Cookie & Privacy policy

COOKIE POLICY

Cookie Policy. Effective as of February 4th, 2024

INTRODUCTION

This cookie policy is made for the site https://www.neamilano.com (Site). The document is drafted taking into account the provisions of European Regulation 679/2016 on the protection of personal data (GDPR), the Privacy Code (Legislative Decree No. 196 of June 30, 2003) and the Guidelines of the Privacy Guarantor (especially the Guidelines on the use of cookies issued on July 10, 2021).

Data Controller: Nea Milano di Anastasia Emelina P.IVA 10727000969, Via P. Eugenio 51, 20155 MI Milano

GENERAL INFORMATION

What are cookies

A cookie is a text file that a website visited by the user sends to his terminal (computer, mobile device such as smartphones or tablets), where it is stored and then transmitted to that site on a subsequent visit to the same site.

Cookies are distinguished

on the basis of the subject who installs them, depending on whether it is the same manager of the site visited (so-called "first party cookies") or a different subject (so-called "third party cookies");
according to the purpose of each cookie: some cookies allow better navigation, storing some of the user's choices, such as language (so-called "technical cookies"), other cookies allow monitoring the user's navigation also in order to send advertising and/or offer services in line with his/her preferences (so-called "profiling cookies").

Only profiling cookies require the prior consent of the user to their use.

The Data Controller is only responsible for first party cookies installed on the Site.

In the section "First party technical cookies" you can view the types of first party technical cookies set by the Site.

The management of profiling cookies is described in the section "Third party profiling cookies", where present. If this section is not present it means that the Site does not set profiling cookies. If the Site sets profiling cookies you can express and modify your consent to the set of these cookies using the options indicated in the so-called "cookie banner" (the banner that appears when you first access the Site).

In any case, you can also enable/disable cookies through the options of your browser:

Internet Explorer

Click on Tools menu, then Internet Options.

Click on Privacy, then Advanced.

In the Cookies window, select your preferences.

Google Chrome

Click on Chrome's menu.

Select Settings, then click on Advanced.

In the Privacy and Security section, click on the Content Settings button.

Select your preferred options in the Cookies section.

Firefox

Click on Tools, then click on the Options menu.

Click on Privacy and Security settings.

Select Use custom settings for history.

Select your preferred options in the Accept cookies and data from websites section.

Safari

Click on Safari, then Preferences.

Click on the Privacy and Security section.

Go to Block Cookies and select your preferred options.

First-party technical cookies

These cookies are necessary for the operation of the Site and cannot be disabled. They are usually defined as a response to actions taken that constitute a request for services, such as setting cookie preferences, logging in or filling out forms, browsing preferences.

The Site sets navigation or session cookies that guarantee normal navigation and use of the Site.
The Sites sets also cookies which document your consent to the release of profiling cookies and the relevant preferences. These cookies recognize you the second time you access the Site so that you do not have to request consent again for the installation of profiling cookies.
We also use technical cookies that allow you to navigate the Site while maintaining the choices you have made.
The Site Owner also uses "anonymized" Google Analytics. This means that the cookies issued by Google Analytics only allow analysis of statistical data, without the possibility of identifying the individual user.
The Site also uses cookies that maintain your choice as to how you view Products on the Site.
The Data Controller also uses cookies that keep track of the Products viewed by the user during the session on the Site.
The Site Owner also uses "anonymized" Google Analytics. This means that the cookies issued by Google Analytics 4 only allow analysis of statistical data, without the possibility of identifying the individual user.

Third-party profiling cookies

In the cookie banner that appears the first time you access the Site, you can review the profiling cookies issued by the Site and express your preferences.

Rights of the user

Pursuant to Article 13 of the GDPR, the Data Controller informs you that you have the right to:

request from the Data Controller access to your personal data and the rectification or erasure of the same or the limitation of the processing concerning you or to object to their processing, in addition to the right to data portability
to withdraw consent at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation
to lodge a complaint with a supervisory authority (e.g. the Italian Data Protection Authority).

The rights referred to above may be exercised with a request made without formalities to the contacts indicated in the Introduction.

Communication of data

The Data Controller does not disclose information resulting from the use of cookies to third parties.

Storage of the information

Data from technical cookies is stored for the time necessary to enable the service to which the individual technical cookie relates.
If the Site sets profiling cookies, the user's behavioural data will be stored until the user's consent is revoked.

INTRODUCTION

This information takes into account the provisions of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and of the Privacy Code (Legislative Decree 30 June 2003 n. 196). The document has also been drafted in accordance with the Guidelines of the Privacy Guarantor (especially the Guidelines for combating spam issued by the Privacy Guarantor on July 4, 2013).

Data Controller: Nea Milano di Anastasia Emelina P.IVA 10727000969, Via P. Eugenio 51, 20155 MI Milano

Site to which this privacy policy refers:https://www.neamilano.com (Sito).

The Data Controller has also appointed a DPO (Data Protection Officer), who is responsible for monitoring the Data Controller's compliance with the GDPR. You can find DPO's contact in the introduction of this document.

GENERAL INFORMATION

This document describes how the Data Controller processes your personal data.

