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PRIVACY NOTICE

REASONS FOR THE INFORMATIVE

This privacy statement (the "Privacy Policy") contains important information about personal data that is collected by visiting this Web site, as a registered or unregistered user, and describes how  such data are used. Where applicable, it also explains the processing methods of the data provided by the user. This information is complementary to any other information received in such other circumstances.This document contains important information on the following:

    A. TREATMENT OF PERSONAL DATA

    B. PERSONAL DATA COLLECTED

    C. PURPOSE OF THE PROCESSING OF PERSONAL DATA

    D. COMMUNICATION OF PERSONAL DATA

    E. PROTECTION OF THE PRIVACY OF MINORS

    F. ARCHIVING, ACCESSIBILITY AND TRANSFER OF PERSONAL DATA

    G. SECURITY AND CONFIDENTIALITY OF PERSONAL DATA

    H. RIGHTS OF ACCESS TO PERSONAL DATA - MANAGEMENT OF CHOISES  

    I. RIGHTS OF PRIVACY REQUIRED FOR CALIFORNIA CITIZENS

    J.  DATA CONSERVATION

    K. POLICY ON COOKIES AND SIMILAR PROCESSES

    L. LINKS, ADVERTISERS, SPONSORS AND ADVERTISING

    M. HOLDER OF TREATMENT - COMPANY CONTACTS

    N. UPDATES OF THIS INFORMATION - COMMUNICATIONS  

 

ACCEPTANCE

By visiting the Website, using its services or interacting with the Company, the user confirms that he has read and understood this Privacy Policy and accepts that the Company collects, uses, archives, transmits and discloses personal data collected through the Website and / or its Sales Offices in accordance with this Privacy Policy. Except in the case in which it is already registered, the Company may require the user to provide its consent (for example, by ticking a box), where it deems it appropriate to safeguard its rights or where required by current regulations. If you do not accept the terms of this Privacy Policy, you are requested  to not visit this Website, do not create an account and do not otherwise use this Website or send personal data to us or do not give your consent when this option it is offered in accordance with the regulations in force.

 

A. TREATMENT OF PERSONAL DATA

In this Privacy Policy, the term "Personal Data" is used with reference to any information that allows the Company to identify the user (or a third party for whom the user provides the data), directly or indirectly, including any information connected to the purchase of goods or services, or that the user chooses to communicate to the Company or to share with it, or with third parties, during the use of the Website or at the Sales Offices. The processing of personal data will be carried out in accordance with the General Data Protection Regulation (EU) 2016/679 "Reg. (EU) 2016/679 "and, where applicable, to the legislation of the country where the data should be collected. The Company reserves the right to perform further processing of data, where required by law or in the context of investigations or criminal proceedings or of other type.  


B. PERSONAL DATA COLLECTED

Data source

The Company collects personal data from the user only if the latter voluntarily provides information, for example:

in the case of the Website: placing an order therefore opening an account or modifying it; creating a wish list; by participating in a promotion; doing research on the Website; by contacting the Company by sending a comment or a request; by subscribing to e-mail newsletters and updates regarding the latest products and services, events or promotions; or requesting to receive confirmation of an order, shipment or other notice;

in the case of the Company's Sales Offices: by sending email requests to the Company's Sales Offices, interacting with it or purchasing products; in the case of events: by participating in events, surveys and market research, promotions, including online, for example, on mini-sites managed by the Company on third party social networks such as Facebook;

in the case of the Company's customer service: requesting assistance, special services or after-sales assistance;

in the case of e-mail, SMS and other electronic messages: exchanging communications between the Company and the user.  

If the user provides the Company with personal data of third parties (for example, family members, other customers or potential customers), the same should ensure that such third parties are informed and have authorized the use of their data as described in this Privacy Policy .  

