemption referred to in art. 22.2.c) of the GDPR, as it is based on the explicit consent of the data subject.

The user therefore has the right, at any time, to:

- obtain human intervention from Duealpha;- express his opinion;- contest the decision taken by Duealpha (e.g.: inclusion in a given cluster).

To exercise this right, the user can contact Duealpha at the following addresses:

telephone: +39.349 7159218 (Monday to Friday, from 9.00 to 12.30 and from 14.30 to 17.00, excluding Saturdays and Sundays, as well as public holidays in Italy); e-mail: info@lasignoradeisaponi.it


The legal basis for this processing is the explicit consent of the data subject (art. 6.1.a) of the Regulation). The user can revoke the consent given at any time and/or object, at any time, to the processing of his data for profiling purposes for marketing purposes:

- by contacting Duealpha at the following addresses:telephone: +39.349 7159218 (from Monday to Friday, from 9.00 to 12.30 and from 14.30 to 17.00, excluding Saturdays and Sundays, as well as public holidays in Italy); e-mail: info@lasignoradeisaponi.it

For the purpose of profiling for marketing purposes, Duealpha will process the user's data until the withdrawal of consent and/or the exercise of the right to object and, in any case, no later than 12 months from collection. The provision of data for the purpose of profiling for marketing purposes is optional: that is, there is no legal or contractual obligation on the part of the user to provide such data for this purpose and/or to give consent to the processing of his data for this purpose.


Further information

The user is informed of the following:

- users, subject to their consent, are grouped according to characteristics identified by Duealpha and for these reasons included in specific clusters. Clusters are created on the basis of both individual characteristics relating to the Site Service used by users (e.g.: pages visited, products viewed, frequency and type of purchases) and other information relating to users (e.g.: gender, age group, device used, zip code). Duealpha then sends users or displays "targeted" promotional communications, as they correspond to the profile of the user that has been created in this way and automatically matched to the cluster in which the user has been inserted. Each user can be placed in more than one cluster. Clusters can be crossed. As a result of this processing activity, therefore, the user receives promotional communications with a different content from that of the communications received by another user or the user views recommended or suggested products on the Site that are different from those viewed by another user or in a different order from that of another user;

- for the purpose of profiling for marketing purposes, Duealpha also uses personal data initially collected for other purposes and, in particular, for the purposes of registration on the Site and/or the conclusion and/or execution of the online purchase contract and/or navigation on this Site; such further processing is permitted, as it is based on the consent of the data subject;

- the withdrawal of consent does not affect the lawfulness of the processing based on the consent given before the withdrawal;

- in the event that the user objects to the processing of his/her data for profiling purposes for marketing purposes and/or withdraws consent to the processing for profiling purposes for marketing purposes, his/her data will no longer be processed by Duealpha for this purpose and will be kept by Duealpha only in the event that there is another legal basis (such as,  for example, the establishment, exercise or defence of a right in court or administration or the fulfilment of legal obligations);

- failure to provide data for profiling purposes for marketing purposes and/or failure to provide consent to such processing and/or the revocation of such consent and/or the exercise of the right to object will not have any consequence on the user's ability to register on the Site.

7. PROCESSING OF DATA BY DUEALPHA FOR ASSISTANCE/CUSTOMER CARE PURPOSES

Duealpha will process user data for general assistance and customer care activities and therefore to respond to requests for information from users or to respond to complaints, reports and disputes. The legal basis for this processing is the execution of pre-contractual measures adopted at the request of the data subject (art. 6.1.b), last paragraph, of the Regulation) or, as the case may be, the legitimate interest of Duealpha (art. 6.1.f) of the Regulation). It is in Duealpha's legitimate interest to respond to requests for information and/or reports and/or disputes and/or complaints from users of the Site. This legitimate interest of Duealpha also coincides with the legitimate interest of the users themselves who make the requests and/or reports and/or disputes and/or complaints in question and who, therefore, in the context of the relationship with Duealpha, can be considered to reasonably expect their personal data to be used by Duealpha to provide them with feedback. The legitimate interest of Duealpha, thus identified, can therefore be considered to prevail over the fundamental rights and freedoms of the data subject, also because of these reasonable expectations and the relationship existing between the data subject and Duealpha as well as in consideration of the nature of the data processed and the coinciding interest of the data subjects themselves. The user has, in any case, the right to object, at any time, for reasons related to his personal situation, to the processing of personal data concerning him for the purpose in question (i.e. assistance and customer care).

