DESA TRADE PRIVACY STATEMENT

Effective Date: 25th may 2018

This Privacy Statement explains how Desa s.r.l. collect, control, process, and use information about you.(which we call “personal data”).

When we talk about the “Site”, we mean our platforms, which include our websites, mobile applications, communications we send or services we provide, social networking sites, or any other websites we offer that link to or reference this Privacy Statement.

Titolare del trattamento dei dati personali:

DESA srl
V.le G. DeGennaro, 1 | c/o Interporto Puglia
70123 – BARI, ITALY

Change: We routinely update this Privacy Statement to clarify our practices and to reflect new or different privacy practices, such as when we add new services, functionality, or features to the Site. If we make any material changes we will notify you, either by email (sent to the email address specified in your account), by means of notice on the Site or by using other methods. You can determine when this version of the Privacy Statement was adopted by referring to the “Effective Date” above.

You understand that your continued use of the Site after we send a notice about our changes to the Privacy Statement means that the collection, control, processing, and use of your personal data is subject to the updated Privacy Statement.  If you object to any changes, you may modify your account settings or close your account as described below.

1. Personal Data We Collect

 

We will collect the following personal data when you interact with the Site:

  • Authentication and identification information (e.g. your name, email address, and password). This information is necessary to set up and log you into your account. If you don’t provide it, we may not be able to provide our services to you;
  • Basic personal details (e.g. your name, date of birth, and nationality);
  • Contact details (e.g. your postal address, telephone number, and email address). We may need some of this information to deliver products to you, such as your postal address, and won’t be able to carry out these services if you don’t provide it;
  • Payment details (e.g. your credit card details or payment tokens from third party payment providers like PayPal). We use these to process your order, and won’t be able to take payment from you or give refunds if you don’t provide it; and
  • Information about your contacts (e.g. call recordings, instant messages on our site, and user generated content).
  • We will also automatically collect personal data when you interact with the Site through your computer, mobile device, or other device. This personal data includes the following:
  • Analytics data (e.g. information about app downloads, app and web page histories), which may include data collected from cookies and other types of device identifiers;
  • Profile inputs (e.g. page and deal views on the site, click information and information about the website you clicked to our Site from). This may include data about your location. With respect to geolocation information collected from your mobile device, we will only collect this where you have provided consent; and
  • Device details (e.g. MAC address, IP address, bluetooth data and advertising identifiers).
  • We will collect the personal data described above at various stages in your relationship with us when you:
  • Register, subscribe, authorise the transfer of, or create an account with us;
  • Open or respond to emails or messages from us;
  • Connect, log-in, or link to the Site using social networking tools; and post comments to the online communities sections of the Site.

2. Your choices

 

You can manage the types of personal data you provide to us and can limit how we communicate with you. At the same time, we think that the more you tell us about yourself and what you like, the more relevant and valuable your experience with our Site and services will be.

You can manage your email, push notification, location information and subscription notification preferences by logging into your account through the Site or by adjusting the settings in our mobile application:

  • Push notifications and location information.  Your device provide you with options to control push notifications and how and when we collect your geolocation. You can disallow our use of certain location data through your device or browser settings, for example, by disabling “Location” services in Apple’s iOS and Android privacy settings, or by disabling “Location” services for your device;
  • Cookie.  Cookies.  You can manage how your browser handles cookies. You may also manage how your mobile device and mobile browser share information on and about your devices with us, as well as how your mobile browser handles cookies.

1) "technical" cookies:

these cookies are functional to navigation and guarantee the safe and efficient exploration of the site. Furthermore, Google Analytics cookies are used to collect only information, in aggregate form, on the number of users and how they visit the site. These are third-party cookies collected and managed anonymously to monitor and improve the performance of the host site (performance cookies). For more information on the Google cookies policy, please refer to the link below: http://www.google.com/intl/it_ALL/analytics/learn/privacy.html).

