Privacy Policy

Privacy Policy (Article 13 EU Regulation 679/2016)

Pietro Romanengo fu Stefano S.r.l. ("Romanengo") considers the protection of personal data of users who browse and/or purchase products on its website (the "Users") to be of fundamental importance and guarantees that the processing of personal data carried out through the website www.romanengo.pro (the "Website") takes place in compliance with the data subject's rights, with the provisions of European Regulation no. 679/2016 (the "GDPR") and other relevant national and community provisions.

1. Who processes User personal data?
The Data Controller is Pietro Romanengo fu Stefano S.r.l., with registered and operational office in Genoa, via Soziglia 74/76 r 16123 Genoa, e-mail: sabrina.zampardi@romanengo.pro. The Data Controller can be contacted at any time at the addresses specified above. All Romanengo employees who will have access to User data will be appointed by the Data Controller as authorized data processors and will have received adequate operating instructions in this regard.

2. What data is processed?
Romanengo collects certain personal data of Users (the "Data"), such as aggregated information during navigation on the Website and personal data voluntarily provided by the User when purchasing products offered by the Website and/or requesting information sent to the Website via e-mail or through the "Contact Us" box. For more information regarding the type and use of cookies on the Website, please refer to Romanengo's cookie policy available on this Website.

Browsing data
The computer systems and software procedures used to operate the Website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow Users to be identified.
This category of data includes IP addresses or domain names of computers used by Users connecting to the website, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the User's IT environment.

Data provided voluntarily by the User
Romanengo primarily collects the data necessary to finalize the purchase of products requested by the User or to contact the User in response to an information request. Romanengo may collect, for example, the following Data:

1) first name and last name;
2) address;
3) e-mail;
4) tax code or VAT number;
5) date of birth;
6) gender;
7) telephone number.

3. What are the purposes and legal bases of the processing?
Romanengo will process User Data for the following purposes: a) to allow registration on the Website, enable navigation on the Website and the use of services reserved for registered users; b) to conclude and execute the product purchase contract offered on the Website; c) to respond to information requests sent to us via e-mail or through the "Contact Us" box; d) to carry out direct marketing activities, aimed at promoting Romanengo's products and brand; e) to send newsletters and periodic updates relating to products, initiatives and events organized by Romanengo, including invitations to reserved events; f) to carry out statistical surveys.

The processing of Data for the purposes listed above is carried out:
1) to provide the service requested through browsing the Website (e.g., registration and creation of the reserved area, communications related to the provision of the service) and to execute a contract or pre-contractual measures requested by the User, as well as to comply with legal obligations, for purposes a., b., and c.; 2) after obtaining the User's express consent, for purposes d. and e.; 3) based on the legitimate interest of the Data Controller for purpose f., with the clarification that in this case the User can always object to the processing.

4. What are the consequences of not providing the Data?
Except as specified for browsing data, Users have the right to provide or not provide Data in the various sections of the Website for the purchase of products available on the Website or by sending an information request to the Website via email or the appropriate "Contact Us" box. The provision of User Data to Romanengo, which is requested on various occasions, may, in some cases, be indispensable for achieving the purposes identified in this privacy policy. In the event of refusal to provide the Data requested for the purposes listed in Article 3, points a., b., and c., the consequence will be the impossibility for Romanengo to provide the User with the products and to respond to their requests. The provision of Data for the purposes listed in Article 3, points d. and e., requires express consent, pursuant to the GDPR. In the case of the purposes listed in the aforementioned points d. and e., the consent given for sending commercial and promotional communications by electronic means is also understood to be given in relation to traditional contact methods. In the event of refusal to provide the Data requested for the purposes listed in the aforementioned points d. and e., the consequence could be the mere impossibility for Romanengo to carry out the activities indicated therein and therefore for the User to receive commercial information and updates regarding Romanengo's activities.

5. And what are the processing methods?
The processing of Data will be based on the principles of lawfulness, fairness, transparency, proportionality, and minimization and may also be carried out through automated methods suitable for storing, managing, and transmitting them, and will take place using suitable tools, as far as reasonable and state-of-the-art, to guarantee security and confidentiality through the use of appropriate procedures that avoid the risk of loss, unauthorized access, illicit use, and dissemination.

6. Who are the recipients of the Data communication?
In addition to Romanengo's employees and/or collaborators, the Data will be (or may be) communicated to: a) Romanengo's tax consultants; b) Romanengo's IT consultants and electronic/technological service providers; c) Romanengo's legal consultants; d) courier companies for the delivery of purchased products; e) competent authorities; f) subjects who can access the Data by virtue of legal provisions or secondary or community legislation; The updated list of recipients can be consulted by writing to the email: sabrina.zampardi@romanengo.pro. The Data will not be disseminated.

7. Where is the Data processed?
The Data will be processed within the European Economic Area.

8. And the Data retention period?
The Data will be archived in electronic format and stored for the period of time strictly necessary to comply with legal and contractual obligations. In this regard, it is specified that the Data: 1) necessary to fulfill requests will be kept for the period strictly necessary to fulfill the request, if it does not have a contractual follow-up; 2) necessary to guarantee Romanengo's compliance with legal obligations (e.g., accounting and tax regulations) will be kept for the period indicated by the applicable legislation; 3) necessary for Romanengo to execute any contracts stipulated with the User will be kept for the entire duration of the contract as well as for the period necessary to guarantee Romanengo's defense of its rights in the event of disputes inherent to the contract concluded with the User (6 months after the expiry of the legal statute of limitations); 4) necessary for carrying out the activities indicated in Article 3, points d. and e. will be kept until the User withdraws consent. 5) necessary for carrying out statistical surveys, until the User objects to the processing.

9. What are the data subject's rights?
The User has the right to ask the Data Controller for:
1) confirmation that Data processing is underway and, if so, access to the Data and information referred to in Article 15 of the GDPR (purposes of processing, categories of data, categories of recipients, data retention period); 2) rectification of inaccurate Data; 3) integration of incomplete Data; 4) erasure of Data, in cases provided for by law; 5) restriction of Data processing, which allows you to obtain, in cases provided for by law, the marking of stored personal data with the aim of limiting future processing; 6) to receive the Data in a structured, commonly used and machine-readable format and to transmit it to another data controller (so-called portability); 7) to withdraw consent where given; 8) to object in whole or in part to the processing of Data, in accordance with the law, where applicable; 9) not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them; 10) to lodge a complaint, pursuant to Article 77 of the GDPR, with the national supervisory authority of the European Union member state in which you have your habitual residence or place of work or where the alleged violation of your right occurred; if this state is Italy, the entity you can contact is the Guarantor Authority for the protection of personal data.

It is specified that the User's right to object to the processing of Data for the purposes listed in Article 3, points d. and e., carried out through automated contact methods, extends to traditional methods, and the possibility for the User to exercise this right in part remains, i.e., in this case, by objecting, for example, only to the sending of promotional communications carried out through automated tools. These rights may be exercised by contacting Romanengo at the addresses indicated in Article 1 of this privacy policy.

10. Third-party sites
This policy applies to User personal data collected through the Website; it does not apply to other websites owned by third parties, which may be accessed via a link on the Website. Romanengo cannot be held responsible for the content of these websites and the rules adopted by them, including with regard to User privacy and the processing of their personal data during browsing on such websites. Users are therefore invited to pay attention when connecting to these websites via the links on our Website and to carefully read their terms of use and privacy policies.