PRIVACY POLICY

Thank you for your interest in the Santillo marketplace www.santillo1970.com (hereinafter “Marketplace”). We respect your privacy and will collect and process your personal data in compliance with the applicable legal requirements at all times. We will never rent or sell your personal data for marketing or other purposes.

This privacy policy explains what kind of personal data we collect when you use the Marketplace and how we handle such personal data.

1. DATA CONTROLLER, DATA PROTECTION OFFICER AND REPRESENTATIVE IN THE EUROPEAN UNION (EU)

1.1 Joint data controllers within the meaning of the European General Data Protection Regulation (GDPR) are Casa Santillo s.r.l., Traversa Crotone, 18 – 88100 Catanzaro, Italia; phone: +39 0961 028459, e-mail: info@santillo1970.com  (jointly hereinafter “Santillo”“we”“our”“us” etc.).

1.2 Our data protection officer can be contacted under Data Protection Officer, Casa Santillo s.r.l., Traversa Crotone, 18 – 88100 Catanzaro, e-mail info@santillo1970.com.

1.3 Our representative in the European Union (EU) is Casa Santillo s.r.l. at Traversa Crotone, 18 – 88100 Catanzaro, Italia, email info@santillo1970.com.

2. WHAT IS PERSONAL DATA

Personal data means any information relating to you, provided that you can be identified or are identifiable (directly or indirectly) with such information. For example, personal data includes your name, address, phone, fax or mobile phone number as well as your e-mail address. Personal data does not include information of a general nature that does not identify you; for example, the number of users of the Marketplace.

3. WHAT TYPES OF PERSONAL DATA WE COLLECT

You may generally visit the Marketplace without providing information to us which directly identifies you. However, please be aware that in this case you may not be able to use certain parts of the Marketplace or particular services offered by us.

3.1 WEB SERVER PROTOCOLS (INCLUDING IP ADDRESS)

When you visit and use the Marketplace our web server, due to technical reasons, automatically collects your IP address, the date and time of your visit of the Marketplace, the sites visited on the Marketplace, the referrer website, your browser type (e.g. Microsoft Explorer or Mozilla Firefox), your operating system (e.g. Microsoft Windows 10), the domain name and the address of your internet access provider. The company Web Service Internet Solutions S.r.l. (2open.it) as supplier of the servers and connectivity for the services offered to the public through the Internet, has been designated as the controller in accordance with Article 28 of EU Regulation no. 2016/679 and of the art. 29 of the Code regarding the protection of personal data.

3.2 PERSONAL DATA SUBMITTED BY YOU IN THE FRAMEWORK OF OUR SERVICES

(a) We collect personal data that you have provided to us on a voluntary basis for the purposes to provide, operate and manage the Marketplace as well as to provide our services in accordance with our user agreement (https://www.santillo1970.com/terms-and-condition-of-use/).

  • For example, we collect (a) your user name and e-mail address when you create an user account and register for the Marketplace; (b) your name, delivery address, phone number, e-mail address, bank respectively payment information when you order a product via the Marketplace; (c) your name, address, phone number, e-mail address, bank account details and tax status respectively tax file number when you sell products via the Marketplace; and (d) your e-mail address when you complete a form or send us an e-mail. When we collect your personal data, we inform you whether the designation of certain personal data is compulsory or optional and of the possible consequences that arise in case of the absence of a designation.
  • In addition, we collect the data which you have provided to us through the visit and use of the Marketplace as well as our services, e.g. your purchases and sales history, favorited and earmarked items on the Marketplace, your movement and actions taken on the Marketplace as well as the content and details of messages send or received via our Newsletter service. Provided that you log in via a social media single sign-on we collect your personal data from the respective social media platform which you have made publically available.

(b) Provided that you have given us your consent, we further collect your e-mail address when you register for our newsletter and promotional messages.

4. HOW WE PROCESS YOUR PERSONAL DATA

4.1 We basically process your personal data in order to provide and operate the Marketplace and render our services to you in accordance with our user agreement (https://www.santillo1970.com/terms-and-condition-of-use/), in particular, (a) to facilitate and coordinate sales and purchases via the Marketplace; (b) to provide you, to the extent possible and reasonable, with a smoothly and accurately functioning Marketplace by monitoring and maintaining its performance (in particular, detecting and resolving issues and errors); (c) to enable and process communication with our support service in case of queries via live chat, e-mail, web forum, social media or phone; and (d) to enable you to communicate and/or exchange ideas with other users via the Marketplace through message boards, chatrooms or other interactive online forums and/or to provide reviews regarding the products offered via the Marketplace.

This processing is necessary for the performance of our contract.

