Privacy Policy

The purpose of this document is to inform the individual (hereinafter the “Data Subject”) about the processing of their personal data (hereinafter the “Personal Data”) collected by the data controller, MC DONALD S.R.L., with registered office at Via Follereau Raul, 8. 24027 Nembro (BG), Tax Code/VAT Number 00963060165, email address web@zenoniecolombi.com, (hereinafter the “Controller”), through the website www.zenoniecolombi.com (hereinafter the “Application”).

The changes and updates will be binding as soon as they are published on the Application. If the changes made to the Privacy Policy are not accepted, the Data Subject must stop using this Application and may ask the Controller to delete their Personal Data.

  1. Categories of Personal Data processed

The Controller processes the following types of Personal Data provided voluntarily by the Data Subject:

    • Contact data: first name, last name, address, email, telephone number, images, authentication credentials, any additional information sent by the Data Subject, etc.
    • Tax and payment data: tax identification number, VAT number, credit card details, bank account details, etc.

    The Controller processes the following types of Personal Data collected automatically:

      • Technical data: Personal Data generated by the devices, applications, tools and protocols used, such as information about the device used, IP addresses, browser type, Internet service provider (ISP) type. Such Personal Data may leave traces that, particularly when combined with unique identifiers and other information received from servers, may be used to create profiles of individuals
      • Application browsing and usage data: such as, for example, pages visited, number of clicks, actions taken, session duration, etc.
      • Data relating to the Data Subject's exact location: for example, geolocation data that precisely identify the Data Subject's location and may be collected via the satellite network (e.g. GPS) and other means, collected with the Data Subject's consent. The Data Subject may withdraw consent at any time.

      Failure by the Data Subject to provide the Personal Data for which there is a legal or contractual obligation, or where such data constitute a necessary requirement for entering into the contract with the Controller, will make it impossible for the Controller to establish or continue the relationship with the Data Subject.

      The Data Subject who communicates third parties' Personal Data to the Controller is directly and exclusively responsible for its origin, collection, processing, communication, or dissemination.

      1. Cookies and similar technologies

      The Application uses cookies, web beacons, unique identifiers, and other similar technologies to collect the Data Subject's Personal Data about the pages, links visited, and other actions performed when the Data Subject uses the Application. They are stored and then transmitted during the Data Subject's next visit. The complete Cookie Policy can be viewed at the following address: ____________________

      1. Legal basis and purposes of processing

      The processing of Personal Data is necessary:

        • for the performance of the contract with the Data Subject, specifically:
        1. fulfillment of any obligation arising from the pre-contractual or contractual relationship with the Data Subject
        2. registration and authentication of the Data Subject: to allow the Data Subject to register on the Application, access it, and be identified, including through external platforms
        3. support and contact with the Data Subject: to respond to the Data Subject's requests
        4. payment management: to manage payments by credit card, bank transfer, or other instruments
      1. due to a legal obligation, specifically:
            1. compliance with any obligation provided for by applicable laws, laws and regulations, particularly in tax matters
              • based on the Controller's legitimate interest, for:
                  1. marketing purposes via email for the Controller's products and/or services to directly sell the Controller's products or services using the email address provided by the Data Subject in the context of the sale of a product or service similar to the one covered by the sale
                  2. management, optimization, and monitoring of the technical infrastructure: to identify and resolve any technical issues, improve the Application's performance, and manage and organize information in an information system (e.g., server, database, etc.)
                  3. security and fraud prevention: to ensure the security of the Controller's assets, infrastructure, and networks
                  4. statistics using anonymized data: to perform statistical analyses on aggregated and anonymized data to analyze the Data Subject's behavior, improve the products and/or services provided by the Controller, and better meet the Data Subject's expectations
                    • based on the Data Subject's consent, for:
                        1. profiling of the Data Subject for marketing purposes: to provide the Data Subject with information about the Controller's products and/or services through automated processing aimed at collecting personal information to predict or evaluate their preferences or behavior
                        2. retargeting and remarketing: to reach the Data Subject with a personalized advertisement after they have visited or shown interest in the products and/or services offered by the Application, using their Personal Data. The Data Subject may opt out by visiting the Network Advertising Initiative page.
                        3. marketing purposes for the Controller's products and/or services: to send commercial and/or promotional information or materials, to carry out direct sales activities for the Controller's products and/or services, or to conduct market research using automated and traditional methods
                        4. detection of the Data Subject's exact location: to detect the presence of the Data Subject, to monitor access, times, and the Data Subject's presence at a specific location, etc.

