Privacy policy

Sgamo Srl (hereinafter, also the “Company” or the “Data Controller”), as data controller wishes to inform you, pursuant to the applicable law on personal data protection, including the European Regulation 679/2016 concerning the protection of personal data (the “Regulation”), that the personal data provided by you during the establishment of the contractual relationship and during its execution, will be processed in compliance with the legislative and contractual provisions in force for the purposes and with the modalities indicated here below. In some circumstances, some data may also be collected from third parties, where necessary and always in compliance with applicable legislation.

1. IDENTITY AND CONTACTS OF THE DATA CONTROLLER

The Data Controller is Sgamo Srl, with registered office in Via Tortona 31, Milano, Italy (Tel. +39 02.36740946 – PEC sgamo@legalmail.it).

2. PERSONAL DATA COLLECTED AND PROCESSED, PURPOSES AND LEGAL GROUNDS FOR PROCESSING

The Data Controller may process:

- identification data and contact details: by way of example name and surname, fiscal code, residence, email address, nationality, date of birth, civil status, telephone number;

- fiscal data or any data connected to payments (to make/made to receive/received);

- data related to product/s purchased, by way of example kind of product purchased and its features, preferences regarding products;

The above mentioned data may be processed for the following proposes and on the basis of the following legal grounds:

a) to fulfil the obligations provided for by the law and/or by the existing contract with the Data Controller, and in any case stipulate and execute the sale purchase contract, that takes place with every purchase, comprehensive of the ancillary obligation of repairing the products; in this case, the data processing is lawful as it is needed to fulfil legal obligations connected to the establishment and management of the contractual relationship (Article 6, Paragraph 1, letters b) and c), of the Regulation);

b) the management of any possible litigation and the safeguard of Company’s rights; in this case, the data processing is lawful as it is needed to pursue a legitimate interest of the Company (Article 6, Paragraph 1, letter f) of the Regulation). For these purposes your consent is not required.

c) the data can be also processed for the purposes of sending newsletters, advertisement and communications, or for marketing purposes; in this case, the data processing requires your consent (Article 6, Paragraph 1, letter a) of the Regulation)

d) to identify the kind and features of products you prefer or are interested in, to create profiles or insert you into profiles and/or market areas and/or bends or parts of a database on the basis of the products you purchased and of your preferences regarding Sgamo’s products. Such activities aims at improving the commercial offer of the Company towards you and the customers in general. The data processed for these purposes can amount to profiling activities but on the related outputs the Company will never take automatic or automated decisions. In this case, the data processing requires your consent (Article 6, Paragraph 1, letter a) of the Regulation).

e) make use of the customer care service in all its forms (email, telephone, direct messaging services, etc.) in order to verify the progress and conclusion of the purchase contract, and in particular to receive from Sgamo useful information regarding the status of each order.

3. MODALITIES OF DATA PROCESSING AND NATURE OF DATA COMMUNICATION

Personal data will be processed by the Company through IT and paper systems, according to accuracy, fairness and transparency principles set by the applicable legal provision on data protection and safeguarding your privacy and your rights by adopting appropriate technical and organisational measures aimed at ensuring a level of safety that is adequate to the risks. The communication to us and the updating of your personal data is mandatory according to current legislation (related to taxation or others) or for the execution of the contractual relationship. Lacking such data, it will not be possible to establish or - in some cases - proceed with the contractual relationship so therefore it will not be possible to complete purchases. The communication of your personal data for the purposes set out at point 2.c. and 2.d. is facultative and not providing the connected data or revoking the consent will have no effect on the contractual relationship and will not imply the impossibility to make purchases successfully, but will result only in the impossibility of processing the data for purely marketing / profiling purposes.

4. DATA RETENTION PERIOD

All the data related to you will be retained in pursuance of the civil and fiscal obligations (e.g., civil obligation to store financial records and company mail for 10 years) and in any case only for the duration of the existent contract. After the termination of the contractual relationship, in order to safeguard Company’s rights, data will be retained - in a manner in which they will be available only in case it is necessary - for a period of time equal to the statute of limitation period of any right you may claim against the Company. This period changes depending on the kind of data and on any act interrupting or suspending such period. In case you give your consent to the data processing for the purposes set out at points 2.c. and 2.d. such data will be retained for a maximum period of 24 months form the data collection.

5. COMMUNICATION OF THE DATA PROCESSED

Your data will not be disclosed but, for the purposes above and pursuant to the principles set by the Regulation, they may be communicated to: the employees of the Company, its collaborators, consultants and professionals (in particular, but not limited to: accountants, company database provider etc.). In fulfilling the obligations arising from the law and from the contractual relationship or upon your request, data may be disclosed to public bodies or public authorities.

6. DATA TRANSFER

Your data will be stored at the registered office of the Company and on its servers, located in UE. Considering that Sgamo operates at a worldwide level, your data can also be retained or processed, in a digital format, by other companies of the Group (for the complete list please see www.sgamo.it). The Company informs you that among Sgamo srl and its affiliates specific agreements based on the EU standard contractual clauses are in place.

7. RIGHTS OF THE SUPPLIER

With reference to the data processing above, the Supplier may exercise the rights provided by the applicable law concerning personal data protection, including the rights to:

- obtain confirmation as to whether or not personal data concerning him/her are being processed, and, where that is the case, access to the personal data and the following information (right of access);

- update, modify and/or correct his/her personal data (right to rectification);

- ask for the erasure or the limitation of the processing of the data processed against the law, including those for which storage is not required by the purposes for which data were collected or otherwise processed (right to erasure and right to restriction of processing);

- revoke the consent, if provided, without prejudice to the lawfulness of the data processed on the basis of the consent given before the revocation;

- raise a claim in front of the Supervisory authority in case of violation of the rules concerning personal data protection;

- receive an electronic copy of the data related to him/her that the Employee provided during the employment contract (e.g., data related to salary and internal mobility services) and ask that such data are transferred to another data controller (right to data portability).

In order to exercise the rights above you can contact Data Controller at any time, sending your request to the following email address privacy@sgamo.it via registered mail to the following address: Via Tortona 31, Milan (MI) - Italy.