2) "analytical" cookies (performance cookies):

These cookies are used to collect and analyze the traffic and use of the site anonymously. These cookies, even without identifying the user, allow, for example, to detect if the same user returns to connect at different times. They also allow you to monitor the system and improve its performance and usability..

3) third-party cookies:

while visiting a website you can receive cookies both from the visited site ("owners"), and from sites managed by other organizations ("third parties"). Third party cookies are those related to "social plugins" such as Facebook, Youtube and Twitter. These are parts of the page visited, generated directly from these sites and integrated into the page of the host site. The most common use of social plugins is to share content on social networks.

The presence of these plugins involves the transmission of cookies to and from all sites managed by third parties. The management of the information collected by "third parties" is specified by the related information which we ask you to refer to. To ensure greater transparency and convenience, find as follows website addresses of the various information and explanation about managing cookies.

The user can decide whether or not to accept cookies using the settings of their browser.

Total or partial disabling of cookies: The total or partial disabling of technical cookies can compromise the use of the site features reserved for registered users. On the contrary, the usability of public content is also possible by completely disabling cookies.

Disabling "third parties" cookies does not affect the navigability in any way

Social networking:  You may also manage sharing certain personal data with us when you connect with us through social networking platforms or applications. Please refer to Section 8 below and also the privacy policy and settings of the social networking website or application to determine how you may adjust our permissions and manage the interactivity between us and your social networking account or your mobile device. 

3. Your rights

 

You can access, update, rectify, and delete your personal data which makes up some of your profile by logging into your account or contacting us here. Keeping your personal data current helps ensure that we can respect your preferences and offer you the goods and services that are most relevant to you.

In accordance with applicable law, you may (i) request access to any personal data we hold about you; (ii) request that it be updated, rectified, deleted or blocked; (iii) request that we delete personal data we hold about you; (iv) request that we restrict our processing of your personal data; and (v) request that we provide you or a third party with a copy of certain personal data about you (that is referred to as the right of  “data portability”). You can also object to any of our uses of your personal data described in this policy, including our marketing activities. 

4. How We Use Information

 

We control and process the personal data you provide to us, which we collect from other sources, and which we generate to:

  • Create your account when you sign up and log you in, which is necessary for us to provide our services to you in accordance with the Terms of Use;
  • Operate, maintain, and improve the Site by analyzing how you and our other customers use and interact with it. This is to meet our legitimate business interests in providing the Site and ensuring that it provides the best experience for our customers;
  • Validate, facilitate, and prevent fraudulent purchases. This may include processing orders for vouchers and other goods and services, payment verification, and verifying that vouchers redeemed by customers are valid. This is necessary to meet our contractual commitments to you set out in the Terms of Use;
  • Carry-out marketing, which may involve:
    • Establishing and analyzing individual and group profiles and customer behavior, in order to determine your or others interest in certain types of offers, products, and services. We do this by analyzing your interactions with the Site and your other personal data to determine what your interests are, and what sorts of products and services people with similar interests also buy, which helps us understand what products and services you may be interested in viewing. This is to meet our legitimate interests in understanding the types of products and services our customers are interested in, and to provide the most relevant products to you and our other customers;
    • Showing relevant offers and advertising. We will use the profiles described above to create advertising for our products that will be displayed on relevant third-party sites. We do this to meet our legitimate interests in showing you products which may be relevant to you, and you can opt out of seeing these types of ads as described in our Cookies Policy;
    • Sending you relevant direct marketing messages and other communications via email or push notifications on mobile devices, including, with your consent, using your location data to notify you of tailored location-based deals. We will either send these messages on the basis that you have consented to receiving them or, where permitted by applicable law, to meet our legitimate interests in showing you which of our products and services are relevant to you;
    • Analyzing advertising effectiveness, which may involve analyzing the advertising campaigns our customers choose to interact with most often. This is to meet our legitimate interests in understanding which types of advertising campaigns are more or less effective than others.
  • Answer your questions and respond to your requests, for example in the context of customer service. This is to meet our contractual commitments to you in the Terms of Use where these questions or requests are part of the purchase process or to comply with legal obligations (such as allowing you to exercise your rights as described above), and in other cases to meet our legitimate interests in providing a good service to our customers;
  • Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, and requested information, including on behalf of Business Partners, EU Affiliates, or other Sellers. This is to meet our legitimate interests in managing our relationship with you effectively;
  • Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events, in order to meet our contractual commitments to you set out in the terms and conditions of those promotional events;
  • Manage our everyday business needs, such as administration of the Site, forum management, fulfillment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and Terms of Use or to comply with the law; and
  • Comply with our legal obligations, resolve disputes, and enforce our agreements. We do this where necessary to comply with legal obligations to which we are subject, or to meet our legitimate interests in enforcing our legal rights and resolving disputes or verifying payments and preventing fraud.5. Come e quando divulghiamo i Dati Personali