                        On the basis of the Controller's legitimate interest, the Application allows interactions with external platforms or social networks, whose processing of Personal Data is governed by their respective privacy notices, which you are kindly asked to consult. The interactions and information acquired by this Application are in any case subject to the privacy settings selected by the Data Subject on those platforms or social networks. In the absence of specific consent to processing for additional purposes, this information is used solely to enable use of the Application and provide the requested information and services.

                        The Personal Data of the Data Subject may also be used by the Controller to protect its rights in legal proceedings before the competent courts.

                        1. Methods of processing and recipients of Personal Data

                         

                        Personal Data is processed using paper and electronic tools, through organizational procedures and methods strictly related to the purposes indicated, and by adopting appropriate security measures.

                        Personal Data is processed exclusively by:

                          • persons authorized by the Controller of the Personal Data who have undertaken to maintain confidentiality or are subject to an adequate legal obligation of confidentiality;
                          • entities acting independently as separate data controllers or entities appointed by the Controller as data processors to carry out all processing activities necessary to pursue the purposes described in this privacy notice (for example, business partners, consultants, IT companies, service providers, hosting providers);
                          • parties or entities to which Personal Data must be disclosed by law or by order of the authorities.

                          The parties listed above are required to use appropriate safeguards to protect Personal Data and may access only the data necessary to perform the tasks assigned to them.

                          Personal Data will not be disclosed indiscriminately in any way.

                          1. Location

                          Personal Data will not be transferred outside the territory of the European Economic Area (EEA).

                          1. Personal Data Retention Period

                          Personal Data will be retained for the period necessary to fulfill the purposes for which it was collected, in particular:

                            • for purposes relating to the performance of the contract between the Data Controller and the Data Subject, they will be retained for the entire duration of the contractual relationship and, after its termination, for the ordinary limitation period of 10 years. In the event of legal proceedings, for the entire duration thereof, until the expiry of the deadlines for bringing appeals
                            • for purposes relating to the Data Controller's legitimate interest, they will be retained until that interest has been fulfilled
                            • for compliance with a legal obligation, by order of an authority and for legal defense, they will be retained in accordance with the time limits provided for by such obligations and regulations, and in any event until the expiry of the limitation period provided for by the applicable laws
                            • for purposes based on the Data Subject's consent, they will be retained until consent is withdrawn

                            At the end of the retention period, all Personal Data will be deleted or stored in a form that does not allow the Data Subject to be identified.

                            1. Rights of the Data Subject

                            Data Subjects may exercise certain rights with regard to the Personal Data processed by the Data Controller. In particular, the Data Subject has the right to:

                              • be informed about the processing of their Personal Data
                              • withdraw consent at any time
                              • restrict the processing of their Personal Data
                              • object to the processing of their Personal Data
                              • access their Personal Data
                              • verify and request the rectification of their Personal Data
                              • obtain the restriction of the processing of their Personal Data
                              • obtain the deletion of their Personal Data
                              • transfer their Personal Data to another data controller
                              • lodge a complaint with the data protection supervisory authority and/or take legal action.

                              To exercise their rights, Data Subjects may send a request to the following email address: web@zenoniecolombi.com. Requests will be handled by the Data Controller immediately and processed as quickly as possible, in any event within 30 days.

                              Last updated: 24/03/2023

                               

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