To exercise this right, the user can contact Duealpha at the following addresses: telephone: +39.349 7159218 (Monday to Friday, from 9.00 to 12.30 and from 14.30 to 17.00, excluding Saturdays and Sundays, as well as public holidays in Italy); E-mail: info@lasignoradeisaponi.it

 


Further information

In the event of exercising the right to object to the processing of data for assistance/customer care purposes, Duealpha will refrain from further processing the personal data of users for this purpose, unless it demonstrates the existence of compelling legitimate reasons for proceeding with the processing that prevail over the interests and rights and freedoms of the data subject or for the ascertainment,  the exercise or defence of a right in court. The provision of personal data for the purpose in question is optional: that is, there is no legal and/or contractual obligation to communicate the data; however, given the purpose of the processing, failure to provide data and/or the exercise of the right to object may make it impossible to respond to requests and/or reports and/or complaints and/or objections from users, if the response to such requests involves the processing of the user's personal data. For this purpose, Duealpha will process the user's data for the time necessary to carry out the requested activities and, therefore, in particular, for the time necessary to provide the information requested by the user or to respond to complaints and/or reports and/or disputes submitted by the user.


8. PROCESSING OF DATA BY DUEALPHA FOR ADMINISTRATIVE, ACCOUNTING AND TAX PURPOSES

Duealpha will process users' data for the purpose of carrying out administrative and/or accounting and/or tax obligations related to the provision of the Website Services and/or the purchase contract concluded through the Website, such as, by way of example, the keeping of accounting records and the issuance of the sales invoice or,  depending on the case, related to registration on the Site such as, by way of example, the obligations referred to in Presidential Decree 430/2001.The legal basis for this processing is the fulfillment of legal obligations to which Duealpha is subject (art. 6.1.c) of the Regulation). The provision of data for the purpose in question is mandatory, because their processing is necessary to allow Duealpha to comply with legal obligations incumbent on it. Any refusal to provide data for this purpose will make it impossible for the user to use the Services of the Site and, in particular, to conclude the purchase contract through the Site. For this purpose, Duealpha will process the user's data until the expiry of the legal terms provided for the performance of each administrative-accounting and tax obligation and/or for the retention times provided for by law for the storage of the related documentation.

9. PROCESSING OF DATA BY DUEALPHA IN ORDER TO ALLOW THE USER TO EXERCISE RIGHTS

Duealpha will process users' data in order to:

- respond to requests to exercise the right of withdrawal and/or requests to exercise the legal guarantee of conformity and/or other rights arising from the purchase contract concluded on the Site and/or provided for by law in relation to such contract and/or in relation to the provision of Site Services;

- respond to requests to exercise rights deriving from registration on the Site;

- carry out the activities that prove necessary as a result of the exercise of these rights and proceed, if necessary, to the related refunds;

- receive and respond to requests to exercise the rights regarding the protection of personal data provided for by the Regulation and carry out all the consequent activities. The legal basis for this processing is the fulfilment of legal obligations to which Duealpha is subject (art. 6.1.c) of the Regulation).

Further information

The provision of data for the purpose in question is mandatory, because their processing is necessary to allow Duealpha to comply with legal obligations as well as the user to exercise the rights that the law or the contract attribute to him. Any refusal to provide data for this purpose will make it impossible for the user to exercise this right. For this purpose, Duealpha will process the data until the expiry of the legal terms provided for the exercise of the right (limitation period and/or forfeiture) or, in the case of exercise of these rights, for the time necessary for the management and closure of the file; in the event of exercising the rights provided for by the Regulation, the data will be processed until the data controller certifies that it has fulfilled the request or until the fulfillment itself, whichever occurs later.

