Fall Winter 2020

Privacy policy

INFORMATION IN ACCORDANCE WITH ART. 13 OF REG. (EU) NO. 2016/679 ("GPDR”)

This notice describes which of your personal data is collected by Zerogrey S.r.l. and by FGF Industry S.p.a. (hereinafter referred to as "us"), the purposes for this and how it is processed. You will also find the information necessary to exercise your rights under GDPR.

In general, we collect your data when you create an account on our online store www.Blauerusa.com (hereinafter "Store"), when you purchase products offered for sale in the Store, when you send us emails or when you call us for assistance. You are hereby informed that the personal data collected during said procedures will be processed in order to respond to your requests, allow you to use the services offered by the Store through the private areas (for example, to process your orders and perform the tasks necessary to do this, including the transactions required for administrative and tax compliance and, at your request and information) and to provide better services, marketing and support for you and other customers, as set out above.

1.       Who processes your data: Data controllers
Zerogrey S.r.l., a sole shareholder company, with registered offices at Via L. Colli, 15 10128 Turin, fiscal code and VAT no. 08003340018 (hereinafter “Zerogrey”) and FGF Industry S.p.a. (hereinafter “FGF”), with registered offices at Vicolo Bellini n. 12, Padova, fiscal code and VAT no. 03315890289, are the joint controllers of your data.

In accordance with Art. 26 GDPR, you are hereby informed that Zerogrey is the controller of your personal data for the purposes of processing and managing your orders, shipping the products you have bought, providing you with the necessary after-sales support, managing the return of purchased products, complying with taxation law, and, subject to your consent, marketing for the purposes and in the ways indicated below.

In accordance with Art. 26 GDPR, you are hereby informed that FGF will process personal data for the following purposes: managing Store accounts during the period of transition to new operators or internalization of services at present assigned to Zerogrey, assisting Zerogrey in processing your data to ensure compliance with the guarantees prescribed by law or other conventions, including the management of purchased product return procedures, the management and maintenance of the Store, and after obtaining your consent, marketing.

2.       DATA PROTECTION OFFICER– DPO)
As per Art. 37 of Reg. 679/2016 (GDPR), FGF has appointed a Data Protection Officer who can be contacted for any question regarding the processing of personal data of all Data Subjects at the following e-mail address: dpo@fgf-industry.com.

3.       Which data we process – Type of data processed
Your contact and account data. We will retain the contact information you provide (for example, your first name, surname, address, telephone number, email, country of residence,) when you create an account on the Store, purchase a product and/or take part in our competitions or promotions.

Your payment and invoicing data. We will retain the payment and invoicing data that you provide (for example, credit card number, post code and address) when you purchase a product, for the purpose of managing your order and shipping the products. At your request, we can also retain the payment and invoicing data in order to make future purchases easier

Website use data. By using our website, you agree for us to process the data from your browser and the device you are using, as well as your IP address (this is the number that identifies a specific device on the internet and that is needed for your device to communicate with websites). We can analyze which site you have come from, what you have done and what you have not done on our website.

4.       Where we get your data – Data collection method:
Directly from you. For example, if you register to make a purchase from the Store, create an account, take part in a competition, ask us a question or contact with our call center.

If you do not send us your data, you will not be able to register at the Store and will therefore be unable to purchase any products offered for sale

Through the use of the Store's features. We use cookies and other technology, such as pixel tags, on our websites and in our emails in order to collect your usage data and to make better targeted promotions. To find out more, please view our Cookie Policy (se paragraph entitled “Cookies”).

5.       Why and how long we process your data for - Purpose and legal basis for data processing; retention period

Purpose of processing	Legal basis for processing	Retention period
For the management of and answer to specific questions from Data Subjects, please contact us directly.	Consent of Data Subject	24 months
Marketing activities, commercial communication, market research, receipt of newsletters	Consent of Data Subject	Until you withdraw your consent in any moment by using the link provided at the end of every promotional email (as regards marketing activities and the newsletter) or by sending us an e-mail to an address listed among the contacts indicated above.
To supply you with the product and services you purchased and to send you communications regarding your order or payment(s).	Execution of purchase and sale contract or pre-contractual measures	10 years or until you request the cancellation of your account
To allow you to interact with customer assistance operators	Execution of purchase and sale contract or pre-contractual measures	10 years or until you request the cancellation of your account
To manage and fulfil the obligations prescribed by law (such as of accounting, administrative, taxation, etc., nature)	Legal obligation	10 years
Management of complaints and any legal disputes derived; to prevent and control unlawful conduct or exercise and protect the exercise of rights.	Legitimate interest	Up to the statute of limitations or until the statutory limitation period
To check and improve our products and Store; to allow you to personalized website content, such as advertising, links, or other products	Consent of Data Subject, as indicated in the website access banner	The retention period of these cookies runs from the date of first access to the site until they are disabled or until the cookie itself expires.

