This privacy policy (“Policy“) describes the personal data processing carried out by Sellmasters S.r.l. (hereinafter, the “Company” or “We”), through the web site https://www.sellmasters.it/ (the “Website“) and as part of its services. This Policy is provided pursuant to Article 13 of the European Data Protection Regulation 679/2016 (the “GDPR“) and Italian Legislative Decree 196/2003 (“Privacy Code“) as amended by Legislative Decree 101/2018.

This Policy applies to all Website visitors and to our clients (“Clients” or “You”) to whom We provide our services (the “Services”). The Policy does not refer to the processing of data by the Company of the Vendor’s customers. Please refer to Privacy Policy for the Vendor’s Customers available at the following link applies.

WHO IS THE DATA CONTROLLER?

Sellmasters S.r.l., TAX CODE/VAT no. 14821441004, with registered office in Rome, Viale di Val Fiorita, 86, 00144 (Italy).

For any communications relating to this Policy or any questions concerning the processing of personal data please send an email to the following dedicated email address: privacy@sellmasters.it.

WHAT PERSONAL DATA DO WE PROCESS?

“Personal data”, pursuant to Article 4 of the GDPR, means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is any person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.

According to the same provision, “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Data subject” shall mean any individual to whom the personal data undergoing processing refer.

The personal data being processed through the Website are the following (“Personal Data”):

• Cookies: please refer to our cookie policy (here). [PLEASE INSERT HYPERLINK]

• Navigation and Interaction Data: computer systems and software procedures designed to run the Website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified individuals, but by its very nature could, through processing and association with data held by third parties, lead to the identification of users. IP addresses or domain names of computers used by users who connect to the Website, the URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in reply, the numerical code indicating the status of the reply given by the server (successful, error, etc.) and other parameters regarding the user’s operating system and computer environment fall into this category. This personal data are collected for the sole purpose of obtaining anonymous statistical information on the use of the Website in order to check its correct functioning, to identify anomalies and/or abuses. In any case, they are deleted immediately after processing. The data may be used to ascertain responsibility in case of hypothetical cybercrimes against the Website or third parties.

• Data You provide: the data that You voluntarily provide us through the Website or other communication channels such as an identification and contact details (name and surname, e-mail, address and telephone number), an online identifier (username) or any data that can identify You or make You identifiable, which You wish to enter on the Website or which, based on Your request, will be provided to us by third parties (e.g. social networks, third party web sites). Should You provide us with data concerning third parties, You must expressly guarantee that You have obtained their prior consent, thus releasing the Company from any liability. The Company reserves the right to carry out periodic checks.

FOR WHAT PURPOSES DO WE USE THE PERSONAL DATA OF VISITORS AND USERS?

Your Personal Data will be processed, with Your consent where necessary, for the following purposes, where applicable:

1. to allow browsing the Website and to provide You with the Services offered by the Company, including security management of the Website;
2. to provide You with our Services or address Your specific requests and for administrative and accounting purposes;
3. to comply with any obligations under applicable national laws and regulations or EU legislation, or to comply with any requests from the authorities;
4. for statistical purposes, in a completely anonymous and aggregate form whereby Your identity cannot be traced.

Your Personal Data may be processed:

1. for the purposes referred to in points 1. and 2. of the preceding paragraph, pursuant to Article 6, paragraph 1, letter b) of the GDPR (“[…] processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject“), as the processing is necessary to provide You with our Services. The provision of Personal Data for these purposes is optional, but failure to provide it would make it impossible for You to use the Services requested;
2. for the purposes referred to in point 3. of the previous paragraph, pursuant to Article 6, paragraph 1, letter c) of the GDPR (“[…] processing is necessary for compliance with a legal obligation to which the data controller is subject“). Once Personal Data has been provided, in fact, the processing is necessary to comply with legal obligations to which the Company is subject;
3. the processing referred to in point 4. of the preceding paragraph is not performed on Personal Data and may therefore be freely carried out by the Company.

WHO DO WE SHARE PERSONAL DATA WITH?

We may share some of Your Personal Data with entities that typically act as data processors under Article 29 of the Privacy Code and art. 28 of the GDPR, namely: (i) persons, companies or professional firms that provide assistance and advice to the Company in accounting, administrative, legal, tax and financial matters; (ii) parties appointed to carry out technical maintenance activities; (iii) consulting services and full management of digital marketing actions; (iv) service providers that are used by the Company to achieve the purposes described above (e.g. app developers and providers of server hosting services, cloud computing, electronic communication systems, chatbots, virtual infrastructures and other IT services); always in compliance with the principle of minimisation, limiting processing to the data strictly necessary to achieve the specific purpose.

We may also share your Personal Data with affiliated or related companies strictly for the purposes set out in paragraph 6, with your explicit consent or for purely internal administrative purposes.

Finally, Your Personal Data will be communicated by the Company to persons, entities or authorities to whom communication is compulsory by law or by authority orders.

The full list of data controllers is available upon request to the Company.

Nevertheless, Your Personal Data will not be transferred to countries outside the European Union that do not offer an adequate level or do not provide appropriate guarantees of protection.

HOW LONG DO WE KEEP THE DATA?

Personal Data processed for the purposes set out in points 1 and 2 will be stored for the time strictly necessary to achieve those purposes. In any case, since the processing is carried out for the provision of Services, the Company will store the Personal Data for the period provided for and allowed by Italian law to protect its interests (Art. 2946 c.c. and ss).

Personal Data processed for the purposes referred to in point 3. will be stored for the period provided for by the specific obligation or applicable law.

YOUR RIGHTS

Pursuant to Chapter III of the GDPR, You have the right to access Your Personal Data at any time and to know their content and origin, verify their accuracy or request their integration, updating, or rectification; You have the right to request the erasure, anonymization or blocking of data unlawfully processed, as well as to object, upon legitimate reasons, to its processing, and the right to obtain in a well-structured, commonly used and machine-readable format Your personal data, under the circumstances provided for by art. 20 of the GDPR.

In any case, You always have the right to file a complaint with the Personal Data Protection Authority, pursuant to art. 77 of the GDPR, if You believe that the processing of Your data is in breach of the applicable legislation.

UPDATES TO OUR PRIVACY POLICY

This Policy was updated on February 8, 2021. The Company has the right to amend this Policy in full or in part, or simply to update its content (e.g. due to changes in applicable law). The Company will publish any updates on this Website.