Privacy

INFORMATION ON THE PROCESSING OF PERSONAL DATA pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR)

Foreword

This information is provided for the "https://shop.classe.it/gb/" (Website) owned by Classe Srl, with registered office at Via Giuseppe di Vittorio 72/74, registered with the Chamber of Commerce of Florence with VAT no. 03763080482; share capital € 100,000.00 fully paid up (Company), in its capacity as Data Controller.

Purchases on the Site

Subject to your prior consent, your personal data will be processed to enable you to make purchases on the Site.

Registration

The information and data requested in the event of registration will be used to allow you both to access the reserved area of the Site and to use the online services offered by the Company to registered users.

Marketing

Subject to your consent, the Company may process the personal data you provide in order to send you advertising material and/or newsletters concerning its own or third parties' products and/or services.

Profiling

Subject to your consent, the Company may process your personal data for profiling purposes, i.e. for the analysis of your consumption choices by revealing the type and frequency of your purchases, in order to send you advertising material and/or newsletters relating to its own or third parties' products and/or services of specific interest to you.

Soft spamming

The Company may use, for the purpose of the direct sale of products and/or services offered for sale through the Site, the e-mail addresses that you have provided in the context of a purchase on the Site, even without your consent, provided that the product and/or service in question is similar to the one that was the subject of the previous sale (so-called soft spamming). You may however refuse this processing at any time by communicating your opposition to the Company.

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In compliance with the GDPR, we hereby inform you that the Company will process your personal data under the following conditions.

Article 1. Purpose and legal basis of processing. Compulsory or optional provision of data. Consequences of refusal to process.

Personal data are processed for the following purposes:

a. to allow registration on the Site and access to the services reserved for registered users, as well as to allow compliance with obligations arising from the law or regulations in force, in particular, in the administrative, accounting and public security fields. The legal basis for the processing is the need for the Company to execute pre-contractual measures adopted at the request of the data subject or to comply with a legal obligation;

b. in the case of placing an online purchase order, to enable the conclusion of the purchase contract and the proper execution of the transactions related to the same (and, where necessary under sector regulations, to fulfil tax obligations). The legal basis for the processing is the Company's obligation to perform the contract with the data subject or to fulfil legal obligations;

c. limited to the e-mail addresses that you provide in the context of a purchase through the Site, to allow the direct offer by the Company of similar products and/or services (so-called soft spamming), provided that you do not object to such processing in the manner provided by this policy. The legal basis of the processing is the legitimate interest of the Company in sending this type of communication. This legitimate interest can be considered equivalent to the interested party's interest in receiving 'soft-spam' communications;

d. with your consent, to send newsletters and to carry out market surveys, also aimed at assessing the degree of user satisfaction, and to send advertising material relating to products and/or services of the Company and/or third parties, by means of systems such as email (marketing purposes); subject to your consent, for the processing of your commercial profile, through the detection and processing of your purchasing choices and habits, in order to monitor the degree of customer satisfaction and to send you advertising material on products and/or services of the Company and/or third parties of your specific interest, by means of systems such as email (profiling purposes). The legal basis for the processing is the consent of the data subject;

e. if the chat service is operational, allow the activation of the service, through which the user can contact and be contacted by the Company, subject to your consent, during your navigation on the Site. The legal basis is the legitimate interest of the Company in carrying out this type of activity. This legitimate interest can be considered equivalent to the interested party's interest in using the Site's chat service;

f. to respond to your requests via the customer care service. Providing this information is optional, but your refusal will make it impossible for the Company to answer your questions via this service. The legal basis for the processing is the legitimate interest of the Company in responding to your requests. This legitimate interest is equivalent to the user's interest in receiving replies to communications sent to the Company;

g. to respond by email, telephone, mail to your requests. Providing the data is optional, but your refusal will make it impossible for the Company to respond to your requests. The legal basis for the processing is the legitimate interest of the Company in responding to your requests. This legitimate interest is equivalent to your interest in receiving a reply to communications sent to the Company.

The provision of data for the purposes referred to in points a) and b) is purely optional. However, since such processing is necessary in order to make a purchase on the Site, your refusal to provide such data will make it impossible to make such purchase via the Site.

Consent to the processing of your data for marketing and profiling purposes is purely optional. Failure to consent will only entail the consequences described below.

Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to products and/or services of the Company and/or third parties, and will also make it impossible for the Company to carry out market surveys, including those aimed at assessing the degree of user satisfaction, and to send you newsletters.

Failure to consent to the processing of your personal data for profiling purposes will make it impossible for our Company to process your commercial profile, by surveying your purchasing choices and habits, as well as to send you advertising material, relating to products and/or services of the Company and/or third parties, of your specific interest.

Notwithstanding the foregoing, it is understood that the Company may nevertheless use your personal data for the sole purpose of properly fulfilling its obligations under applicable laws and its obligations arising from the contractual relationship between you and the Company.

We would like to remind you that you may also object to the processing of your personal data via a link at the bottom of any promotional e-mail sent by the Company.

