PRIVACY POLICY

Privacy is not something that I’m merely entitled to, it is an absolute prerequisite”
– Marlon Brando - Actor & Film Director

Suite106 takes the privacy of our customers very seriously. We value our customers and respect your privacy.

Please read our Privacy Policy carefully, as it applies each time you access the web site and decide to navigate through it and use its services, regardless of whether or not you purchase products. This Privacy Policy provides you with all information that is useful for understanding how we collect and use the information identifying users of suite106.it.


Pursuant to art. 13 of the European Regulation (EU) 2016/679 (hereafter GDPR), and in relation to the personal data of which Suite 106 will become available, we inform you as follows.

Data owner

The owner of the data processed by this site is Ediltre srl, which is headquartered in Italy at Via Torino 95 - 00184 Roma, Trade and Companies Register, Tax ID  No. and VAT Registration No. 05475231006, in quality of company licensee of the registered trade-mark “suite106”. The owner independently decides on the purposes and methods of the processing, as well as on the security procedures to be applied to guarantee confidentiality, integrity and availability of the data.

Ediltre srl has not appointed a person responsible for the protection of personal data (RPD or, data protection officer, DPO).

Optional or mandatory provision of data

Providing Suite106 with your personal data, which is requested at various collection times, may be necessary to carry out the purposes indicated in the appropriate information, or this may be optional. 
The mandatory or optional nature of such provision is specified by the symbol(*) which is placed alongside information which is mandatory.
Any refusal to provide Suite106 with such data when this is marked mandatory renders it impossible to pursue the main purpose of that collection: such refusal could, for example, make it impossible for Suite106 to perform the purchase agreement, or to provide other services that are available on suite106.it. Supplying Suite106 with subsequent data, other than data marked as essential, is conversely optional, and does not result in any consequences in terms of completing the main purpose of such collection.

Data controllers

At the present time, some of the data controllers who process your data are as follows:

- Suite106, for processing data needed to provide call centre and customer care services to our users;
- Netsons/Supernova srl for processing data concerning management and server maintenance services for Suite106;

- DHL, which handles the processing of data needed to perform shipping, delivery and returns for products purchased on our web site; 


Your rights

According to Art. 7 of Legislative Decree 196/2003, you always have the right to obtain confirmation from Suite106 as to whether or not personal data concerning you was processed, even if it has not yet been recorded, and to be communicated such data in an intelligible form.
You also have the right to obtain information from Suite106 about the source of your personal data; the purpose and method of processing your personal data; the logic applied for processing performed with the aid of electronic tools, identification details of the data owner and controllers, an indication of the subjects or categories of subject for which personal data may be communicated or which could become known by people acting as, for example, data controllers.

Furthermore, you always have the right to obtain from Suite106:

a)
request access to your personal data and information relating to them, updating, rectification, integration of your personal data;
b) the cancellation, conversion to an anonymous form or blocking of any personal data that was processed in violation of the law, including data which it is not necessary to store for the purposes for which said data was collected or subsequently processed;
c) an attestation that notice of the operations indicated in letters a) and b) was given, including as concerns their content, to those people whose data was communicated or disseminated, except in the event that such measure proves to be impossible or entails using means which are clearly disproportionate with regard to the right protected.

You nevertheless have the right to object, in part or in full:
a) in the cases in which the legal basis of the treatment is the contract or consent, and the same is made by automated means - that your personal data are processed in a structured and readable form by automatic device, also in order to communicate such data to another data controller (so-called right to the portability of personal data);

b) to propose a complaint to a supervisory authority (Authority for the protection of personal data, www.garanteprivacy.it).

You have, however, the right to object in whole or in part:

a) for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of the collection;

b) to the processing of personal data concerning you for the purpose of sending advertising materials or direct marketing or for carrying out market research or commercial communication.

You also have the right to withdraw your consent at any time, limited to the cases in which the processing is based on your consent for one or more specific purposes and concerns common personal data (for example date and place of birth or place of residence), or particular categories of data (eg data revealing your racial origin, your political opinions, your religious beliefs, your health status or your sex life). The treatment based on consent and carried out prior to the revocation of the same preserves, however, its lawfulness;

You can freely and at any time exercise your rights, with a written request addressed to Suite106 - to the e-mail address customercare@suite106.it - ​​to which we will promptly reply.

To ensure that your personal data is always accurate, up-to-date, relevant and complete, please report to us - at customercare@suite106.it - ​​any changes that have occurred.

Those shown up here are the minimum information that Suite106 is obliged to provide: for any further information regarding the processing of your personal data by Suite106, we invite you to read this Privacy Policy in its entirety.


A summary of our privacy policy

The following are the principles on which our privacy policy is based:

1. processing data exclusively for the purposes and according to the methods illustrated in the information presented when the data was collected;
2. only using the data for purposes in addition to those for which it was specifically released when the user has expressly consented;
3. only providing access to data to third parties for purposes which are essential for performing the service requested and within the context of appointing a data controller; not communicating data, assigning it or transferring it to third parties for their own specific processing unless the users have been informed in advance and have given their consent;
4. responding to requests for cancelling, changing or adding the data provided, opposing the processing of data for the purposes of sending commercial and advertising information;
5. insuring proper and lawful data management, safeguarding the privacy of users, as well as applying appropriate security measures to protect the confidentiality, integrity and availability of the data provided.

