PRIVACY POLICY

INTRODUCTION

For Chill Remedy S.R.L., owner of the chillremedy.com website, the protection of the privacy of its users is very important. We have therefore decided to draw up a detailed document on the privacy measures taken. This document describes, among other things, what personal data we collect, the purposes and methods of processing for which your personal data are intended and the security measures taken for the protection of the same.

This is an information provided pursuant to art. 12 and ss EU Regulation 679/2016 – General Data Protection Regulation (hereafter “Regulation”) – to those who interact with our web service accessible electronically at the address www.chillremedy.com. We hereby inform users that the personal data provided to chillremedy.com may be subject to processing, in compliance with the aforementioned legislation and confidentiality obligations.

The information is made only for the Site and not also for other websites that may be consulted by the user through links. In addition, this general information does not refer to the specific data processing that may be carried out, within the Site, by different Data Controllers for specific purposes, as indicated in the appropriate information issued by them.

According to the rules of the Regulation, the processing carried out by chillremedy.com will be based on the principles of lawfulness, correctness, transparency, limitation of purposes and storage, minimization of data, accuracy, integrity and confidentiality.

1. Data controller

The Data Controller, i.e. the person who determines the purposes and means of the processing of personal data is: Chill Remedy S.R.L, VAT number IT11669080969 with headquarters in Corso Indipendenza, 5 – 20129 Milan, +39 3518880212[email protected]

2. Data processed

Following the navigation of the Site, we inform you that the Data Controller will process personal data that may consist of an identifier such as the name, an identification number, an online identifier, one or more elements characteristic of the physical, economic, cultural or social identity suitable to make the data subject identified or id.

If it is necessary to know the data referred to in art. 9 of the Regulation (revelation of racial or ethnic origin, political opinions, religious or philosophical beliefs, adherence to parties, genetic data, biometric data, data relating to health or sexual life or sexual orientation) where collected in accordance with the provisions of the legislation may be subject to treatment only with your written consent and for the specific purpose for which they are collected (art.9 letter c) as well as in the cases referred to in the letters from (b) to (j) referred to in art. 9 of the Identifiable Regulation.

2.1 Navigation data

The it systems and software procedures responsible for the operation of this website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols.

This is connection data; IP addresses; domain names and other parameters related to the browser and operating system used by the user; log data; data related to navigation flows and page display; usage and feature counts

This information is not collected to be associated with identified data subjects, but which by their very nature could, through processing and associations with data held by third parties, allow users to be identified.

2.2 Data voluntarily provided by the user

The optional, explicit and voluntary sending of e-mail to the addresses indicated on the Site involves the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data entered.

Personal data are also collected when registering on the Site and, with the consent of the interested user, at the time of request on the Site they will be used by Chill Remedy for the only performance of the service in favor of the same user.

To access some sections of the Site, a registration with the creation of special usernames and passwords shall be requested by Chill Remedy. The collection of personal data marked with an asterisk, in the registration form or during the use of the services, is necessary to allow the user to access the features of the Site indicated at the time of registration. The service, through the crossing and processing of the data provided, will be necessary to correctly identify the user. Personal data will be stored with the user’s consent to allow him to access the personal area of the portal again. The provision of this data is optional, but the refusal to provide it means that the user is unable to obtain registration on the Site and the use of the services reserved for registered users.

In addition, the personal identification and contact data voluntarily provided during registration on the Site or in the use of some of the services offered in it, may, with the specific and distinct consent of the data subject, be transmitted by Chill Remedy to some partners selected for their commercial and marketing initiatives, with automated tools (email, sms, fax, mms, messages on social networks, whatsapp, messenger, online instant messaging applications and self-responders) and /or non-automated (paper mail, telephone with operator) without prejudice to the possibility, for the user, to oppose the sending of such communications at any time even being able to select with which tools to be contacted or not.

The e-mail address provided at the time of the request for a quote will be used by Chill Remedy, with the explicit consent of the data subject, to send you commercial information regarding its services similar to those offered and requested by the user at the time of the request for a quote, without prejudice to the possibility for the user to object to the sending of such communications at the time of data collection and at any time there after. You can refuse to receive further commercial or marketing communications at any time by clicking on the appropriate cancellation link at the bottom of all communications.

