pursuant to EU Regulation no. 679/2016 ("GDPR") and Legislative Decree 196/2003 as amended by Legislative Decree 101/2018
This Policy is provided pursuant to EU Regulation 679/2016 and subsequent national adaptation legislation (hereinafter, collectively "GDPR") ") and describes how the company identified in the following paragraph collects and processes Personal Data (the term "Personal Data" shall mean all categories of data set out in Point 3. below, taken together) of users or customers. This Policy applies to all activities of collection and subsequent processing of Personal Data - both online and offline - through the various channels, such as the websites of KUCINO, in particular www.kucino.it ("Site") the apps, social networks and, more generally, all activities described in this Policy.
Kucino di Roushdy Farag Emile (hereinafter "Kucino") is the controller of the Personal Data. Kucino pays the utmost attention to the security and confidentiality of Personal Data processed in the performance of its activities. These activities include
- management of e-commerce activities carried out through the Site (management of the purchase of products from the virtual store and related activities);
- managing the Site (e.g. managing and developing the Site and services for users, including the management and operation of cookies)
- offering of specific services related to the same
WHAT PERSONAL DATA CONCERNING YOU MAY BE COLLECTED
As part of its activities described above, Kucino may collect the following categories of Personal Data about you:
- Contact Data - first name, last name, address, telephone number, e-mail address and any other data that you voluntarily provide within the Site to proceed with online orders and to register. - Demographic data and interests - data describing your demographic characteristics or habits, e.g. date of birth, age or age range, gender, geographical origin (postcode/ZIP code), preferred products.
- Social Log-In - information related to your Social account as well as other data you provide to the Social Network used to log-in to the Site, which may be disclosed according to the privacy preferences you have set on that Social Network.
As a general rule, Kucino will not process Personal Data regarding your personal beliefs, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health information, sex life or sexual orientation (hereinafter "Special Categories of Data"). In the event that it is necessary to process Special Categories of Data, Kucino undertakes to process such data in accordance with the applicable legislation. The legal basis for such processing is, as a general rule, the fulfilment of a legal obligation, it being understood that Kucino will ask for your explicit consent if there is no concrete legal obligation to process such Data.
COMPULSORY OR OPTIONAL NATURE OF PROVIDING DATA AND CONSEQUENCES OF REFUSAL TO PROVIDE DATA
The Personal Data required for registration on the Site or identified with an asterisk in the forms relating to the various activities are necessary to allow registration, as are the data required to allow the use of the online purchase and/or booking and/or order functions or for the provision of the specific service requested. Unnecessary Personal Data are not identified with an asterisk in the various forms and may not be returned without any consequence.
FOR WHAT PURPOSES YOUR PERSONAL DATA MAY BE USED
Kucino may process your Personal Data for one or more of the purposes set out below and on the basis of the legal basis indicated from time to time.
A) Processing of purchase orders placed through the Site and activities related to the management of orders (e.g. providing e-commerce services, customer support sales and after-sales service, communication with the customer on the status of the order, receiving your requests for information about the products purchased, payment management, notifications, home delivery and / or collection by you at the agreed point of sale, etc.); as well as to ensure the proper fulfillment of obligations under the law, including the legislation on prize competitions in case of your participation in them. Your Contact Data and Payment Data may be processed by Kucino in order to process your purchase order made by filling in the relevant form on the Site.
A prerequisite for the processing is the execution of a contract to which the data subject is a party and the fulfilment of legal obligations connected to such contract. The provision of such data is mandatory in order to process your order; otherwise, we will not be able to do so.
B) Registration to the Site, also through the Social Log-In system - to simplify the registration operations using the information already given to your Social Network
Prerequisite for processing: fulfilment of contractual obligations, to allow you to register on the Site, it being understood that you are not obliged to use the Social Log-In to complete your registration.
C) Account management in case of registration on the Site for the use of its services The use of the Site does not require the creation of a personal account; however, in order to access some pages reserved for registered users, you will have to create one and thus become a registered user. The Personal Data you provide may be processed by Kucino for the management of your personal account on the Sites.
