Privacy Policy
Data protection policy for consumer customers and other individuals engaged in professional or business activity.
Introduction
Your privacy is important to us at Zulla.
We have written this privacy policy (hereafter also just “policy”) in a simple and understandable way to help you understand who we are, what data about you we collect, and what we do with it.
We want you to be aware that your personal data (hereafter also, simply “data” or “your data”) is represented by any information or set of information from which you can be identified, directly or indirectly, in particular by reference to an identifier, such as first and last name, email address, telephone number, etc.
Please consider that this is a generic disclosure-you may find more specific information about different products, services, or applications we offer elsewhere on the site.
Please take some time to read the entire policy, so that if you disagree with the way we treat personal information, you can avoid providing it to us.
What is the purpose of this disclosure?
This policy explains how we collect and use (ie: process) your data for example:
– When you visit or use our websites, applications, or social channels;
– Purchase or use our products, services, systems, or applications;
– you sign up for our newsletter;
– You provide us with products or services;
– contact our customer service department;
– participate in our events;
Or in any other way you interact with us as a purchaser, customer, consumer, business partner, supplier, contractor, or as an employee of another business or humanitarian organization or other nonprofit entity that has a business relationship or contact with us, or in any other capacity you may have a professional or business relationship with us.
WHO WE ARE.
When this notice says “we” or “the company” it refers to the owner of the personal data, which is Semplifai Srl
WHAT TYPES OF DATA DO WE COLLECT ABOUT YOU?
Depending on who you are (customer, consumer, supplier, business partner, etc.) and how you interact with us (e.g. online, offline, by phone, etc.) we may process different data.
For example, we may collect your information when you visit our website, our applications or our social media, when you purchase our products, use our services, our products our systems or our applications, subscribe to our newsletter, download a software update, provide us with goods or services, contact our customer service, participate in our events, enter our contests, or interact with us in some other way.
Below you will find an overview of the categories of data we may process.
Information you provide to us directly
Data category / examples of data
– Identifying data: e.g., first name, last name, title, date of birth
– Contact data: e.g. Email, phone number, address, country
– Login credentials: such as user name, password or other security codes
– Images and/or videos by which you may be identified: as photos uploaded to your accounts or otherwise provided
– Any other information you decide to share with us: e.g. Feedback, opinions, reviews, comments, uploaded files, interests, information provided in our due diligence procedures
Information we collect automatically
When you visit or use our websites or applications, subscribe to our newsletter, or interact with us through our digital channels in any other way, we may collect, in addition to the information you provide to us directly, information that your computer, mobile phone, or other device you use to access our channels automatically sends us.
Data category/types of data
– Device information: Model, IMEI code and other unique device identifiers MAC address, IP address, operating system version, device settings you use to access various services
– Log information: Time and duration of your use of the digital channel or product
– Location information: your location (i.e., the geographic area in which you are located) which is derived from your IP address or other geolocation-based technologies that allow us to have this type of information when you enable location on our products or services, such as when you use our apps
– Other information about your use of our digital channels or products: The apps you use, the websites you visit the links you click on when you receive our promotional emails, data from motion sensors
Information we can gather from other sources
Subject to applicable regulations, in addition to our websites, apps, and other digital channels, we may also obtain information about you from other sources, such as public databases, business partners, social media platforms, and other third parties.
For example, depending on the settings of your social profiles if you decide to connect to our products or services through your social account, have one of our applications access your social account, or connect to one of our pages through a social network you use some of your social media account data may be shared with us, including some data that is part of your profile.
How do we use your data?
We may use your information for various legitimate reasons and purposes related to our business.
Below are the purposes for which we process your data:
– Evaluation and monitoring of (potential) customers, suppliers, and/or business partners: Due diligence procedures
– Conclusion and execution of contracts: sales, billing, shipping of products, registration to mobile applications or websites, warranties, communication services, account management
– Provide you with assistance (at your request): provide you with assistance through our communication channels such as customer service or contact center
– Direct marketing: promoting contact with business or consumer customers, email marketing, market research, personalizing your experience by presenting you with products and offers modeled after you (such as on our websites or apps or through other communication channels)
– Security and protection of our interests or assets: develop and maintain technical and organizational security measures, conduct internal audits and investigations, conduct assessments to verify conflicts of interest
– Legal obligations: Disclose data and information to relevant authorities, data protection supervisory authorities, according to applicable regulations in the countries in which our business partners operate, e.g., for voluntarily enforceable payment control or anti-money laundering regulations, insurance compliance, obligations related to record keeping and reporting, conduct audits related to compliance ala regulations, comply with inspections and requests from governments or authorities, comply with court requests, e.g., regarding witness obligations, and handle internal claims or complaints.
– Defense in court: Acting or defending ourselves in court
If we ask you to provide us with your information, but you choose not to in some cases we may not be able to guarantee that you will be able to take advantage of our products, services, systems or applications. Or we may not be able to respond to your requests.
How do we use your data for marketing?
We may send you regular commercial communications about our products services events and promotions.
If you give consent in the request forms we have set up, we will send you direct marketing communications designed to promote our activities. These communications will come to you through email.
We will always give you the opportunity to revoke the consent you have given us.
In any case, you can always opt out of receiving marketing messages: for emails in particular, just follow the unsubscribe instructions provided at the bottom of each email.
If you are registered and have your own profile you can always change your preferences regarding marketing communications in the dedicated area.
You can always contact us (you will find our contact information in the “what are my rights?” section) to opt out of receiving marketing-related communications.
Please note that even if you decide not to receive marketing communications, you will continue to receive our administrative communications, such as those related to product or service updates, price changes, abnormal account activity, and other important notices.
