Our website address is: https://www.vroomvroomaccessories.com
Bertalan Ivan, with its registered office in Italy, in Via Rimini 6g, 15048 Valenza (AL), in its capacity as Data Controller, hereby informs you, pursuant to Art. 13 of Italian Legislative Decree no. 196 of 30.6.2003 (hereinafter, the “Privacy Code”) and Art. 13 of EU Regulation no. 2016/679 (hereinafter, “GDPR”), that your data will be processed in the following manner and for the following purposes:
1. Subject of the Processing
The Data Controller processes personal, identifying data (e.g., name, surname, company name, address, telephone number, e-mail address, bank and payment details – hereinafter, “personal data”) that you have provided upon entering into contracts for the Data Controller’s services.
2. Purposes of the processing
Your personal data are processed:
A) without your express consent (Art. 24 (a), (b), (c) of the Privacy Code and Art. 6 (b), (e) of the GDPR), for the following Service Purposes:
- To conclude contracts for the services of the Data Controller;
- To fulfil pre-contractual, contractual, and tax obligations arising from existing relationships with you;
- To comply with obligations established by law, regulation, EU legislation, or an order from an Authority (such as in relation to anti-money laundering);
- To exercise the rights of the Data Controller, for example, the right to legal defence;
B) Only with your specific and separate consent (Art. 23 and 130 of the Privacy Code and Art. 7 of the GDPR), for the following Marketing Purposes:
- To send you newsletters, commercial communications, and surveys on the satisfaction with the quality of services, and/or advertising material on products or services offered by the Data Controller and/or its business partners via e-mail, post, and/or text message and/or telephone contact;
3. Method of processing
The processing of your personal data is carried out through the operations indicated in Art. 4 of the Privacy Code and Art. 4(2) of the GDPR, namely: collection, recording, organisation, storage, consultation, processing, modification, selection, retrieval, comparison, use, interconnection, blocking, communication, erasure, and destruction of data. Your personal data are subject to both paper-based and electronic and/or automated processing. The Data Controller will process personal data for the time necessary to fulfil the aforementioned purposes and, in any case, for no longer than 10 years from the termination of the relationship for Service Purposes and for no longer than 2 years from the collection of the data for Marketing Purposes.
4. Access to data
Your data may be made accessible for the purposes set out in Art. 2.A) and 2.B):
- To employees and collaborators of the Data Controller in their capacity as persons in charge of the processing and/or internal data processors and/or system administrators;
- To third-party companies or other entities (by way of example, credit institutions, professional firms, consultants, insurance companies for the provision of insurance services, etc.) that carry out outsourced activities on behalf of the Data Controller, in their capacity as external data processors.
5. Communication of data
Without the need for express consent (pursuant to Art. 24 (a), (b), (d) of the Privacy Code and Art. 6 (b) and (c) of the GDPR), the Data Controller may communicate your data for the purposes set out in Art. 2.A) to Supervisory Bodies, Judicial Authorities, insurance companies for the provision of insurance services, as well as to those subjects to whom communication is mandatory by law for the fulfilment of said purposes. These subjects will process the data in their capacity as independent data controllers.
6. Data Transfer
Personal data is stored on servers located in Germany, within the European Union. It is in any case understood that the Data Controller, should it become necessary, will have the right to move the servers, including to locations outside the EU. In such a case, the Data Controller hereby ensures that the transfer of data outside the EU will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided for by the European Commission.
7. Nature of data provision and consequences of refusal to respond
The provision of data for the purposes set out in Art. 2.A) is mandatory. In its absence, we will not be able to guarantee the Services as per Art. 2.A). The provision of data for the purposes set out in Art. 2.B) is optional. You may therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications, and advertising material relating to the Services offered by the Data Controller. You will, however, continue to be entitled to the Services as per Art. 2.A).
8. Rights of the data subject
In your capacity as a data subject, you have the rights set out in Art. 7 of the Privacy Code and Art. 15 of the GDPR, namely the rights to:
- obtain confirmation of the existence or otherwise of personal data concerning you, even if not yet recorded, and their communication in an intelligible form;
- obtain the indication of: a) the origin of the personal data; b) the purposes and methods of the processing; c) the logic applied in case of processing carried out with the aid of electronic instruments; d) the identification details of the Data Controller, the data processors, and the designated representative pursuant to Art. 5(2) of the Privacy Code and Art. 3(1) of the GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity as a designated representative in the territory of the State, data processors or persons in charge of the processing;
- obtain: a) the updating, rectification or, where interested, the integration of the data; b) the erasure, transformation into anonymous form, or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) certification that the operations as per letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfilment proves impossible or involves a use of means manifestly disproportionate to the protected right;
- object, in whole or in part: a) for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated calling systems without the intervention of an operator, by e-mail and/or by traditional marketing methods by telephone and/or paper mail. It should be noted that the data subject’s right to object, as set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that, in any case, the data subject may exercise the right to object even only in part. Therefore, the data subject can decide to receive only communications using traditional methods or only automated communications, or neither of the two types of communication.
Where applicable, you also have the rights under Articles 16-21 of the GDPR (Right to rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to lodge a complaint with the Supervisory Authority.
9. How to exercise your rights
You may exercise your rights at any time by sending:
- An e-mail to privacy@vroomvroomaccessories.com
- By contacting customer service from your personal page
10. Data Controller, processor and persons in charge
The Data Controller is Bertalan IVAN with registered office in Italy, in Via Rimini 6g, 15048 Valenza (AL).