This Privacy Information explains how your personal details are collected, used and disclosed by Enervit Spa and companies of the Enervit Group. This Policy also informs you on how you can access and update your personal information and make some decisions on how your personal information will be used. This Policy governs our online and offline data collection activities, including the personal data we collect through our various channels such as Internet web sites, applications, social networking sites, centres for customer relations management, points of sale and events. Please note that the personal details we collect using one method (e.g. an Internet web site) are combined with personal data we collect with another method (e.g. an offline Enervit event). As a result of the above we can combine personal data originally collected by different entities. Please read Section 8 for more information on how to block that action.
1. SOURCES OF PERSONAL INFORMATION
2. PERSONAL DATA WE COLLECT ABOUT YOU AND COLLECTION METHODS
Depending on how you interact with Enervit (online, offline, by phone, etc.), we collect various kinds of information from you in the ways described below. Personal contact information. This kind of information includes all the information you supply us with and that allows us to contact you, such as your name, address, e-mail address, social networking details or telephone number. Information for account access. Any information needed to supply you with access to your specific account profile, e.g. access identification/e-mail address, username, irretrievable password and/or security questions and answers. Personal information. Any (non contact) information that describes yourself and your behaviour, e.g. date of birth, age or age range, gender, geographical location (e.g. post code), preferred products, hobbies and interests, household information or related to life style. Technical information on your computer/mobile device. Any information on the IT system or other technological device you use to access one of our Internet web sites or applications, such as the IP address used to connect your computer or device to the Internet, the kind of operative system, the type and version of web browser. If you access an Enervit web site or application through a mobile device such as a smartphone, the collected information will also include (where permitted) your mobile phone unique identification, the advertising ID, geolocalisation and similar data related to your mobile device. Information on the use of Internet web sites/communications. When you browse and interact on our Internet web sites or newsletter, we use automatic data collection technologies to collect certain information on your actions. This includes information related to the links you have clicked on, displayed pages or contents and how long they were displayed for and other similar information and statistics regarding your interactions, response times to contents, downloading errors and the duration of your visits to certain pages. This information is collected using automated technologies such as cookies (browser cookies, flash cookies) and web beacons. It is also collected by using third party monitoring services. You have the right to oppose to the use of such technologies. For more details please check Section 3. Consumer feedback. This data includes information on your experience regarding the use of our products and services that you willingly share with us. Consumer-generated content. This refers to any contents you create and then share with us on a social networking site or by uploading them onto one of our Internet web sites or applications, including the use of networking applications such as Facebook. This includes photos, videos, personal stories or other media or similar contents. Where permitted, we collect and publish contents generated by customers and related to a variety of activities (including competitions and other promotions), by the shared functions of Internet web sites, events users have participated in and third party social events. Information from social networking sites. This refers to any information you publicly share on a social networking site or information that is part of your profile on a third party social networking site (such as Facebook) and that you allow the third party social networking site to share with us. Examples include basic account-related information (such as name, e-mail address, gender, date of birth, city/town of residence, profile photos, user identification, list of friends, etc.) and all the other information or activities that you allow the third party social networking site to share. We receive your social networking profile information (or part of the information) every time you download or interact with an Internet Enervit application on a social networking site such as Facebook, every time you use a function integrated with an Internet Enervit site (such as Facebook Connect) or every time you interact with us through a social networking site. To learn more about how information on you is obtained by Enervit from third party social networking sites, or to stop sharing such social networking information, please visit the pages of the social networking site in question. Payments and financial information. All the information we need to process an order, or that you use to make a purchase, e.g. the details of your debit or credit card (card holder’s name, card number, expiry date, etc.) or other types of payment (if available). In all cases we manage payment and financial information in compliance with all the applicable laws, regulations and safety standards, such as, for example, the data protection standards of the payment card sector. Calls to Customer Services. Communications with Customer Services may be recorded, in compliance with applicable laws, for local operating needs (e.g. for quality or training purposes) and, in some cases, to obtain proof of consent to direct marketing or profiling. Payment card details are not recorded. If required by the law, you will be informed of call recording at the beginning of your call and you will be able to oppose such action.
3. COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS
A cookie is a small file sent by a web site and memorised in the user’s browser while the user visits an Internet web site. Cookies can be stored just for the time a given web site is used (session cookies) or for a longer period that is session-independent (persistent cookies). Cookies work with the contents of the Internet web site and normally their function is to improve the usability and the browsing experience on the web. They allow Enervit to learn about the displayed contents, the selected choices and every use of the web site by the user. This function also allows Enervit to offer more useful advertising targeted to individual users. Enervit could also work with third parties (that use tracing technologies) to advertise on the Internet. These companies can collect anonymous information on the visits to our web site.
To pursue the aims listed above and other aims, cookies collect and record browsing information, although Enervit’s policy is to leave users to decide whether they want cookies to be used or not. As a result, if users block or stop cookies being used, some functions of the web site could be blocked, slower or inefficient.
4. USE OF YOUR PERSONAL DATA
The paragraphs below describe the various purposes for which we collect and use your personal data and the various kinds of personal data collected for each purpose. Please note that not all the uses listed below will be relevant to everybody. Customer assistance. We use your personal data for customer assistance purposes, including to answer your questions. This usually requires the use of certain personal contact details and information related to the reason of your question (e.g. the status of the order, technical issues, questions/complaints related to the product, general enquiries, etc.). Competitions, marketing and other promotions. With your consent (where required) we use your personal data to supply you with information on products or services (e.g. marketing communications or campaigns or promotions). This can be done via e-mails, advertisements, text messages, phone calls or snail mail in the way it is allowed by the applicable laws. Some of our campaigns and promotions may appear on third party social networking sites and/or Internet web sites. This use of your personal details is not mandatory, which means you can oppose the processing of your data for this purpose. For detailed information on how to change your preferences on marketing communications, please read Sections 8 and 9 below. To learn more about our competitions and other promotions, please read the rules or the official details published with every competition/promotion. Social networking sites: We use your personal details when you interact with the functions of third party social networking sites, such as the “Like” functions, to offer you advertisements and to involve you in our social networking. By reading the privacy policies of the relevant third party social networking sites, you will be able to learn more about how these functions operate, the profile data we obtain about you and about how to withdraw. Customisation (offline and online). With your consent (if required), we use your personal data (i) to analyse your preferences and habits, (ii) to anticipate your needs according to our analyses of your profile, (iii) to improve and customise your experience on our Internet web sites and applications; to ensure the content of our Internet web sites/applications is optimised to suit you and your computer or device; (iv) to allow you to take part in interactive functions when you decide to participate in them. We remember, for example, your access identification/e-mail address or user name so that you can complete access immediately the next time you visit our web site or to allow you to retrieve the products you had previously added to your shopping basket. Based on this type of information and with your consent (if required), we display specific Enervit contents or promotions we think you may be interested in. This use of your personal details is not mandatory, which means you can oppose the processing of your data for this purpose. For detailed information on how to withdraw, please read Section 8 below. Order processing. We use your personal data to process and deliver your orders, to inform you on order status, to correct addresses, to verify identity and for other fraud-identification activities. This requires the use of certain personal details and payment information. Other general purposes (e.g internal and analytical research, security). In compliance with applicable laws, we use your personal details for other purposes of a general nature, such as carrying out internal marketing studies, population-related studies and measuring the effectiveness of advertising campaigns. We also use your personal details to ensure our security.
5. DISCLOSURE OF YOUR PERSONAL DATA
In addition to Enervit S.p.A., the data controller, we share your personal data with the types of third party organisations listed below: Service suppliers. We use external companies to help us manage our activity (e.g. order processing, payment processing, identification of fraud and identity checking, credit recovery, functioning of the Internet site, support services, promotions, development of the Internet web site, data analysis, Customer Service, etc.). Service suppliers (and their selected staff) are only allowed to access and use your data on our behalf and for the specific tasks we have asked them to carry out according to our instructions. They are required to ensure the confidentiality and security of your personal data. Third party companies that use personal details for their own marketing purposes. With the exception of the situations in which you have given your consent, we do not grant licences for nor sell your personal data to third companies for their own marketing purposes.