Prerequisite for processing: execution of pre-contractual measures requested by the data subject and execution of a contract to which the data subject is a party. The provision of such information is mandatory for the creation and management of the account; otherwise, we will not be able to process it.
D) Adhering to and implementing any loyalty programmes organised by Kucino (e.g. cash-back) and/or conventions stipulated between Kucino and various entities (both public and private) and to proceed with the issue and management of the relative cards necessary to take advantage of the relative prizes and/or discounts connected to these programmes and/or conventions. Your Contact Data and Payment Data may be processed by Kucino in order to manage the loyalty programmes and/or to adhere to the above conventions, as well as to issue the relative card and allow you to take advantage of the relative prizes and/or discounts connected to these programmes and/or conventions. The provision of such data is compulsory to enable participation in such programmes and conventions.
Prerequisite for processing: performance of a contract to which the data subject is a party and fulfilment of legal obligations related to such contract. The provision of data is mandatory in order to implement the aforementioned loyalty programmes; otherwise, we will not be able to implement them.
E) Marketing Activities
Subject to your express consent, your contact data may be processed by Kucino for marketing and advertising purposes, including personalised advertising, after analysis of your choices, habits and purchasing preferences, through the use of e-mail, SMS and other bulk messaging tools, etc., or traditional methods of contact (e.g. paper mail, telephone call with operator) or for market research and statistical surveys.
Prerequisite for processing: the consent of the data subject.
Failure to provide consent for marketing activities has no consequences on contractual relations. The consent can be revoked at any time by means of the contacts listed below under "Your data protection rights". You may also change or enrich your preferences at any time via the "Newsletter" drop-down menu on www.Kucino.it or in the "My account" section on www.Kucino.it, by expressing your consent to be contacted about offers on specific shops, or products of interest.
F) Statistical analysis, service improvement and protection of legitimate interests Kucino may use, where possible in aggregate and anonymous form, your Personal Data, including those relating to the use of the Site, your choices, habits and purchasing preferences, the geographical area of reference, the level of expenditure incurred, active services, frequency of use for internal purposes of statistical research and improvement of services offered, as well as for the activities of customer care and customer satisfaction, complaint management, administrative and accounting management, etc.. Prerequisite for processing: the legitimate interest of Kucino.
Within the limits of the provisions of Article 21 of the GDPR, you have the right to object to the processing of personal data concerning you carried out by Kucino in the pursuit of its legitimate interest. Your request to object should be addressed to the following address: info@Kucino.it.
Your Personal Data will not be used to profile you for commercial and marketing purposes, unless you have given your prior consent in accordance with point E) above. Only in this case the described profiling activity may also be carried out for the purpose of sending personalised commercial communications as per point E) above.
G) Defence of rights in the course of judicial, administrative or extrajudicial proceedings, and in the context of disputes arising in relation to the services offered
Your Personal Data may be processed by Kucino in order to defend its rights or to take action or make claims against you or third parties.
Prerequisite for processing: Kucino's legitimate interest in protecting its rights.
Kucino uses appropriate security measures in order to improve the protection, security, integrity and accessibility of your Personal Data. All of Your Personal Data is stored on our secure servers (or appropriately stored hard copies) or those of our suppliers, and is accessible and usable according to our standards and security policies (or equivalent standards for our suppliers).
HOW LONG WE KEEP YOUR DATA
Kucino retains your personal data only for as long as it is necessary for the purposes for which it was collected or for any other related legitimate purpose. Your personal data that is no longer needed or for which there is no longer a legal basis for storage will be irreversibly anonymised or securely destroyed.