The following describes the main processing of your personal data. In particular, we explain the legal basis of the processing, whether the provision of personal data is compulsory and the consequences of not providing personal data. To better describe your rights, if necessary, we have specified if and when a certain processing of personal data is not carried out.On the Site you have the possibility to enter personal data of third parties. In this case you guarantee to have obtained the consent of these subjects to the insertion of these personal data. Therefore, you agree to indemnify and hold harmless the Data Controller from any liability.

Site registration

The information and data requested in case of registration will be used to allow you both to access the private area of the Site and to use the online services offered by the Data Controller to registered users. The legal basis of the processing is the need for the Data Controller to execute pre-contractual measures taken at the request of the data subject. The conferment of data is optional. However, your refusal to provide the data will make it impossible to register on the Site.

Purchases on the Site

Your personal data will be processed to allow you to make purchases on the Site. in the case of making an online purchase order, to allow the conclusion of the purchase contract and the proper execution of transactions related to the same (and, if necessary under the legislation, to fulfill tax obligations). This treatment of personal data also includes the possibility of sending communications (e.g. tracking and order information) via automated tools such as SMS and/or WhatsApp. The legal basis for the processing is the obligation of the Data Controller to execute the contract with the data subject or to comply with legal obligations. Apart from the above (and therefore your consent), the Data Controller may process your data for the purpose of so-called "soft-spam", governed by art. 130 of the Privacy Code. This means that limited to the email you provided in the context of a purchase through the Site, the Data Controller will process the email to allow direct offers from similar products/services, unless you object to such processing in the manner provided by this policy. The legal basis for processing is the legitimate interest of the Data Controller to send this type of communication. This legitimate interest can be considered equivalent to the interest of the data subject in receiving "soft-spam" communications.The Data Controller may send emails to remind the user to complete a purchase. The legal basis for this processing is the legitimate interest of the Data Controller in sending this type of communication. Through the "follow on shop" option, the Data Controller may process your personal data to send updates via email and/or telephone (depending on the options available on the Website) regarding order status, shipments, and/or supplies. The legal basis for this processing is the Data Controller's legitimate interest in sending this type of communication. This interest is equivalent to your interest in receiving this type of updates. Providing personal data for this purpose is optional. However, if personal data is not provided, it will not be possible for the Data Controller to send this type of communication.

Answering your requests

Your data will be processed to respond to your requests for information. The conferment is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis for the processing is the legitimate interest of the Data Controller in fulfilling your requests. This legitimate interest is equivalent to the user's interest in receiving a response to communications sent to the Data Controller.

Marketing

Subject to your consent, the Data Controller may process the personal data provided by you in order to send you advertising material and/or newsletters relating to its own products or those of third parties. The legal basis of this treatment is your consent. The provision of personal data for this purpose is purely optional. Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to products/services of the Data Controller and/or third parties, as well as making it impossible for the Data Controller to carry out market surveys, also aimed at assessing the degree of user satisfaction, and to send you newsletters. These communications will be sent to your e-mail.

Profiling

Subject to your consent, the Data Controller may process your personal data for profiling purposes, i.e. for the analysis of your consumption choices by revealing the type and frequency of purchases made by you, in order to send you advertising material and/or newsletters relating to its own products or third parties, of your specific interest. The legal basis of this treatment is your consent. The provision of data for this purpose is purely optional. Failure to consent to the processing of your personal data for profiling purposes will make it impossible for the Data Controller to elaborate your commercial profile, through the detection of your choices and buying habits and to send you advertising material about products of the Data Controller and/or third parties, of your specific interest. These communications will be sent to your e-mail.

Data transfer

The Data Controller does not transfer your personal data to third parties.

Geolocalization

The Site does not implement tools to geolocate the user's IP address.

Curriculum Vitae

It is not possible to send CVs via the Website. Your data will therefore not be processed for these purposes.

Booking Service

There are no third-party appointment booking systems active on the Site. Therefore, your data will not be processed for this purpose. In any case, you can always contact the Data Controller at the contacts indicated in the heading.

Communication of personal data

As part of its ordinary business, the Data Controller may communicate your personal data to certain categories of subjects. In article 2 you can find the list of subjects to which the Data Controller communicates your personal data. In order to facilitate the protection of your rights, Article 2 may specify in certain cases when your data is not communicated to third parties.

The "communication" of personal data to third parties is different from the "transfer" (governed by the preceding point). In fact, in the communication the third party to whom the data is transmitted can use it only for the specific purposes described in the relationship with the Data Controller. In the transfer, instead, the third party becomes the autonomous Data Controller. Moreover, to transfer your personal data to third parties is always required your consent.

Without prejudice to the foregoing, it is understood that the Data Controller may still use your personal data in order to correctly fulfill the obligations provided for by the laws in force.

Art. 1 Method of processing

1.1 The processing of your personal data will be mainly carried out with the help of electronic or automated means, according to the methods and with the tools suitable to ensure their security and confidentiality. If the automatic chatbot service is operational, your personal data will also be processed to allow the activation of this service, through which the user can contact and be contacted by the Data Controller, subject to consent. The legal basis is the legitimate interest of the Data Controller to respond to the user's requests through the chatbot service. This legitimate interest may be deemed equivalent to the interest of the data subject in using the automated chatbot service.