Finally, all data (voluntarily provided and browsing data) could be processed to pursue a legitimate interest of the owner or a third party, such as, for example, protection from scams or other conduct contrary to the User Agreement, as well as to assert and defend a right in court.

2.3 Particular categories of personal data

In the use of some sections of the Site there may be a provision of personal data falling within the category of particular categories of personal data referred to in art. 9 of the Rules of Procedure mentioned above.

We invite the data subject to communicate such data only where necessary. We specify that in view of the transmission of particular categories of personal data, but in the absence of a specific manifestation of consent to process such data, the Data Controller cannot be held responsible in any way, nor can he receive disputes of any kind, since in this case the processing will be allowed as it concerns data made manifestly public by the data subject, in accordance with art. 9.1.e) of the Rules of Procedure.

However, we specify the importance, as already mentioned above, of expressing explicit consent to the processing of particular categories of personal data, where the data subject shares such information.

3. Purpose and legal basis of the processing

The processing, with specific consent where necessary, is characterized by the following purposes:

  1. allow the provision of the services to be requested, namely: i) the provision of the sales services offered by Chill Remedy; ii) the request for contact by Chill Remedy or by subjects specially appointed by it; iii) access to the reserved area of the Site;
  2. respond to requests for assistance or information;
  3. comply with any legal, accounting and tax obligations;
  4. marketing and profiling. The data provided may be processed, subject to explicit and specific consent, for the sending of promotional and marketing communications, including the sending of newsletters and market research, through automated tools (sms, mms, e-mail, push notifications, faxes) and non-promotional (paper mail, telephone with operator), as well as for the analysis of the user’s personal data, purchase choices and behavioral preferences on the Site, in order to better structure personalized communications and commercial proposals , to carry out general analyses and, in general, for profiling activities.

The legal basis for the processing of personal data for the purposes referred to in this section is art. 6.1 letters b) and c) of the Regulation as the processing is necessary for the provision of services or for the response of requests of the data subject, also representing a treatment necessary to comply with a legal obligation in charge of Chill Remedy S.R.L.. The provision of personal data for these purposes is optional but failure to provide it would make it impossible to activate the services provided by the Site, to find requests or to evaluate,

The data provided for the purposes referred to in the letter e) may be processed, subject to explicit and specific consent, for the sending of promotional and marketing communications, including the sending of newsletters and market research, through automated tools (sms, mms, e-mail, push notifications, faxes) and non-spam (paper mail, telephone with operator), as well as for the analysis of personal data, purchase choices and behavioral preferences on the Site, in order to better structure personalized communications and commercial proposals , to carry out general analyses and, in general, for profiling activities. The legal basis of the processing of data for these purposes is art. 6 point 1), letter a) of the Rules of Procedure. Commercial profiling and direct marketing treatments are optional and depend on the user’s free choice; therefore failure to provide consents for these purposes will not affect the use of the services. For the processing carried out for the purpose of sending directly its advertising material or direct sale or for the performance of its own market research or commercial communications in relation to products or services of the Data Controller similar to those of Chill Remedy may use, without the consent of the data subject, the e-mail and paper mail addresses pursuant to and to the extent permitted by art. 130, point 4 of the Code and the measure of the Guarantor Authority for the protection of personal data of 19 June. 2008. The legal basis of the processing of data for this purpose is art. 6, point 1, letter f) of the Rules of Procedure. The data subject has the possibility to object to such processing at any time, initially or on the occasion of subsequent communications, easily and free of charge also by writing to the e-mail address: indicated above, as well as to obtain an immediate feedback confirming the interruption of this processing (art. 15 of the Regulation).

Where necessary, specific summary information on the processing of personal data and requests for consent will be progressively reported or displayed on the pages of the Site prepared for particular services.

4. How to treat

The personal data collected will be recorded, processed and stored in our archives, both paper and electronic, in compliance with the appropriate technical and organizational measures referred to in art. 32 of the Rules of Procedure.

Specific security measures are observed to prevent data loss, unlawful or incorrect uses, and unauthorized access, including https secure protocol for certain sensitive parts of the site and applications, and protections from abusive access to servers and other computers in use.