Data types

The Company may collect and use different types of personal data according to the specific purposes pursued and described below:

  1. personal information, such as name, surname, gender, age / date of birth, country of origin and other personal data that the current regulations allow to collect; company information as business name etc.
  2. contact information, such as address, email address, telephone number, mobile phone number, fax number and other contact information that current regulations allow to collect;
  3. payment information, as payment instrument (credit or debit card), if applicable, and passport number, if required for tax reasons or in relation to anti-money laundering legislation;
  4. information relating to the sale, such as data, products or services provided, place of purchase, product codes, amount, total sale, VAT number / tax code, complaints, returns, refunds or other information relating to the sale that the current regulations allow to collect;
  5. habits and profiles, such as data on purchases (purchase history, type, quantity and price of products purchased), information on activities and initiatives relating to the management of relationships with customers (date and categories of these actions implemented or to be achieved and their results ), purchase habits and preferences (wish list, preferred product categories, knowledge of the Company's trademarks), notes on purchase habits that the current regulations allow to collect;

 

C. FINALITY OF THE PROCESSING OF PERSONAL DATA

Depending on the specific circumstances in which the interaction between the user and the Company occurred, personal data could be used for the following purposes.

1. For online sales and c / o offices (Sales Offices where the user makes the purchase) or by the local website provider, as identified in the Conditions of Sale of the online purchase.

The personal data provided by the user or collected at the time of purchase, whether or not as a registered user, ie basic personal data, contact information, purchase data, tax data, payment details, sales information and any other data strictly necessary for the delivery of the products, will be used for:

  1. to manage, administer and process product purchases, sales and after-sales services, such as administrative activities, accounting, returns, guarantees, tax-free refunds, where applicable, fraud prevention and communication with the user, including by email, for any problem relating to the management of the order or subsequent requests relating to the order;
  2. to comply with obligations imposed by EU laws, regulations or legislation (including anti-money laundering legislation) and make a legal claim or defend against it.

It is necessary to provide personal data for the aforementioned purposes and the refusal would make it impossible to complete the purchase. Except where otherwise required to comply with local regulations in force, the processing of data for these purposes, as necessary to fulfill contractual and legal obligations, may be made without requesting the user's consent.

2. For the specific purposes for which the data were provided voluntarily

The personal data provided by the user or collected when the same requires a specific   service (for example, by registering his account on the Website, handling complaints or requesting information), namely personal information, contact information and data strictly necessary to follow up at the request, they will be used for:

  1. to provide the required services (for example, execute the account registration processes, manage authentication on the Website and the user's accounts, assist him and manage any complaints and wish lists and answer a question or contact request, if any forwarded by the user, also through customer service);
  2. to manage subscription to the newsletter where the user is not registered.

Personal data must be provided for the aforementioned purposes and the refusal would make it impossible to complete the request. Except where otherwise required to comply with local regulations in force, the processing of data for these purposes could be made without requiring the user's consent, as necessary to follow up on the request. 

3. For the purposes of managing customer relations (CRM) if the user registers 

The personal data provided by the user by filling in the Company's forms or collected during visits to the Website or interaction with the Company, that is personal and contact information and data concerning the user's habits and profile, will be included in the centralized CRM system for:

  1. to offer promotions, discounts and other personalized services and send newsletters, other marketing and commercial communications on products and services and invitations to events on the Company's brands (organized by the company or its distribution chain), surveys and research, market analysis, invitations to promotions and other initiatives for users or registered customers of the Company's trademarks ("marketing"). The Company may use traditional means of contact (ordinary mail and telephone) and / or digital and automated (e-mail, SMS, MMS, telephone and other digital channels, such as social media) and may send the user such communications on the basis of its profile, if the same has given its consent to profiling (see the following point b);
  2. to analyze the user's contacts with the Company, interests, preferences and purchasing habits, and create individual or aggregated profiles based on them, understand how to provide a better service, also to offer a better sales experience in all Sales Offices in Italy ("profiling"). The Company may also use personal data to create groups and perform statistical and market analyzes aimed at identifying products and / or services of interest to customers of its brands and improving its services (including the Website). The data collected on the Website will be combined with any information obtained from the Company through interactions with sales staff of the Sales Offices. The processing of personal data for profiling is carried out respecting the guarantees and parameters established by the law in force. 

