Who is the Data Controller?

The Data Controller of your personal data processing carried out through the Website  is:

WESTPOLE S.p.A. – Lungotevere Vittorio Gassman 22, 00146 Roma (Italia) – Tel.: +39 06 519 931
email: [email protected]; PEC: [email protected]

Taxpayer’s number: 03705590580; VAT number: 01230291005
Share capital: € 500,000.00 fully paid-up – Chamber of Commerce: 448372 – Court Reg.: 4127/79 REA (Economic Register)

What type of personal data do we collect?

 

a) Personal data collected when you use the WESTPOLE Website for informative purposes only.

Information relating to your Website use

When you use our Website for informative purposes only (e.g., you are visiting the Website pages without registering on or otherwise submitting your personal data through the Website ), your internet browser automatically collects, and transfers to us, certain basic information relating to your Website use. Such data may include:
• your browser type and version
• your operating system and interface
• language preferences
• the Website from which you are visiting us (referrer URL)
• webpage(s) you are visiting on our Website
• date and time of your visit
• your internet protocol (IP) address

Personal data processed by external social media providers (“Social Media Data”):

Our Website contain share buttons that enable you to share WESTPOLE content with your friends through third party media platforms and/or social networks, such as for example Facebook (“External Platforms”). The mere use of our Website does not generally involve data processing activities (including data transfers) in relation to the External Platforms. However, when you use the share button, these External Platforms may collect and otherwise process personal data about you. For more information about the scope and purposes of the data processed by the External Platform provider, including your rights and setting option to protect your privacy, please see the privacy notice of the respective External Platform providers.

 

b) Data processed through cookie. We use cookies and similar technologies during the operation of the Website. Please see the specific section “Cookie Policy”..

 

c) Information collected when you subscribe to the WESTPOLE newsletter. If you subscribe to our newsletter or other marketing communication via the Website in order to receive information on WESTPOLE promotions, collections, discount campaigns, and special events, we will collect personal data through the Newsletter subscription form.

 

d) Information collected when you otherwise interact with us via the Website. The Website enable you to get in touch with us in different ways (for example via e-mail telephone, etc.). The collection of personal data depends on how you interact with us and what information you provide us with. If you contact us via the “Contact Us” section or if you make any service request as available on the Website, we may collect the following personal data:

• First and Last Name
• Email Address
• Phone Number
• The content of your query

 

Important Notice:When we collect personal data through forms, including but not limited to electronic forms, we will indicate the mandatory fields via asterisks. Failure to provide the data marked with an asterisk could prevent you from accessing our products and/or services. While submitting any data please ensure it is accurate and do not transmit any sensitive data such as health information, political opinions, religious or philosophical beliefs, information on your sex life or sexual orientation, racial or ethnic origin, nor any content which is not expressly requested through a questionnaire or any other collection method (such as commercial information, advertising, personal creations, ideas, or concepts), unless this is required in exceptional cases. Our Website does not offer services specifically directed to children and persons under the age of 18, therefore we do not knowingly collect personal data from children.

 

Our Website does not offer services specifically directed to children and persons under the age of 18, therefore we do not knowingly collect personal data from children.

Purposes of the processing and legal basis

 

We process your personal data only if we have at least one of the following legal basis:

• to comply with any applicable legal/regulatory obligations
• to perform the service requested by you (for example when you subscribe to the newsletter)
• to pursue our legitimate interests or the ones by a third party
• once we’ve received your consent to our specific use

 

The purpose for which we use and process your personal data and the legal basis on which we carry out each type of processing is explained below.

 

Purposes of the processing	Legal basis
Sending communications to you about our products, services, promotions, offers, news, and events.	We will send electronic communications to you if you have consented to these communications. With respect to other communications it is in our legitimate interest to communicate to you about our products, services, promotions, offers, news, and events. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
Serving advertising and offers to you based on your interests and online activities	We will serve you advertising and offers to you based on your interests and online activities if you have consented to this processing
Improving our Website, through your experience and your judgments on the quality of the service.	It is in our legitimate interest to improve our offerings. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
Providing you with information and services that you request from us.	It is necessary for us to process your personal data in order to provide the information or deliver the services you have requested.
Managing our Website including troubleshooting, data analysis, testing, research, to keep our Website safe and secure and to prevent detect fraud and abuse.	It is in our legitimate interest to continually monitor and improve our services and your experience of the Website and to ensure network security. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

 

To unsubscribe from our “Newsletter” or stop receiving our emails, you may simply click on the “unsubscribe” link at the bottom of each Newsletter or email.

