Privacy notes on E-commerce

I.g.b. S.r.l. undertakes to protect all the personal data received. Therefore, the processing and the security of any personal data will be carefully guaranteed, in accordance with the article 13 of the Italian Legislative Decree no. 196/2003 (so-called “Codice della Privacy”, Privacy Code, translator’s note) and of the articles 13 and 14 of the EU Regulation no. 2016/679 (GDPR – General Data Protection Regulation).
This informative note indicates who we are, as well as the aims and the methods of processing of your personal data. It also specifies the subjects that could receive your personal data, where they could be transferred and your rights.

The Data Controller
Your personal data will be processed by I.g.b. S.r.l. in its quality of Data Controller (Italian VAT No 02921590960 R.E.A. No. 1600524 [Repertorio Economico e Amministrativo, Economic and Administrative Register, translator’s note], with registered office In Milan (MI) at Via Pontaccio no. 14 and operative office in Viggiù (VA), at Via Varese No. 115 (hereinafter called “Data Controller”).
I.g.b. S.r.l. appointed its own Data Processor. You can contact the Data Processor at the address of the Data Controller or on the website www.childresistantcartons.com, section “Contact us”.
The List of any external Data Processor dealing with the processing of personal data is available in the offices of I.g.b. S.r.l.

Why your personal data are collected
I.g.b. S.r.l. will use your personal data only for the following aims:

1. Purposes related to the managing of contractual relations and provision of services. Your personal data will be processed for the following aims: managing and provision of services and training courses; updating and information on the services offered and the functions available; fulfilment of any accounting and fiscal obligation; updating of our records and managing of your account; uploading of contents such as users’ interest and reviews, suggestions on products and services of users’ interest; improvement of our online shop and services; prevention or discovery of frauds or misuses damaging our website;
2. Purposes related to marketing activities. Upon your specific consent, your personal data will be processed for the following aims: market researches; economic and statistical studies; updating on training courses; sending of newsletters including advertising/informative/promotional material on the services and products offered.

I.g.b. S.r.l. will carry out the data processing:
- upon your consent;
- when necessary for any contractual obligation quoted in point 1 (for example, the provision of the services offered);
- when necessary for the fulfilment of the legal obligations we are subjected thereto, as quoted in point 1 (for example, accounting obligations);
- when necessary for the pursuing of a legitimate interest (for example, prevention of frauds and misuses damaging our website).

Therefore, the collection of personal data is fundamental for the purposes specified in point 1.
Law does not provide for the purposes quoted in point 2; therefore, any related consent is optional.
The omission or any partial entry of personal data will cause the total or partial impossibility to reach the purposes above mentioned.
The relevance and the adequacy of the personal data transferred will be examined in each single case, in order to take decisions thereon and to avoid the processing of data exceeding our aims.
We will not use your personal data for aims other than those hereby described, except in case of previous communication thereon and upon your consent.

How your personal data are used
I.g.b. S.r.l. undertakes to protect your personal data and to process them in accordance with the principles of fairness, lawfulness and transparency. Therefore, we inform you that your personal data will be processed by systems and through processes, records, paper and digital supports, computer and electronic devices that ensure the highest level of security and confidentiality.
The Provider of the server will process the personal data electronically collected by the Data Controller in its quality of External Data Processor. This processing includes activities of data registration, consultation, communication, storage and erasure, which are generally carried out with electronical systems and by ensuring the adoption of data security and data confidentiality measures.
Your personal data will be stored on an electronical support and will be recorded on a server owned by I.g.b. S.r.l. In this server, your personal data will be protected against the risk of intrusion and non-authorized access thanks to the adoption of security measures that guarantee the integrity and availability of data, as well as the protection of any space and location chosen for data storage and accessibility.
Collaborators and/or employees of the Data Controller will process personal data. The Data Controller expressly authorizes this processing, taking into consideration the functions of any collaborator and/or employee and giving any necessary instruction thereon.
Please note that the website www.childresistantcortons.com offers the possibility to make payments in consideration of the services provided. Nevertheless, our website does not access to confidential information on your credit cards, which will be managed by the intermediaries and credit card issuers concerned.
The information quoted in point 2 can be communicated in a traditional way (for example by post), or by automated systems (for example telephone calls without operator) and by other similar devices (for example by fax, e-mail, telephone message, mms).
In any event, you have the possibility to exercise your right to object with reference to any traditional and automated communication, except in case of your different indications thereon.