6.       Cookies
What cookies are. Cookies are small text files that are sent to your computer when you visit a website. Your computer saves the cookies and sends them back to the website when you visit the website again.

The cookies used by the Store and their purpose. The site uses cookies whose purpose is to allow some sections to function correctly, for example when accessing the private area of the Store ("technical cookies"), to guarantee certain personalized features ("functional cookies"), to improve the browsing experience ("analytical cookies") and to help us offer you personalized recommendations for products you may like ("profiling cookies").

The first time you visit the website, a banner will ask you to accept (or not accept) cookies. You can refuse to accept all or some cookies or you can change your computer's settings so that you know when you receive cookies or so that you can stop your computer from automatically accepting cookies.

The Store uses the following types of cookies:

•      Technical (or browsing) cookies, which help the Site to function, by allowing you to browse pages and access the Site's private area, for example; the legal basis for processing data using these cookies is the joint controllers' interest in providing efficient, well-functioning services to their customers; the retention period of these cookies runs from the date of first access to the site until the end of the session or a maximum of one month.

•      Functional cookies, which allow certain Store features to be enabled and preferences (such as language) to be saved in order to improve your browsing experience; the legal basis for processing data using these cookies is the joint controllers' interest in providing efficient, well-functioning services to their customers; the retention period for these cookies runs from the date on which the site was first accessed until the date on which the cookies are disabled. Users may accept and disable these cookies whenever they like using the cookie management tool

•      Analytical cookies, which allow us to acquire aggregated, anonymous statistical information concerning browsing habits; the legal basis for processing data using these cookies is the joint controllers' interest in providing efficient, well-functioning services to their customers; the retention period for these cookies runs from the date on which the site was first accessed until the date on which the cookies are disabled. Users may accept and disable these cookies whenever they like using the cookie management tool.

•      Profiling cookies, which allow us to personalize advertising messages based on your interests and preferences so that we can send you only the adverts that you will find relevant or interesting; the legal basis for processing data using these cookies is the consent of the interested party; the retention period for these cookies runs from the date on which the site was first accessed until the date on which the cookies are disabled and, in any case, will be no longer than 12 months. Users may accept and disable these cookies whenever they like using the cookie management tool


The cookies that are enabled when the website is visited are:

Partner	Category	Optout	>cookie.blocked_domains<	>cookie.mandatory<
Facebook	Marketing	https://www.facebook.com/help/568137493302217	Array		1
Google Analytics	Statistics	https://policies.google.com/privacy	Array		1
New Relic	Statistics	http://newrelic.com/privacy	Array		1
Pinterest	Marketing	https://about.pinterest.com/en/privacy-policy	Array		1
Twitter	Marketing	https://support.twitter.com/articles/20170405-your-privacy-controls-for-tailored-ads	Array		1

To analyze how the site is used, we use Google Analytics, a web analysis service provided by Google Inc. ("Google") which leaves cookies on your computer so that we can perform our statistical analyses. The data collected is aggregated and does not allow us to identify you in any way. To read Google's privacy notice for the Google Analytics service, please visit this website: http://www.google.com/analytics/learn/privacy.html . To read Google's privacy policy, please visit this website http://www.google.com/intl/it/privacy/privacy-policy.html . You can refuse to accept Google Analytics cookies by following the procedure indicated by Google available at https://tools.google.com/dlpage/gaoptout?hl=it ). For this reasons, if you continue to use the Arduino site without refusing Google Analytics cookies, you agree to your data being processed by Google strictly in the ways and for the purposes outlined above.

How to disable technical cookies. You can change your browser's settings to disable cookies. Some of the site's features may not work correctly if you do so.

Below you will find links explaining how to disable cookies on a range of browsers (for any other browser you may be using, we suggest searching for this option in the software's help section, which you can normally access by pressing the F1 key):

·        Internet Explorer: Click the Tools button and then 'Internet options'. Click the Privacy Section and in Settings move the slider up to block all cookies.