10. PROCESSING OF DATA BY DUEALPHA FOR THE PURPOSE OF ASCERTAINING, EXERCISING OR DEFENDING A RIGHT

Duealpha will process the data of users for the establishment, exercise or defense of a right in all competent forums. The legal basis for this processing is the legitimate interest (art. 6.1.f) of the Regulation.It is in the legitimate interest of the data controller to exercise remedies to ensure compliance with its contractual rights or to demonstrate that it has fulfilled the obligations arising from the contract with the data subject, including the promise to the public referred to in the rules of a prize event,  or imposed on the data controller by law. This legitimate interest is founded, in turn, in the constitutionally protected right of defense. It can therefore be considered to prevail over the fundamental rights and freedoms of the data subject, also by reason of the reasonable expectations of the same. The user has, in any case, the right to object, at any time, for reasons related to his personal situation, to the processing of personal data concerning him for the purpose in question (i.e. defense of a right/purposes of justice). To exercise this right, the user can contact Duealpha at the following addresses: telephone: +39.349 7159218 (Monday to Friday, from 9.00 to 12.30 and from 14.30 to 17.00, excluding Saturdays and Sundays, as well as public holidays in Italy); e-mail: info@lasignoradeisaponi.it

Further Information

Please note that, in particular, Duealpha will retain and possibly use the data:

a) for the purpose of proving the fulfilment of the purchase contract through the Website and/or the provision of the Website Services and/or to initiate or respond to actions relating to this contract and/or this performance before any administrative and/or judicial authority and/or to protect its rights in the preparatory phases of the trial and/or procedure; for this purpose, the data will be kept for 10 years from the delivery of the product and/or from the provision of the Site Services, including the registration service (in this case the data will be kept for 10 years from the closure of the account) or from the termination of the contract, in the event of non-delivery of the product;

b) to prove that it has responded to users' complaints and/or reports and/or complaints;

c) in the event of exercising the rights provided for by the Regulation, the data will be stored for 5 years from the certification of having responded to the request of the data subject or from such feedback, whichever is later;

d) in the case of exercising rights provided for by the purchase contract or by law, the data will be kept for 10 years, starting from the closure of the file or from the performance of the action that defines it (e.g.: refund, in case of withdrawal; or delivery of the replacement product, in case of legal warranty); closure of the file means the last correspondence relating to the exercise of the right in question;

e) in the event of complaints and/or reports and/or disputes, the data will be kept for three years from the closure of the file, to be understood as the last correspondence on the matter.

It should also be noted that:

- the provision of data for this purpose is optional: there is no legal or contractual obligation that requires the data subject to provide data for this purpose;

- for the purpose in question, data initially collected for a different purpose are used, the further processing of which is permitted as it is based on the legitimate interest of the data controller, given the compatibility of this additional purpose with the initial purpose of the collection, also taking into account the fact that, to the extent that the processing is necessary for the assessment,  to the exercise and defence of a right, the data controller is also exempt from the obligation of erasure, by express provision of the Regulation;

- in the event of exercising the right to object, in fact, the data controller shall refrain from further processing the personal data, unless he demonstrates the existence of compelling legitimate reasons for proceeding with the processing that prevail over the interests, fundamental rights and freedoms of the data subject or for the establishment, exercise or defence of a right in court.

11. PROCESSING OF HEALTH-RELATED DATA BY DUEALPHA

To register on the Site and to purchase the products offered for sale on the Site, the provision of health-related data is not required. It may happen, however, that, given the type of products sold through the Site, in the event of the user's exercise of the legal warranty of conformity and/or reports, disputes or complaints by users and relating to the products purchased on the Site, Duealpha may process data that, on the basis of art. 4.15) of the Regulation, can be considered as "data relating to health", as they can be inferred, even indirectly, the state of health of a natural person or information relating to his or her state of health can be inferred. Such data will be processed only for the purpose of executing the user's request and only and exclusively subject to the explicit and specific consent of the data subject, which will be requested from the user once the user's request containing such data has been received and before further processing of the same. The legal basis for this processing is the explicit consent of the data subject (art. 9.2.a) of the Regulation). The provision of health-related data is optional: there is no legal or contractual obligation that requires the user to provide such data. The provision of consent to the processing of such data is also optional. However, given the purpose of the processing (i.e. to allow the response to the requests of the data subject and/or the exercise of rights by the data subject), in the event of failure to provide such data and/or failure to provide consent to the processing of data relating to health, the user will not be able to obtain a response to the request, even for the exercise of a right,  Made. If you do not provide consent to the processing of health-related data, the health-related data provided by the data subject will be deleted immediately.