1.2 The information acquired and the methods of treatment will be relevant and not excessive in relation to the type of services rendered. Your data will also be managed and protected in secure computer environments appropriate to the circumstances.

1.3 Through the Site are not processed "special data". Particular data are those that can reveal racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade union, health and sex life.

1.4 No judicial data is processed through the Site.

Art. 2 Communication of personal data

The Data Controller may communicate your personal data to certain categories of subjects. The subjects to whom the Data Controller reserves the right to communicate your data are indicated below:

The Data Controller may communicate your personal data to all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative measures.
Your personal data may also be disclosed to all those public and / or private individuals and / or legal entities (legal, administrative and tax, judicial offices, Chambers of Commerce, Chambers and Offices of Labor, etc..), if the communication is necessary or functional to the proper fulfillment of obligations under the law.
The Data Controller does not make use of employees and/or collaborators in any capacity. Therefore, your personal data will not be communicated to this category of subjects.
In its ordinary activity of managing the Site, the Data Controller makes use of companies, consultants or professionals in charge of the installation, maintenance, updating and, in general, the management of the hardware and software of the Data Controller or which the latter uses for the provision of its services. Therefore, only with reference to these purposes, your data may also be processed by these subjects.
In order to send its communications, the Data Controller uses external companies in charge of sending this type of communication (CRM platforms). Your personal data (in particular your email) may therefore be communicated to these companies.
The Data Controller does not use external companies to provide customer care services. Therefore, your personal data will not be processed for this purpose.
The purchaser's personal data may be communicated to post offices, couriers or forwarding agents responsible for the delivery of the Products purchased through the Site.

The Data Controller reserves the right to modify the above list in accordance with its ordinary operations. Therefore, you are invited to regularly access this information to check to which subjects the Data Controller communicates your personal data.

Art. 3 Personal data retention

3.1 This article describes how long the Data Controller reserves the right to retain your personal data.

For marketing purposes, personal data will be kept until consent is revoked. For inactive users, personal data will be deleted after one year from the sending of the last email eventually viewed.
As provided for in Article 2220 of the Civil Code, invoices, as well as all accounting records in general, are kept for a minimum period of ten years from the date of registration, so that they can be presented in the event of an audit.

3.2 Without prejudice to the provisions of Article 3.1, the Data Controller may retain your personal data for the time required by specific regulations, as amended from time to time.

Art. 4 Transfer of personal data

4.1 The Data Controller is located in a country that has an adequate level of security from a regulatory standpoint. If the transfer of your personal data takes place to a non-EU country and for which the European Commission has expressed a judgment of adequacy, the transfer is deemed safe from a regulatory standpoint in any case. This article 4.1 indicates from time to time the countries where your personal data may possibly be transferred and where the European Commission has expressed a judgment of adequacy.

It may happen that for articles offered by the Site your personal data must be transferred to Israel. This transfer is safe from a regulatory point of view in the light of the decision of the European Commission of 31 January 2011 n. 2011/61/EU (published in the Official Journal of the European Communities L 27/39 of 1 February 2011). This decision has established that the State of Israel, as defined under international law, provides an adequate level of protection for personal data transferred from the European Union with regard to automated international transfers of personal data from the European Union.
Your personal data may be transferred to the USA based on what is established by the adequacy decision of the European Commission. With this decision, the European Commission has determined that the USA provides personal data protection comparable to that offered by the European Union.
The Data Controller may transfer your personal data to the United Kingdom. In fact, the European Commission has ruled in its decision of 28 June 2021 that the United Kingdom offers an adequate level of protection of personal data under the GDPR.

4.2 Without prejudice to what is stated in article 4.1, your data may also be transferred to countries outside the EU for which the European Commission has not issued an adequacy opinion. You are therefore invited to regularly review this article 4.2 to find out to which of these countries your data may be transferred.

4.3 In this article, the Data Controller indicates the countries in which it may specifically direct its activities. This circumstance may imply the application of the legislation of the reference country, together with that which governs the relationship with the user as indicated in the Preamble.

At the request of the user, the Data Controller will apply to the processing of personal data any more favourable legislation provided for by the user's national legislation.

Art. 5. Your rights

The Data Controller informs you that you have the right:

to request from the Data Controller access to your personal data and the rectification or erasure of the same or the restriction of the processing thereof or to object to the processing thereof, in addition to the right to data portability
revoke consent at any time without affecting the lawfulness of the processing based on the consent given before revocation
to lodge a complaint with a supervisory authority (e.g. the Italian Data Protection Authority).

The rights referred to above may be exercised by making a request without formalities to the contacts indicated in the Introduction.

Art. 6. Amendments

The Data Controller reserves the right to make changes to this policy at any time, giving appropriate publicity to users of the Site and ensuring in any case an adequate and similar protection of personal data. In order to view any changes, you are invited to regularly consult this policy. In case of substantial changes to this privacy policy, the Data Controller may give notice of such changes also by email.