VIRILI BY RAGOSTA DANIELE, VIA ROMA, 55 – 80040, VOLLA, NAPOLI, ITALIA; EMAIL: PRIVACY@VIRILI.EU

PERSONAL INFORMATIONS. PURPOSE OF THE TREATMENT.

THE EXPRESSION “PERSONAL INFORMATION” MEANS ANY INFORMATION RELATING TO USERS THAT PERSONALLY IDENTIFIES THEM, ALONE OR IN COMBINATION WITH OTHER INFORMATION. PERSONAL INFORMATION IS AUTOMATICALLY COLLECTED FROM THE SITE OR RECEIVED THROUGH MULTIPLE SOURCES: FORMS, CHATS, E-MAILS, APPS, DEVICES, SOCIAL MEDIA AND OTHER MEANS. THE SITE PROCESSES PERSONAL INFORMATION IN VARIOUS FORMS FOR THE FOLLOWING PURPOSES:

• NAVIGATION’S DATA

THE SITE COLLECTS NON-SENSITIVE NAVIGATION DATA WITH AUTOMATIC MEANS IN ORDER TO ENABLE AND IMPROVE THE USER’S NAVIGATION (FOR EXAMPLE IP ADDRESS, DATE / TIME OF VISIT AND RELATIVE DURATION, POSSIBLE REFERENCE URLS, PAGES VISITED ON THE SITE, DEVICE OTHER INFORMATION). PROCESSING THIS INFORMATION ALLOWS USERS TO ACCESS THE SITE AND ENJOY FULLY OF ITS FEATURES AND SERVICES. IN ADDITION, THE NAVIGATION DATA MAY BE USED TO VERIFY THAT THE SITE IS WORKING PROPERLY. FROM TIME TO TIME, THE NAVIGATION DATA ARE PROCESSED ANONYMOUSLY FOR STATISTICAL PURPOSES. IT IS UNLIKELY THAT THE NAVIGATION DATA WILL ALLOW THE IDENTIFICATION OF THE PERSON CONCERNED BY THE DATA. HOWEVER, BY THEIR OWN NATURE, THE NAVIGATION DATA MAY ALLOW THE IDENTIFICATION OF USERS IF ASSOCIATED WITH OTHER INFORMATION. THE NAVIGATION DATA DESCRIBED ABOVE ARE STORED ONLY TEMPORARILY IN COMPLIANCE WITH APPLICABLE LAW.

• ORDERS

AT THE TIME OF THE VERIFICATION, THE SITE ASKS USERS TO PROVIDE PERSONAL INFORMATION FOR THE ESSENTIAL PURPOSE OF FACING THEIR PURCHASE ORDERS AND COMPLYING WITH THE CONTRACTUAL OBLIGATIONS (FOR EXAMPLE NAME AND SURNAME, EMAIL ADDRESS, E-MAIL ADDRESS). THIS PERSONAL INFORMATION IS ALSO ESSENTIAL TO ALLOWING CUSTOMER SERVICE TO ASSIST CUSTOMERS WITH REGARD TO YOUR REQUESTS AND FOR ANY RELATED NEEDS, BEFORE OR AFTER SALE (FOR EXAMPLE, RELATING TO THE STATE OF DELIVERY OF THE ORDER OR RETURNS). PERSONAL INFORMATION RELATING TO ORDERS WILL BE KEPT FOR THE TIME NECESSARY TO FULFILL APPLICABLE CONTRACTUAL AND FISCAL AND FINANCIAL REPORTING OBLIGATIONS. THE SITE MAY ALSO VERIFY THE PAYMENT TOOLS USED BY CUSTOMERS FOR PURCHASES ON THE SITE (FOR EXAMPLE, CREDIT CARDS OR DEBIT CARDS, ETC.) MAINLY TO PREVENT FRAUDULENT ACTIVITIES OR UNDER APPLICABLE ANTI-LAUNDERING LAWS. BECAUSE FULL CONFIDENCE IS GRANTED TO THE ENTITIES PROCESSING THIRD PARTY PAYMENTS IN THE VERIFICATION OF PAYMENTS, THE DATA PROCESSORS DO NOT PROCESS NOR ARCHIVE FINANCIAL INFORMATION BELONGING TO CUSTOMERS. FAILURE TO TRANSMIT PERSONAL INFORMATION REQUIRED AT THE TIME OF THE VERIFICATION WILL PREVENT USERS FROM COMPLETING AN ORDER ON THE SITE. ON THE BASIS OF ITS LEGITIMATE INTEREST IN IMPROVING THE RELATIONSHIP WITH CUSTOMERS, THE SITE WILL SEND TO THESE LATEST COMMUNICATIONS VIA E-MAIL WITH SUGGESTIONS ON PRODUCTS, DISCOUNTS, REQUESTS FOR FEEDBACK OR OTHER UPDATES. CUSTOMERS ARE ALWAYS FREE TO UNSUBSCRIBE TO SUCH E-MAIL COMMUNICATIONS (FOR EXAMPLE, BY CLICKING ON THE “UNSUBSCRIBE” LINK AT THE BOTTOM OF EACH E-MAIL).