 

·        Google Chrome: Click the menu in the browser's toolbar. Select 'Settings'. Click 'Advanced'. In the Privacy section, click the 'Content Settings' button. Select 'Prevent sites from saving cookie data'.

 

·        Mozilla Firefox: Click the menu button and selection 'Options'. Select the Privacy panel. Under the History Settings heading, select 'Use Custom Settings for History'. To enable cookies, tick 'Accept cookies from web sites'; to disable cookies, untick the box.

 

·        Safari: Click the 'Safari' button on the menu bar, then 'Preferences'. Now click on 'Privacy', then 'Details' to select the site, then click 'Remove'.

Alternatively you can disable Google Analytics cookies only by using the opt-out add-on provided by Google for major browsers https://tools.google.com/dlpage/gaoptout?hl=it 

7.       Where your data is processed – data transfer
Data will be processed and stored at the Zerogrey offices at Via L. Colli no. 15, Turin, and at the FGF Industry S.p.a. offices at Via Zocco 99, 36047 Montegalda (VI).

For internal administrative and organizational reasons, we may pass some of your data to companies in the Zerogrey Group operating within the European Union

8.       Who we share your data with – personal data recipients
On the understanding that, where required by law, we will obtain your prior consent and carry out any formalities required by the law; we may share your data with the following third parties (acting as external data processors):

Our service providers. We may share your data with third parties so that they can provide us with services (for example, couriers, call center companies, warehousing and logistics companies) but in this case we will enter into an agreement in compliance with Art. 28 GDPR for the purpose of protecting your data. These parties will only have possession of the data required to perform their functions and may use this data only for the purpose of providing services on our behalf or complying with the law. You can find out details of such data processors pursuant to Art. 28 GDPR by emailing. the contact addresses of the Data Controllers and any Data Protection Officers they have appointed.

Wherever we deem required by law or necessary for ensuring our own judicial protection or that of third parties. Where permitted or required by the law, we may also share the data requested by a government body or by another authorized third party or organization for the purpose of protecting or exercising our rights or those of third parties or for the purpose of limiting or preventing fraud (including credit card fraud or other fraud that we believe may have occurred during a lottery, promotion or event) and other illegal activities.




9.       Minors
Our Store is aimed at an adult audience and not minors less than 16 years old. If you are a parent or guardian and you think your child may have transmitted data, you can contact us.

10.     Security measures
We adopt the security measures required by the law. We adopt security measures to protect your data. The standard security measures that we use depend on the type of data that we process and meet the legal requirements and the standards of European government agencies.

 

11.     Your rights

You can contact Zerogrey and FGF Industry S.p.a., to request access to your personal data, modify it, delete it or limit its processing, to oppose its processing, and to request the portability of your data; you can also withdraw your consent at any time (this will not prejudice the lawfulness of the processing on the basis of the consent granted prior to the withdrawal).

 

When you exercise your right of access, you have the right to know whether your data is currently being processed, what the purpose of the processing is, what categories of data are being processed, who the recipients of your data or categories of recipients are (and, if they reside in a third country, what guarantees this transfer is based on), the retention period for your data (or the criteria for determining the retention period), whether automated processing is being carried out (for example through profiling), what the reason for the processing is, and the origin of the data (when not initially collected by us).

You have the right to submit a complaint to the National Data Protection Authority and, at any time, to ask the joint controllers for information about the data processors and parties that are authorized by the data controllers to process your data and the contents of the agreement between the joint controllers under Art. 26 GDPR.

You can exercise your rights by contacting either Zerogrey (at the addresses provided above or by emailing privacy@zerogrey.com) or FGF Industry S.p.a. (at the addresses indicated above or by emailing dpo@fgf-industry.com).

In any case, you can modify or withdraw your consent using the Store's settings.

You can withdraw your consent to receiving marketing communications, including the newsletter. To stop receiving marketing communications, you can access your account and change your choice or follow the instructions in the promotional message you receive. Alternatively you can withdraw your consent by emailing one of the addresses stated above.

You can control and disable cookies and other profiling tools. To find out how we use cookies and other profiling tools, click here.

You can change your preferences regarding marketing emails and data processing through profiling by using the privacy settings in your account or by writing to one of the email addresses given above.

12.     What happens if we change this policy
We may make changes to our privacy policy. We will inform you of any changes, in accordance with the law. We will also publish an updated version on our website. It will have a different date and version number to the one given below. Please visit the site regularly to check for updates.

Latest update: 14 October 2020