The website aspesi.com is managed by The Level Group S.r.l. ("TLG"), an Italian company with its registered office in Italy at Via Santa Sofia 27, 20122, Milan, business register number, tax code and VAT number 07234250962.
TLG controls the use of aspesi.com users' personal data together with Alberto Aspesi & C. SpA, an Italian company with registered office in Italy at Via Salvatore Quasimodo n. 53, 20025 Legnano (MI), business register number, tax code and VAT number 02683610139 (jointly referred to as "TLG and Aspesi").
1. Our Policy
Everyone has the right to protection of his/her personal data. TLG and Aspesi respect its users' right to be informed regarding the collection of and other operations involving their personal data. In using data that may directly or indirectly identify you personally, we will apply a principle of strict necessity. For this reason, we have designed aspesi.com in such a way that the use of your personal data will be kept to a minimum and will not exceed the purposes for which your personal data was collected and/or processed; we do not process your personal data when we can provide you with services through the use of anonymous data (such as marketing research made for improving our services) or by other means which allow TLG and Aspesi to identify you, apart from when it is strictly necessary or upon request by competent public authorities or the police (for example, in case of traffic data or your IP address).
TLG and Aspesi determine the purposes and means for processing your personal data, including security measures, as TLG and Aspesi control aspesi.com users' personal data.
2. Who Processes Your Personal Data
TLG and Aspesi control the use of aspesi.com users' personal data; TLG and Aspesi autonomously determine the purposes and means of processing personal data and the instruments used, including those for security measures. Due to organizational and operational purposes only, we have appointed certain entities that will also process personal data belonging to aspesi.com's users for purposes strictly connected to the performance of services on aspesi.com, including the sale of products.
The above mentioned processors have been chosen by TLG and Aspesi because of their experience in processing personal data and they provide sufficient guarantees regarding compliance with data processing laws (including the technical security measures governing the processing to be carried out). In processing the personal data of aspesi.com's users, the processors shall act only on instructions from TLG and Aspesi. We regularly check that our processors comply with our instructions and that they continue to provide sufficient guarantees regarding their full compliance with the provisions on personal data processing.
Aside from the companies appointed for personal data processing, your information will be made available also to third parties, autonomous controllers, for purposes related to supplying services requested by user (for example, for purchase transactions). For more information on the matter, see section 5 (To Whom Your Personal Data Will Be Disclosed).
3. How We Use Personal Data and for What Purposes
Your personal data are collected and processed by TLG and Aspesi for purposes which are strictly connected use of the Website, its services and to purchase products on aspesi.com. However, your personal data may also be used for other processing operations within the limits of such purposes.
In particular, your personal data shall be processed for the following purposes:
A. when you register with our website we collect your personal data (for example, your personal details, password, e-mail address, gender) through the registration form (My Account) in order to provide you with services in aspesi.com’s reserved access areas and to send you our Newsletter, when specifically requested;
B. when you require assistance from our Customer Service area, we collect your personal data (for example, your name and surnames, e-mail address and password) for purposes strictly necessary to providing you with services related to aspesi.com and to the purchase of products on aspesi.com;
C. when you execute purchasing procedures for products sold on aspesi.com, we collect your personal data (such as personal details, e-mail address, address, Credit Card numbers, bank code, tax code and telephone number) on your order form only for the purpose of selling the products ordered by you;
D. when you require technical assistance, we collect your personal data in order to provide you with information on browsing, browser compatibility and viewing or loading aspesi.com web pages;
E. when creating a Wish List, we process your personal data in order to customize our services for the purchase of products on aspesi.com.
Your personal data is mostly processed by electronic means and in some circumstances by paper-based means, such as when the processing of your personal data is required for preventing fraud on aspesi.com. Your personal data shall be stored in a way which allows TLG and Aspesi to identify you for the period necessary for the purposes which the data was collected for and subsequently processed and, in any case, in accordance with applicable law. Please report any modification of your personal data to email@example.com, in order to ensure that your personal information is always accurate and up-to-date, relevant and complete.
Your personal data shall not be disclosed to third parties for purposes which are not permitted by law or without your explicit consent.
Your personal data may only be disclosed to third parties when it is necessary for processing an order. Moreover, your data may be disclosed to the police or to judicial authorities, according to law and upon a formal request by such entities, for example in the event TLG and Aspesi need to prevent fraud on aspesi.com (anti-fraud services).
Data processors will also have access to your personal data as stated in section 2 for the specific purposes stated therein. In all the above circumstances, your consent for data processing is not required. Your personal data will not be transferred abroad to non-EU countries that do not ensure an adequate level of protection of individuals. Should this be necessary in order to supply services or to execute a contract for the purchase of products, your personal data shall be transferred to such non-EU countries only after the execution of specific contracts between TLG and Aspesi, and such entities in accordance with applicable law and regulations.
We wish to inform you that TLG and Aspesi shall process its users' personal data for purposes that are strictly connected to the supply of services on aspesi.com, execution of contracts related to the sale and purchase of products on aspesi.com and, after receiving your consent, to send you information on new commercial initiatives which are strictly connected to the web site's activities and services.
TLG and Aspesi shall process your personal data for direct marketing purposes, including by e-mail, only after receiving your consent. TLG and Aspesi may have access to third parties' personal data which was directly disclosed by their users, for example when a user bought a product to be sent to a friend, when the user paying for the product is different from the recipient of the product, or when a user wishes to recommend to a friend a service of aspesi.com or the sale of a particular product.
