TABLE OF CONTENTS
- Definitions used in this Policy
- Data protection principles we follow
- What rights do you have regarding your Personal Data
- What Personal Data we gather about you
- How we use your Personal Data
- How long do we keep your Personal Data
- How can you view, edit or delete your Personal Data
- Who else has access to your Personal Data
- How we secure your data
- Information about cookies
- Contact information
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us (either capitalized or not) – Simonetta Roma/AssuringBusiness Global Sl
DATA PROTECTION PRINCIPLES
We promise to follow the following data protection principles:
- Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
- Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
- Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
- Processing is limited with a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
DATA SUBJECT’S RIGHTS
The Data Subject has the following rights:
- Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
- Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled, please contact us.
- Right for the help of supervisory authority– meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
DATA WE GATHER
Information you have provided us with
This might be your e-mail address, name, company name, business/home/billing address, telephone number etc. – mainly information that is necessary for delivering your expected level of engagement with us which may include obtaining information about or procuring/using a product/service, subscribing you to your chosen mailing lists, or to enhance your customer experience with us. We may also save the information you provide us with in order for you to access member areas, comment or perform other activities on the Site.
Information automatically collected about you
This includes information that is automatically stored by cookies and other session tools, for example, your IP address, your activity history on our Site (if there is any) etc. This information is used to improve your customer experience and to enable us to present relevant information or advertisements. Some of this information is also used to help protect the Site and users against malicious activity. When you use our services or look at the contents of our Site, your activities may be logged.
Publicly available information
We might gather information about you that is publicly available.
When visitors leave comments on the Site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
If you upload images to the Site, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the Site can download and extract any location data from images on the Site.
We use contact forms to make it easy for you to interact with us for example by sending enquiries, requesting information about our products and services or joining a mailing list. Although we will necessarily store and process information from the contact form to be able to deal with the request we will not automatically add these details to our marketing and mailing lists, unless the contact form makes it clear that this will happen as a result of you submitting your information and you confirm your acceptance to this. In any event, you will always have the choice to opt-out of all marketing and mailing lists at any time.
HOW WE USE YOUR PERSONAL DATA
We use your Personal Data in order to:
- provide our service to you. This includes for example registering your membership/account; providing you with products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you in matters concerning your membership/account or communications received from you; and notifying you of changes to any content, terms and services.
- enhance your customer experience;
- enhance protection of the Site and our users against malicious activity;
- fulfil an obligation under law or contract;
- send you relevant promotional communications.
We use your Personal Data on legitimate grounds and/or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:
- to identify you;
- to provide you a product/service or to send/offer you a product/service;
- to communicate for sales, invoicing or other necessary product fulfilment or service engagement.
On the grounds of legitimate interest, we Process your Personal Data for the following purposes:
- to send you personalized offers;
- to administer and analyse our client and Site user base (Site and purchasing behaviour and history) in order to improve the quality, variety, and availability of products/ services and Site structure, function and information offered/provided;
- to conduct questionnaires concerning client satisfaction or other special interest areas.
As long as you have not informed us otherwise, we consider offering you products/services that are similar to your purchasing history/browsing behaviour to be our legitimate interest.
With your consent we Process your Personal Data for the following purposes:
- to send you newsletters and promotional offers;
- for other purposes we have asked your consent for.
We Process your Personal Data in order to fulfil obligations arising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised.
HOW LONG DO WE KEEP YOUR DATA?
We are required to save your billing information for accounting and tax purposes for six (6) years.
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our Site as members, we also store the personal information they provide in their user profile and retain this data indefinitely until you choose to delete that data and disable your account. All registered members can see, edit, or delete their personal information at any time (except they cannot change their username). Site administrators can also see and edit that information. We reserve the right to review and disable members that have not accessed the Site membership area for more than a year but if we do this we will notify you of our intent to do so before it happens.
Other information gathered about you will only be maintained for a period reasonably necessary for the obligation to service your chosen level of engagement, but not longer than one year unless you provide permission to do so. Prior to this time limit will seek permission to use and store the data for a further year. If you do not give repeated permission the data that we are not obligated by law to retain will be deleted from our systems or anonymised.
We might process your Personal Data for additional purposes that are not mentioned here but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
- the link between purposes, context and nature of Personal Data is suitable for further Processing;
- the further Processing would not harm your interests and;
- there would be appropriate safeguards for Processing.
HOW YOU CAN VIEW OR DELETE YOUR PERSONAL DATA
If you have an account/membership on this Site, or have left comments, you can request to receive an exported file of the Personal Data we hold about you, including any data you have provided to us. You can also request that we erase any Personal Data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes. Please use our Member’s Page (you need to be logged in) to edit your details, or visit Privacy Tools to view or delete your Personal Data, or email our admin team and we will process your request for you.
WHO ELSE CAN ACCESS YOUR PERSONAL DATA
We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience. We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We share your data with:
Our processing partners:
- GoDaddy.com LLC, 14455 N. Hayden Rd., Ste. 226, Scottsdale, AZ 85260 USA; GoDaddy hosts our Site on servers located within the European Economic Area («EEA»). For the contractual terms applicable to how they protect this information as Data Processors, please refer to their Data Processing Addendum.
Visitor comments may be checked through an automated spam detection service.
We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it. If any portion of Simonetta Roma brand is sold, your Personal Data may be part of the business assets that we transfer.
We also reserve the right to use, disclose and share your Personal Data to investigate, prevent or take action with respect to any potential or actual crime, circumstances that threaten the safety, rights and freedoms of any person, violations of our Terms & Conditions or as otherwise required by law.
HOW WE SECURE YOUR DATA
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks deploying various technical and operational controls with this objective.
Even though we try our best we cannot guarantee the security of information. However, we promise to notify suitable authorities of known data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account/membership with us, note that you have to keep your username and password secret and use passwords that are considered difficult to guess or hack.
COOKIES AND OTHER TECHNOLOGIES WE USE
A cookie is a tiny data file stored on your computer. Cookies store information that is used to help make websites work. You can control your cookies at the browser level and we also provide tools on our Site to enable your choice to opt-in or opt-out of cookie use. Choosing to disable cookies may hinder your use of certain functions.
- Necessary cookies – these cookies are required for you to be able to use some important features on our Site, such as logging in.
- Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms, so you don’t have to re-enter this information next time when commenting.
- Analytics cookies – these cookies are used to track the use and performance of our Site and services
- Advertising cookies – these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to website functionality provided by the other organisation.
You can remove cookies stored in your computer via your browser settings. We also provide tools on our Site to enable you to opt-in or opt-out of cookie use. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
Specifically, we use these cookies (cookie names):
(ads/ga-audiences) via Google Adwords to help serve relevant ads based on your browsing history.
(AWSALB) via McAfee Secure which is used to enable users to validate our Site security credentials and assess potential risks. They in turn use Amazon Web Services to host their system. This cookie allows them to deliver their service seamlessly from multiple services using a load balancer, so the cookie simply records which server cluster is serving you.
(ginger-cookie) via Ginger – EU Cookie Law by Manafactory that is used to provide cookie notification and opt-in/opt-out options for Site users.
(slimstat_tracking_code) via Slimstat which is a website tracking and analytics tool to help us understand user behaviour and improve the performance of our website.
Phone: +34 91399 6200
Phone: +34 632 28 6546
Last modification was made 24 November 2021.