What happens in the event you do not provide your personal data?

 

Where the data are necessary to provide a response to a query, a service you requested we cannot provide any answer/service unless we have access to your personal data (i.e. email or telephone).

How do we process your personal data?

 

The processing of your personal data is carried out with appropriate procedures and measures to protect the security of your data, in terms of integrity, confidentiality and availability. WESTPOLE uses commercially reasonable measures to keep your personal data confidential and safe. We take appropriate physical, electronic and administrative steps to maintain the security of personal data we collect, including limiting the number of people who have access to our servers, as well as employing electronic security systems and password protections that guard against unauthorized access. While we use commercially reasonable means to ensure the security of information you transmit to us, we cannot guarantee that such information will not be intercepted by third parties. We may, however, prosecute any unauthorized or fraudulent action to the fullest extent permitted by law.

Spoofing, phishing and other risk

 

Spoofing and phishing and other kinds of attacks are common Internet scams. These scams may occur when you receive an email from what appears to be a legitimate source requesting personal data from you. Please be aware that WESTPOLE will never send you an email requesting you to verify payment card or bank information. If you ever receive an email that appears to be from us requesting such information from you, do not respond to it, and do not click on any links appearing in the email.

How long will we retain your Personal Data?

 

WESTPOLE will retain your personal data for no longer than is necessary for the purposes for which the personal data are processed,  and normally it will stored for 24 (twenty-four) months (2 years) on WESTPOLE’s computer systems (back end site and CRM), after which they will be automatically deleted. Your personal data may be stored for longer periods where necessary for the establishment, exercise or defence of legal claims.

Regarding cookies, the storage times are those indicated in the cookie banner and in the detail of your preferences with respect to the specific selection you have made and which is shown on the section below “Your Cookie Preferences”

Which subjects may become aware of/receive your Personal Data?

 

We may share your personal data in limited circumstances, such as to conduct our business, and share some data (email addresses) in rare circumstances with the Westpole Group companies in order to communicate to you about our companies new products, services, promotions, offers, news, and events.

 

Service Providers

We share your personal data with service providers that help with our business activities, including shipping vendors, billing and refund vendors, payment card processors, marketing and advertising vendors, and companies that help us improve our products and services. We require our service providers to keep your personal data secure. We do not allow our service providers to use or share your personal data for any purpose other than providing services on our behalf. Your personal data may be stored and processed by our service providers only in Italy.

It is our policy to only use third-party support providers that are bound to maintain appropriate levels of data protection, security and confidentiality, and that comply with any applicable legal requirements

Google Analytics (Google)

Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of the WESTPOLE Website , compiling reports and sharing them with other services developed by Google.
Google may use your Personal Data to contextualize and customize ads from its advertising network. Collected Personal Data: Cookies and Usage Data. Place of processing: USA – https://www.google.com/analytics/learn/privacy.html

Legal Requirements and Protection of Our Company and Others

We may share your personal data in other special circumstances, which include situations when sharing is required by law, or we believe sharing will help to protect the safety, property, or rights of WESTPOLE, our customers, our associates, or other persons.

Transfer of your personal data

In the event that all or a part of our Company is merged, sold or reorganized (including transfers made as a part of insolvency or bankruptcy proceedings), your personal data could be shared with the successor Company. We will use reasonable measures to help ensure that any successor treats your information in accordance with this Privacy Policy.

Transfer of Personal Data to third countries extra-UE

Personal Data collected automatically while browsing the pages of the Website or freely provided by the User will not be transferred by WESTPOLE to third countries or international organisations outside the EU.

What are your rights and How you can contact us?

 

WESTPOLE grant you the rights to know the personal data processes and related purposes, as well as the ability to revoke the consent in case the consent is the legal basis of the personal data processing. In particular, the following rights can be exercised (*):

• Right of access to your personal data: you have the right to ask us for confirmation on whether we are processing your personal data, and access to the personal data and related information
• Right to correction: you have the right to have your personal data corrected, as permitted by law
• Right to erasure: you have the right to ask us to delete your personal data, as permitted by law
• Right to restriction of processing: you have the right to request the limiting of our processing under limited circumstances
• Right to data portability: you have the right to receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible
• Right to object: you have the right to object to our processing of your personal data, as permitted by law, under limited circumstances

You also have the right to lodge a complaint with the data protection authority in the European Member State of your habitual residence, place of work or place of the alleged infringement.