If you sign up for the newsletter, but do not consent to marketing communications, you will receive only the newsletter you have requested, until you decide to unsubscribe, either in the manner indicated in the email with which we send you the newsletter or through the site.
What is the legal basis for our treatments?
To lawfully process your data we can services of several legal bases:
– Your consent (only when required or permitted by law). IF we use consent as the legal basis for processing your data, you can withdraw it easily and without charge at any time;
– The need to enter into a contract with you and fulfill the obligations arising from it;
– The need to comply with obligations imposed on us by law, or to exercise a right or defend ourselves in court;
The need to pursue a legitimate interest of ours, such as:
– Making sure our network and information is secure
– For administrative and accounting needs related to the group of companies to which we belong;
– To prevent suspected violations of law or investigate violations of law that have actually occurred, as well as of violations of contracts with business clients or for non-compliance with policies or principles we follow and impose on our suppliers and business partners (e.g., Codes of Ethics, quality standards);
– The need to respond to your request;
– the need to analyze traffic on the site in order to improve its performance and your browsing experience.
WHEN DO WE SHARE YOUR DATA?
We share your data with others only in the cases indicated below.
If it is necessary for the pursuit of the purposes set forth in this policy, we may disclose data to the recipients listed below.
Affiliated or related companies: because we are a multinational company, your data may be shared with other companies that are part of the same group. We guarantee that in any case only authorized parties who must necessarily process your data will have access to it.
Providers: we may outsource some services to third parties we trust to provide us with features and services, such as providing ICT services, shipping services, or consulting services.
Business partners: we may share your data with reliable business partners so that they can provide you with the service you request;
Public and government authorities: when required by law, or when it is necessary to protect our rights, we may share data with relevant agencies.
Businesses, professionals and consultants: we may share your data with professionals and consultants such as banks, insurance companies, auditors, lawyers, accountants.
Other parts in the event of corporate transactions: in the event of corporate transactions or transfers of business units, we may share your data with other companies or groups of companies depending on the transaction from time to time put in place, purchase or sale of a company or business unit, corporate reorganization, mergers, incorporations, joint ventures, or any other transaction of a corporate or corporate nature (including bankruptcy or composition with creditors or other similar insolvency proceedings).
WHEN DO WE TRANSFER YOUR DATA ABROAD?
Traffic data, IP addresses, and data you provide to us through cookies can be made accessible or transferred by affiliates or trusted third parties in many countries around the world.
It means that your data may be processed in countries other than the one where you live if it is necessary for the purposes we have highlighted in this policy.
If you live in the European Economic Area be aware that your data may be processed outside the EEA, and specifically in the United States. The companies to which we transfer data and operate this country are Privacy Shield members and the European Commission has recognized that they offer an adequate level of protection (adequacy decision).
HOW LONG DO WE KEEP YOUR DATA?
We keep your data for as long as necessary to achieve the purpose for which we collected it (for clarification of purposes read “How do we use your data?”).
Please keep in mind that in some cases a longer retention period may be permitted or required by law. Criteria for determining the retention period include:
– How long do we need the data to provide you with the product or service or to conduct our business?
– Have you requested our newsletter and never said you wanted to unsubscribe?
– Do you have an account? In this case we will keep your information as long as the account is active, for as long as it is needed to provide the service to you.
Are we under a legal, contractual, administrative, or similar obligation regarding the retention of your data? For example, when there are regulations requiring data retention, or judicial orders to retain data relevant in an investigation, or data must be retained to enforce a right in court.
HOW DO WE PROTECT YOUR DATA?
To protect your data, we take appropriate measures in compliance with applicable regulations, including asking our service providers to use appropriate measures to keep information about you confidential and to keep your data secure.
Depending on the state of the art, implementation costs and the nature of the data to be protected we put in place technical and organizational measures to prevent risks of destruction, loss, alteration, disclosure or unauthorized access to your data.
WHAT SHOULD I DO?
We want to remind you that it is your responsibility to ensure to the best of your knowledge that the data you provide us with is accurate, complete, and up-to-date. Also, if you share other people’s data with us, it is a specific responsibility to treat that data according to the law.
For example, it will be up to you, to inform the people whose data you provide to us, of the contents of this notice and to obtain their consent if the law so provides.
WHAT ARE YOUR RIGHTS?
We provide access to your data.
You can generally control your data fully independently (e.g., by logging into your account) and can update, modify, or, if the law allows, delete it.
We encourage you to check your data regularly.
You can still contact us if you want:
– Review, change, or delete the data you have provided to us (if we are no longer allowed to keep it or are not obligated to keep it);
– object to certain processing (e.g., for marketing communications);
– Receive a copy of your data (in a commonly used readable format);
– Ask us for any other information regarding the protection of your data
The contact details of the owner:
– Semplifai SRL – Corso Buenos Aires 56, 20124, Milan (MI)
– info@semplifai.it
We do our best to respond to requests on time and without cost except when it requires disproportionate effort.
In some cases we may ask you to verify your identity before we take over your request.
If you are not satisfied with the response you receive, you can complain to the competent supervisory authority in your country (for Italy it is the Italian Data Protection Authority).
HOW DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
For information on this type of processing, read thecookie policy
DO WE PROCESS DATA OF MINORS?
We do not intentionally process data from children under 16.
Specific information for children under 16: If you are under 16 years of age, please be advised that you must obtain the consent of your parent or guardian before giving us your information.
Specific disclosure for parents of children under 16: We recommend that you control and monitor your children’s use of products, services, applications and systems (including the website we other digital communication channels) to ensure that your children do not share any information with us without your permission .
WHEN WILL THIS INFORMATION BE UPDATED?
This policy may change over time.
The most recent version of the policy on the site is the one that reflects the processing of personal data and information that we operate.