The insertion of data in the CRM system is optional (being based on the consent that the user can choose to lend) and can only take place where personal data are provided for both marketing and profiling purposes as per points IIIa) and IIIb ) or only for one of the two. The user can cancel the registration or withdraw his consent at any time (see the next point H). In any case, the refusal to provide personal data for one or both of these purposes CRM does not prevent the user from using the Company's services or making purchases, but the Company can not inform him of the marketing initiatives and events described above and not he will understand his interests and offer him a more personalized shopping experience.

 

D. COMMUNICATION OF PERSONAL DATA

The Company shares your personal data with its affiliated companies, its distributors and affiliates, including those located in other countries, and with other companies that provide services on its behalf (as detailed below), under its direction or that of third parties. These companies and organizations will only receive the personal data necessary to perform the services and will not be authorized to use them for any other purpose.

I. Communication of personal data to data controllers

When the user purchases the products or uses the Company's online sales services, his    personal data may be shared by the e-commerce provider of this Website with selected third parties providing services to the supplier, including those who orders, send products,  process payments by credit or debit card and perform anti-fraud checks.

Your personal data may be shared with third parties to monitor and analyze the activity of the Website, host the contents of the Website, provide technical and organizational services functional to the aforementioned purposes, maintain the customer database, provide marketing assistance and manage email, market analysis, surveys, promotions. These third parties may have access to the user's personal data or store them or process them in order to provide such services on behalf of the Company in Italy, in the country in which the user is located or abroad. The Company's service providers are not authorized to use personal data for purposes other than providing the contracted services.

The processing of personal data of the user for CRM purposes will be performed, according to the instructions provided by the Company, as the controller of the treatment.

II. Dissemination of personal data

Your personal data may need to be shared with payment processing and fraud control companies, which operate independently as data controllers in order to provide you with online sales services.

In the case of patrimonial or corporate transactions (for example, mergers or acquisitions, corporate restructuring or liquidation), customer data will probably be one of the transferred assets and may be shared with legal successors, to the extent permitted by law based on legitimate interest of society. Personal data will remain subject to the pre-existing privacy policy, except where the user decides otherwise.

The Company may also disclose your personal data to third parties (i) where required by EU or Member State legislation; (ii) in the case of legal proceedings; (iii) in response to a request from law enforcement agencies based on legitimate grounds; or (iv) to protect the rights, privacy, security or property of the Company or the public.

In addition, to the extent permitted by law, the Company may disclose personal data to third parties in case of complaints related to the use of the Website, where deemed necessary to investigate, prevent or take measures regarding illegal activities, suspected fraud or in the event that the Company, in its sole discretion, considers that the use of the Website by the user is incompatible with the terms of the Website itself.

The complete list of designated data processors and third parties to whom the data are communicated can be obtained using our contacts indicated below (point M).

  

E. PROTECTION OF THE PRIVACY OF MINORS

This Website is intended for general public, however its services are intended for persons aged 18 and over. The Company does not require, collect, use or disclose personal data provided by persons under the age of 18 online or at Sales Offices. If the Company learns that it has personally collected data from a minor, it will delete them.

In the event that the user is not of the required age, please do not register or proceed with the online purchase and ask an adult (or their parents or guardian) to perform the necessary procedures.

 

F. ARCHIVING, ACCESSIBILITY AND TRANSFER OF THE PERSONAL DATA

The processing of personal data collected through the Website is mainly carried out using electronic or web-based means, including web analytics services hosted by servers of selected suppliers of the Company operating both within the European Union (for example, in Germany and Ireland, for online sales transactions on Websites managed directly by the Company) that outside of it (for example, in the United States, for the Company's newsletter subscription services). In Sales Offices, the processing of personal data can also be carried out on paper. In both cases, personal data, for CRM purposes, are inserted in the centralized database and made safe by the Company located in Italy and managed by the CRM Managers and by the marketing team in Italy and abroad. 