• REGISTRATION ON THE WEBSITE

WHEN USERS CHOOSE TO REGISTER A PERSONAL SITE ACCOUNT, THEY ARE ASKED TO SUBMIT PERSONAL INFORMATION (EXAMPLE DATE OF BIRTH, GENDER, ETC.). THE SITE CLEARLY INDICATES WHICH PERSONAL INFORMATION IS REQUIRED (OR LESS) TO SET UP A SITE ACCOUNT. USERS MUST PROVIDE TRUE AND ACCURATE PERSONAL INFORMATION AT THE TIME OF REGISTRATION AND ARE INVITED TO KEEP THEIR PERSONAL INFORMATION UP TO DATE (IF CHANGES OCCUR) BY ACCESSING THE PERSONAL ACCOUNT TO MAKE ANY CASE CHANGES. USERS WHO CHOOSE TO ACTIVATE OR ACCESS THEIR SITE ACCOUNT THROUGH A SOCIAL MEDIA SHOULD BE AWARE THAT WHEN LINKING THEIR SITE ACCOUNT TO A SOCIAL MEDIA ACCOUNT, THE SITE COLLECTS CERTAIN PERSONAL INFORMATION THAT THE USER HAS ALREADY THIS SOCIAL MEDIA (FOR EXAMPLE, THE EMAIL ADDRESS AND THE PUBLIC PROFILE ON FACEBOOK). THE OWNERS OF THE DATA PROCESSING DO NOT OVER-UNDERSTAND NOR CONTROL SUCH SOCIAL MEDIA SERVICES OR USER PROFILES ON THESE SERVICES AND DO NOT ESTABLISH THE PRIVACY SETTINGS OR THE RULES REGARDING THE METHOD OF USE OF PERSONAL INFORMATION ABOUT THESE SERVICES. USERS ARE STRONGLY INVITED TO READ ALL THE POLICIES AND INFORMATION REGARDING THE APPLICABLE SOCIAL MEDIA SERVICES IN ORDER TO OBTAIN FURTHER INFORMATION ON THE PROCESSING OF PERSONAL INFORMATION.

• NEWSLETTER AND MARKETING COMMUNICATIONS

ON THE SITE, USERS MAY CHOOSE TO RECEIVE NEWSLETTERS AND COMMERCIAL COMMUNICATIONS. THE SITE ALWAYS COLLECTS THE EXPRESS, FREE AND UNequivocal CONSENT OF USERS BEFORE SENDING NEWSLETTERS AND MARKETING COMMUNICATIONS TO SUCH USERS OR, MORE GENERALLY, BEFORE UNDERTAKING ELECTRONIC MARKETING INITIATIVES DEDICATED TO THEM. IN SUCH CASES, USERS MAY BE INVITED TO PROVIDE PERSONAL INFORMATION IN ADDITION TO THEIR EMAIL ADDRESS (EX. GENDER, COUNTRY OF RESIDENCE, ETC.) TO HAVE PERSONALIZED MARKETING COMMUNICATIONS AND NEWSLETTERS FOR THE USER PROFILE. USERS CAN ALWAYS EASILY REVOKE THEIR CONSENT TO THE RECEPTION OF NEWSLETTERS AND COMMERCIAL COMMUNICATIONS IN THE FOLLOWING WAYS: THROUGH THEIR ACCOUNT SETTINGS; BY CLICKING ON THE ‘UNSUBSCRIBE’ LINK IN ANY OF SUCH E-MAIL; CONTACTING OUR CUSTOMER SERVICE. WITH REGARD TO THE PERSONAL INFORMATION OF NON-REGISTERED USERS WHO HAVE CHOSEN TO RECEIVE NEWSLETTERS AND MARKETING COMMUNICATIONS, THE DATA CONTROLLER IS VIRILI DI RAGOSTA DANIELE.