Further information

Please note that:

- the consent given will be effective only in relation to the specific request made by the data subject and the data relating to health contained therein and/or connected to it;

- in the event that the user makes a new request containing and/or involving the processing of data relating to health, consent to the processing of such data will be requested again, it being understood that the consent given in relation to a request may be revoked at any time without prejudice to the lawfulness of the processing based on the consent given before the withdrawal;

- You are prohibited from including health-related data in reviews; if, in violation of this prohibition, you include health-related data in your reviews, they will be immediately deleted and the review will not be published.


The user may revoke consent by contacting Duealpha at the following addresses:

telephone: +39.349 7159218 (Monday to Friday, from 9.00 to 12.30 and from 14.30 to 17.00, excluding Saturdays and Sundays, as well as public holidays in Italy); e-mail: info@lasignoradeisaponi.it

For this purpose, Duealpha will process the data for the time necessary to manage the request made by the data subject and, therefore, with the maximum retention times indicated in sections 7 and 9 of this policy, without prejudice to the additional retention periods permitted by the purpose referred to in section 10 of this policy and/or by the law and/or by the Regulation.

12. CATEGORIES OF SUBJECTS TO WHOM DUEALPHA COMMUNICATES THE USER'S PERSONAL DATA (RECIPIENTS)The

personal data provided by the user may be communicated by Duealpha to the categories of recipients indicated below. The subjects to whom Duealpha communicates the data act as external data processors designated by Duealpha through a specific contract ("Data Processors") or as persons authorized to process personal data under the direct authority of Duealpha ("Persons in Charge") or, in the case of third parties used by the Data Processor, as "Sub-Processors",  pursuant to art. 28.4 of the Regulation, except in cases where the recipient acts as an independent data controller, such as, for example, in the case of the Payment Service Provider, or even as an independent data controller, such as in the case of couriers.

Further information

Users' personal data may be communicated by Duealpha to the following categories of recipients:

- companies of the group to which Duealpha belongs and/or to employees and/or collaborators of Duealpha, for the performance of administration, accounting and IT and logistical support activities;

- to companies, consultants or professionals who may be in charge of the installation, maintenance, updating and, in general, management of Duealpha's hardware and software, including cloud computing service providers, and to third parties they use;

- to companies appointed by Duealpha to send commercial communications both by e-mail and SMS and by post;

- to companies that carry out logistical and/or warehouse and/or packaging and/or shipping and delivery or collection activities of the Products purchased on the Site and/or constituting the prizes of any competitions organized from time to time by Duealpha and to third parties they use;

- to the Payment Service Provider and/or the acquirer and/or banks in order to allow the payment of purchases made on the Site or their refund, if any, and to third parties they use;

- to the companies that provide the software for carrying out tracking, monitoring and profiling activities both for marketing purposes and for the purpose of preventing the improper use of the Website Services and to third parties they use;

- to all those subjects, including public authorities, who have access to the data by virtue of regulatory or administrative measures;

- to all those public and/or private entities, natural and/or legal persons (legal, administrative and tax consultancy firms), if the communication is necessary or functional to the correct fulfilment of the contractual obligations assumed in relation to the Website Services, including


13. RIGHT TO OBJECT

The data subject has the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her carried out for the purposes set out in sections 7 and 10 of this policy and having as its legal basis the legitimate interest of the data controller. In the event that the data is processed for direct marketing purposes (and therefore in the case of processing for the purposes referred to in sections 4, 5 and 6 of this policy), the data subject also has the right to object at any time to the processing of personal data concerning him or her carried out for such purposes, including profiling to the extent that it is related to such direct marketing.

The interested party can exercise the right to object by contacting Duealpha at the following addresses:

telephone: +39.349 7159218 (from Monday to Friday, from 9.00 to 12.30 and from 14.30 to 17.00, excluding Saturdays and Sundays, as well as public holidays in Italy); e-mail: info@lasignoradeisaponi.it

The data subject may also object to the further processing of his/her data for direct marketing purposes (purposes referred to in sections 5, 6 and 7 of this policy):

- through the appropriate link in each promotional communication sent by Duealpha by e-mail;- by accessing the "Personal Information" section on the "Login" page of the Site, in the event that the user is registered on the Site.


Further information

In the event of exercising the right to object, the controller shall refrain from further processing the personal data, unless the controller can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

If the data subject objects to processing for direct marketing purposes, the personal data will no longer be processed for this purpose.