With respect to your communication with other users via our message boards, chatrooms or other interactive online forums as set out under item 4.1 lit. d above please be aware that if you post a comment on a message board or in a chatroom, this information will be made available to the public in an online environment. Each user is solely responsible for its posted comments. If you choose to use any such interactive area, please be aware that this environment and all personal data posted there is publicly accessible. We cannot control how other visitors of the Marketplace will use this information. In particular, we are unable to prevent you from receiving unsolicited messages from third parties.

4.2 Further we may process your personal data for the purpose of preventing fraud on the Marketplace.

This processing is necessary for the purpose of our legitimate interests. Our legitimate interests in this context are the protection of the integrity of the Marketplace, our services, our system as well as our users.

4.3 Further, we process your personal data for our endeavors (a) to provide you with an optimal and meaningful user experience on the Marketplace and within our services; and (b) to improve and optimize the Marketplace and our services, the layout and content of the Marketplace.

This processing is necessary for the purpose of our legitimate interests. Our legitimate interests are to provide an optimal and meaningful user experience on the Marketplace which fulfils your expectations and needs as well as our commercial interests.

4.4 Provided that you have given us your consent, we will further use the personal data collected for the provision and optimisation of our marketing measures via e-mail, in particular, the provision of our newsletter and other promotional messages on Santillo events, services, products and/or special offers. You may withdraw your consent at any time with future effect.

You may, at any time, opt out from receiving such communications by following the instructions included in each e-mail or contacting Santillo customer service e.g. by sending us an e-mail to the contact details set out under item 1 above or.

This processing is based on consent given by you.

4.5 Further, we may process your web server information (cf. item 3.1 above) in cooperation with your internet access provider and/or local authorities in cases of a system misuse in order to investigate and identify the originator of such system misuse.

This processing is necessary for the purpose of our legitimate interests. Our legitimate interests in this context are the protection of the integrity of the Marketplace, our services, our system as well as our users.

5. TRANSFER OF PERSONAL DATA

Your personal data is very important and helpful for us to provide and optimize our services and the Marketplace. We do not share personal data with any third party, unless this (a) is necessary to fulfil our services and/or the provision of the Marketplace; (b) is permitted by applicable law; or (c) has been agreed by you. Insofar, we share personal data with third parties within the scope specified below:

5.1 In order to properly render our services in form of facilitating sales respectively purchases made between users via the Marketplace, we have to share your name, the delivery address and phone number on behalf of the selling user with third-party service providers respectively fulfillers for manufacturing, printing, logistics or processing services. Please be aware that the provision of such personal data solely takes place to process the sale respectively purchase of a product made between users via the Marketplace. Under no circumstances we provide such personal data to these service providers respectively fulfillers for marketing purposes.

This processing is necessary for the performance of our contract.

5.2 In case third-parties address Santillo with the allegation that content submitted by you onto the Marketplace infringes applicable law, intellectual property rights of the third party (including without limitation, copyrights and ancillary copyrights, patents, trademarks, company symbols, work titles, or designs) or any other rights of the third party (including without limitation, the general right of privacy and the right of one’s own image), we are entitled pursuant to our user agreement to provide the third party with your name, address and/or information relating to the content which has been objected, in order to enable the third party to claim such rights vis-à-vis you directly.

This processing is necessary for the performance of our contract.

5.3 Further, we are entitled to outsource the processing of personal data (completely or partially) to external service providers which are acting on our behalf as data processors in the meaning of Art. 4 no. 8 GDPR. When such third-party service providers are located outside of the European Union (EU) or the European Economic Area (EEA), we will put in place appropriate safeguards in accordance with the requirements set by law and data protection authorities to ensure that your personal data is duly protected.

In particular, we use external service providers for the following purposes in the framework of providing and operating the Marketplace as well as our respective services:

  • To host the Marketplace and to store its back-end database.
  • To enable and provide communication via live chat.
  • To enable and provide the technical basis for user product reviews.
  • To detect, identify and prevent fraudulent use of the Marketplace.
  • To monitor the performance of the Marketplace as well as to detect and solve issues and errors on the Marketplace.
  • To provide customer relationship management, in particular, customer and product support services for the Marketplace as well as the identification and resolve of customer support issues via live chat, e-mail, web forum, social media or phone.
  • To provide data reporting and enable analysis for our internal business purposes.
  • To optimize the typography on the Marketplace.
  • To organize and manage internal business goals effectively and efficiently.
  • To optimize and enhance our budgeting, corporate performance, analysis and reporting.
  • To provide payment services for our users.
  • To provide marketing and marketing optimization services.

