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INFORMATION ON THE PROCESSING OF PERSONAL DATA OF USERS VISITING THE WEBSITE PURSUANT TO ARTICLE 13 OF THE LEGISLATIVE DECREE N. 196/2003, AMENDED BY THE LEGISLATIVE DECREE. N. 101 OF AUGUST 10TH 2018, AND TO ART. 13 OF THE EU REGULATION 2016/679

Introduction

The following document was written pursuant to art. 13 of the legislative decree nr. 196/2003 and following (hereinafter referred to as “Privacy Code”), amended by the legislative decree. n. 101 of 10/08/2018 and by the EU Regulation 2016/679 (hereinafter referred to as the “Regulation”), and applies to any individual visiting and interacting with e-commerce site of the “Ethen S.r.l.” company, with legal office in 20842 Besana in Brianza (MB), Via Alessandro Manzoni n. 8 and production in Besana Brianza (MB), via Zappa n.11/13, fiscal code and VAT number 08197570966, in the person of its legal representative pro tempore Rocca Davide Antonio, in order to describe our privacy policy and the way how personal data are processed when you use our site (www.ethen.ue, di hereinafter referred to the “Site”) and, if needed, in order for you to accept personal data processing through express consent and by being aware of what you consent to.

Information and data supplied while using surfing services and access to the private area of the Site (hereinafter referred to as the “Services”) will be processed according to the Regulation and to confidentiality rules.

Your data shall be processed on a lawful basis, according to fairness and transparency principles, according to purpose and retaining restraints, through data minimization, in compliance with precision, integrity and confidentiality principles as well as in compliance with responsibility rules as of art. 5 of the Regulation.

This privacy statement updates and replaces possible previous versions released before.

Data controller

Data controller is Mr. Rocca Davide Antonio, born in Milan (MI) on 10/09/1980, fiscal code RCCDDN80P10F205H, living in in Castelleo di Brianza (LC), Via Papa Giovanni XXIII n. 48.

The Company works independently and under contract, through wholesale and retails as well as through Internet portals (e-commerce) thereby selling products, equipment and accessories for sportswear and leisure time, sport and related services.

Before communicating any personal information to the data controller, please read this document as it contains important information on personal data protection.

The data controller may be contacted at the addresses reported in the section “Contacts” of this privacy statement.

Personal information

In the following you find definitions as of the EU Regulation 2016/679:

Personal data means: any information relating to an identified or identifiable natural person (<>); an identifiable natural person is one who can identified, directly or indirectly in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Processing means any operation or operations which is performed on personal data or on sets of personal data, whether or not by automated means such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Furthermore, personal data processed through the Site are as follows:

Cookies

When browsing through this web site, you may receive cookies, i.e. short text strings that web sites send to the user’s browser (i.e. the programme needed to browse), where they are saved in order to be then transmitted again to the same web site during the following visits. When browsing through a site, the user may also receive cookies of web sites or web servers on his PC that are different from the site he is visiting (i.e. “third-party cookies”).

Cookies used in the site are as follows:

Technical cookies: compliant with surfing and session cookies;

Cookie Analytics: compliant with technical cookies, used to collect information in an aggregated form, in order to improve site performances;

Functionality cookies;

Third-party cookies, managed by Google, Addthis, Facebook, Paypal, Stripe, Amazon..

If cookies are not accepted, some interactive functions of the site may not work, totally or partly.

Data processing purposes

Personal information is treated by the data controller in order to:

  1. allow for site surfing and supplying of services provided by the data controller (among them for example access to and browsing of the Store, putting the products into the cart and agreement implementation), including Site safety management;
  2. comply to possible obligations defined by law, by regulations or European standards in force, among them for example administrative and/or accounting and/or fiscal duties, related to services supplied through the Store and/or purchase agreement stipulated through the Store;
  3. comply with Authority requests; manage withdrawal requests and/or legal compliance guarantee and/or other rights originating from the purchase agreement stipulated in the Site and/or provided by the law in relation to the agreement and/or to Site services; carry out all necessary activities deriving from such rights and, if necessary, perform the relative refunds; receive and check requests of exercising rights relating to personal data protection provided for by the Regulation and carry out all related tasks;
  4. process statistics, thereby making it impossible to trace your identity;
  5. send newsletter and promotional information for direct marketing through email, sms, mms, push notifications, fax, paper mail, call center. The products advertised may also belong to other partner companies;
  6. do profiling activities through collection and analysis of selections and choices made inside the Site, in order to send customised offers concerning other products and/or services;
  7. communicate/transfer personal data to third companies, such as Partner companies in order to send newsletter and promotional communications for marketing purposes through email, sms, mms, push notifications, fax, paper mail, call center;
  8. h. check and/or exercise and/or defend a right, in any competent jurisdiction.

Special safety measures are adopted in order to prevent data loss, illegal or incorrect use and unauthorized access.

Legal principles and (compulsory or optional processing) features of processing

Personal data processing is carried out pursuant to art. 6.1.b. of the Regulation: processing is necessary in order to supply services and to check user requests.

Personal data processing is carried out pursuant to the scope as of b and c of art. 6.1.c. of the Regulation (i.e. “processing is necessary to comply with the legal obligation the data controller is subject to”): data supply is not compulsory, however, without your personal information we won’t be able to activate the services required.

Processing as of paragraph d is not carried out on the basis of personal information therefore it can be performed freely by the data controller.

Personal data processing is carried out pursuant to the paragraphs e, f, g of art. 6.1.a. of the Regulation: processing is based on consent, that is optional and withdrawable at any time without any consequence (except that you won’t receive marketing communications and/or no profiling activity will be carried out any more).