14. RIGHT OF ACCESS

The data subject has the right to obtain from the data controller (and, therefore, from Duealpha) confirmation as to whether or not personal data concerning him or her is being processed and, if so, to obtain access to the personal data and information indicated below.

The interested party can exercise the right of access by contacting Duealpha at the following addresses:

telephone: +39.349 7159218 (from Monday to Friday, from 9.00 to 12.30 and from 14.30 to 17.00, excluding Saturdays and Sundays, as well as public holidays in Italy); e-mail: info@lasignoradeisaponi.it

Further information

In the event of exercising the right of access, the user may obtain access to personal data and the following information:

a) the purposes of the processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular if they are recipients in third countries or international organisations; d) where possible, the envisaged retention period of personal data or, if this is not possible, the criteria used to determine such period; e) the existence of the right of the data subject to request from the controller the rectification or erasure of personal data or the limitation of the processing of personal data concerning him or her or to object to their processing; (f) the right to lodge a complaint with a supervisory authority; g) if the data are not collected from the data subject, all available information on their origin; (h) the existence of automated decision-making, including profiling, which produces legal effects concerning the data subject or similarly significantly affects him/her, and at least in such cases, meaningful information about the logic used, as well as the significance and envisaged consequences of such processing for the data subject;

Where personal data are transferred to a third country or to an international organisation, the data subject has the right to be informed of the existence of appropriate safeguards in relation to the transfer, in accordance with Article 46 of the Regolamento.Il controller shall provide a copy of the personal data being processed. In the event of additional copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. If the data subject submits the request by electronic means, and unless otherwise indicated by the data subject, the information shall be provided in a commonly used electronic format.

15. RIGHT TO RECTIFICATION

The data subject has the right to obtain from the data controller (and therefore from Duealpha) the rectification of personal data concerning him or her without undue delay. Taking into account the purposes of the processing, the data subject has the right to obtain the completion of incomplete personal data, including by providing a supplementary statement.

The interested party may exercise the right to rectification by contacting Duealpha at the following addresses:

telephone: +39.349 7159218 (from Monday to Friday, from 9.00 to 12.30 and from 14.30 to 17.00, excluding Saturdays and Sundays, as well as public holidays in Italy); e-mail: info@lasignoradeisaponi.it

16. RIGHT TO ERASURE

The data subject has the right to obtain from the data controller (and therefore from Duealpha) the erasure of personal data concerning him or her without undue delay and the data controller is obliged to erase the personal data without undue delay, if one of the following reasons exists:

a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; b) the data subject withdraws the consent on which the processing is based (and, therefore, in the event of withdrawal of consent to the processing for the purposes referred to in sections 4, 6 and 11 of this policy), if there is no other legal basis for the processing; c) the data subject objects to processing based on the legitimate interest of the controller on grounds relating to his or her particular situation (and therefore in the event of objection to processing for the purposes set out in sections 7 and 10 of this policy) and there is no overriding legitimate reason or objects to the processing of his or her personal data for direct marketing purposes,  including profiling to the extent that it is related to such direct marketing (and, therefore, in the case of objection to processing for the purposes set out in sections 4, 5 and 6 of this policy); d) the personal data are processed unlawfully; e) the personal data must be erased in order to comply with a legal obligation under Union or Member State law to which the controller is subject.

The interested party can exercise the right of cancellation by contacting Duealpha at the following addresses:

telephone: +39.349 7159218 (from Monday to Friday, from 9.00 to 12.30 and from 14.30 to 17.00, excluding Saturdays and Sundays, as well as public holidays in Italy); e-mail: info@lasignoradeisaponi.co.ukFurther Information

If the controller has made personal data public and is obliged to erase them, taking into account the available technology and the costs of implementation, it shall take reasonable steps, including technical measures, to inform the controllers who are processing the personal data of the data subject's request to erase any link, copy or reproduction of his/her personal data.

The right to erasure does not apply to the extent that the processing is necessary:

a) for the exercise of the right to freedom of expression and information; (b) for compliance with a legal obligation under Union or Member State law to which the holder is subject or for the performance of a task carried out in the public interest or in the exercise of official authority; (c) for reasons of public interest in the field of public health; (d) for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes, in so far as the right to erasure is likely to render impossible or seriously impair the achievement of the objectives of such processing; e) for the establishment, exercise or defence of a right in court.


