Reasons for the disclosure
This privacy policy (the “Privacy Policy”) contains important information about the personal data that is collected by visiting this Website and other Company brand sites (collectively, the “Websites”), as a registered user or not registered, and describes how the data is managed. Where applicable, it also explains how the data provided by the user or collected during visits to corporate communication tools, or during other contacts with the Company, are processed. This information is supplementary to any other information received in such other circumstances.

This document contains important information on the following:

  • Treatment of personal data
  • Personal data collected
  • Purpose of the processing of personal data
  • Communication of personal data
  • Protection of the privacy of minors
  • Storage, accessibility and transfer of personal data
  • Security and confidentiality of personal data
  • Access rights to personal data – management of choices
  • Data retention
  • Policy regarding cookies and similar processes
  • Links, Advertisers, Sponsors and Advertisements
  • Data controller, data protection officer: company contacts
  • Updates to this information

Acceptance
By visiting the Website, using its services or interacting with the Company and / or linked websites, the user confirms that he has read and understood this Privacy Policy and accepts that the Company collects, uses, archives, transmits and discloses personal data collected through the Websites in accordance with this Privacy Policy. Except in the case in which it is already registered, the Company may require the user to provide his consent (for example, by checking a box), where he deems it appropriate to safeguard his rights or where required by current regulations. If you do not accept the conditions of this Privacy Policy, the user is requested not to visit this Website, not to create an account and not to otherwise use this Website or send personal data, or not to provide his consent when this option is offered to him in accordance with the regulations in force.

1. Processing of personal data
In this Privacy Policy, the term “Personal Data” is used with reference to any information that allows the Company to identify the user (or a third party whose data the user provides), directly or indirectly, including any information related to the purchase of services, or that the user chooses to communicate to the Company or to share with it, or with third parties, while browsing the Websites. The processing of personal data will take place in accordance with the General Regulation on the protection of personal data (EU) 2016/679 “Reg. (EU) 2016/679” and, where applicable, to the legislation of the country where the data should be collected. The Company reserves the right to carry out further data processing, where required by law or in the context of criminal or other investigations or proceedings.

2. Collected personal data

2.1 The origin of data
The Company collects personal data from the user only where the same voluntarily provides information, for example: in the case of Branded Websites that distribute the Company’s products: by making a purchase of the services through the Web Site (s) as a “guest”; opening an account or modifying it; creating a wish list; by entering a contest, sweepstakes or promotion; doing searches on the Website; by contacting the Company by sending a comment or a question; subscribing to email newsletters or “lead magnet programs” and updates regarding the latest services, events or promotions; o requesting to receive confirmation of a “demo” of a service; in the case of events: by participating in events, surveys and market research, challenges and other promotions, including online, for example, on minisites managed by the Company on third-party social networks such as Facebook (or other social networks); in the case of e-mails, SMS and other electronic messages: by exchanging communications between the Company and the user. If the user provides the Company with personal data of third parties (for example, other potential customers), the same should ensure that such third parties are informed and have authorized the use of their data as described in this Privacy Policy.

2.2 Types of data
The Company may collect and use different types of personal data according to the specific purposes pursued and described below: personal information, such as name, surname, gender, age / date of birth, country of origin and other personal data that current regulations allow to pick up; contact information, such as address, email address, telephone number, mobile number and other contact information that current regulations allow us to collect; payment information, such as payment methods (credit or debit card), if applicable, and passport number, where required for tax reasons or in relation to anti-money laundering legislation; habits and profiles, such as data regarding purchases, other information (information on the work carried out, education, hobbies and lifestyle) that the current regulations allow to collect.

3. Purpose of the processing of personal data
Depending on the specific circumstances in which the interaction between the user and the Company took place, personal data could be used for the following purposes.

3.1 For online sales of the company’s services
Personal data provided by the user or collected at the time of purchase, whether or not made as a registered user, i.e. basic personal data, contact information, purchase data, tax data, payment details, sales information and any other data strictly necessary for the delivery of the products, will be used to: manage, administer and process product purchases, sales and after-sales services, for example administrative activities, accounting, fraud prevention and communications with the user , also via email, for any problem relating to the management of the order or subsequent requests relating to the order; comply with obligations imposed by EU laws, regulations or legislation (including anti-money laundering legislation) and make a legal claim or defend against it. It is necessary to provide personal data for the aforementioned purposes and refusal would make it impossible to complete the purchase. Except where otherwise required to comply with local regulations in force, the processing of data for these purposes, as necessary to comply with contractual and legal obligations, could be carried out without requiring the user’s consent.

