GENNY.COM SITE - PRIVACY POLICY
Dear User,
privacy and the protection of your data are our priority,
In accordance with EU Reg. EU/2016/679 ("GDPR"), the company SWINGER INTERNATIONAL SPA, with registered office in Bussolengo (VR), Via Festara Vecchia n. 44, VAT no. 00531950202 P.IVA 00881950232 may process your data while you are browsing the site www.genny.com ("Site") or using the services on the Site.
HOLDER OF THE TREATMENT
The data controller is the company SWINGER INTERNATIONAL SPA ("Owner", "Swinger" or "Company") which can be contacted by e-mail privacy@swinger.it PEC swinger@pec.it or by post at the above address.
PURPOSE AND LEGAL BASIS OF THE TREATMENTS
Personal data may be processed to allow:
- the navigation of the Site and the security of the same,
- to carry out the procedure of registration to the Site, access and execution of services reserved for registered users,
- filling out forms for various requests,
- the purchase of goods and/or services, the execution of the relative contract of sale, the execution of commercial transactions connected to online purchases and provide the necessary assistance requested, also by telephone.
The legal basis for purpose a) is the legitimate interest of the Data Controller, for purposes b) c) and d) is the execution of pre-contractual measures at the request of the data subject or the performance of a contract.
In addition, the same may be processed:
- for any marketing purposes, to carry out commercial information activities, via telephone, SMS, e-mail, on Genny's promotional and commercial initiatives, for market research and surveys to detect customer satisfaction,
- In order to provide you with offers that are in line with your interests, Swinger may perform some analysis on aggregated data without performing any profiling activities on your specific habits, according to an automated decision-making process.
The legal basis for purposes e) and f) is your express consent.
For further information on the cookies and tools used by the Site to achieve the above purposes, please refer to the cookie policy.
NATURE OF CONTRIBUTION
The provision of data for the purposes b), c), d), e) and f) is optional, failure to provide such data will make it impossible to complete the registration process, use the services of the Site, purchase products and/or services on the Site and to find out about promotions and special offers that may be of interest to you.
COMMUNICATION OF DATA TO THIRD PARTIES
For the above-mentioned purposes, our Company may communicate the data to third parties who carry out activities auxiliary to or connected with the processing described above, in particular (but not limited to) subjects in charge of managing the shipment of products and invoicing, consultants of the Company. The complete list of recipients may be requested from the Data Controller through the e-mail addresses provided above.
DATA RETENTION
The data retention period for purposes a) is 1 year, b), c) and d) is 10 years from the end of the execution of the contract, for purposes e) and f) is 2 years.
DATA TRANSFER AND PROFILING
The Company may transfer data outside the EEA to manage e-mail and marketing services, in which case appropriate safeguards will apply, such as standard contractual clauses. The Owner will not carry out profiling activities.
RIGHTS OF THE INTERESTED PARTY
We also inform you that you can exercise, where applicable, the following rights, namely access to data, rectification, cancellation, limitation and opposition to the processing, revocation of consent, where given, and the right to portability. You may lodge a complaint with the control authority (Guarantor Authority for the Protection of Personal Data - www.garanteprivacy.it) or other competent authority. In order to exercise the above rights with regard to the Data Controller, you may send an e-mail request to privacy@swinger.it or by post to the address of the Company indicated above.
[TO BE ADDED ONLY IN THE PRIVACY POLICY IN ENGLISH].
INFORMATION FOR CALIFORNIA CONSUMERS
This document contains a section devoted to California consumers and their privacy rights that complements what was reported earlier.
The provisions contained in this section apply to all Users who are deemed to be consumers residing in the state of California, United States of America, pursuant to the "California Consumer Privacy Act of 2018" (such Users are referred to below simply as "you", "your", "you" or "your"), and, for those Users, these provisions prevail over any other possibly divergent or conflicting provisions contained in this privacy policy.
This part of the document uses the term "personal information" as defined by the California Consumer Privacy Act (CCPA).
CATEGORIES OF PERSONAL INFORMATION COLLECTED, DISCLOSED OR SOLD
This section summarizes the categories of personal information we have collected, disclosed or "sold" under the CCPA and the related purposes of processing. You can find detailed information about these activities in the section called "Personal Information Processing Details" in this document.
Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: identifiers, biometric information, and Internet information. We will not collect additional categories of personal information without first notifying you of a new disclosure.
How we collect information: what are the sources of the personal information we collect?
