Sellmasters S.r.l. (“Sellmasters“) has been entrusted by the Vendor (the “Vendor“) to perform certain services concerning the online sale and shipment of products (the “Services”) involving the processing of the data of the Vendor’s customers (“Data Subjects” or “You”).

This Privacy Policy (the “Policy”) applies to the customers of the Vendor, which, with respect to the processing of their data, is the data controller pursuant to EU Regulation 2016/679 (“GDPR“). Such data are provided by the Vendor to Sellmasters, which processes them on behalf of the Vendor in its capacity as data processor.

In order to ensure the utmost transparency on purposes and means of the processing carried out by Sellmasters, below is the Policy pursuant to Article 14 of the GDPR.

1. DATA CONTROLLER

The data controller is the Vendor in the person of its legal representative pro tempore (the “Controller“). The contact details are indicated on the invoice or on the shipping documents.

2. DATA PROCESSOR

The data processor is Sellmasters S.r.l., with registered office in Rome (RM), Via di Val Fiorita, 86 – 00144, email address: privacy@Sellmasters.it (the “Processor“).

3. DATA SOURCE, LEGAL BASIS, PURPOSE AND NATURE OF PROCESSING

The data processed by the Processor are provided by the Controller. These data may be data that You have provided to the Controller, to execute the purchase of the Services or for requesting customer services related to the purchase (e.g. returns, feedback on the purchase, invoice requests), or data that have been processed by the Controller.

Personal Data (as defined below) are processed in accordance with Article 6(1)(b) of the GDPR, under which “[…] 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 prior to entering into a contract“. More specifically, the processing of Personal Data is based on by the sales contract executed between You and the Controller. On the basis of a deed of appointment as Processor, the Controller has authorised Sellmasters, under its responsibility and control, to process the data in the performance of the Services.

The purposes of the processing are strictly related to the administrative and accounting activities required to perform the sales contract between You and the Vendor.

The provision of Personal Data is necessary for the performance of such contract. Failure to provide the requested data may make it impossible to properly perform the contractual relationship.

4. PERSONAL DATA

Personal Data processed may be (i) common data directly provided by You to the Controller, such as contacts data, identifiers, email, shipping address and (ii) data concerning orders placed collected by the Controller (“Personal Data”).

5. CATEGORIES OF PERSONS TO WHOM PERSONAL DATA MAY BE DISCLOSED

Personal data may be disclosed by the Processor to the Controller and to the following recipients:

• employees of the Processor duly trained and appointed as persons authorised to process the Personal Data;
• external parties who carry out specific processing operations, in accordance with the instructions given by the Controller, in the name and on behalf of the Controller, duly appointed as data processors; and
• persons, entities or authorities that require disclosure of Your Personal Data pursuant to law or order of the competent authorities.

6. DATA RETENTION PERIOD

Since the processing is carried out for the provision of the Services, the Processor will keep the Personal Data for the period envisaged and permitted by Italian law to protect its interests (Art. 2946 c.c. and following).

7. RIGHTS OF THE DATA SUBJECTS

With regards to the processing of the Personal Data covered by this Policy, You are granted the rights provided for in Chapter III of the GDPR, namely the right to access Your own data, to request their rectification, the right to obtain the erasure of Your data in the cases provided for by art. 17 of the GDPR, the right to request the limitation of the processing in the cases provided for by art. 18 of the GDPR, to object to the processing in the cases provided for by art. 21 of the GDPR, as well as to obtain the Your data in a structured, commonly used and machine-readable format, in the cases provided for by art. 20 of the GDPR.

You are also entitled to lodge at any time a complaint with the Data Protection Authority, pursuant to art. 77 of the GDPR, if You believe that the processing of Your Personal Data is in breach of the applicable legislation.

You may exercise the above-mentioned rights by written communication to the following email address: privacy@sellemasters.it.