4. What Happens if You Do Not Disclose Your Personal Data to TLG and Aspesi
Granting your personal data to TLG and Aspesi (in particular, your personal details, your e-mail address, your address, your Credit/Debit Card numbers and bank code and your telephone number) is necessary for processing your order for the purchase of products on aspesi.com, supplying other services provided on the web site upon your request, or when your personal information is needed to fulfill obligations required by law or regulations.
The refusal to provide TLG and Aspesi with some of your personal data necessary for performing the above purposes may consequently prevent TLG and Aspesi from processing your order for the purchase of products sold on aspesi.com or from supplying other services provided on aspesi.com, such as Customer Care services, sending the Newsletter, using the Wish List or fulfilling obligations required by law and other regulations. Therefore, failing to provide data may constitute, in some cases, a legitimate and justified reason for not processing your order for the purchase of products sold on aspesi.com or not providing aspesi.com’s services.
Disclosure of further personal data to TLG and Aspesi other than that required for fulfilling legal or contractual obligations or for providing the services requested, is, on the contrary, optional and does not have any effect on the use of the web site and of its services or on the purchase of products on aspesi.com.
In some circumstances and if required, from time to time we will duly inform you if the personal data you are disclosing to TLG and Aspesi is compulsory or optional. We will point out to you whether the disclosure of your data is compulsory or optional by marking with an appropriate symbol (*) the information that is compulsory or data needed for providing the required services on aspesi.com and for the purchase of products on aspesi.com. Failing to provide optional personal data will not imply any obligation or disadvantage to our users.
5. To Whom Your Personal Data Will Be Disclosed
Personal data will be disclosed to third party companies that provide, on behalf of TLG and Aspesi, specific services as data processors or to other recipients of personal data collected by TLG and Aspesi that autonomously process your personal data only for the performance of a contract for purchasing products on aspesi.com and only when such purpose does not exceed the purposes for which your personal data was collected and subsequently processed and, in any case, according to applicable laws and regulations.
Personal data will not be disclosed to third parties or disseminated or transferred without informing our users of such disclosure/dissemination/transfer, without their consent and, in any case, in accordance with the law.
6. How We Collect Your Data on aspesi.com
When you are using aspesi.com, some personal data might be collected automatically (through "cookies"), for example, when we automatically collect users' IP addresses and other information regarding the users' data traffic or the users' preferences in the choice of services provided on this web site and of the products purchased through the provided services. This information and data are collected directly and automatically by the web site as part of its operational functions. This information and data are then processed in a collective and anonymous way for commercial purposes in order to optimize the services provided on aspesi.com for the needs and preferences of the web site's users.
In other circumstances, TLG and Aspesi directly collect personal data and information from its users when they register online with aspesi.com or when they send purchase orders of products sold on the web site in order to finalize e-commerce transactions. TLG and Aspesi will process such data only for the purposes and within the limits of what is stated in the section regarding data collection and may be disclosed to third parties only for the purposes related to providing the services requested by the user.
7. Security Measures
It is advisable that your computer be provided with software devices that protect network data transmission/receipt (such as updated antivirus systems) and that your Internet service provider take appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering).
9. Opt-in/Opt out
TLG and Aspesi process your personal data only after receiving your consent, freely expressed, in order to send you advertising material and direct marketing or other commercial communications, including by e-mail, which do not fall within customer requested services provided by aspesi.com. Each time your consent is required, we will inform you in advance and we will give you the option to either provide or refuse your consent for the use of your personal data, including your e-mail address, for the above purposes, by ticking the appropriate boxes.
We wish to inform you that TLG and aspesi.com may process your personal data also without your consent in certain circumstances provided by law, such as when such processing is necessary for performing a legal obligation to which TLG and aspesi.com are subject or when such processing is necessary for performing obligations undertaken in contracts with the users (such as, for example, if you purchased products on aspesi.com or if you asked to use specific services through our web site).
In any case, we wish to inform you that TLG and Aspesi guarantee that its users may exercise, at any time and without having to state their reasoning, their right not to receive future communications connected to particular services upon request.
10. Your Right to Access Personal Data and Further Rights
You are entitled to obtain, at any time, confirmation from TLG and Aspesi as to whether or not data relating to you is being processed, whether the data is not yet registered, and the communication in intelligible form of the data undergoing processing.
Moreover, you are entitled to receive from TLG and Aspesi information on the source of your personal data; the purposes and way of processing your personal data; the logic involved in any electronic data processing; details of the data controller and of the data processors; the names of the entities and categories of entities to whom your personal data may be disclosed or who may access your personal data, for example, as a data controller or a party so appointed.
A. the updating, adjustment or, when you have an interest in such, the integration of your personal data;
B. the deletion, the transformation into an anonymous form or blocking of your personal data (unlawfully processed), including data which does not need to be stored for the purposes for which it was collected and subsequently processed;
C. the confirmation that the operations above have been reported (together with the contents of the same) to whom the data was disclosed or disseminated, except when it becomes impossible or if the means used are clearly disproportionate to the right’s protection.
You are entitled to object, in whole or in part:
A. for legitimate reasons, to the processing of your personal data, even if it is related to the purposes for which it was collected;
B. to the processing of your personal data for advertising or direct marketing purposes or in order to carry out marketing research or commercial communications.
You may freely exercise your rights at any time, provided that you do so in compliance with applicable laws, by sending your request to TLG and Aspesi at the following e-mail address: firstname.lastname@example.org. We will reply to you as necessary.
11. Links to Other Web Sites
If you wish to receive further information on how TLG and Aspesi process your personal data, please send an e-mail to email@example.com. Should you require any further information on your rights and on personal data protection law you can contact the personal data protection authority at the following address: www.garanteprivacy.it.
13. Governing Law