(*) These rights apply only for natural persons living in the European Union

In order to exercise any of these rights, please contact us using the “Contact Us” section, or send an email to [email protected], indicating in the subject  of the communication that it is a request for “Exercise of Rights pursuant to EU Regulation no. 2016/679”.

Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply. You have the right to obtain a copy of the Personal Data undergoing processing from the Data Controller. In the event of further copies being requested by the data subject, the Data Controller may charge a reasonable fee based on administrative costs. The right to obtain a copy shall not affect the rights and freedoms of others.

In the event you request to exercise your rights, we may need to verify your identity and, therefore, need you to provide your identifying data and contact data essential to identify and contact you with reference to your request. Possible limitations to the exercise of your rights, and to the consequent obligations of WESTPOLE, can be imposed by the applicable law.

Cookie Policy

 

Want to update your cookie settings? Go to the section: “Your cookie preferences“

 

We use cookies on our Website. A cookie is a small piece of data that a Website stores on the visitor’s computer or mobile device. When you use the Website, one or more cookie is sent to your device. We use both session cookies and persistent cookies, as well as First Party and Third-Party cookies:

• First-Party cookies are cookies set by the Website you’re visiting. Only those Website can read them. In addition, a Website might potentially use an external service to analyse how people are using the site.
• Third-Party cookies are cookies set by other parties, on the visitor of our Website
• Session cookies are cookies saved on your computer which are deleted automatically when you close your browser
• Persistent cookies are cookies saved on your computer which are not deleted automatically when you close your browser. Persistent cookies are used to re-identify you upon your next visit.

 

Your web browser may provide you with some options regarding cookies. Please note that if you delete, or choose not to accept, cookies, you may not be able to utilize the features of the services provided via the Website. We do not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who visit our Website or use the services provided via our Website.

 

How we use cookies and similar technologies, in particular, for services adapted to your profile:

 

Strictly necessary cookies. Strictly necessary cookies let you move around the Website and use essential features like secure areas, shopping baskets and online billing. We use strictly necessary cookies to:

• Remember information you’ve entered on forms when you visit different pages in a single web browser session
• Identify you as being logged in to our Website
• Make sure you connect to the right service on our Website when we make any changes to the way the Website works

 

Cookies we have defined as strictly necessary will NOT be used to:

• Gather information that could be used to advertise products or services to you
• Remember your preferences or username beyond your current visit
• Personalize our Website and concerned services provided, such as remembering your data so that you will not have to re-enter it during your use of, or the next time you use, our Website and concerned services provided

 

Other Cookies that can be used to (if you accept them):

• Personalize our Website and concerned services provided, such as remembering your data so that you will not have to re-enter it during your use of, or the next time you use, our Website and concerned services provided
• Provide customized advertisements, content, and information adapted to your profile
• Monitor and analyse the effectiveness of our Website and the concerned services provided and marketing activities adapted to your profile
• Monitor aggregate site usage metrics such as total number of visitors and pages viewed
• Track your entries, submissions, and status in any activities offered through our Website and concerned services (services adapted to your profile). Tracking technology also helps us manage and improve the usability of the Website, detecting whether there has been any contact between your computer and us in the past and to identify the most popular sections of the Website

 

You may also disable the installation of cookies by configuring your browser appropriately. For more information, please read the specific information made available (by Chrome, by Explorer, …) Please be aware that restricting cookies may impact your user experience and may prevent you from using parts of our Website or services.

 

Use of pixels in emails. Our emails often contain a single, campaign-unique “web beacon pixel” to tell us whether, and how many times, our emails are opened and verify any clicks through to links or advertisements within the email. We use this information for purposes including:

• Determinate which of our emails are more interesting to users
• Determinate users’ activity and engagement with our products and services
• Informe our advertisers (in aggregate) how many users have clicked on their advertisements

 

The pixel will be deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, you should select to receive emails from us in plain text rather than HTML via your email provider settings.

Notification of changes to Privacy Policy

 

We reserve the right, in our sole discretion, to modify this policy at any time. We will notify you of material changes to this Privacy Policy by posting an advice on the Website. We encourage you to periodically review this Privacy Policy to stay informed about how we are using and protecting the personal data we collect. The effective date of this version of the Privacy Policy is the one indicated in the “Date of Last Modification”.

If you do not accept the changes made to this Privacy Policy, you must stop using the Website and request WESTPOLE to remove your Personal Data. Unless otherwise specified, the aforementioned Privacy Policy will continue to apply to the Personal Data collected up to that time.

 

WESTPOLE S.P.A.

_______________________________________________________________________________

Date of Last Modification: 01/03/2021