Privacy Policy En

Privacy policy for users

IN.PRO.DI. S.p.A. with registered office in Via Massimo Inghirami 1/3, 52037 Sansepolcro (AR), Italy, VAT no. 04972520961 (hereinafter, “Owner“), is the owner of the website www.ingram1949.com (hereinafter, the “Site“), operating in the role of the data controller for processing the personal data of users who visit or are registered on the site (hereinafter, the “Users“). In this document, the owner sets out the privacy policy pursuant to article 13 of EU Regulation 2016/679 of 27 April 2016 (hereinafter, the “Regulation” or “Applicable regulations”).

Please note that the owner has appointed a Group Data Protection Officer, who can be contacted at dpo@inghiramicompany.it.

This site and any services offered through the Site are reserved for persons over the age of eighteen. The Owner therefore does not collect personal data relating to subjects under 18 years of age. Upon request of the Users, the Owner will promptly delete all personal data involuntarily collected and relating to subjects under 18 years of age.

The Owner ensures the utmost consideration of the Users’ rights to privacy and protection of personal data. For any information in relation to this privacy policy, Users may contact the Owner at any time, using the methods described in point 4.

 

  • Purposes of the processing 

 

Users’ personal data will be lawfully processed by the data controller in accordance with article 6 of the Regulation, for the following purposes 

  1. Navigation on the site, in particular as concerns the collection of data such as IP address, necessary at a technical level for purposes of browsing the site.
  2. Contractual obligations and provision of the service in case of online purchases, to implement the General Conditions of Sale, as accepted by the user when registering on the site, and to comply with specific User requests. The User’s data collected by the Owner for purposes of registration on the Site include: Mandatory: e-mail address, password, first name, last name, shipping address, postal code, city, province, country, Optional: all personal information voluntarily communicated by the User. Unless the User gives the Owner specific and optional consent to the processing of his/her data for the further purposes indicated in the following paragraphs, the Owner will use the User’s personal data for the exclusive purpose of ascertaining the User’s identity (including by validating the e-mail address), thus avoiding possible fraud or abuse, and to contact the User for service reasons only (e.g. sending notifications regarding the services offered on the Site). Without prejudice to what is provided elsewhere in this privacy policy, under no circumstances will the Owner make the User’s personal data accessible to other Users and/or third parties.
  3. Administrative-accounting purposes, to carry out activities of organisational, administrative, financial and accounting nature, such as internal administrative activities and activities functional to the fulfilment of contractual and pre-contractual obligations.
  4. Registration on the reserved area of the site, enabling online purchases and facilitating purchase operations, avoiding that the User should repeatedly insert their data.
  5. Obligations under the law, to comply with obligations indicated in Italian law, by an authority, or in European legislation or regulations.

The provision of personal data for the processing purposes indicated above is optional, but necessary for the User to navigate the site, register on the site and use the services offered by the Owner on the Site, since failure to provide the data will make these operations impossible.

With reference to the purposes referred to in points 1/a, 1/b, 1/d, the legal basis of the processing is the performance of the services provided through the Site and requested by you (pursuant to Article 6, paragraph 1, letter b of Regulation 2016/679). With reference to the purposes referred to in points 1/c and 1/e, the legal basis of the processing is to fulfil a legal obligation applying to the data controller (pursuant to Article 6, paragraph 1, letter c of Regulation 2016/679).

The User may voluntarily send further data to the e-mail addresses published on the website. The data will be processed for purposes of responding to any requests made by the User and to manage the resulting activities. If necessary, IN.PRO.DI S.p.A. staff will provide specific privacy information in these regards.

 

  • Further processing purposes: marketing and newsletters (sending advertising material, direct sales, commercial communications)

 

With the User’s free and optional consent, some of the their personal data (first name, last name, e-mail address, full shipping address, etc.) may be processed by the Owner for marketing and newsletter purposes (sending advertising material, direct sales, commercial communications, newsletters containing information in the sector pertinent to the Site), or so that the Owner can contact the User by mail, e-mail, telephone (fixed and/or mobile, with automated calling or communication systems, with and/or without the intervention of an operator) and/or SMS messages to propose the Owner’s products and/or services for purchase by the User, and to present offers, promotions or commercial opportunities. In case of lack of consent, the possibility of registering on the Site and/or accessing the services offered will not be affected in any way.

The User may revoke their previous consent at any time, by making a request to the Owner in the manner indicated in paragraph 5 below.

The User may also object to the continuation of promotional communications and e-mail newsletters by contacting the Owner in the manner indicated in paragraph 5 below. In the case the User revokes their consent, the Owner will send an e-mail to confirm the revocation. If the User wishes to revoke their consent to contact by telephone, while continuing to receive promotional communications via e-mail, or vice versa, they may send a request to the Owner in the manner indicated in paragraph 5 below.

The Owner informs that, following the exercise of the right to object to the sending of promotional communications and newsletters via e-mail, it is possible that for technical and operational reasons (e.g. formation of contact lists already completed shortly before the Owner receives the request for objection), the User may receive some additional promotional messages and newsletters. Should the User continue to receive promotional messages and newsletters after 7 days from the exercise of the right of objection, please report the problem to the Owner, using the contacts indicated in paragraph 5 below.

The legal basis for the processing is the free and specific consent of the data subject (Article 6 paragraph 1 letter a) of Regulation 2016/679).

 

  • Processing methods and data retention 

 

The Owner will process the Users’ personal data using manual and computerised means, applying a logic strictly related to the purposes, and in any case so ensuring the security and confidentiality of the data.

The personal data of the Site Users will be kept for the time strictly necessary to carry out the purposes indicated in paragraph 1 above, or in any case in accordance with what is necessary to protect the interests of both the Users and Owner. The data used for the purposes set out in paragraph 2 will be kept until the User revokes their consent, through the procedures for exercising the rights set out in paragraph 5.

 

  • Scope of data communication and disclosure

 

The Owner provides for the formal appointment of “data managers”, who will manage the site and process the User’s data exclusively for the purposes indicated in this notice and in compliance with the provisions of the applicable regulations. The employees and/or collaborators of the data manager may become aware of the Users’ personal data. 

Users’ personal data may also be communicated to third parties, who may process personal data on behalf of the data controller in their capacity as “External Data Processors“, such as, for example, providers of information technology and logistics services functional to the Site operation, providers of outsourcing or cloud computing services, professionals and consultants. The data may also be communicated to tax authorities and/or other public authorities where this is required by law, or at their request. Users have the right to obtain a list of any data processors appointed by the Owner, by making a request to the Owner in the manner indicated in paragraph 4 below. The data will not be disclosed in any way.

 

  • Rights of the interested parties

 

Users may exercise the rights guaranteed to them by the Applicable Regulations, by contacting the Owner in the following ways:

  • by sending a registered letter with return receipt to the registered office of the Owner; 
  • by sending an e-mail to privacy@inghiramicompany.it

In accordance with the Applicable Regulations, users may exercise their rights under Article 15 et seq. of the Regulation, in the manner provided for in Article 12 of the same.

If you consider that the processing concerning you is in breach of the Regulation, you have the right to lodge a complaint with a Supervisory Authority, in the Member State where you are normally resident, where you work, or where the alleged breach has occurred. The Italian supervisory authority is the Italian Data Protection Authority http://www.garanteprivacy.it/ – e-mail: garante@gpdp.it.