Below we list the retention times in relation to the different purposes listed above:
a. Fulfillment of purchase orders made through the Site and activities related to the management of orders: for 10 years from the date of purchase in accordance with the ordinary contractual prescription.
b. Account management in case of registration to the Site for the use of the relevant services: 3 years from the date of the last service provided to the user or, in case of inactivity, 3 years from your registration to the Site.
c. Adhere to and implement the loyalty programmes organised by Kucino (e.g. cash-back) and/or the agreements entered into with the various entities (both public and private): 10 years from the date of use of the programme or agreement by the user.
d. Marketing activities to provide promotional offers, including personalised offers: Personal Data processed for this purpose may be stored for 3 years from the date on which Kucino obtained your last consent to receive commercial communications (unless you revoke your consent earlier). Where Personal Data is processed for marketing purposes, including personalised marketing, as part of a loyalty programme, your Personal Data will be stored for the entire duration of your participation in the loyalty programme (including any renewals, unless you have the right to object).
e. Defending your rights in the course of judicial, administrative or extrajudicial proceedings, and in the context of disputes arising in relation to the services offered: for 10 years from the end of the proceedings with the final passage of the relative sentence or from the settlement and/or agreement reached.
WITH WHOM WE MAY SHARE YOUR PERSONAL DATA
Your Personal Data may be accessed by external consultants and suppliers such as: cloud service providers, IT providers or hosting providers, tax and legal advisors, etc. appointed, where they do not act as independent data controllers, as data processors.
In addition, if requested, your Personal Data and information about transactions carried out and other activities performed through the Site may be made available to the authorities and the judicial police in compliance with procedural rules or to other state administrations where expressly requested.
TRANSFER OF DATA TO COUNTRIES OUTSIDE THE EU
Kucino may transfer your Data to countries that do not belong to the European Union (EU) or to the European Economic Area (EEA) (hereinafter the "Third Countries") whose data protection laws may be of lower standards than those of the EEA. In the latter case Kucino will ensure that all your Data accessible outside the EEA is treated with appropriate safeguards. Kucino will provide adequate safeguards and guarantees for such cross-border transfers in accordance with the requirements of data protection law, including the use of European Commission approved Standard Contractual Clauses, Codes of Conduct and/or Binding Corporate Rules. These clauses impose similar data protection obligations directly on the recipient, unless we are permitted by applicable data protection law to transfer the data without such formalities. Certain third countries, such as Canada and Switzerland, have been authorised by the European Commission as providing protection similar to that of the EEA data protection legislation and therefore no additional legal safeguards are required.
YOUR DATA PROTECTION RIGHTS AND YOUR RIGHT TO COMPLAIN TO THE SUPERVISORY AUTHORITY
Based on Articles 15-21 of the GDPR, You have the right to request:
- access to your Personal Data and the purposes and logic of the processing activities carried out by Kucino; - a copy of the Personal Data you have provided to us (so-called portability),
- the rectification of your Personal Data held by Kucino;
- the deletion of your Personal Data when: (i) the Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (ii) the Personal Data is unlawfully processed; (iii) You have legitimately objected to the processing activity and there is no overriding legitimate reason for the retention; (iv) the Personal Data must be erased to comply with a legal obligation. However, Kucino is entitled to disregard your request for erasure if the right to freedom of expression and information prevails or for the exercise of a legal obligation or to defend a right in court;
- the revocation of your consent, if the processing is based on your consent;
- the restriction of processing (i) for the period necessary for Kucino to verify the accuracy of your Personal Data in case of dispute; (ii) in case of unlawful processing of your Personal Data when you object to the deletion of your Personal Data by requesting a restriction of processing (iii) if, although the data is no longer necessary and must be erased, you need it to be processed for the establishment, exercise or defence of legal claims; (iv) for the period necessary to verify whether Kucino's legitimate reasons prevail over your request to object to the processing.
Furthermore, you have the right to object to the processing of your Personal Data by Kucino for reasons related to your particular situation, unless there are compelling legitimate grounds for Kucino to continue the processing or there is a need to retain your Personal Data for the establishment or defence of legal claims.
Kucino will take into strict consideration any complaints or reports on how your Personal Data is processed and will make every effort to respond to your requests. However, you may forward complaints or reports to the competent supervisory authority, namely: the Italian Data Protection Authority - E-mail: firstname.lastname@example.org.
The contact details of Kucino are:
KUCINO di Roushdy Farag Emile, with registered office in L'Aquila (AQ), Viale Nizza 11, CAP 67100, VAT no.: 01900310663- email@example.com.