We share your personal data as follows:

  • with your consent;
  • with unaffiliated third-party Sellers and Business Partners , so they can sell, deliver, and provide the products or services purchased to you . We share personal data with unaffiliated third-party Sellers and Business Partners in order to meet our contractual obligations to you, and they are not permitted to use your personal data in any way other than for selling, delivering, and/or providing the products or services purchased by you;
  • with third parties, to send you survey emails on our behalf, provided you have consented to receive such emails;  
  • to comply with legal orders and government requests, or as needed to support auditing, compliance, and corporate governance functions, where this is necessary to comply with these legal obligations;
  • to combat fraud or criminal activity, and to protect our rights or those of our EU Affiliates, Sellers, or Business Partners, and users, or as part of legal proceedings affecting us and/or our EU Affiliates, as it is in our legitimate interests to prevent fraud and protect these rights;
  • in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts, to the extent this is necessary to comply with such legal obligations.In nessun caso condividiamo i vostri dati personali con altri soggetti per fini diversi da quelli indicati precedentemente.

6. Security of Personal Data

 

We have implemented an information security program that contains administrative, technical and physical controls that are designed to safeguard your personal data, including industry-standard encryption technology. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

7. Retention of Personal Data

 

We will retain your personal data for as long as your account is active or as needed to provide you services. If you close your account, we will retain your personal data for a period where it is necessary to continue operating our business effectively, to maintain a record of your transactions for financial reporting purposes or fraud prevention purposes until these purposes no longer exist, and to retain as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

8. Social Network

 

Social Community Areas

You may access the Site through, or the Site may contain connections to, areas where you may be able to publicly post information, communicate with others such as discussion boards or blogs, review products and merchants, and submit media content. Prior to posting in these areas, please read our Terms of Use carefully. All of the information you post may be accessible to anyone with Internet access, and any information you include in your posting may be read, collected, and used by others. For example, if you post your email address along with a public restaurant review, you may receive unsolicited messages from other parties. You should avoid publicly posting sensitive information about you or others.

Connecting through Social Networks

We offer social networking users the opportunity to interact with friends and to share on social networks. If you are logged into both the Site and a social network, when you use the Site’s social networking connection functions, you will connect your social network account with the website account (this happens automatically, if the email addresses match).

When you use the Site’s social network connection function, you will have the opportunity to consent to our accessing all of the elements of your social network profile information that you have made available to be shared (as per the settings chosen by you in your social network profile) and to use it in accordance with the social network’s terms of use and this Privacy Statement. You can withdraw this consent at any time.

9. Privacy Practices of Third Parties

 

This Privacy Statement only addresses the collection, processing and use (including disclosure) of personal data by us through your interaction with the Site. Other websites that may be accessible through links from the Site may have their own privacy statements and personal data collection, processing, use, and disclosure practices. Our Business Partners may also have their own privacy statements. We encourage you to familiarise yourself with the privacy statements provided by these other parties prior to providing them with information or taking advantage of a sponsored offer or promotion..

10. Contact Us

 

If you have any questions or comments about our privacy practices or this Privacy Statement, if you want to make use of any of the above rights, or other rights that you may have in relation to your personal data, please contact us