3.2 For the specific purposes for which the data were provided voluntarily
Personal data provided by the user or collected when the user requests a specific service (for example, by registering his account on the Websites, or requesting information), i.e. personal information, contact information and data strictly necessary to follow up on the request , will be used to: provide the requested services; manage the subscription to the newsletter where the user is not registered. Personal data must be provided for the aforementioned purposes and refusal would make it impossible to complete the request. Except where otherwise required to comply with local regulations in force, the processing of data for these purposes could be carried out without requiring the user’s consent, as necessary to process the request.

3.3 For the purposes of customer relationship management (CRM) if the user registers
The personal data provided by the user by filling in the Company’s forms or collected during visits to the Websites or interacting with the Company, i.e. personal and contact information and data regarding purchasing habits, needs and profile of the ‘user, will be included in the centralized CRM system to: offer promotions, discounts and other personalized services and send newsletters, other marketing and commercial communications on services and invitations to Company events, surveys and research, market analysis, invitations to competitions, sweepstakes or promotions and other initiatives for users or registered customers of the Company’s trademarks (“marketing”). The Company may use traditional means of contact (ordinary mail and telephone) and / or digital and automated (e-mail, SMS, MMS, telephone and other digital channels, for example social media) and may send the user such communications on the base of his profile, if he has given his consent to profiling (see point 3.3b below). The processing of personal data for profiling is carried out in compliance with the guarantees and parameters established by the law in force. The insertion of data in the CRM system is optional and free (being based on the consent that the user can choose to give) and can only take place where the personal data are provided for both the marketing and profiling purposes referred to in points 3.3a ) and b) or only for one of the two. The user can unsubscribe or withdraw his consent at any time (see point 8 below). In any case, the refusal to provide personal data for one or both of these CRM purposes does not prevent the user from using the Company’s services or making purchases, but the Company cannot inform him of the marketing initiatives and events described above and not can understand his interests and offer him a more personalized shopping experience.

4. Communication of personal data
The Company shares your personal data with its affiliated companies, and partners including those located in other countries, and with other companies that provide services on Company behalf (as detailed below), under company direction or that of third parties. These companies and organizations will only receive the personal data necessary to perform the services and will not be authorized to use them for any other purpose.

4.1 Communication of personal data to data processors
The user’s personal data may be shared with third parties to monitor and analyze the activity of the Website, host contents of the Website, provide technical and organizational services functional to the aforementioned purposes, maintain the customer database, provide marketing assistance and manage emails, market analyzes, surveys, contests, sweepstakes or promotions. These third parties may have access to the user’s personal data or store or process them in order to provide these services on behalf of the Company in Italy, in the country where the user is located or abroad. The Company’s service providers are not authorized to use personal data for purposes other than the provision of contracted services. The processing of the user’s personal data for CRM purposes will be carried out, according to the instructions provided by the Company, by the partner companies that manage the Company’s services locally in Italy and in other countries or online and by the Company’s business partners (for example SellingExperience. com Srl), as data processors.

4.2  Dissemination of personal data
The user’s personal data may need to be shared with companies that deal with payment management and anti-fraud controls, which operate independently as data controllers, in order to provide the user with online sales services.
In the event of asset or corporate transactions (for example, mergers or acquisitions, corporate restructuring or liquidation), customer data will likely be one of the assets transferred and may be shared with legal successors, to the extent permitted by law on the basis of legitimate interest. of society. Personal data will remain subject to the pre-existing privacy policy, unless the user decides otherwise. The Company may also disclose the user’s personal data to third parties (i) where required by EU or Member State legislation; (ii) in case of legal proceedings; (iii) in response to a law enforcement request based on legitimate grounds; or (iv) to protect the rights, privacy, safety or property of the Company or the public. Furthermore, to the extent permitted by law, the Company may disclose personal data to third parties in the event of complaints relating to the use of the Website, where deemed necessary to investigate, prevent or adopt measures regarding illegal activities, suspected fraud or in the event that the Company, in its sole discretion, considers that the use of the Website by the user is incompatible with the conditions of the Website itself. The complete list of designated data processors and third parties to whom the data is disclosed can be obtained using our contacts indicated below (point 13).

5. Protection of the privacy of minors
This Website is aimed at a general public, however its services are intended for individuals aged 18 and over. The Company does not knowingly request, collect, use and disclose personal data provided by persons under the age of 18 online. If the Company learns that it has personally collected data from a minor, it will delete them. In the event that the user is not of the required age, please do not register.