Data provided as part of the 'Make a gift' service

On the Site you will have the opportunity to give one or more products and/or services to a person by entering the personal data requested from time to time. You are aware that the Company will retain such personal data for the time strictly necessary to document that your request has been fulfilled. In order to use this service you must be able to prove, if requested by the Company, that you can legitimately use the personal data of your friends/contacts.

Social networks

By choosing the option of registering and/or accessing the Site via Facebook, Google Plus, and Instagram, you agree that the respective social networks used from time to time to access the Site transmit to the Company the personal data required for registration and/or access.

Payment card data

In order to make a payment using one of the payment cards offered on the Site, the user must enter the confidential data of the payment card directly on a page that will communicate via secure encryption protocol with the payment service provider (who will act as the autonomous data controller), without passing through the Company's server, which will therefore not process this data in any way. The data will be acquired in encrypted format.

With reference to the payment card data, please note that the processing of your personal data is necessary to enable the conclusion of the online purchase contract with the Company. Failure to provide this data, therefore, will not allow you to complete the online purchase process.

PayPal

On the Site it is also possible to purchase via the PayPal payment tool. In this case, you will be redirected to a page outside the Site, where you will have to indicate the personal data required by PayPal - which will act as autonomous data controller - to complete the purchase process. The personal data will not pass through the Site's server, which, therefore, will not process such data in any way. The processing of your personal data is necessary to allow the conclusion of the online purchase contract with the Company. Failure to provide this data, therefore, will not allow you to complete the online purchase process.

Bank transfer

If you choose bank transfer as the payment instrument, in the event of any reimbursement scenario, the Company will ask you for your bank details in order to arrange payment.

Special or judicial data

The company does not process special or judicial data.

Article 2. Modalities of processing

The processing of your personal data will mainly be carried out with the aid of electronic or otherwise automated means, in the manner and with the tools suitable to guarantee their security and confidentiality in accordance with the GDPR.

The information acquired and the manner in which it is processed will be relevant and not excessive in relation to the type of services rendered. The data will also be managed and protected in environments whose access is under constant control.

Article 3. Communication and dissemination of data

Your data may be disclosed:

• to all those entities (including public authorities) that have access to personal data by virtue of regulatory or administrative measures
• companies or third parties in charge of printing, enveloping, shipping and/or delivery and/or collection services for products purchased through the Site
• to post offices, couriers or forwarding agents entrusted with the delivery of products purchased through the Site
• banking institutions and companies operating national or international payment circuits through which online payments are made for products purchased through the Site
• companies, consultants or professionals that may be entrusted with the installation, maintenance, updating and, in general, the management of the Company's hardware and software or which the Company uses for the provision of its services
• to external companies in charge of sending advertising communications on behalf of the Company
• to employees and/or collaborators of the Company
• the company in charge of carrying out customer care activities
• to entities handling online payment transactions
• to all those public and/or private subjects, natural and/or legal persons (legal, administrative and tax consultancy firms, Judicial Offices, Chambers of Commerce, Chambers and Labour Offices, etc.), if the communication is necessary or functional for the correct fulfilment of the obligations deriving from the law.

The data concerning you will not be disseminated, except in anonymous and aggregate form, for statistical or research purposes.

Art. 4. Data controller

The Company, as Data Controller, can be contacted at the following addresses:

Classe Srl Via Giuseppe di Vittorio 72/74
Telephone: 057183421
Email: info@classe.it
Via the contact form on the Site.

Article 5. Retention of personal data

The user's data will only be stored for as long as is necessary to ensure the proper provision of the services offered and in any case within the time limits laid down by law or by the provisions of the Personal Data Protection Authority.

In the event that the Website account is closed at the user's initiative, the data in it will be retained for administrative purposes for a period not exceeding 90 days, without prejudice to any specific legal obligations on the retention of accounting documents or for public security purposes.

In any case, it is understood that personal data will be stored and processed for marketing and profiling purposes for the period of time allowed by law and by the provisions of the Personal Data Protection Authority. At the end of this period, the Company may ask the user to renew their consent to the processing of their data for these purposes or render them anonymous and keep them solely for statistical or historical purposes.

Article 6. Rights of the data subject

Pursuant to Article 13 of the Privacy Regulation, the Company informs you that you have the right to:

• request from the Company access to and rectification or erasure of your personal data or restriction of their processing or to object to their processing, as well as the right to data portability
• withdraw consent at any time without affecting the lawfulness of the processing based on the consent given prior to withdrawal
• file a complaint with a supervisory authority (e.g. the Data Protection Authority).

The aforementioned rights may be exercised by making a request to the Company at the above-mentioned contacts without formalities.

Art. 7. Amendments

The Company reserves the right to make changes to this policy at any time, giving appropriate publicity to users of the Site and ensuring in all cases adequate and similar protection of personal data. In order to view any changes, you are invited to consult this policy on a regular basis.

"In order to be able to offer you Klarna's payment methods, at checkout we may transmit your personal data to Klarna in the form of contact and order details so that Klarna can assess your suitability for its payment methods and customise these payment methods. Your personal data

transferred are processed in line with the policy on privacy of Klarna."