• PROFILING

UNDER THE USER’S EXPRESS CONSENT, THE NEWSLETTER AND MARKETING COMMUNICATIONS MAY BE ADAPTED TO THE USER “PROFILE”, BASED ON THE PERSONAL INFORMATION THAT THE SITE COLLECTS OR RECEIVES ABOUT THE USER. AS REGARDS THE CUSTOMERS OF THE SITE, IT IS IN THE SITE’S LEGITIMATE INTEREST TO PROCESS PERSONAL INFORMATION TO OFFER MORE INTERESTING PRODUCTS, IMPROVE THE SITE AND CUSTOMIZE THE PRODUCTS OFFERED ON THE SITE. THE MAIN PURPOSE OF THE PROFILING IS TO OFFER PRODUCTS, SERVICES AND INITIATIVES MORE RESPONDING TO TASTE, PURCHASING HABITS AND INTERESTS OF USERS AND CUSTOMERS. PERSONAL INFORMATION MAY ALSO BE USED FOR THE PURPOSES OF REMARKETING, RETARGETING OR PROFILING, ALSO THROUGH THIRD PARTIES (EX. SOCIAL NETWORK, ETC.). NEITHER THE SITE NOR THE DATA PROCESSING HOLDERS WILL EVER PERFORM PROFILING ACTIVITIES RELATING TO CHILDREN.

COOKIES

INFORMATION RELATING TO COOKIES USED ON THE SITE IS AVAILABLE AT THE FOLLOWING LINK: COOKIE POLICY.

SHARING AND TRANSFER OF PERSONAL INFORMATION

THE OWNERS OF THE DATA PROCESSING MAY TRANSFER THE PERSONAL INFORMATION OF THE CUSTOMERS TO PRIMARY THIRD PARTY SUPPLIERS, AS “PERSONS RESPONSIBLE FOR THE PROCESSING OF THE DATA” (THE “RESPONSIBLE”), IN ORDER TO PERFORM THE BUSINESS OPERATIONS NECESSARY TO FULFILL THEM. DATA CONTROLLERS WILL DO THEIR BEST TO ENSURE THAT ALL CONTROLLERS APPLY THEIR BEST SECTOR PRACTICES TO PROTECT PERSONAL INFORMATION AND THAT THEY DO NOT USE PERSONAL INFORMATION FOR PURPOSES OTHER THAN THOSE AGREED WITH THE DATA CONTROLLERS. FOR EXAMPLE, DATA PROCESSING OWNERS MAY SHARE PERSONAL INFORMATION WITH THE FOLLOWING CATEGORIES OF RESPONSIBLE:

• • COURIERS AND POSTAL OPERATORS;

• • ORDER AND DEPOSIT PROCESSING CENTERS;

• • ADVERTISING, DIGITAL, MARKETING AND SOCIAL MEDIA AGENCIES;

• • IT SERVICE PROVIDERS; CUSTOMER SUPPORT SERVICE PROVIDERS;

• • PAYMENT SERVICE PROVIDERS. PERSONS, COMPANIES OR PROFESSIONAL FIRMS THAT PROVIDE ASSISTANCE AND ADVICE TO THE HOLDERS IN ACCOUNTING, ADMINISTRATIVE, LEGAL, TAX, FINANCIAL MATTERS;

• • SUBJECTS, BODIES OR AUTHORITIES TO WHICH IT IS OBLIGATORY TO COMMUNICATE PERSONAL DATA FOR THE PURPOSE OF COMPLIANCE, ABUSE OR FRAUD, OR BY ORDER OF THE AUTHORITIES