Access to personal data will be allowed only to authorized personnel of the Sales Offices and the local e-commerce provider (for example, to the staff of the digital marketing and IT departments, retail sales, administration and security), depending on the actual need to know this information and using access control tools on multiple levels. This personnel is committed to respecting the obligations of confidentiality and has been expressly designated as responsible for the treatment, as required by the law in force. In particular, where the user has given his consent to the processing of his personal data for the purposes of CRM, the related data may be read, modified and updated by the Company staff and by that of the Sales Offices and / or local suppliers of the e-commerce (especially from sales and marketing staff). Personnel, present in Italy or abroad, have received special training and are required to comply with confidentiality obligations. The Company may use it to collect, use and disclose information according to its instructions.

If the Company needs to transfer personal data abroad in order to pursue the purposes set out in this Privacy Policy, even where the personal data legislation differs from that applicable in the country where the user is located, the same will adopt measures to ensure that such communications occur in accordance with European data protection standards or other local standards used in the country where data is collected, so that user data remains secure and confidential.  

 

G. SAFETY AND CONFIDENTIALITY OF PERSONAL DATA  

The Company has implemented appropriate measures to protect the user's personal data from accidental loss and from unauthorized access, use, modification and disclosure. For example, when the user provides order information, the Company uses SSL (Secure Socket Layer) technology, an encryption tool that ensures security when transmitting information over the Internet. In the management of this Web site, password controls, a firewall technology and other technological and procedural security measures are also used. Although the Company has implemented the aforementioned security measures for the Website, the user must be aware that 100% security can not be guaranteed. Therefore, the user provides his personal data at his own risk and, to the fullest extent permitted by applicable law, the Company will not be in any way responsible for their disclosure due to errors, omissions or unauthorized third party actions during or after their transmission to the same. The Company recommends that the user (i) periodically update the software to protect the transmission of data on networks (for example, anti-virus software) and check that the provider of electronic communication services has adopted appropriate means for the security of transmission of data. data on networks (for example, firewalls and anti-spam filters); (ii) to keep confidential and not to communicate to anyone the username and password to access the account; and (iii) change the password periodically.

In the unlikely event that the Company believes that the security of the personal data of the user in its possession or under its control has been or may have been compromised, the same will inform the user of the incident according to the procedures established by law , using the methods prescribed by it (providing the Company with its email address, the user agrees to receive such communications in electronic format through this email address).

 

H.  HIRING ACCESS TO PERSONAL DATA - MANAGEMENT OF CHOICES

User rights

At any time and for free, the user can access his data, receive his electronic personal data in a structured and commonly used mechanically readable format and transmit them to another data controller (data portability), and have them corrected, updated, modify or delete (subject to any applicable exceptions). The user can update the data provided to the Company by contacting the same address provided below. Requests for cancellation of data are subject to legal obligations and the conservation of documents imposed on the Company.

If you believe there is a problem with how your personal data are handled, you will have the right to file a complaint with your national personal data protection authority or any other country in the EU or the European Economic Area.

To exercise these rights, the user may send a request by contacting the Company or the Company's Sales Office in its country, by sending an email to sales@first-componetns.com or a letter by ordinary mail to the address given below (point M). When contacting the Company, you must ensure that you include your name, e-mail address, postal address and / or telephone number (s) to be sure that it can properly handle your request.

Accuracy - Updating of personal data

To enable the Company to better serve the user, he is invited to check and update his personal data on a regular basis. If registered, the user will be able to access his personal data and modify them using the user account settings on the Website; otherwise, you may contact the Company (see point M) for assistance in updating personal data.

Management of choices related to direct marketing and profiling. If the user wishes not to give his consent to the use of data for CRM, marketing and / or profiling purposes, or to manage his / her own advertising preferences, he / she can send a simple request to the Company (see point M) of below or manage your account choices accordingly. The same procedure applies where the user wishes to withdraw his consent to profiling.