Duration of personal data retention
Your personal data will be stored after their collection/updating only for a period in compliance with the above quoted aims of the processing. For further information, also on the criteria used to define this time limit, please visit the related privacy section on the website www.childresistantcartons.com.

Subjects, Duration, Main legislative provisions
Subjects: Customers and suppliers
Duration: 5 - 10 years
Main legislative provisions: Article 2948 of the Italian Civil Code, which provides for a statute barred after 5 years in case of periodic payments; Article 2220 of the Italian Civil Code, which provides for a ten-year storage of any accounting record; Article 22 of the Decree of the Italian President of the Republic no. 600/1973.

Subjects: prospect of customers
Duration: in accordance with the time limits provided for by the law for any specific activity or until revocation of the consent or until the exercise of the right to object. Main legislative provisions: article 23 of the Italian Legislative Decree no. 196/2003; General Provision of 15.05.2013; Article 21 of the EU Regulation no. 2016/679.

Subjects: customers’ data for marketing aims
Duration: in accordance with the time limits provided for by the law for any specific activity or until revocation of the consent or until the exercise of the right to object.
Main legislative provisions: article 23 of the Italian Legislative Decree no. 196/2003; General Provision of 15.05.2013; Article 21 of the EU Regulation no. 2016/679.

Sharing of your information
For the purposes quoted in point 1 and in order to manage and provide our services, your personal data could be communicated to third subjects (for example natural persons, companies or professional firms providing services of assistance, consultancy and collaboration with I.g.b. S.r.l. on accounting, administrative, legal, fiscal and financial matters).
For the purposes quoted in point 2, your personal data could be communicated to third companies, which collaborate with I.g.b. S.r.l.
For any purpose defined in this informative note, your personal data could be communicated abroad too, inside and outside the European Union. This data transfer complies with any right and guarantee provided for by current law and is carried out after verifying that the country concerned has an “adequate” level of data protection.
Your personal data could be communicated to specific subjects appointed by the Data Controller to provide services instrumental or necessary to the fulfilment of any obligation related to the registration on the website www.childreistantcartons.com, within the limits and in accordance with any instruction given.
We also inform you that all the e-mails received will be stored by an outsourcing archiving system. Only public bodies are allowed to access to any data archived under the cases and modalities provided for by current law and in the event of legal disputes.
Your personal data are not subjected to dissemination.

Your rights
By sending an e-mail to the address privacy@childresistantcartons.com you have at any time the right to:
- access to your personal data;
- rectify them in case of inaccuracy;
- erase them;
- limit their processing.
- limit their processing.

You have also the right to:
- oppose to their processing:
a) if personal data are processed for the pursuit of a legitimate public interest of I.g.b. S.r.l.;
b) if personal data are processed for direct marketing aims;
- data portability, that is to receive the personal data you communicated on a common and readable structured format, which can be used with any automatic device.
We will consider your request with the greatest attention in order to ensure the effective exercise of your rights. Finally, you have the right to lodge a complaint with the Italian Data Protection Authority, at: www.garanteprivacy.it.

Revocation of your consent
At any time, you have the right to revoke your consent, without prejudice to:
- the lawfulness of the data processing previously carried out upon consent;
- any other data processing carried out in compliance with other provisions (for example, contractual obligations or obligations laid down by law for I.g.b. S.r.l.).
After revocation, it will be impossible to consider your further requests.

Further information
For any further information on this informative note or on any matter concerning privacy or if you wish to exercise your rights or to revoke your consent, you can contact directly our Data Controller, whose e-mail address is quoted in the section “Data Controller” (E-mail address: privacy@childresistantcartons.com).

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