Privacy Policy

PRIVACY POLICY

INFORMATION FOR THE PROCESSING OF PERSONAL DATA IN ACCORDANCE WITH ART. 13 OF THE REG. EU 2016/679 (GDPR)

Pursuant to art. 13 of the European Regulation (EU) 2016/679 (hereinafter GDPR), we inform you as follows:

1. HOLDER OF THE TREATMENT

Caramanna Gioielli srl with registered office in Via Cavallerizza, 46 • 80121 Naples VAT number: 07315491212 (hereinafter, "Owner"), as the data controller, in the person of the legal representative, domiciled at the company, who can be contacted at the following email address (info@caramannagioielli.it).

2. Purpose of the processing

The data you provide: name, surname, company name, address, telephone, e-mail, bank and payment details ("personal data" or even "data"), will be processed:

1. A) without your express consent art. 6 lett. b), e) GDPR), for the following Service Purposes:

- fulfill the pre-contractual obligations (i.e. requests for quotations, shipments reservations), contractual (order confirmations, order changes, compilation of notes and invoices), deriving from existing relationships with you;

1. B) Only with your specific and distinct consent (Article 7 of the GDPR), for the following Marketing Purposes:

• send them via e-mail, post and / or sms, and / or whatsapp messages, and / or telephone contacts:

newsletters, commercial communications and / or advertising material on products or services offered by the Data Controller, detection of the degree of satisfaction with the quality of services;

• collect data within cookies while browsing the website www.caramannagioielli.it

If the processing intends to further process personal data for a purpose other than that for which they were collected, before such further processing it will provide the interested party with information regarding this different purpose and any further relevant information.

The data collected automatically are navigation data. Such data, although not collected in order to be associated with the user's identity, could indirectly, through processing and association with data collected by the Data Controller, allow its identification.

Following the sending of newsletters, the platform used makes it possible to detect the opening of a message and the clicks made within the newsletter itself, together with details relating to the IP and the browser / device used. The collection of this data is essential for the operation of the implicit renewal of processing systems (see the item Processing Methods) and an integral part of the operation of the sending platform.

The provision of data for the purpose of sending newsletters for promotional, information or research purposes is optional and the refusal to give the relative consent to the processing will make it impossible to be updated about commercial initiatives and / or promotional campaigns, to receive offers or other promotional material and / or to send you personalized offers. Caramanna Gioielli srl does not provide third parties with any user information without their consent, except where required by law.

3. Methods of processing and data retention period

The processing of your personal data is carried out by means of the operations indicated in art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data will be subjected to both paper and electronic processing, in any case providing for the annual verification of the data stored in order to delete those deemed obsolete, unless the law provides for archiving obligations.

Personal data will be stored on servers located at the registered offices. In any case, it is understood that your data will be recorded on a single physical server located in the Italian territory. Every precaution will be put

in place to minimize the risk of unauthorized access, cancellation, modification or appropriation by unauthorized third parties. The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the relationship for the purposes of service, and for no more than 2 years from the collection of data for marketing purposes.

Data processing usually takes place by personnel or external collaborators duly designated as data processors. The complete list of data processors and persons in charge of personal data processing can be requested by sending a specific request to the email address info@caramannagioielli.it

4. Access to data

Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B):

• to employees and collaborators of the Data Controller, in their capacity as data processors

5. Data communication

the Data Controller may communicate your data for the purposes referred to in art. 2.A) to external suppliers such as accountants, lawyers, IT consultancy companies, as well as to those subjects to whom the communication is mandatory by law for the accomplishment of the aforementioned purposes. These subjects will process the data in their capacity as independent data controllers.

6. Transfer of data

In any case, it is understood that the Data Controller, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller ensures from now on that the transfer of data outside the EU will take place in compliance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.

7. Nature of the provision of data and consequences of refusing to respond

The provision of data for the purposes referred to in art. 2.A) is mandatory. In their absence, we will not be able to guarantee the services of the art. 2.A). The provision of data for the purposes referred to in art. 2.B) is optional. You can therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material relating to the Services offered by the Data Controller. However, you will continue to be entitled to the Services referred to in art. 2.A).

8. Rights of the interested party

In your capacity as an interested party, you have the rights referred to in art. 15 GDPR and precisely the rights of:

1. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
2. obtain the indication: a) of the origin of the personal data; b) the purposes and methods of the processing; c) of the logic applied in case of treatment carried out with the aid of electronic instruments; d) the identity of the owner, manager and the representative appointed pursuant to art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or agents;

iii. obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including data which need not be kept for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment is proves impossible or involves the use of means that are manifestly disproportionate to the protected right;

1. object, in whole or in part: a) for legitimate reasons to the processing of personal data concerning you, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by email

and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the data subject's right to object, set out in point b) above, for direct marketing purposes through

automated methods, extends to the traditional ones and which in any case remains without prejudice to the possibility for the interested party to exercise the right to object even only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or neither of the two types of communications. Where applicable, it also has the rights referred to in Articles. 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

Right pursuant to art. 17 of EU Reg. 2016/679 - right to cancellation ("right to be forgotten").

The interested party has the right to obtain from the data controller the cancellation of personal data concerning him without undue delay and the data controller is obliged to cancel the personal data without undue delay, if one of the following reasons exists:

a) the personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed;

b) the interested party revokes the consent on which the processing is based in accordance with Article 6, paragraph 1, letter a), or Article 9, paragraph 2, letter a), and if there is no other legal basis for the processing ;

c) the interested party opposes the processing pursuant to Article 21, paragraph 1, and there is no legitimate overriding reason to proceed with the processing, or opposes the processing pursuant to Article 21, paragraph 2;

d) the personal data have been unlawfully processed;

e) personal data must be deleted to fulfill a legal obligation under Union law or the law of the Member State to which the data controller is subject;

f) the personal data have been collected in relation to the offer of information society services referred to in Article 8, paragraph 1 of EU Reg. 2016/679

Right referred to in art. 18 Right to limitation of treatment

The interested party has the right to obtain from the data controller the limitation of the processing when one of the following hypotheses occurs:

Right pursuant to art. 20 Right to data portability

The interested party has the right to receive the personal data concerning him in a structured format, commonly used and readable by an automatic device and has the right to transmit such data to another data controller without impediments by the data controller.

9. How to exercise your rights

You are entitled to withdraw your consent to the processing of your personal data by sending a registered letter with return receipt to the following address: Caramanna Gioielli srl with registered office in Via Cavallerizza, 46 • 80121 Naples accompanied by a photocopy of your identity document, or an e-mail to the address: info@caramannagioielli.it .

If you wish to have more information on the processing of your personal data, or to exercise the rights referred to in point 7 above, you can send a registered letter to the following address Caramanna Gioielli srl with registered office in Via Cavallerizza, 46 • 80121 Naples accompanied by a photocopy of his identity document, or an e-mail to the address: info@caramannagioielli.it. Before we can provide you, or change any information, you may need to verify your identity and answer some questions.

10. Updates and changes

Caramanna Gioielli srl reserves the right to modify, supplement or periodically update this Information in compliance with the applicable legislation or the measures adopted by the Guarantor for the protection of personal data. The aforementioned changes or additions will be brought to the attention of the interested parties through a link to the Privacy Policy page on the website and will be communicated directly to the interested parties by email. We invite users to read the Privacy Policy regularly, to check the updated information and decide whether or not to continue to use the services offered.