We collect the above categories of personal information, directly or indirectly, from you when you use this Site. For example, you directly provide us with personal information when you submit requests via any form on this Site. In addition, you indirectly provide us with personal information when you browse this Site, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties who work with us in connection with the provision of the Service or the operation of this Site and its features.
How we use the information we collect: sharing and disclosing your personal information with third parties for operational purposes.
We may disclose your personal information to third parties for operational and service purposes. In this case, we will enter into a written contract with such third party that obligates the recipient of your personal information to keep such information confidential and not to use it for any purpose other than necessary to carry out the contract. We may also disclose your personal information to third parties when you request or authorize us to do so in order to provide you with our Service. For more information about the purposes of processing, please see the relevant section of this document.
Sale of your personal information
For purposes of this document, the term "sale" means "to sell, assign, release, make public, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic means, personal information about a consumer by one business to another business or to third parties, for a fee or other gain." This means that, for example, a sale can occur whenever an app runs advertisements, performs statistical analysis on its traffic or views, or simply uses tools such as social network plug-ins and similar tools.
Your right to opt-out of the sale of your personal information
You have the right to opt-out of the sale of your personal information. This means that whenever you ask us not to sell your information, we will carry out your request.
Such requests can be made freely, at any time, and without submitting any request subject to verification, simply by following the instructions below.
Instructions for opting out of the sale of personal information
If you would like more information or to exercise your right to opt-out in connection with all sales made from this Site, whether online or offline, you may contact us using the contact information provided herein.
What are the purposes for which we use your personal information?
We may use your personal information to enable the proper functioning of this Website and its features ("operational purposes"). In such cases, your personal information will be processed in a manner that is appropriate and proportionate to the purposes for which it was originally collected and strictly within the limits of compatible purposes.
We may also use your Personal Information for other reasons, such as for business purposes (as set forth in the "Personal Information Processing Details" section within this document), as well as to comply with the law and defend our rights before competent authorities when our rights or interests are threatened or when we suffer harm.
We will not use your personal information for different, unrelated or incompatible purposes without first notifying you of a new notice.
Your privacy rights in California and how to exercise them
Right to knowledge and portability
You have the right to know the following:
- the categories of personal information we collect about you and the sources of that information, the purposes for which we use your personal information, and with whom we share it;
- if we sell or disclose personal information to third parties for operational purposes, we will provide you with two separate lists in which we will disclose to you:
- for sale, the categories of personal information disclosed to each category of recipient; and
- for disclosure to third parties for operational purposes, the categories of personal information obtained from each category of recipients;
The above information will be limited to personal information collected or used within the last 12 months.
In the event that our response is delivered electronically, the information contained therein will be "portable," that is, delivered in a compatible format so that you can transmit the information to other entities without impediment - provided that this is technically feasible.
Right to request deletion of your personal information
You have the right to request the deletion of any of your personal information, subject to exceptions provided by law (such as, without limitation, if the information is used to identify and repair errors on this Website, to detect security incidents, for purposes of protecting against fraudulent or illegal activities, to exercise certain rights, etc.). If no statutory exception applies, we will delete your personal information following the exercise of your right and ask our suppliers to do the same.
How to exercise your rights
To exercise the rights described above, you must submit a verifiable request by contacting us using the contact information provided herein.
In order to respond to your request, it is necessary for us to be able to identify you. Therefore, you can only exercise the above rights by submitting a verifiable request that must:
- provide sufficient information to allow us to reasonably verify that you are the person to whom the personal information we have collected relates or an authorized representative of that person;
- Describe your request in sufficient detail for us to understand, evaluate, and properly respond to what you are asking.
We will not respond to any request unless we are able to verify your identity and, therefore, confirm that the information we hold about you is accurate. If you cannot make a verifiable request yourself, you may delegate a person registered with the California Secretary of State to do so on your behalf. If you are an adult, you may make a verifiable request on behalf of someone who falls under your parental authority. You may submit a maximum of 2 requests within a 12-month period.
How and how quickly we will handle your request
Within 10 days we will confirm that we have received your request and provide you with information about how we will process it. We will respond to the merits of the request within 45 days of receiving it. If we need more time, we will explain why and let you know how much time we need. In this regard, please note that it may take up to 90 days to process your request. Our communications will cover the previous 12-month period. If we deny your request, we will explain the reason for the denial.
We will not charge a fee to process or respond to your verifiable request unless the request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or deny the request. In either case, we will notify you of our decisions and explain our reasons.