6. Storage, accessibility and transfer of personal data
The processing of personal data collected through the Websites takes place mainly using electronic or web-based means, including web analytics services hosted by servers of selected Company suppliers operating both within the European Union (for example, in Ireland , for online sales transactions on the Websites managed directly by the Company) and outside it. In both cases, personal data, for CRM purposes, are entered in the centralized and secured database of the Company located in Italy and managed by the internal processing manager. Access to personal data will be allowed to the local e-commerce provider based on the actual need to know such information and using access control tools on multiple levels. This staff has undertaken to comply with the confidentiality obligations and has been expressly designated as data processor, as required by current law. In particular, where the user has given his consent to the processing of his personal data for CRM purposes, the related data may be read, modified and updated by the Company’s staff and / or local e-commerce suppliers. The staff, present in Italy or abroad, have received appropriate training and are required to comply with the confidentiality obligations. The Company may use it to collect, use and disclose data according to its instructions. If the Company has to transfer personal data abroad in order to pursue the purposes set out in this Privacy Policy, even where the legislation on personal data differs from that applicable in the country where the user is located, the same will adopt measures to ensure that such communications take place in compliance with European data protection standards or other local standards used in the country where the data is collected, so that user data remains safe and confidential.

7. Security and confidentiality of personal data
The Company has implemented suitable measures to protect the user’s personal data from accidental loss and from unauthorized access, use, modification and disclosure. When the user provides information on the order, for example, the Company uses SSL (Secure Socket Layer) technology, an encryption tool that guarantees security during the transmission of information over the Internet. Password controls, firewall technology and other technological and procedure-based security measures are also used in the management of this Website. Although the Company has implemented the aforementioned security measures for the Website, the user must know that it is not possible to guarantee 100% security. Therefore, the user provides his personal data at his own risk and, to the maximum extent permitted by current law, the Company will not be in any way responsible for their disclosure due to errors, omissions or unauthorized actions of third parties during or after their transmission to the same. The Company recommends to users: (i) periodically update the software to protect the transmission of data over the networks (for example, anti-virus software) and check that the provider of electronic communications services has adopted suitable means for the security of the transmission of the data on networks (for example, firewalls and anti-spam filters); (ii) keep confidential and do not communicate the username and password to anyone to access the account; and (iii) periodically change the password. In the unlikely event that the Company deems that the security of the user’s personal data in its possession or under its control has been or may have been compromised, the Company will inform the user of the incident in the manner prescribed by the law in force. , using the methods prescribed by it (by providing the Company with their email address, the user agrees to receive such communications in electronic format through this email address).

8. Rights of access to personal data – management of choices

8.1 User rights
At any time and free of charge, the users can access their data, receive their electronic personal data in a structured and commonly used, mechanically readable format and transmit them to another data controller (data portability), as well as have them corrected, updated , modify or delete (subject to any applicable exceptions). The user can update the data provided to the Company by contacting the same at the address provided below. Requests for deletion of data are subject to current legal obligations and the conservation of documents imposed on the Company. If the user believes that there is a problem in the way personal data is managed, the user will have the right to file a complaint with the national personal data protection authority or any other country in the EU or the European Economic Area. To exercise these rights, the user can send a request by sending an e-mail to privacy@madetosell.it or a letter by ordinary mail to the address listed below (point 13). When contacting the Company, the user must ensure that they include their name, email address, postal address and / or telephone number (s) to be sure that the same can handle their request correctly.

8.2 Accuracy – Updating of personal data
To allow the Company to better serve the user, the user is invited to regularly check and update their personal data. If registered, the user will be able to access their personal data and modify them using the user account settings on the Website; otherwise,the user can contact the Company (see point 13) to receive assistance in updating personal data.

8.3 Management of choices related to direct marketing (lead generation) and profiling
If the user wishes not to give his consent to the use of data for CRM, marketing and / or profiling purposes, he can send a simple request to the Company (see point 13) indicated below or manage his choices accordingly. related to the account. The same procedure applies where the user wishes to withdraw their consent to profiling.

9. Data retention
Personal data will be kept for the duration of the commercial relationship and for as long as necessary to pursue the purposes described in this Privacy Policy (for example, where the user subscribes to a newsletter, for the duration of this subscription, or where has a user account, until the same is closed). After this period, the user’s personal data will be kept only to comply with legal and regulatory obligations (for example, for 10 years, in the case of accounting purposes; for the duration of the mandatory retention obligation, in the case of tax purposes. ; etc.) or to allow the Company to maintain proof of their respective rights and obligations. The user’s personal data that are processed for CRM purposes (point 3.3) will be kept until the account is closed or until consent to their processing for these purposes is withdrawn. The personal data relating to which the processing is carried out for profiling and marketing purposes will be kept for a limited period, in line with the term allowed by the law in force, and, at the expiry of this term, they will be permanently deleted or anonymised.

