Homines, in the person of the legal pro tempore representative, as data controller (hereinafter "Data Controller"), wishes to inform you that, pursuant to Article 13 of EU Reg. no. 679/2016 (hereinafter "GDPR"), it needs to proceed with the processing of personal data subject to the signed release, in compliance with current regulations and as better specified below.
- Object of the Processing and categories of data processed
The Data Controller processes the personal identification data communicated by you (contact details) with a specific authorization.
- Purpose, legal basis of the processing and consequences of failure to communicate the Data
These Data are processed lawfully and correctly for the purposes described below.
A. "Institutional" use
Only subject to your specific and distinct consent (pursuant to Article 7 GDPR), which you are free to give or not and which constitutes the legal basis of the processing, personal data will be processed by the Data Controller for institutional use. This use, by way of example and not exhaustive, includes the chronicle of events or other institutional activities (eg conferences, seminars), information, educational and educational purposes, including, for example, competitions, paper publications, newsletters, institutional websites, spaces on social networks, etc., as well as any purpose referred to in the release.
The provision of data for these purposes is optional. You can therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided (without prejudice to the processing carried out before such refusal): in this case the Data Controller will not be able to proceed with the processing of your data.
B. Marketing and commercial communications
Commercial promotion, sale and improvement of products and services, market research (direct marketing).
Only subject to your specific and distinct consent (pursuant to Article 7 GDPR), which you are free to give or not, these activities are aimed at:
B.1. allow the Data Controller to carry out market research and analysis aimed at detecting the degree of customer satisfaction on the quality and type of services rendered and initiatives relating to the improvement of the services provided, as well as to send you promotional material and / or communications and information of a commercial and direct marketing nature on new products offered for sale and on new services offered by the Data Controller or by third parties (including any other future companies of the Homines Group), as well as on the related offers, discounts and any other promotional and loyalty initiative reserved for you, by means of traditional contact systems (paper mail or calls via operator);
B.2. allow the Data Controller to carry out market research and analysis aimed at detecting the degree of customer satisfaction on the quality and type of services rendered and initiatives relating to the improvement of the services provided, as well as to send you promotional material and / or communications and information of a commercial and direct marketing nature on new products offered for sale and on new services offered by the Data Controller or by third parties (including any other future companies of the Homines Group), as well as on the related offers, discounts and any other promotional and loyalty initiative reserved for you, with the use of automated call or call communication systems without the intervention of an operator, or by e-mail and / or SMS messages (Short Message Service).
The processing of Data for the aforementioned purposes (both "B.1." and "B.2.") is allowed in relation to the free movement of data as required by the GDPR and can take the form of activities aimed at satisfying the legitimate commercial interests of the Data Controller, including the commercial development activities carried out by the latter.
The provision of data for these purposes is optional. You can 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 commercial communications and promotional material relating to the services offered by the Data Controller.
C. Provision of "tailor-made" products and services and processing of information relating to preferences, habits, consumption choices (profiling)
Only subject to your specific and distinct consent (pursuant to Article 7 GDPR), which you are free to give or not, the Data Controller may need to process information relating to preferences, habits, consumption choices aimed at dividing the interested parties into homogeneous groups for behavior or characteristics (profiling), also through the use of techniques or algorithms and advanced computer systems and also through data enrichment, in order to develop, promote and provide products and services "tailored" to the Data Controller or third parties (which also include any other future companies of the Homines Group).
Consent is given separately for profiling cookies and for data freely provided by the user.
The provision of data for these purposes is optional. You can 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 dedicated commercial communications.
- Processing methods
The processing of your data is carried out by means of the operations indicated in art. 4 n. 2) GDPR and precisely: collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction of Data.
Your data are subjected to both paper and electronic and / or automated processing.
The acquired data are processed, in full compliance with the law, as well as the principles of lawfulness, correctness, transparency, non-excess and protection of your privacy and your rights.
- Data retention period
The Data Controller retains the Data in compliance with local laws and internal company policies and procedures for the time necessary for the purpose of fulfilling the aforementioned purposes and satisfying its legitimate commercial interests, legal obligations or to establish, exercise or defend legal claims. Once the need to keep the Data for these purposes has been exhausted, they will be securely deleted.
- Communication, dissemination and access to Data
Your Data may be made accessible for the purposes described above:
- to employees and collaborators of the Data Controller in Italy and abroad, in their capacity as data processors and / or sub-managers, or persons authorized to process pursuant to the GDPR and / or subjects with specific functions and tasks pursuant to art. 2-quaterdecies of Legislative Decree no. 196/2003;
- to any other future companies of the Homines Group (parent companies, subsidiaries and/or associates) in Italy and abroad and to their employees and collaborators;
- to third-party companies or other subjects that carry out outsourced activities on behalf of the Data Controller, in their capacity as data processors, including suppliers or persons in charge of performing ancillary or instrumental services for the purposes indicated above, with which the Data Controller stipulates specific agreements;
- The Data Controller also reserves the right to make personal data accessible with some third parties, including: legal bodies, police forces, armed forces and other public administrations, for the fulfillment of obligations established by law, regulations or community legislation.