17. RIGHT TO RESTRICTION OF PROCESSING
The data subject has the right to obtain from the data controller (and therefore from Duealpha) the restriction of processing when one of the following cases occurs:a) the data subject contests the accuracy of the personal data for the period of time necessary for the data controller to verify the accuracy of such personal data; b) the processing is unlawful and the data subject opposes the erasure of the personal data and instead requests that their use be limited; c) although the controller no longer needs them for the purposes of the processing, the personal data are necessary for the data subject to establish, exercise or defend legal claims; d) the data subject has objected to the processing in the cases of processing based on the legitimate interest of the data controller, for reasons related to his or her particular situation (and, therefore, in the event of objection to the processing of data for the purposes referred to in sections 7 and 10 of this policy), pending verification of whether the legitimate reasons of the data controller prevail over those of the data subject.

The interested party may exercise the right of limitation by contacting Duealpha at the following addresses:

telephone: +39.349 7159218 (from Monday to Friday, from 9.00 to 12.30 and from 14.30 to 17.00, excluding Saturdays and Sundays, as well as public holidays in Italy); e-mail: info@lasignoradeisaponi.co.ukFurther information

If the processing is restricted, the personal data subject to the restriction will be processed, except for storage, only with the consent of the data subject or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. The data subject who has obtained the restriction of processing shall be informed by the controller before the restriction is lifted.

18. RIGHT TO DATA PORTABILITY

The data subject has the right to receive in a structured, commonly used and machine-readable format, the personal data concerning him or her provided to a data controller and has the right to transmit such data to another data controller without hindrance from the data controller to whom he or she has provided them,  where:

a) the processing is based on the consent of the data subject or on a contract; b) the processing is carried out by automated means. The data subject may therefore exercise the right in question in relation to the purposes referred to in the following sections of this policy: 3, 4, 6 and 11.

The interested party can exercise the right to portability by contacting Duealpha at the following addresses:

telephone: +39.349 7159218 (from Monday to Friday, from 9.00 to 12.30 and from 14.30 to 17.00, excluding Saturdays and Sundays, as well as national holidays in Italy); e-mail: info@lasignoradeisaponi.it

Further information

In exercising your right to data portability, you have the right to obtain the direct transmission of your personal data from one controller to another, if technically feasible. The exercise of the right to portability is without prejudice to the right to erasure. The right to portability must not harm the rights and freedoms of others.

19. TIMING AND METHODS OF RESPONSE IN THE EVENT OF EXERCISE OF THE RIGHTS OF THE DATA SUBJECT

The data controller provides the data subject with information about the actions taken in relation to a request to exercise the rights recognized by articles 11 to 17 of the Regulation (i.e. right of access, right of rectification, right of erasure, right of limitation of processing,  right to data portability, right to object) and referred to in sections 13, 14, 15, 16, 17 and 18 of this policy ("Rights of the Data Subject"), without undue delay and, in any case, within one month of receipt of the request itself. This period may be extended by two months, if necessary, taking into account the complexity and number of requests. The controller shall inform the data subject of such extension, and of the reasons for the delay, within one month of receipt of the request. If the data subject submits the request by electronic means, the information shall be provided, where possible, by electronic means, unless otherwise indicated by the data subject.

Further information

If the controller does not comply with the data subject's request, it shall inform the data subject without delay, and at the latest, within one month of receipt of the request, of the reasons for the non-compliance and of the possibility of lodging a complaint with a supervisory authority and of bringing a judicial remedy. Communications in response to the exercise of the Data Subject's Rights and the actions taken are free of charge. If the data subject's requests are manifestly unfounded or excessive, in particular because of their repetitive nature, the controller may:

(a) charge a reasonable fee, taking into account the administrative costs incurred in providing the communications or taking the action requested; b) refuse to comply with the request. Where the controller has reasonable doubts as to the identity of the natural person making the Data Subject Rights request, it may request additional information necessary to confirm the identity of the data subject.

20. RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

Without prejudice to any other administrative or judicial remedy, the data subject who considers that the processing of his or her concerning him or her violates the Regulation has the right to lodge a complaint with a supervisory authority, in particular in the Member State in which he or she habitually resides, works or the place where the alleged violation occurred. The supervisory authority to which the complaint has been lodged shall inform the complainant of the status or outcome of the complaint, including the possibility of a judicial remedy.

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