Previous consents can be withdrawn, as reported in the special paragraph infra

As regards processing in order to send direct advertising material or for direct sale or market research and commercial communications relating to products and services of the data controller similar to those you use, the Company may use e-mail addresses pursuant to art. 130, par. 4 of the Code and to the measure adopted by the Authority in order to protect personal data (June 19th 2008), also in case of lacking of explicit consent.

Personal data processing for such purpose is carried out pursuant to art. 6.1.f. of the Regulation.

Anyway, you may object easily and free of charge to such processing at the beginning of it or later on, when you receive successive communications, also by writing to the delivery addresses reported in the “Contacts” section of this statement, thereby getting immediate confirmation of processing interruption (art. 15 of the Regulation).

Personal data processing is carried out pursuant to art. 6.1.f of the Regulation: the data controller has a legitimate interest in seeking remedies in order to guarantee compliance with his contractual rights and/or to show that he fulfilled the obligations deriving from the agreement entered into with the user or enforced by law. Such legitimate interest is also based on the right of defence, guaranteed by the Italian constitution.

However, at any time and due to personal reasons, the user can withdraw his consent to personal data processing for the purposes mentioned above (i.e. defence of one’s own rights/legal purposes).

Personal data recipients

Your personal data may be shared, for the following purposes, with:

  • subjects typically in charge of data processing pursuant to art. 29 of the Code and to art. 28 of the Regulation, i.e. subjects cooperating with the data controller in order to attain the purposes mentioned above, including those have to carry out technical maintenance work; employees and/or partners who have to carry out administrative or accounting tasks, to supply computer and logistic support;
  • subjects, institutes or Authorities, whom personal data have to be transmitted to comply with the laws in force or with Authorities’ orders;
  • companies and/or consultants and/or professionals that may be in charge of installation, maintenance, updates and, generally, of company hardware and software maintenance, including suppliers of services such as cloud computing, and to third-parties with whom they co-operate;
  • companies and/or consultants and/or professionals that may be in charge of installation, maintenance, updates and, generally, of company hardware and software maintenance, including suppliers of services such as cloud computing, and to third-parties with whom they co-operate;
  • to all public and/or private subjects, natural and/or legal persons (among them e.g. legal, administrative, fiscal, consulting studies), should communication be necessary or necessary to fulfil contractual obligations deriving from site services, including purchase agreement, as well as legal obligations, i.e. in case of check, exercise or defence of a right;
  • persons authorized by the data controller pursuant to art. 30 of Code and art. 29 of the Regulation to process personal data necessary to carry out activities strictly linked to services supply and who are committed to confidentiality or have a special legal obligation to confidentiality.

You can receive an updated list of subjects who may process your personal data as data controllers by sending a written request to the data controller at the addresses reported in the “Contact” section of this statement.

Data transfer

As far as possible data transfer to third countries is concerned, the data controller declares that processing shall be done in compliance with the laws in force such as consent of the person interested, the application of standard clauses approved by the European Commission, the selection of subjects adhering to international programs for the free circulation of data (e.g. EU-USA privacy Shield) or working in Countries that are considered “safe” according to the European Community.

On request, you can have more information from the data controller in the “Contacts” section.

Data storage

We will only retain personal data as long as necessary to fulfil the purpose for which they were collected or to comply with the special requirements or with applicable law and for the time needed to safeguard Company rights and interests pursuant to art. 2946 and 2947 and following of the Italian Civil Code.

Your rights

You can exert your rights at any time in compliance with art. 15 - 22 of the Regulation, as follows:

you may ask for confirmation of personal data collection, you may ask for information about processing purposes, personal data categories, recipients or recipient categories whom personal data were or shall be communicated and, if possible, about the retaining period as well; you may ask for data rectification and cancellation; you may ask for processing limits; you may ask for data portability, i.e. get the data from the data controller in a structured and commonly used format, that can be read by an automatic device, and transmit them to another controller without problems; you may object to processing, any time and even in case of processing for direct marketing purposes; you may reject an authorised decision process concerning natural persons, including profiling; you may ask the data controller for data access in order to rectify or cancel data or you may ask for restriction of processing and withdraw your consent at any time. You also have the right to data portability; you can withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal as well as the right to submit a complaint to a regulatory Authority.

Requests have to be sent in writing to the data controller, that is to the addresses reported in the “Contacts” section of this privacy statement.

Feedback times and methods

The data controller provides information to the person interested about actions undertaken to deal with a request of exercising the rights as of art. 15 - 22 of the Regulations. He has to react promptly, without unjustified delay and, in any case, within a month from receiving the above mentioned request. If necessary (due to the complexity and to the number of requests received), this term may be extended to two months. The data controller informs the subject interested of such extension and of the reasons of delay within a month from the request. Should the subject interested submit the request through electronic means, information are provided, if possible, through electronic means, except if a different indication is given by the subject interested.

Contacts

In order to exercise the rights mentioned above and/or for any other request, please write to the data controller using the following addresses:

  • Ethen S.r.l., 20842 Besana in Brianza (MB), Via Alessandro Manzoni n. 8;
  • Pec: info.ethen@pec.ethen.eu;
  • Email: info@ethen.eu;
  • Telephone: 0362.1513077;

Please write in the Subject line “Request of exerting privacy rights”.


This privacy statement updates and replaces possible previous versions and may be changed and / or integrated and /or updated partially or totally in order to comply with the laws in force.

Therefore you should visit this section regularly in order to be informed about the most recent and updated version of the document.


  • I declare that I have read and accepted the privacy statement pursuant to art. 13 of the UE Regulation 2016/679

  • I hereby give my consent
  • I DON’T give my consent

to receive promotional material, commercial and / or promotional communications, within the limits provided by and in compliance with the standards mentioned above.


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