How and why we process your personal data

Your personal data is processed using primarily electronic and telematic means by Suite106 and by other parties who, having been appropriately selected for their reliability and expertise, perform operations which are instrumental to pursuing purposes that are strictly related to use of the web site, its services and to the purchasing of products through the web site.

Generally, the data is processed to perform the following services, which are available by accessing our site:
1. registration or subscription to services offered by the Suite106 world;
2. order fulfilment and related activities;
3. management of payments;
4. management of your requests: technical, of a commercial nature, regarding the progress of your orders, as well as requests for information in the broader sense;
5. making contact with our service professionals;
6. sending, upon your consent, and for marketing purposes, commercial communications through various channels, both electronic and telematic (e-mail, sms) as well as using traditional methods (paper-based mail, telephone).

7. sending, upon your consent, for profiling purposes to improve your navigation experience on the site, commercial proposals which are in line with your interests. Profiling is carried out, for example, through the use of third party cookies. To that end, we ask that you read our Cookie Policy.

In processing data which could directly or indirectly identify you, we seek to follow a principle of strict necessity.
Therefore, we have configured the site in such a way that your personal data is reduced to a minimum.

Your data will be communicated to third parties only with your express consent, except in cases where communication is mandatory by law or is necessary for the purposes prescribed by the law to pursue purposes for which the consent of the interested person is not requested; in these cases, data may be made available to third parties that will independently process it, and only for the aforementioned purposes (for example, in the case of a request made by the police or  judiciary, or other competent entities, or to perform obligations deriving from the contract entered with you).

Any processing purpose other than the one specified for which you have provided your personal data shall be demonstrated in the information and shall only be pursued by Suite106 upon obtaining your express consent.

Lastly, we inform you that your personal data will not be transferred abroad to countries that do not belong to the European Union, or which do not provide adequate levels of personal protection. In the event this is necessary to provide you with services, or to enter into a contract with Suite106 to purchase products, we assure you that the transfer of your personal data to countries which do not belong to the European Union or which do not provide an adequate level of protection shall be performed only prior to the signing by Suite106 and said parties of specific contracts in accordance with the applicable law and regulations.

Suite106 may end up processing personal data of third parties which has been directly communicated to Suite106 by its own users, for example in the case where a user has purchased a product to give to a friend, or when the party paying the price to purchase the product is different from the party for whom the product is intended, or even when the user intends to inform a friend of a service on suite106.it or of a sales offer of a particular product.
On these occasions you are responsible for obtaining the consent of the person whose data is indicated prior to communicating it to Suite106 and to informing said party about this Privacy Policy, because you will be the sole party responsible for communicating information and data relating to third parties, without them having expressed their consent or for any use by them which is incorrect or contrary to law.
We inform you that these parties’ consent is not necessary when the data is communicated to Suite106 to enter the contract, with Suite106, in favour of the third party.

Security measures

We adopt adequate security measures to reduce to a minimum the risks of destruction or loss, including accidental – of data, unauthorized access or unapproved processing or processing which does not conform to the purposes of collection indicated in our Privacy Policy.

However, Suite106 may not guarantee to its users that the measures adopted for the security of the site and the transmission of the data and information on the site limit or exclude any risk of access without consent, or dissemination of data by devices belonging to the user: we advise you to make sure that your computer is equipped with adequate software to protect against the transmission in data networks, whether through input or output (such as updated antivirus systems) and that your Internet service provider has adopted suitable measures on network data transmission security (such as, for example, firewalls and spam filters).


Link to other web sites

Our site contains links to other web sites which may not have any connection to us.


Suite106 does not control nor does it perform monitoring operations on these web sites and their content.
Suite106 may not be held liable for the content of these sites and for the rules adopted by them, including with regard to your privacy, and to the processing of your personal data during your navigation activity. We ask that you thus pay attention, when you connect to these sites through the links on our site, and that you carefully read their conditions of use and privacy policies. Our Privacy Policy does not apply to third party web sites. Our site provides links to these sites only to facilitate a user in his/her search and navigation, and to facilitate hypertext links to other sites. Activating the links does not constitute any recommendation or suggestion by Suite106 to access and navigate to these sites, nor does it provide any guarantee as to their content, services or the goods provided and sold by them to Internet users.

Legislative references

The processing of your personal data is carried out by Suite106 in full compliance with the regulations on the subject provided for by the Regulation (EU) 2016/679 general regulation on data protection, the rules on the processing of personal data and Italian measures of the Supervisory Authority Italian (http://www.garanteprivacy.it).


Modification and updates to the Privacy Policy

Suite106 may modify or simply update all or part of the site’s Privacy Policy, including in consideration of the modification of legal rules or regulations which govern this subject area and protect your rights. Changes and updates to the Privacy Policy will be published on the web site as soon as they are adopted and will be binding as soon as they are published on the web site. Therefore, please access this section regularly to check on the publication of the most recent and updated Privacy Policy.


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