10. Policy regarding cookies and similar processes
For further general information on cookies and their enabling and disabling, consult the Cookies and Advertising Management section on the website madetosell.eu/cookiepolicy.

11. Links, Advertisers, Sponsors and Advertisements
This Website may contain links to various websites owned by the Company or controlled by it, as well as to websites of partner companies (for example SellingExperience.com Srl). Where the user chooses to provide his personal information on such linked website (s), such information will be subject to the privacy policy and security policies of such linked websites – including websites administered and operated by approved distributors of the Company, with the exception of the data collected there by the Company’s distributors for CRM purposes if the Company’s privacy policy is published – and not this Privacy Policy. Since the Company is not responsible for the information sent or collected, used, disclosed or otherwise subjected to processing by third party websites, the user should be aware of these other privacy policies.

12. Data controller, data protection officer: company contacts
For the purposes of this Privacy Policy and the data processing described here, it is specified that the term “Company” refers to Made to Sell Srl, with Italian headquarters in Via di Pratignone, 11, cap 50019 Sesto Fiorentino (Florence – Italy) . As the parent and ultimate beneficiary of various brands, through its affiliated companies, the Company is the data controller (as defined in Reg. (EU) 2016/679) of the data collected from the Websites for the CRM purposes referred to in points 3.2 and 3.3. The Company has designated its Data Protection Officer, in charge of managing any question or claim relating to the processing of personal data for CRM purposes, who can be contacted at the following e-mail address: privacy@madetosell.it

13. Updates to this information
The Company, at its discretion, reserves the right to change, modify, add or delete parts of this Privacy Policy at any time, by publishing the revised version on this page of the Website and updating the “Last Modified” date of indicated below. It is the user’s responsibility to review the Privacy Policy from time to time to become aware of any changes made. In some cases, the Company may provide further communications relating to significant changes to this Privacy Policy by publishing a notice on the home page of this Website or, in the case of registered users, by sending a notification email or by inserting a notice on their account. By accepting this revised Privacy Policy by clicking on the “accept” button in this notification email or in the communication published on the account page (where required to comply with current regulations), completing a purchase on the Website or in any store after the revision of the Privacy Policy, or, otherwise, by using or submitting information to the Website after the publication of the revised Privacy Policy, the user accepts this revised Privacy Policy. Following the changes, where required by current legislation, the user’s data will not be processed without the explicit consent of the user.

LAST EDIT
Last Revised February 2021

COOKIE POLICY MADE TO SELL WEB SITE
Extended Cookies information

  • Made to Sell S.r.l. the data controller, informs you that information regarding the use of the site through cookies is collected. When a user visits our site, or the partner sites Madetosellanalysis.eu, Srvitalia.it, and SellingExperience.com, we send to your device cookies that are stored uniquely by your browser.

    Cookies are small text strings that the sites visited by the user send to his device, where they are stored and then transmitted to the same sites on the occasion of the next visit by the same user. Furthermore, when browsing the site, the user can also receive cookies on his terminal that are sent from different websites or web servers (so-called Third Parties). The user is informed that the Made to Sell website also sends Third Party cookies. The Made to Sell sites use so-called technical cookies, as described below.

  • The data collected through cookies, will be used by the owners, their employees responsible for maintenance and management of the site and more generally by all employees including third parties (service providers, infrastructure, IT and similar) who are involved in the management and supervision of the same and duly appointed controllers. The list of managers is available on request.
  • As is known, all the rights provided for in the General Data Protection Regulation (EU) no. 679 of 27 April 2016 (Articles 15-22), namely:
    1. Right of Access: The data subject has the right to access personal data concerning him / her that are being processed in order to check whether his / her personal data are treated in accordance with the law.
    2. Right of Rectification: The interested party has the right to obtain the correction of any inaccurate or incomplete information about himself, in order to guarantee the accuracy of such information according to the purposes of the processing.
    3. Right to Cancellation: The data subject has the right to request that the data owner delete his information and no longer process the data.
    4. Treatment Restriction Right: The data subject has the right to request that the data controller limits the processing of his data.
    5. Right to data portability: The data subject has the right to receive personal data in a structured, commonly used and automatically readable form, and to transmit this data to another data controller.
    6. Right to object to processing: The data subject has the right to object to the processing of data in the cases provided for by the GDPR, at any time and without having to justify his/her decision.
    7. Right not to be the subject of automated decision-making processes: The data subject has the right not to be subjected to a decision based exclusively on automated processing of his/her data, including profiling, which produces legal effects on him/her or that affects his person in a similar way.

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