Pursuant to art. 13 of the European Regulation for the protection of personal data no. 679/2016 (“GDPR”), Sorridi Editore S.r.l., as Data Controller and owner of the website www.tkart.it powered by mag3 (hereinafter the “Site” ), wishes to inform you about the processing of personal data carried out via the Site.
- DATA CONTROLLER
The data controller is Sorridi Editore S.r.l. with registered office in Via Padova 330, 20132 Milan, VAT number 04797440965, (hereinafter also the “Controller”), e-mail address: [email protected]
- TYPE OF DATA PROCESSED
Sorridi Editore s.r.l. processes your identification and contact data (for example, name, surname, IP address, e-mail address) and your browsing preferences, i.e. information on how you use the Site.
Your personal data may be collected because you voluntarily provide it (for example when you register on the Site or purchase a subscription) or by analysing your browsing behaviour on the Site.
Payment information relating to the PayPal and Amazon Pay account, as well as the credit card information entered in the appropriate fields managed by Stripe, are processed by the platform of the chosen payment service provider, as an independent data controller. Therefore, Sorridi Editore s.r.l. shall not process payment data or credit card data, to which it will not have access.
- PURPOSE, LEGAL BASIS OF THE PROCESSING AND NATURE OF THE PROVISION OF DATA
The personal data you provide shall be processed for the following purposes:
- a) Purposes necessary for the fulfilment of contractual and legal obligations and for the exercise of our rights
The Data Controller processes your personal data as necessary to proceed with the registration on the Site and provide the related free functions (such as, for example, the creation of a personal area and the possibility of using a free trial subscription for a limited period of time, according to the provisions of the general conditions available on the site), as well as if you decide to subscribe to the Magazine on the Site, for the execution and management of a purchase order on your part. The legal basis of this processing is the execution of your registration request and the fulfilment of a contractual obligation, pursuant to art. 6, section 1, letter b) of the GDPR. In case of failure to provide for this purpose it will not be possible to register, nor to provide you with the subscription service to the Site as requested.
Furthermore, some personal data, such as, for example, the identification data of the device from which the connection is made, to the relative browser, could be processed by Sorridi Editore S.r.l. for the purpose of defending its rights with reference to the prevention of the violation of the general conditions of use of the Site and the purchase of a subscription on the Site.
- b) Marketing purposes
On the basis of your express consent, your data will be processed for the conduct of direct marketing and commercial communication activities carried out via promotional communications sent by e-mail and via browser notifications. which you will see in your reserved area on the Site and relating to the services, products and commercial and promotional initiatives of Sorridi Editore s.r.l., as well as being aimed at carrying out market research, also to find out your degree of satisfaction with the products and services of Sorridi Editore. The legal basis for this processing is your consent, which is completely free and always revocable. In fact, you can withdraw your consent at any time for these marketing purposes, either by clicking on the “Unsubscribe” option at the bottom of all e-mails, or by writing to the e-mail address [email protected]. The provision of your data for this direct marketing purpose is optional. Failure to provide your data for this purpose and your lack of consent do not affect your registration on the Site, or the possibility of proceeding with the purchase of online services and only make it impossible to send you commercial and promotional communications on Sorridi Editore initiatives, products and/or services.
- c) Purpose of profiling the browsing behaviour on the Site for authenticated users
Sorridi Editore has technologies with which, thanks to the query of an ID (in alphanumeric form), it is possible to track the navigation on the Site of registered users who access the Site and browse it as authenticated users.
Therefore, with your express consent, Sorridi Editore s.r.l. may process the data relating to your navigation paths on the Site and display activities on the same, performed by you as an authenticated user, and this in order to present to you with editorial content (e.g. articles published in the Magazine on the Site) during your navigation on the Site similar to those displayed by you, and therefore, customised according to the interests expressed by you during your navigation. Furthermore, if you have also given, in addition to consent for the purposes described in this letter c), your consent to receive the marketing communications referred to in letter b) above, the latter may also be customised based on the interests you have expressed while browsing the Site.
The legal basis of the processing referred to in this letter c) is your consent, completely free and always revocable. In fact, you can revoke your consent for these profiling purposes at any time by contacting the Data Controller by writing to the e-mail address [email protected]. The provision of your data for this profiling purpose is optional. Failure to provide your data for this purpose and your lack of consent do not affect either registration on the Site or the possibility of proceeding with the purchase of online services and only make it impossible to personalise the editorial content and communications based on the interests expressed by you while browsing the Site as an authenticated user.
- RECIPIENTS OR CATEGORIES OF RECIPIENTS OF THE DATA
The personal data you provide shall be processed by Sorridi Editore as Data Controller and by its appointees for the same purposes indicated above. The Data Controller may also make use of companies specifically appointed as Data Processors pursuant to art. 28 GDPR.
Your personal data shall not be disclosed and may be disclosed to other entities or subjects only if this is necessary for the performance of the contract (e.g. Pay Pal, with the exclusion of payment data, which, as mentioned above, is not processed by the Data Controller), for the fulfilment of legal obligations or for the exercise by the Data Controller of its own right in legal proceedings.
- PROCESSING METHODS AND RETENTION PERIOD
The processing shall be carried out in an automated and/or manual format, following methods and using tools aimed at ensuring maximum security and confidentiality.
The identification data you entered at the time of registration shall be processed by Sorridi Editore, as long as you remain registered plus any additional period required by law, in order to allow you, via your personal account, to use of the services of the Site and, where applicable, the purchase of editorial products or services available on the Site.
For the purpose of executing the purchase contract for the subscription to the Magazine on the Site your data will also be kept for the period necessary for the proper execution of the contract and for any further period required by law.
The data relating to the operations and views carried out by the Users registered on TKART shall be kept for 12 months.
For direct marketing purposes, the data will be processed, as a general rule and without prejudice to the principle of data retention proportionate to the purpose of processing, until your consent is revoked or until your profile on the Site is deleted, without prejudice to your right. to withdraw consent at any time via the “Unsubscribe” option contained in all e-mails or by writing to the e-mail address [email protected] or by writing to Sorridi Editore s.r.l., Via Padova 330, 20132, Milan.
- RIGHTS OF THE INTERESTED PARTIES
You have the right, at any time, to ask the Data Controller to access your personal data, to rectify, integrate, delete it, or limit its processing. Furthermore, you have the right to object to the processing of your data at any time as well as the right to data portability. You can at any time request the deletion of your data, revoke your consent and oppose processing for the marketing and profiling purposes described in this statement. To exercise the above-mentioned rights, as well as the additional rights provided for in articles 15 et seq. of EU Reg. No. 679/2016, the interested party may contact the Data Controller by writing to the e-mail address: [email protected], or by writing to Sorridi Editore s.r.l., Via Padova 330, 20132, Milan.
If you find a violation of your rights, you can contact the competent supervisory authority, always without prejudice to the possibility of directly referring to the judicial authorities.