6. HOW WE KEEP PERSONAL DATA SECURE

While we take all necessary and reasonable steps to keep your information secure, no security system is impenetrable and, due to the inherent nature of the internet, we cannot guarantee that information, during transmission through the internet or while stored on our systems or otherwise, will be absolutely safe from unauthorized access by others. Your payments are handled over an encrypted connection or via a secure third-party data processor. Access to personal data on our databases is subject to reasonable technical safeguards and is restricted to authorized staff on a strict need-to-know basis. Further, we require our external service providers with access to personal data to sign data processing agreements (Art. 28 GDPR) that require them to take the necessary and reasonable steps to protect the personal data provided to them.

7. STORAGE TIME

We will only store your personal data as long as necessary to fulfil the purposes for which they were collected or – where the law provides for longer retention periods – for the duration of the retention period required by law. After that your personal data will be deleted.

8. WEB ANALYSES SERVICES, COOKIES AND OTHER TECHNOLOGIES

8.1 We want to provide you with an optimal and meaningful user experience. Therefore, we use cookies and other technologies on the Marketplace and within our services (a) in order to better understand how our users use the Marketplace and our services; (b) for the optimization of the Marketplace and our services; (c) in order to provide and maintain, to the extent possible and reasonable, a smoothly and accurately functioning Marketplace; as well as (d) for marketing purposes and market research.

Cookies and other technologies help us in many ways to make your visit of the Marketplace more enjoyable and meaningful.

Cookies are text information files that our web server sends to and places on your computer when you visit the Marketplace. Most browsers accept cookies automatically, but can be configured in their settings not to accept cookies or to indicate when a cookie is being sent. For more information please check the help menu of your browser. Some or all of our cookies may be disabled or deleted later. You can either disable our cookies via the browser settings or via the opt-out possibilities as set out in the table under item 8.3 below. Please note that you do not have to accept our cookies in order to use the Marketplace. However, if you opt out of the cookie function, some areas and functions of the Marketplace may be disabled.

8.2 We use the following types of cookies on the Marketplace for the following purposes:

(a) Technical cookies

Cookies that allow the navigation through the Marketplace and the use of different options or services that exist in it, such as allowing the communication of data, identifying your user account, accessing restricted access Marketplace areas, storing products from orders, completing the purchase process of an order or storing content for the broadcast of videos and sound and share content.

This processing is necessary for the performance of our contract.

(b) Customization cookies

Cookies that allow the access to the Marketplace with some general predetermined characteristics according to several criteria out of the user’s device, such as the language, the web browser, the regional settings etc.

This processing is necessary for the performance of our contract.

(c) Advertising cookies

Cookies that allow Santillo to analyse and manage the information related to the advertisements displayed to each user on the Marketplace. Those cookies allow to manage, in the most efficient way, the advertising spaces of the Marketplace pursuant to different information such as the edited content or the frequency in which such advertisements are displayed.

This processing is necessary for the purpose of our legitimate interests. Our legitimate interests are to provide a user-friendly and meaningful Marketplace which fulfils your expectations and needs as well as our commercial interests.

(d) Conduct or behavior advertising cookies

These cookies store information on the behavior of users obtained through the continuous observation of their browsing habits, which allows the development of a specific profile in order to display different advertisements based on such profiling process.

It is also possible that by visiting a website or by opening an e-mail where an advertisement or promotion about our services is displayed, a cookie will be installed in your browser that will be useful to show to the user some other advertisements related to the searches that it has carried out, to develop a control of our advertising in connection, for example, with the number of times each advertisement is displayed, where or at what time it is displayed etc.

This processing is necessary for the purpose of our legitimate interests. Our legitimate interests are to provide a user-friendly and meaningful Marketplace which fulfils your expectations and needs as well as our commercial interests.

(e) Third-party analytics cookies

Together with our server logs and other web analysis programs, analytical cookies enable Santillo to ascertain the total number of users visiting the website and the most popular areas. Thanks to them, Santillo can obtain information to improve browsing and offer a better service to users.

This processing is necessary for the purpose of our legitimate interests. Our legitimate interests are to provide a user-friendly and meaningful Marketplace which fulfils your expectations and needs as well as our commercial interests.

(f) Third-party social networks cookies

If you interact with the content of the Marketplace, third-party cookies may also be installed (for example, by clicking on social media buttons or viewing videos housed on other websites). Third-party cookies are those established by a domain different to the Marketplace and subject to the relevant social network’s policies.

This processing is necessary for the purpose of our legitimate interests. Our legitimate interests are to provide a user-friendly and meaningful Marketplace which fulfils your expectations and needs as well as our commercial interests.

8.3 In particular, we use the following third-party services which use cookies and other technologies. If you do not agree to this use, you may deactivate these services by refusing to accept the cookies in your browser. You may also deactivate the service by clicking on the opt-out link or using other opt-out possibilities. For the opt-out links and other opt-out possibilities, please see the column “Opt-out” in the table below. You will find further information about the services in the related privacy policies, accessible via the links provided in the section “Privacy and/or security policy” in the table below. The table further displays under “Countries where data is transferred and appropriate safeguards” to which country the data is transferred and if appropriate safeguards are fulfilled.