6. STORAGE OF YOUR PERSONAL DATA
In compliance with applicable laws, we use your personal data for the time needed to satisfy the purposes your personal details were collected for (as described in Section 4 above) or to meet all the applicable legal requirements. The personal data used to provide you with a customised experience will be stored for the time allowed by the applicable laws.
7. DISCLOSURE, FILING AND/OR TRANSFER OF YOUR PERSONAL DATA
We use a number of reasonable measures (described below) to ensure the confidentiality and security of your personal data. However, please be aware that these measures do not apply to the information you have chosen to share in public areas such as social networking sites. People who can access your personal data. Your personal data will be processed by our authorised staff according to the knowledge required and depending on the specific purposes that your personal data was collected for (e.g. the staff managing matters related to customer assistance will have access to the customers’ profile). Measures taken in operating environments. We store your data in an operating environment that uses reasonable security measures to prevent unauthorised access. We comply with reasonable standards to protect your personal information. Unfortunately the transmission of information over the Internet is not completely safe and, although we will do our best to protect your personal information, we cannot guarantee data security during transmission via our Internet web sites/applications. Measures we expect you to implement. It is important that you also play a role in keeping your personal data secure and protected. When you open an online account, please choose a password that cannot easily be guessed and never tell anybody your password. You must guarantee the confidentiality of your password and any use you make of your account. If you use a shared or public computer, never tick ‘remember me’ for your access identification/e-mail address or password. Check that you log out every time you move away from the computer. You must also use any security setting or control we may supply you with in our Internet web site/application. Transfer of your personal data. The filing and processing of your personal data described above may ultimately require the transfer/transmission of the data and/or its filing with third parties. You accept that these activities may take place in countries that offer a lower data protection level than the country you are living in.
8. ACCESS TO YOUR PERSONAL DATA
Access to your personal data. Where permitted by the law, you, your successors, representatives and/or delegates have the right to access, review and request a hard copy or an electronic copy of the stored information regarding you. You may also have the right to ask for information on the source of your personal data. You can exercise these rights by writing to Enervit S.p.A., Viale Achille Papa 30, 20149 Milano (MI) and providing a copy of (one of) your identification document(s) or equivalent details (if that is requested by us and permitted by the law). If the request is submitted by someone other than you, the request will not be granted unless that person proves that the request is legitimately made on your behalf. Please note that any identification information supplied to us will only be processed in compliance with and in the measure permitted by the law. Modification and deletion of your personal details. Where granted by the law, you, your successors, representatives and/or delegates can (i) request the deletion, correction or reviewing of your personal data; (ii) oppose to the processing of the data; (iii) limit the use and disclosure of your personal details; and (iv) withdraw your consent to all our data processing activities. Please note that in some circumstances we may not be able to delete your personal details without deleting your user account at the same time. We may have to keep some of your personal details after you have asked for their deletion in order to fulfil our legal or contractual obligations.
9. YOUR CHOICES ON HOW WE USE AND DISCLOSE YOUR PERSONAL DATA
We endeavour as much as possible to offer you choices regarding the personal data you supply us with. The mechanisms listed below offer you some types of control over your personal data: Cookies/similar technologies. You can adjust your browser’s settings so that you can refuse some or all cookie browsers, or to warn you when cookies are being used. Please read section 3 above. Advertising, marketing and promotions. If you do not want Enervit to use your personal data to promote its products or services, you can state your wish by ticking the relevant box(es) in the registration form or answering the question(s) made by our sales staff, Customer Service or our representatives in stores. If you no longer wish to receive such communications, you can at any time unsubscribe from receiving marketing communications, following the instructions supplied in each of those communications and, in all cases, by writing to Enervit S.p.A., Viale Achille Papa, 30, 20149 Milano (IT) or to: firstname.lastname@example.org. To opt out of marketing communications sent in any way, including through third party social networking sites, you can unsubscribe at any time by accessing the Internet web sites/applications and modifying your user settings in your account profile, unticking the relevant boxes or calling our Customer Service. Please note that, even if you opt out from receiving marketing communications, you may continue receiving from us communications of administrative nature, as well confirmation of orders or other transactions, notifications related to activities with your account (account confirmation, password modification, etc.) and other important announcements.
11. DATA SUPERVISORS AND CONTACT INFORMATION
Data controller Enervit S.p.A.