The processing of personal data will be based on principles of fairness, lawfulness and transparency and will take place in a manner that is compatible for the purposes for which they were collected.

The processing may be carried out using paper and/or IT media in any case suitable to guarantee security and confidentiality and with the use of appropriate procedures that avoid the risk of loss, destruction, accidental damage, subtraction, unauthorized access or processing, unlawful use, unwanted modifications and dissemination.

5. Communication of data to third parties

Your data will be processed by the Data Controller, the Data Controllers appointed and the strictly authorized persons, in any case through the adoption of technical-organizational measures suitable to meet compliance with privacy legislation.

In particular, your data may be communicated to:

subjects who typically act as data controllers under ex art. 28 of the Rules of Procedure: (i) persons, companies or professional firms providing assistance and advice to the Data Controller in accounting, administrative, legal, tax, financial and debt collection matters in relation to the provision of the Services; ii) subjects with whom it is necessary to interact for the provision of the Services (e.g. hosting providers) (iii) or subjects delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communications networks); (collectively “recipients”); the list of data controllers who process data, in addition to those specifically indicated above, can be requested from the Data Controller by writing to the address above.

  1. subjects, bodies or authorities, autonomous data controllers, to whom it is mandatory to communicate your personal data by virtue of legal provisions or orders from the authorities;
  2. persons authorized by the Data Controller to process Personal Data ex art. 29 of the Regulation necessary to carry out activities closely related to the provision of the Services, which have committed themselves to confidentiality or have an adequate legal obligation of confidentiality.

As already clarified above, regarding the possible purposes of the processing in the presence of specific consents, free and informed of the users concerned, issued by them in specific sections of the Site, personal data may be communicated to some partners selected by Chill Remedy, whose categories are specified in the appropriate and specific requests for consent, for their commercial and marketing initiatives, with automated tools (email, sms, fax, mms, messages on social networks, whatsapp, messenger, online instant messaging applications and self-responders) and /or non-automated (paper mail, telephone with operator).

We accept payments through the VivaWallet circuit. During payment processing, some data is transferred to VivaWallet, including information necessary to process or support payment, such as total purchases and billing data. For more details, see VivaWallet’s privacy policy.

5.1 Third-party website

This privacy policy does not apply to third-party websites linked via links on our website. We cannot guarantee that these third parties will manage your personal data reliably or securely. We recommend that you read the privacy policies of these websites before using these websites.

6.Data retention

Personal data will be adequate, relevant and stored only for the time necessary for the pursuit of the purposes for which they are collected, in compliance with the principle of minimization referred to in Article 5.1.c) of the GDPR. Since it is a periodic continuous service, the data will be processed by the Data Controller until the aforementioned service is ceased by the user (for more information see General Conditions of Use of the Site).

7. Rights of data subjects

Pursuant to Articles 15 and following of the Rules of Procedure, the data subject has the right to request, at any time, access to personal data, rectification or deletion of the same, limitation of processing in the cases provided for by art. 18 of the Regulation, obtain in a structured format, common use and readable by automatic device the data concerning it, in the cases provided for by art. 20 of the Rules of Procedure. At any time, the data subject has the possibility to: revoke, ex art. 7 of the Rules of Procedure, the consent given; complain to the competent supervisory authority (Guarantor for the Protection of Personal Data) pursuant to art. 77 of the Regulation, if you believe that the processing of your data is contrary to the legislation in force.

The data subject has the opportunity to make a request to oppose the processing of personal data ex. article 21 of the Regulation in which to give evidence of the reasons justifying the opposition: the Data Controller reserves the right to evaluate the request, which would not be accepted in case of existence of binding legitimate reasons to proceed with the processing that prevail over the interests, rights and freedoms of the data subject.

For any request and/or communication regarding this Policy or the processing carried out and the exercise of rights, the user may contact customer support, sending an e-mail to: [email protected]

8. Validity of data protection policy

This privacy policy, subject to periodic improvements and revisions, was last updated on June 9, 2020 and applies to all citizens of the European Economic Area. We reserve the right to make changes to this privacy policy. It is recommended that you regularly review this privacy policy to be aware of any changes.

Any changes to this Policy will apply to the information collected from the date of publication of the modified version and to the existing information we retain. Using the website after the changes are published, you automatically accept those changes.