IN SUCH CASES, THE SHARING OF PERSONAL INFORMATION WITH THE MANAGERS IS NECESSARY TO ALLOW THE DATA PROCESSORS TO FULFILL THEIR CONTRACTUAL OBLIGATIONS AND, ALSO, TO IMPROVE THE PRODUCTS AND SERVICES OF THE SITE. USERS MAY REQUEST AN UP-TO-DATE LIST OF MANAGERS INVOLVED IN THE PROCESSING OF PERSONAL INFORMATION RELEVANT TO THE SITE’S ACTIVITIES BY WRITING AN E-MAIL TO: PRIVACY@VIRILI.EU DATA PROCESSING OWNERS MUST ALWAYS RESERVE THE RIGHT TO DISCLOSE PERSONAL INFORMATION ABOUT USERS PROVIDED BY LAW (FOR EXAMPLE, IN RESPONSE TO REQUESTS FOR APPLICATION OF THE LAW) AND WHERE NECESSARY TO PROTECT THE RIGHTS OF THE DATA CONTROLLERS AFFILIATES OR THIRD PARTIES. IN ADDITION, PERSONAL INFORMATION MAY BE MADE NOTICE TO OTHER COMPANIES WITHIN THE SAME GROUP OF THE DATA PROCESSING HOLDERS OR TO THIRD PARTIES IN THE EVENT OF A BUSINESS RESTRUCTURING PROCESS, IN FULL COMPLIANCE WITH APPLICABLE LAW. IN ALL OTHER CASES, THE SHARING OF PERSONAL INFORMATION WILL BE SUBJECT TO THE PRELIMINARY AND EXPRESS CONSENT OF THE USER, UNLESS THE PROCESSING IS ALLOWED UNDER AN ALTERNATIVE LEGAL BASIS. DATA PROCESSING OWNERS WILL NOT TRANSFER ANY PERSONAL INFORMATION OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA), UNLESS THE USER HAS EXPRESSLY AUTHORIZED SUCH TRANSFER OR THE TRANSFER OF PERSONAL INFORMATION OUTSIDE THE EEA IS PERMITTED BY THE GDPR ON ‘OTHER LEGAL BASIS.

PROCESSING METHODS AND SECURITY MEASURES

THE PERSONAL INFORMATION OF USERS IS PROCESSED BY THE HOLDERS OF THE DATA PROCESSING WITH COMPUTER, AUTOMATED AND ELECTRONIC TOOLS AND, IN LIMITED CASES, USING DOCUMENTAL MEANS. IN COMPLIANCE WITH THE RGPD, SPECIFIC SECURITY MEASURES HAVE BEEN IMPLEMENTED TO PREVENT THE LOSS OF DATA, ILLEGAL OR INCORRECT USE AND UNAUTHORIZED ACCESS. ONLY THE AUTHORIZED EMPLOYEES OF THE DATA PROCESSING OWNERS AND THE AUTHORIZED EMPLOYEES OF THE THIRD-PARTY SUPPLIERS, AS APPROVED ON BEHALF OF THE DATA PROCESSING OWNERS, HAVE ACCESS TO PERSONAL INFORMATION RELATING TO THE ACTIVITIES OF THE SITE. DATA PROCESSING AGREEMENTS ARE IN BEING WITH THOSE IN CHARGE TO ENSURE THAT THEY ALWAYS SATISFY THE LEVEL OF SECURITY REQUIRED BY THE RGPD DURING THE PROCESSING OF PERSONAL INFORMATION RELATING TO THE ACTIVITIES OF THE SITE. EVEN IF THE SITE TAKES PRIMARY SECURITY MEASURES TO PREVENT THE LOSS, DESTRUCTION OR DISSEMINATION OF PERSONAL INFORMATION, AT THE SAME TIME IT CANNOT EXCLUDE THE SECURITY RISKS THAT ARE NATURALLY ASSOCIATED WITH THE ONLINE TRANSMISSION OF DATA. YOU ACCEPT THE RISKS INHERENT WITH THE PROVISION OF PERSONAL INFORMATION ON THE INTERNET AND WILL NOT HOLD THE SITE RESPONSIBLE FOR ANY SECURITY VIOLATIONS, UNLESS SUCH VIOLATION IS DUE TO NEGLIGENCE OR MALICE OF THE SITE.

STORAGE OF PERSONAL INFORMATION

THE DATA PROCESSING HOLDERS WILL KEEP THE PERSONAL INFORMATION FOR ALL THE TIME NECESSARY TO PROVIDE USERS AND CUSTOMERS WITH THE REQUIRED SERVICES OR TO FULFILL THE LEGAL OR FISCAL OBLIGATIONS OR FOR THE MINIMUM PERIOD PRESCRIBED BY THE LAW. IN ORDER TO DETERMINE THE APPROPRIATE RETENTION PERIOD FOR PERSONAL INFORMATION STORED BY THE SITE WITH THE USER’S CONSENT, THE DATA PROCESSING HOLDERS WILL TAKE ACCOUNT OF MULTIPLE FACTORS TO ENSURE THAT THE PERSONAL INFORMATION IS NOT KEPT FOR A LONGER PERIOD NECESSARY OR APPROPRIATE. THESE CRITERIA WILL ALSO INCLUDE:

