Privacy Policy

Information on the processing of personal data

LDA FASHION S.R.L. Via delle Genziane, 13/E 00012 Guidonia Montecelio (RM) PEC ldafashionsrl@pec.gocciagroup.it VAT NUMBER 14345861000 Information pursuant to art. 13 and 14 of the European Regulation 679/2016 on the protection of personal data [GDPR][GDPR] ). In accordance with the requirements set by the General Regulations on the protection of personal data, the Data Controller provides the data subject with the following information in relation to the processing of personal data carried out.

DATA CONTROLLER
Proprietor	Mr. Ravicini Andrea
Address	Via delle Genziane 13/E – 00012 Guidonia Montecelio (RM)
VAT NUMBER	RVCNDR82P05L182C
CONTACTS	PEC: ldafashionsrl@pec.gocciagroup.it
Legal representative	Ravicini Andrea
Privacy referent	Ravicini Andrea (ldafashionsrl@pec.gocciagroup.it)
Data protection referent	Not present
Joint data controller	No co owner present
If you intend to request further information on the processing of your personal data or for the possible exercise of your rights, you can contact the aforementioned Privacy Referent in writing directly.

CATEGORIES OF INTERESTED PARTIES
List of categories of interested parties	Clients or users, potential clients, partners, associates and subscribers, minors

TREATMENT CARRIED OUT
Online commercial activities with or without customer loyalty
DESCRIPTION	Activities relating to the processing of personal data for the production, distribution and sale of goods or services online. It can provide for customer loyalty by signing up for a loyalty program.

ORIGIN,PURPOSE,LEGAL BASE AND NATURE OF DATA PROCESSED
Origin	The data is partly collected from the interested party and partly collected from third parties. escription of the source: the data can be collected through a website (s) of ours or of third parties and managed by us and through our management systems. The data comes from a publicly accessible source
Purpose	1. Mail order or telephone sale – Consent received from the data subject during the collection of personal data by acceptance included in the information. In case of non-consent, no mail order or telephone sales will be made. 2. Sale electronically or via radio and television – Consent received from the interested party during the collection of personal data by acceptance included in the information. In case of non-consent, the sale will not be carried out electronically or by radio and television. 3. Customer management – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. 4. Fulfillment of tax and accounting obligations – Acquisition of data for printing and sending the invoice in both paper and digital form. 5. Dispute management – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. 6. Monitoring of contractual obligations – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. 7. Scheduling of activities – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. 8. Marketing (analysis and market surveys) – Consent not necessary as the communications, for the purpose of direct sales of their products / services or for the purpose of satisfaction analysis or market surveys, use the e-mail coordinates collected from the interested party in the context of the sale of a product or service similar to those of the sale and without the express refusal by the interested party to such use, initially or on the occasion of subsequent communications. In each communication, information is given of the possibility of opposing the processing at any time (so-called opt out). 9. Advertising – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. 10. Promotional activities – Consent received from the interested party during the collection of personal data by acceptance included in the information. In case of non-consent, the data subject will not be profiled for promotional purposes. 11. Detection of the degree of customer satisfaction – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. 12. Radio and television information – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. 13. Information to customers of new services / products – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. 14. Sending information and / or advertising material also by telephone or internet and instant messaging applications such as whats app, messenger, telegram and the like – Consent received from the data subject during the collection of personal data by acceptance included in the information. In case of non-consent, the information and / or advertising material will not be sent. 15. Electronic information – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. 16. Consulting activities – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. 17. Service provision – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out
Legal base	For the purpose 1,2,3,5,6,7,9,10,11,12,13,14,15,16,17: Consent of the interested party. For the purpose 4 : The treatment is necessary to fulfill a legal obligation to which the data controller is subject. For the purpose 8 : The treatment is necessary for the continuation of the legitimate interest of the data controller and third parties
Personal data processed	Topics of interest, Tax code and other personal identification numbers, Telephone contact, Bank details, Contact and communication data, Behavioral data, profiles of users, consumers, taxpayers, etc., Residential address, E-mail address, Name , address or other elements of personal identification, Declared profession, Video surveillance video recordings, Sex m / f
The “particular” data (sensitive data) are those defined by articles 9 and 10 of Regulation 2016/679 / EU (“GDPR”). These data are processed in compliance with the provisions of the GDPR as well as in light of the General Authorizations issued by the Authority for the protection of personal data.
Particular data processed	–
Legal base art. 9

RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL DATA
Categories of recipients	The communication of your personal data, carried out on the legal bases provided for in Article 6 of Regulation 2016/679 / EU, to the following third parties is envisaged:
	Judicial offices, Consultants and freelancers also in associated form, Companies and enterprises, Armed forces, Police forces, Employers, Associations of entrepreneurs and companies, Parent companies, Subsidiaries and associated companies, Associations and foundations, Associated and registered shareholders, Judicial authority, Revenue Agency, Internal Managers, External Managers, Authorized subjects, Private subjects (natural or legal persons), maintenance companies or supply of goods and services.
	These bodies, organizations, companies and professionals act as Data Processors appointed by Mr. Ravicini Gabriele or are themselves Data Controllers of the personal data transmitted to them.
Your personal data, or the personal data of third parties in its ownership, may also be disclosed to external companies, identified from time to time, to which Mr. Ravicini Andrea entrusts the execution of obligations deriving from the assignment received to which the only data necessary for the activities requested of them. All employees, consultants, temporary workers and / or any other “natural person” who, authorized to process, carry out their activities on the basis of the instructions received from Mr. Ravicini Andrea, pursuant to art. art. 29 of the GDPR, are designated “Persons in charge of processing” (hereinafter also “Persons in charge”). To the Officers or Managers, possibly designated, Mr. Ravicini Andrea gives adequate operating instructions, with particular reference to the adoption and compliance with security measures, in order to ensure the confidentiality and security of the data. Precisely with reference to the protection aspects of personal data, you are invited, pursuant to 33 of the GDPR to report to Mr. Ravicini Andrea any circumstances or events from which a potential “breach of personal data (data breach)” may arise in order to allow an immediate assessment and the adoption of any actions aimed at countering this event by sending a communication to Mr. Ravicini Andrea at the addresses indicated above. The obligation of Mr. Ravicini Andrea to communicate the data to Public Authorities on specific request remains unaffected.

TRANSFER ABROAD
Transfer towards foreing countries (outside ue) or international organizations	·Arizona · Transfer subject to adequate guarantees (Article 46). ·Code of conduct approved pursuant to Article 40, together with the binding and enforceable commitment by the data controller or processor in the third country to apply the guarantees adequate, also with regard to the rights of the interested parties. ·Personal data is transmitted to a country in the United States of America through the use of a CRM software owned by a third party established in the U.S.A.
The transfer abroad of your personal data can take place if it is necessary for the management of the assignment received. For the processing of the information and data that will eventually be communicated to these subjects, the equivalent levels of protection adopted for the processing of the personal data of its employees will be required. In any case, only the data necessary for the pursuit of the intended purposes will be communicated and the regulatory instruments provided for by Chapter V of the GDPR will be applied.

METHODS, PROCESSING LOGICS AND STORAGE TIMES
Duration of the treatment	The data for the purpose of loyalty in the strict sense that is necessary to allow adherence to the loyalty program and for the management of the loyalty card will be processed and stored until the administrative duration of the relative program, or in any case until cancellation occurs and / or termination by the member. In the event of any withdrawal, disabling due to non-use within a certain time frame, expiry or return of the card (based on the provisions of the separate Loyalty Program Regulations), the retention period of personal data for exclusive administrative purposes (and not including profiling or marketing) will not exceed one quarter (without prejudice to any specific legal obligations on the conservation of accounting documentation). In such cases, the Data Controller has implemented suitable automatic data cancellation mechanisms, including by third parties to whom they may have been communicated. For other purposes, the processing will last no longer than necessary for the purposes for which the data were collected. The filming data are kept for a maximum duration of 24 hours, with subsequent automatic deletion.
Your data is collected and recorded in a lawful and correct manner for the purposes indicated above in compliance with the principles and requirements set out in art. 5 c 1 of the GDPR. The processing of personal data takes place using manual, IT and telematic tools with logic strictly related to the purposes themselves and, in any case, in order to guarantee their security and confidentiality.