 

I.  RIGHTS TO PRIVACY PROVIDED IN CALIFORNIA

Pursuant to Section 1798.83 of the California Civil Code, persons residing in California are entitled to request from the companies with which they have established a business relationship some information regarding the types of personal data that the same shares with third parties who conduct direct marketing activities, and to know the identity of third parties with whom the Company has shared this information during the immediately preceding calendar year. If you are a resident of California and would like to receive a copy of the information provided under this law, you can send a written request to the Company. The answer will be provided within 30 days of the request.

 

J.  DATA CONSERVATION

Personal data will be kept for the duration of the commercial relationship and for all the time necessary to pursue the purposes described in this Privacy Policy (for example, where the user subscribes to a newsletter, for the duration of such registration, or where have a user account, until it is closed). After this period, the user's personal data will be kept only to comply with legal and regulatory obligations (for example, for 10 years, for accounting purposes, for the duration of the mandatory conservation obligation, in the case of tax purposes , etc.) or to allow the Company to maintain evidence of their respective rights and obligations.

The personal data of the user that are processed for CRM purposes (point C.3) will be kept until the account is closed or until consent to their treatment for these purposes is withdrawn. Personal data relating to information on purchases that are processed for profiling and marketing purposes will be kept for a limited period, in line with the deadline allowed by the law in force, and will be erased or anonymized at the end of this deadline. permanent way.

 

K. POLITICS IN THE FIELD OF COOKIES AND ANALOGUE PROCESSES

For more general information on cookies and their enabling and disabling, consult the Cookies section on the website first-components.com /cookie.policy

 

L. LINKS, ADVERTISERS, SPONSORS AND ADVERTISING

This Website may contain links to various websites owned or controlled by the Company, as well as to websites of third parties. Where the user chooses to provide his or her personal data on such linked websites, such information will be subject to the privacy policy and security policies of such linked websites - including Web sites administered and managed by approved distributors of the Company, with the exception of the data collected by the Company's distributors for CRM purposes if the Company's privacy notice is published - and not to this Privacy Policy. Since the Company is not responsible for the information sent or collected, used, disclosed or otherwise subjected to processing by third party websites, the user should be aware of these other privacy policies.

 

M. HOLDER OF TREATMENT - RESPONSIBLE OF PROTECTION DATA - COMPANY CONTACTS

For the purposes of this Privacy Policy and the processing of data described herein, it is hereby specified that the term "Company" refers to FIRST Components S.r.l., with registered office in Via Cavour, 10A - 21022 Azzate (VA), Italy. The Company is the data controller (as defined in Reg. (EU) 2016/679) of the data collected at the Sales Offices and / or Website in Italy and abroad for the CRM purposes referred to in points C.2 and C.3.

The data controller of the data collected at the Sales Offices and / or the Website for purposes related to the sales referred to in point C.1, is the Sales Office or the First Components online store at which the purchase is made and / or who has collected the data that undertakes to process the personal data of the user following the principles set forth in this Privacy Policy.

For any comments or questions about this Privacy Policy and to talk to the local contact person in charge of handling data processing requests, you can also contact the Company's customer service department at the email address sales@first-components.com


N. UPDATES OF THIS INFORMATION – COMMUNICATIONS

The Company, at its discretion, reserves the right to change, modify, add or delete parts of this Privacy Policy at any time, publishing its revised version on this Web Site page and updating the date of the "last modification" below indicated. It is the user's responsibility to review the Privacy Policy from time to time to be aware of any changes made. In some cases, the Company may provide further communications regarding significant changes to this Privacy Policy by posting a notice on the home page of this Website or, in the case of registered users, by sending a notification email or entering a notice on their page. account. By accepting this Revised Privacy Policy by clicking on the "accept" button in this notification email or in the communication published on the account page (where required to comply with current regulations), by completing a purchase on the Website or in any Sales Office after review of the Privacy Policy, or otherwise, by using or sending information to the Website after the publication of the revised Privacy Notice, the user accepts this revised Privacy Notice. Following the changes, where required by current legislation, the user's data will not be processed without the explicit consent of the user.  

 

This information becomes effective from 01.01.2018

 

HISTORY 

01/01/2009

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