This information is given in accordance with art. 13 of Regulation 2016/679 (GDPR), pursuant to art. 13 of the d.lgs. n. 196/2003 (Code on the protection of personal data) to users who access the website actiondirecte.it and is related to all personal data processed in the manner indicated below.

Data controller

The data controller is Action Directe S.C., based in Via Valprato 68, 10155 Turin (TO).

Types of data collected

The personal data processed are collected as they are provided directly by the data subject or provided automatically.

The data provided directly by the data subject are all personal data that are provided to the Data Controller in any way, directly by the data subject. In particular, the following personal data are collected and processed:

First name
Last name/Surname
Billing and shipping address
Phone number
email address
VAT and social security number, only if invoice required

The data collected automatically are navigation data. Such data, although not collected in order to be associated with the identity of the user, could indirectly, through processing and association with data collected by the Data Controller, allow its identification.

Following the sending of newsletters, the platform allows the Client to detect the opening of a message and the clicks made within the newsletter itself, along with details of the IP and browser/ device used. The collection of this data is fundamental for the functioning of the systems of implicit renewal of the treatment (see the item Modality of the Treatment) and an integral part of the operation of the sending platform.

Legal basis and subject of the processing.

The data are processed exclusively for the purposes for which they are collected, as described below.

We use the data provided by data subjects only in case of a specific consent of the user that occurs when allowing the adhesion to specific and additional services such as the sending of future informative and promotional info by email or by electronic means.

The provision of data listed in the “Collected Data” section is mandatory to allow the user to access the service. For this reason, consent is required, and the refusal to process the failure or inaccurate or partial provision of data could have the consequence of the impossibility of a correct provision of the service.

The provision of data for the purposes of sending newsletters for promotional purposes, information or research is optional and the refusal to give the relative consent to the Processing will result in the impossibility of being updated about commercial initiatives and/ or promotional campaigns, to receive offers or other promotional material and/or to send the Client personalized offers. Action Directe S.C. does not provide any user information to third parties without their consent, unless required by law.

In any case, the dissemination and transfer of data outside the EU area is excluded.

Consent revocation

The data subject may revoke his consent to receive promotional and commercial communications immediately, by sending a request to the email address info@actiondirecte.it .

Processing methods

Personal data are processed with automated tools and just for the time strictly necessary to achieve the purposes for which they were collected. The website provides an annual verification of the data stored to delete those deemed obsolete. In case the law provides for storage obligations it will not be possible to delete the data.

The data processing usually takes place at the headquarters of the company Action Directe S.C., by staff or external collaborators duly designated as data processors. The complete list of data processors and data processors can be requested by sending a request to the e-mail address info@actiondirecte.it.

The registration and the relative treatment are considered valid until the unsubscribe by the user is present in each email.

Specific security measures are observed to prevent data loss, unlawful or incorrect use, and unauthorized access.

Data subject’s rights

Pursuant to art. 7 of the Privacy Code and art. 13 GDPR each user has the right to obtain confirmation of the existence or not of his personal data, even if not yet registered, and their communication in an intelligible form.

In particular, the data subject has the right to obtain from Action Directe S.C. the following information.

1. a. Data source
   b. processing purposes and methods
   c. the logic applied if the processing is carried out using electronic/computer tools;
   d. the identity of the owner, managers, and designated representative;
   e. the subjects and categories of subjects to whom the data may be communicated or who may become aware of it as designated representative in the territory of the State, responsible persons or persons in charge.

In addition, the data subject has the right to obtain from Action Directe S.C. the updating, correction or integration of their data; the cancellation, the transformation into anonymous form or the blocking of data processed in violation of the law; access to their data, that is, confirmation that personal data concerning them are being processed or not; limitation of processing; data portability, that is, the right to receive in structured format the personal data concerning them; the right to complain to the Supervisory Authority.

Finally, the data subject has the right to object, in whole or in part, for legitimate reasons to the processing of personal data concerning him, even if relevant to the purpose of the collection. In particular, the data subject has the right to object to the processing of personal data concerning him for the purpose of sending commercial advertising material or direct sales or for the performance of market research or commercial communication. The requests mentioned in the previous points must be sent by email to info@actiondirecte.it.

Updates and changes to this Privacy Policy

Action Directe S.C. reserves the right to amend, supplement or periodically update this Policy in accordance with the applicable legislation or the measures adopted by the Guarantor for the Protection of Personal Data.

The aforementioned changes or additions will be brought to the attention of the interested parties through links to the Privacy Policy page on the website and will be communicated directly to the interested parties by email.

We encourage users to read the Privacy Policy regularly, to check the updated Policy and decide whether or not to continue to use the services offered.

Cookies

The software applications used may contain the cookie technology. Cookies mainly have the function of facilitating navigation by the user. Cookies may provide information on navigation within the Site and allow the operation of certain services that require the identification of the user’s path through different pages of the website.

The cookies in the software applications used are anonymous and cannot be traced back to the user’s data. For any access to the portal regardless of the presence of a cookie, the type of browser (e.g. Google Chrome, Mozilla Firefox), the operating system (e.g. Macintosh, Windows), the host, and the visitor’s URL are recorded in addition to the data on the requested page.

However, you can set your browser so that you are informed when you receive a cookie and decide to delete it. More information about cookies can be found on websites related to browsers.

For further information about your privacy rights, please visit the website of the Data Protection Authority at garanteprivacy.it.