Privacy Policy for Users

Reklame S.r.l., having its registered office in via E. Pistelli n. 16, 50135, Firenze (Italy), VAT no. and fiscal code no. 06207100485 (hereinafter the “Data Controller”), owner of the website www.reklame.it (hereinafter the “Website”), as the data controller of personal data of the users who browse and are registered on the Website (hereinafter the “Users”) provides the following privacy policy according to Article 13 of EU Regulation 2016/679 dated 27 April 2016 (hereinafter, “Regulation” or “Applicable Regulations”).

This Website and any services offered through the Website are reserved for individuals who are 18 years and over. Therefore, the Data Controller does not collect personal data relating to individuals under 18 years of age. Upon request of the Users, the Data Controller will promptly delete all personal data that has been involuntarily collected and related to subjects under the age of 18.

The Data Controller takes the utmost account of its Users’ right to privacy and protection of personal data. For any information related to this privacy policy, Users may contact the Data Controller at any time, using the following methods:

Sending a registered letter with return receipt to the registered offices of the Data Controller (Via E. Pistelli n. 16, 50135, Firenze (Italia));
Sending an electronic mail message to the address [email protected]

Users may also contact the Data Protection Officer (DPO) of the Data Controller, the contact data of which is reported below: Italian company Shibumi S.r.l. in the designated person of Avv. Anna Maria Lorito: [email protected]

1. Processing purposes

The personal data of the Users will be processed lawfully by the Data Controller pursuant to Article 6 of the Regulation for the following processing purposes:

a) contractual obligations and supply of the services: to allow surfing of the Website by the User and to execute the Website Terms of Use, which are accepted by the User during registration to the Website and/or when using the services, and to fulfil the User’s specific requests. Pursuant to the provisions of the Website Terms of Use, the User’s personal data (i.e. name, surname, e-mail address, date of birth, gender and residence postal code) will be processed by the Data Controller for marketing purposes (sending advertising material, direct sales, commercial communication), so that the Data Controller can contact the User via e-mail, telephone (landline and/or mobile phone, with automated calling or communication systems with and/or without the intervention of an operator) and/or SMS to propose to the User the purchase of products and/or services offered by the Data Controller and/or third party companies, to present dedicated offers, promotions and commercial opportunities.

The legal basis for this purpose of processing is the consent given by the User (art. 6 let. a) of the Regulation), who may at any time withdraw the consent given by making a request to the Data Controller in the manner indicated in paragraph 4 below. The withdrawal of consent does not affect the lawfulness of processing based on consent before revocation.

The User may also easily oppose the further sending of promotional communications via email by clicking on the appropriate link for the withdrawal of consent, which is included in each promotional email.

The Data Controller informs that, following the exercise of the right to object the sending of promotional communications via email, it is possible that, for technical and operational reasons (e.g. formation of contact lists already completed shortly before the receipt by the Data Controller of the request for opposition) the User continues to receive some further promotional messages. Whether the User continue to receive promotional messages after 48 hours from the exercise of the right to object, please report the problem to the Data Controller, using the contacts indicated in paragraph 4 below.

b) Legal obligations, or to fulfil obligations provided by the law, an authority, a regulation or European legislation. The legal basis for this processing purpose is the fulfilment of a legal obligation to which the Data Controller is subject (Art. 6, letter c) of the Regulations).

2. Processing methods and data retention times

The Data Controller will process the personal data of Users using manual and IT tools, with logic strictly related to the purposes themselves and, in any case, in order to guarantee the security and confidentiality of the data.

The personal data of Website Users will be retained for the time strictly necessary to carry out the main purposes explained in paragraph 1 above (and therefore until the completed execution of the services requested by the User pursuant to the Website Terms of Use) or, in any case, as necessary for the protection in civil law of the interests of both the Users and the Data Controller and/or in compliance with a legal obligation or an order from an Authority.

3. Transmission and dissemination of data

The employees and/or collaborators of the Data Controller who are in charge of carrying out Website maintenance may become aware of the personal data of the Users. These subjects, who have been instructed by the Data Controller accordingly to article 29 of the Regulation, will process the User’s data exclusively for the purposes indicated in this policy and in compliance with the provisions of the Applicable Law.

The personal data of the Users may also be disclosed to third parties who may process personal data on behalf of the Data Controller as “Data Processors“, such as, for example, IT and logistic service providers functional to the operation of the Website, outsourcing or cloud computing service providers, professionals and consultants.

Users have the right to obtain a list of any data controllers appointed by the Data Controller, making a request to the Data Controller in the manner indicated in paragraph 4 below.

4. Rights of the Data subjects

Users may exercise their rights granted by the Applicable Law by contacting the Data Controller as follows:

Sending a registered letter with return receipt to the registered offices of the Data Controller (Via E. Pistelli n. 16, 50135, Firenze (Italia));
Sending an electronic mail message to the address [email protected]

Pursuant to Applicable Regulations, the Data Controller informs that Users have the right to obtain indication (i) of the origin of personal data; (ii) the purposes and methods of the processing; (iii) the logic applied in the event of processing carried out with the aid of electronic instruments; (iv) of the identification details of the data controller and processors; (v) the subjects or categories of subjects to whom the personal data may be communicated or who may come to aware of them as processors or agents.

Furthermore, Users have the right to obtain:

a) Access, updating, rectification, or, when interested, integration of data;

b) The cancellation, transformation into anonymous form or the blockage of data processed in breach of the law, including data that does not need to be stored in relation to the purposes for which the data was collected or subsequently processed;

c) Certification to the effect that notification has been supplied of operations as per letters a) and b), as regards their content, to those to whom the data was communicated or disseminated, except for the case where notification proves impossible or requires the use of means clearly disproportionate to the right being protected.

Moreover, the Users have:

a) The right to revoke consent at any time, if the processing is based on their consent;

b) The right to data portability (the right to receive all personal data concerning them in a structured format, commonly used and readable by automatic device), the right to limit processing of personal data and right of deletion (“the right to be forgotten”);

c) The right to oppose to:

i) In whole or part, for legitimate reasons, the processing of personal data relating to you for legitimate reasons even pertinent to the purpose of collection;

ii) In whole or part, the handling of personal data for the purpose of sending advertising or sales materials or for the carrying out of market research or for commercial communication purposes;

iii) If personal data is processed for direct marketing purposes, at any time, to the processing of data for this purpose, including profiling in so far as it is related to such direct marketing.

d) If it is deemed that the processing concerning their personal data violates the Regulation, the right to lodge a complaint with a Supervisory authority (in the Member State in which they usually reside, in the one in which they work or in the one in which the alleged violation has occurred). The Italian Supervisory Authority is the Data Protection Authority, with registered offices in Piazza Venezia No. 11, 00187 – Rome (http://www.garanteprivacy.it/).

The Data Controller is not responsible for updating all links viewed in this Privacy Policy, therefore, whenever a link does not work and/or is not updated, the Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to by this link.

Version updated April 21, 2021