NATURE OF THE PROVISION
The processing of personal data will be carried out for the following purposes:
Purposes that do not require consent	– Fulfillment of tax and accounting obligations – Acquisition of data for printing and sending the invoice in both paper and digital form. – Marketing (market analysis and surveys) – Consent not necessary when communications, for the purpose of direct sales of their products / services or for the purpose of satisfaction analysis or market surveys, use the e-mail coordinates collected by the interested party in the context of the sale of a product or service similar to those of the sale and without the express refusal by the interested party to such use, initially or on the occasion of subsequent communications. In each communication, information is given of the possibility of opposing the processing at any time (so-called opt out).
Purposes that require consent	– Mail order or telephone sales – Consent received from the interested party during the collection of personal data by acceptance included in the information. In case of non-consent, no mail order or telephone sales will be made. – Sale electronically or via radio and television – Consent received from the interested party during the collection of personal data by acceptance included in the information. In case of non-consent, the sale will not be carried out electronically or by radio and television. – Customer management – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. – Dispute management – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. – Monitoring of contractual obligations – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. – Scheduling of activities – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. – Advertising – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out – Promotional activities – Consent received from the interested party during the collection of personal data by acceptance included in the information. In case of non-consent, the data subject will not be profiled for promotional purposes. – Detection of the degree of customer satisfaction – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. – Radio and television information – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. – Information to customers of new services / products – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. – Sending information and / or advertising material also by telephone or internet – Consent received from the interested party during the collection of personal data by acceptance included in the information. In case of non-consent, the information and / or advertising material will not be sent. – Electronic information – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. – Consulting activity – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out. – Provision of the service – Consent explicitly acquired by the interested party, stored in our management systems and in our specific assets, in the absence of which the described activities are not carried out.
	Only with your explicit consent to be expressed at the bottom of this information, the data, the purposes of which require consent, will be processed. The provision of data is in any case optional and will not result in prejudice in relation to the contractual relationship in place with the Data Controller.
Your consent is not required for the data collected and used for needs related to the execution of activities related to the contractual relationship and compliance with the legal obligations indicated. Failure to communicate the aforementioned personal data will make it impossible to follow up on the relationship in question. Your consent is not required for the data collected and used for the legitimate interest of the Data Controller (letter f, art.6, of the GDPR). The communication of the above personal data is optional but necessary for the execution of the services offered by the Data Controller. Any refusal to communicate such data will make it impossible to provide all or part of the requested services.

RIGHT OF THE INTERESTED PARTIES (Artt. da 15 a 22 of the GDPR)
Right of access	The interested party has the right, in accordance with the provisions of Articles from 15 to 22 of the GDPR to request the owner access to their personal data.
Right of rectification	The interested party has the right, in accordance with the provisions of Articles from 15 to 22 of the GDPR to request the owner to rectify their personal data.
Right of annulment	The interested party has the right, in accordance with the provisions of Articles from 15 to 22 of the GDPR to request the owner to delete their personal data.
Right of limitation	The interested party has the right, in accordance with the provisions of Articles from 15 to 22 of the GDPR to request the owner to limit the data concerning him.
Right of opposition	The interested party has the right, in accordance with the provisions of Articles from 15 to 22 of the GDPR to oppose their treatment.
Right of portability	The interested party has the right, in accordance with the provisions of Articles from 15 to 22 of the GDPR to exercise their right to data portability.
Right of revocation	The interested party has the right, in accordance with the provisions of Articles from 15 to 22 of the GDPR to exercise their right to withdraw consent.
Right of complaint	The data subject has the right under Article 77 of the GDPR to exercise his or her right to complain to the supervisory authority.

AUTOMATED PROCESS
Does an automated process exist?	Yes
Automated processes or profiling methods	Without prejudice to the fact that even in the case of the consent of the interested party we will not proceed with the processing (however prohibited for profiling purposes) of data suitable for revealing the state of health and sexual life, we inform you that the methods of processing will in any case be relevant and not exceeding the type of goods marketed or services rendered. The profiling activity may concern “individual” personal data or “aggregate” personal data deriving from detailed individual personal data. These treatments may be carried out using personal data that are also aggregated according to predefined parameters according to business needs. Such data may include varied personal information, including contractual data and data relating to consumption made, purchases made, habits and volumes of spending, supply levels of goods and / or services, etc from which it is possible obtain further information referable to each interested party (for example, consumption range, level of expenditure incurred at regular intervals, etc.). We recall with particular attention the fact that the provision of personal data and consent to communication to third parties for the purposes described above are absolutely optional and optional (and in any case can be revoked without formalities even after the performance), and failure to provide it will not result in consequences other than ‘impossibility for the data controller to proceed with the aforementioned profiling. Even if you have given your consent to authorize the Data Controller to pursue the profiling purposes, you will still be free to revoke it at any time, by sending a clear communication to that effect without any formalities. Following the receipt of this opt-out request, it will be the responsibility of the Data Controller to promptly remove and delete your data from the databases (the latter in any case not interconnected or a source of intertwining and comparisons of data with those used for loyalty in strict sense) and inform any third parties to whom the data have been communicated for the same cancellation purposes. The simple receipt of your cancellation request will automatically be valid as confirmation of cancellation.
Legal base	Explicit consent of the interested party

The Data Controller reserves the right to make any changes deemed appropriate or made mandatory by current regulations to this information on the processing of personal data, at its sole discretion and at any time. On such occasions, users will be duly informed of the changes that have occurred.