• • THE PURPOSE FOR WHICH THE SITE HOLDS PERSONAL INFORMATION;

• • LEGAL, TAX AND REGULATORY OBLIGATIONS RELATED TO SUCH PERSONAL INFORMATION;

• • THE TYPE OF RELATIONSHIP WITH THE USER OR CUSTOMER CONCERNED (HOW FREQUENTLY THE USER ACCESSES THEIR SITE ACCOUNT, IF USERS CONTINUE TO RECEIVE MARKETING COMMUNICATIONS, HOW REGULARLY THEY BROWSE OR PURCHASE ON THE SITE, ETC.);

• • ANY SPECIFIC USER REQUEST RELATED TO THE DELETION OF PERSONAL INFORMATION;

• • LEGITIMATE BUSINESS INTERESTS.

THE SITE WILL PROMPTLY DELETE OR ANONYMOUS PERSONAL INFORMATION THAT IS NO LONGER REQUIRED OR KEPT UNDER THE LAW.

CONNECTION TO THIRD PARTY WEBSITES OR PLATFORMS

THE SITE MAY CONTAIN BANNERS, ADVERTISING MESSAGES AND OTHER LINKS TO THIRD PARTY WEBSITES OR PLATFORMS. DATA PROCESSING OWNERS CANNOT CONTROL OR BE DEEMED OWNERS FOR THE CONDUCT OF SUCH WEBSITES OR THIRD PARTY PLATFORMS IN RELATION TO PRIVACY LAW. USERS ARE INVITED TO READ THEIR PRIVACY POLICY TO VERIFY HOW THEY COLLECT AND PROCESS PERSONAL INFORMATION.

USERS’ RIGHTS

USERS HAVE THE RIGHT TO RECEIVE CONFIRMATION REGARDING THE POSSIBLE POSSESSION OF THE DATA PROCESSING OF PERSONAL INFORMATION ON THEIR ACCOUNT. IN THIS CASE, UNDER THE RGPD, USERS ALSO HAVE THE RIGHTS TO:

• • BE INFORMED ABOUT THE COLLECTION AND USE OF YOUR PERSONAL INFORMATION;

• • ACCESS THEIR PERSONAL INFORMATION AT NO COST; OBTAIN THE CORRECTION OR COMPLETION OF INACCURATE OR INCOMPLETE PERSONAL INFORMATION;

• • OBTAIN THE DELETION OF PERSONAL INFORMATION (“THE RIGHT TO BE FORGOTTEN”);

• • UNDER SPECIFIC CONDITIONS, OBTAIN RESTRICTION OR SUPPRESSION OF YOUR PERSONAL INFORMATION;

• • OBTAIN AND RE-USE YOUR PERSONAL INFORMATION FOR YOUR OWN PURPOSES AMONG DIFFERENT SERVICES WHEN PROCESSING IS BASED ON A CONTRACT OR CONSENT AND IS PERFORMED AUTOMATICALLY (“THE RIGHT TO DATA PORTABILITY”);

• • UNDER SPECIFIC CONDITIONS, OBJECT TO THE PROCESSING OF THEIR PERSONAL INFORMATION;

• • OPPOSE AT ANY TIME TO THE USE OF YOUR PERSONAL INFORMATION FOR THE PURPOSES OF “PROFILING” OR “AUTOMATED DECISION-MAKING”. THE RIGHT TO SUBMIT COMPLAINTS REGARDING THE COLLECTION AND PROCESSING OF PERSONAL INFORMATION TO THE COMPETENT SUPERVISORY AUTHORITY;

• • THE RIGHT TO WITHDRAW THE CONSENT TO THE PROCESSING OF PERSONAL DATA AT ANY TIME.

USERS CAN CONTACT THE SITE FOR ANY REQUEST AND TO EXERCISE THEIR RIGHTS IN THE FIELD OF PRIVACY AT THE FOLLOWING EMAIL ADDRESS: PRIVACY@VIRILI.EU

CHANGES TO THIS PRIVACY POLICY

POSSIBLE FUTURE CHANGES TO THIS PRIVACY POLICY WILL BE PUBLISHED ON THE SITE AND, IF CASE, NOTIFIED TO USERS VIA E-MAIL. USERS ARE INVITED TO READ THIS PRIVACY POLICY FREQUENTLY TO CHECK FOR ANY UPDATES OR CHANGES.

LAST UPDATE: FEBRUARY 2021