In the event that these subjects are established in non-EU countries, the Data Controller ensures that the transfer of non-EU Data will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission, as provided for in the following article.
- Data Transfer
The Data will be stored on servers and archiving tools located within the European Union. In any case, it is understood that the Data Controller, if necessary, has the right to transfer the Data to countries outside the European Union or the European Economic Area recognized by the European Commission and which guarantee an adequate level of protection of personal data or, otherwise, only if a level of protection of personal data adequate to that of the European Union is contractually guaranteed and the exercise of the rights of the Interested; in this case, the Data Controller hereby ensures that the transfer of non-EU Data will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.
The Data Controller will apply to the aforementioned transfers all the necessary protections pursuant to current privacy legislation.
- Rights of the interested party
In your capacity as an interested party, you have the rights referred to in Articles. 13, paragraph 2, letters b), c) and d), 15, 16, 17, 18, 19 and 21 GDPR and precisely the rights of:
- obtain confirmation of the existence or not of Data concerning you, even if not yet registered, and their communication in intelligible form;
- obtain the indication: a) of the origin of the Data (if they have not been obtained from the interested party); b) the purposes and methods of processing, as well as the related legal basis; c) the logic applied in case of treatment carried out with the aid of electronic instruments; d) of the identification details of the Data Controller, of the Data Protection Officer (if appointed) and of any representative designated pursuant to art. 13, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the Data may be communicated or who can learn about them as appointed representatives in the territory of the State and managers;
- obtain: a) updating, rectification or, when interested, integration of Data; b) the cancellation, transformation into anonymous form or blocking of personal data processed unlawfully, including data whose retention is unnecessary for the purposes for which the personal data were collected or subsequently processed; c) the attestation that the operations referred to in 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 fulfillment 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 Data concerning you, even if pertinent to the purpose of the collection; b) to the processing of Data concerning you for the purpose of sending promotional material or direct selling or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by telephone and / or paper mail. Please note that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to the traditional ones and that in any case the possibility remains for the interested party to exercise the right of opposition even in part. Therefore, the interested party may decide to receive only communications through traditional methods or only automated communications or neither of the two types of communication;
- Where applicable, it also has the rights referred to in Articles. 16 - 21 GDPR (right of rectification, right to be forgotten, right to limitation of processing, right to data portability, right of opposition), as well as the right to complain to the Guarantor Authority;
- revoke at any time any consent given.
With regard to the right to data portability, the interested party may request to receive or transfer their personal data held by the Data Controller in a structured format of common use and readable, for further personal use or to provide them to other data controllers.
- How to exercise your rights
You may at any time exercise your rights or make a request by sending: a registered letter with return receipt to Homines S.r.l., with registered office in Milan, Via Fratelli Gabba No. 3, or an e-mail to the address: firstname.lastname@example.org.
The deadline for response is one month. The aforementioned term may be extended by two months in particularly complex cases: if this occurs, within one month the Data Controller will provide a communication regarding the reasons for the extension.
The Data Controller has the right to request the information necessary for the identification of the applicant.
In general terms, the exercise of rights is free, except in the case of manifestly unfounded or excessive requests, for which the Data Controller may reserve the right to request from the interested party a reasonable contribution based on the administrative costs to be incurred.
- Data Controller, Data Protection Officer and categories of Data Processors
The Data Controller is the company Homines S.r.l., with registered office in Milan, Via Fratelli Gabba n ° 3, in the person of the pro tempore legal representative.
The Data Protection Officer can be contacted at the following e-mail address: email@example.com.
The list of categories of Data Processors is kept at the registered office of the Data Controller.
A cookie is a small amount of information that is downloaded to your computer or device when you visit certain websites. We use a number of different cookies on our website, including strictly necessary, performance, advertising and social media or content cookies. Cookies improve the browsing experience by allowing the website to remember actions and preferences (such as login and region selection). This means that you will not have to re-enter this information every time you return to the site or navigate from one page to another. Cookies also provide information on how people use the website, for example if it is their first time visiting or if they are repeat visitors.
Some cookies are necessary to allow you to browse our website, use its features and access secure areas. The use of these cookies is essential for the website to function.
We also use functional cookies to remember choices made or information provided, such as username, language or region. This allows us to customize the experience on the website based on your preferences.
We use certain tools to help us improve our website and trading platform. To this end, we use reporting and analysis cookies to collect information about how you use our website and how often. These cookies only collect information for statistical purposes and only use pseudonymous cookie identifiers that do not directly identify the visitor. The performance cookies we use include:
Third party analytics cookies: We use other third-party analytics providers listed below to measure how users interact with the content of our website. These cookies "remember" what users have done on previous pages and how interacted with the website.
- Shopify: https://www.shopify.com/legal/cookies
- Google Analytics: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
- Meta Platforms: https://www.facebook.com/policy/cookies/
The Client may receive newsletter containing updates on the Products, services and promotions from Homines.
Pursuant to article 130, comma 4, of the Legislative Decree 196/2003 of Italian Law, the aforementioned right cannot be exercised by Homines only if the Client refused the consent of Treatment of Personal Data while registering on the Website or in some later occasions.