Third party services utilizing tracking on the MarketplaceService providerDescription of the purpose of the tracking and use of the tracking dataPrivacy and/or security policyOpt-outCountries where data is transferred and appropriate safeguards
Google Analytics Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, e-mail data-protection-office@google.com, phone +1.650.253.0000, fax +1.650.618.1806Google Analytics tracks and reports website traffic and user behaviour on our siteTerms of use

Privacy policy

Google OptUSA – EU-US Privacy Shield certified
Facebook Ads ManagerFacebook Inc., 1601 S. California Avenue., Palo Alto, CA 94304, USAAudience building and targeting across Facebook marketing networksExplanationFacebook OptUSA – EU-US Privacy Shield certified

 

8.4. We use a number of social plug-ins on the Marketplace. Plug-ins are small extension modules used by different social networks that allow you to inform other users in the social network that you are on the Marketplace. Please note that we have only limited control over the data transmitted by these social plug-ins. Please read the following information to learn how the social plug-ins work:

When you visit a site of our Marketplace that contains a social plug-in, your browser will establish a direct connection to the servers of the social network. The social network is informed about the site that you are currently visiting on the Marketplace and the social network stores this information in accordance with its privacy policy. The social network may also log your browser history or further information. If you interact with (click on) the social plug-in while you are logged onto the related social network, this information may be matched to your profile and shown on other sites of the internet. If you do not wish the social network to collect data on you through the Marketplace, it may be helpful to log off from the social network before you visit our Marketplace. For further information about the purpose and extent of the data collection and further use of your data by the social network, as well as your profile setting options to protect your privacy, please view the data privacy notices of the social networks:

Name of social plug-inName of social networkPrivacy policyInformation on how to opt-out
FacebookFacebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USAhttps://de-de.facebook.com/policy.phphttps://www.facebook.com/help/cookies/?ref=sitefooter
TwitterTwitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USAhttps://twitter.com/privacy?lang=dehttps://support.twitter.com/articles/20170520-so-verwendet-twitter-cookies-und-ahnliche-technologien
Google+Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USAhttps://www.google.de/intl/de/policies/privacy/https://myaccount.google.com/privacycheckup
PinterestPinterest Inc., 808 Brannan St., San Francisco, CA 94103, USAhttps://policy.pinterest.com/en/privacy-policyhttps://help.pinterest.com/en/articles/we-support-do-not-track
TumblrTumblr Inc., 35 E 21st St., 10th Floor, New York, NY 10010, USAhttps://www.tumblr.com/policy/en/privacyhttps://www.tumblr.com/settings/account

9. YOUR RIGHTS UNDER DATA PROTECTION LEGISLATION

In particular but without limitation, the following rights are vested in you by applicable data protection law:

(a) Right of access, rectification, erasure and restriction of processing: You have the right to obtain at any time access to your personal data stored by us. If we process or use your personal data, we shall endeavor to ensure by implementing suitable measures that your personal data is accurate and up-to-date for the purposes for which they were collected. If your personal data is inaccurate or incomplete, you have the right to obtain the rectification of such personal data. Furthermore, you may have the right to obtain the erasure or restriction of processing of your personal data, for example if no legitimate business purpose exists anymore for the data processing under this privacy policy or applicable law and the further storage is not necessary under statutory storage obligations.

Your user account essentially shows the personal data you have stored with us. You may view, change and/or erase the data as needed. Furthermore, to obtain access to or the rectification, erasure or restriction of processing of your personal data you may at any time contact us as provided in item 1 above.

(b) Right to data portability: You may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another controller. To exercise this right you may at any time contact us as provided in item 1 above.

(c) Right to object: You may have the right to object, on grounds relating to your particular situation, to the processing of your personal data. To exercise this right you may at any time contact us as provided in item 1 above.

(d) Right to withdraw your consent: If you have given your consent to the collection or processing of your personal data, you have the right to withdraw your consent at any time on a prospective basis without affecting the lawfulness of processing based on the consent before its withdrawal. You may also object to use of your personal data for purposes of market research and public opinion polling as well as advertising and unsubscribe from our newsletter (please cf. under item 4.3 above). To exercise any of these rights you may at any time contact us as provided in item 1 above.

(e) Supervisory authority competent for complaints: You have the right to lodge a complaint with the UK Information Commissioner’s Office which you can contact under https://ico.org.uk/global/contact-us/ (ENG) or Garante Privacy Italy http://www.garanteprivacy.it/ (for italian users)

10. CHANGES

Santillo reserves the right to change this privacy policy from time to time in compliance with the legal requirements, for example to be compliant with new laws or to add new services.

Date: 23 May 2018