Information pursuant to Article 13 of EU Regulation No. 2016/679 - GDPR

Pursuant to EU Regulation No. 2016/679 (hereinafter "GDPR 2016/679"), containing provisions on the protection of persons and other subjects with regard to the processing of personal data, we wish to inform you that the personal data you provide will be processed in compliance with the aforementioned legislation and the confidentiality obligations to which the professional is bound.


Data Controller and Data Protection Officer (DPO)

Data Controller(s): La Via Gentile S. r. l.

DPO: Dr. Barbara Scavarda


For the protection of your data you can reach the DPO at any time via e-mail address info@laviagentile.com or at the postal address of the registered office in Via Torino 27/1 Chivasso (TO) - Italy.


Information gathered

We collect two types of information from users.


The first type concerns unidentified and non-identifiable information pertaining to a User (or Users) that may be made available or collected through the use of the Site or the Smartphone App ("Non-Personal Information"). We do not know the identity of any User whose Non-Personal Information has been collected. The Non-Personal Information we collect may include aggregate usage information and technical information transmitted from your device, including certain software and hardware information (e.g., the type of browser and operating system used by your device, language preferences, access time, etc.) and is used to improve the functionality of our Site and Smart Phone Applications (Apps). We may also collect information about your activity on the Site and Apps (e.g. pages and sections viewed, online navigation, clicks, actions, etc.).


The second type concerns Personal Information which is personally identifiable information, i.e. information that identifies an individual or can identify him or her with reasonable effort. Such information includes:

  • Device Information: We collect personal information from your devices. This information includes geolocation data, IP address, unique identifiers (e.g. MAC addresses and UUIDs) and other information about your activity throughout the Site and in smart phone applications.
  • Registration information for apps and newsletters: when the User registers on our Site to our newsletter, he/she will be asked to provide certain details such as: first and last name, e-mail or physical address, and other information.


We receive personal information from various sources:

  • When the User voluntarily provides personal data to register through the site or our smart phone applications;
  • When you use our Site or our apps and access them in connection with the use of our services
  • From third-party providers, public services and registers (e.g. traffic analysis providers).

We do not rent, sell or share information about Users with third parties except as described in this Privacy Policy.


Scope of data processing

The purpose of the processing is the provision of services or information linked to the health and wellness practices carried out by the company and the collection of data necessary for the best possible provision of those services, including services related to the beta test phase for the evaluation of the company products.


We may use the information for the following purposes:

  • Communicating with the User - sending notices about our services, providing technical information and responding to any customer service issues;
  • Communicate with the User and inform him/her of the latest updates and services;
  • Propose advertisements when using our Site or applications;
  • Marketing our websites and products;
  • Carrying out analysis and statistics, aimed at improving the sites and our applications.


In addition to the various uses listed above, we may transfer or disclose Personal Information to our affiliated companies and collaborators.


In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third party providers, which may be located in different jurisdictions around the world, for the following purposes:

  • Hosting and operation of our Site and smart phone applications (apps);
  • Propose our services to the User, including a personalised view of our site or apps;
  • Store and process such information on our behalf;
  • Propose advertisements to the user and support us in evaluating the success of our advertising campaign, as well as helping us to recalibrate the target users;
  • Provide the User with marketing offers and promotional materials relating to the site and services;
  • Carrying out research, technical diagnostics and analysis.


We may also disclose information in good faith if we believe that doing so is useful or reasonable to: (i) comply with applicable laws, regulations, legal process or governmental requests, including health care ones; (ii) enforce our policies (including the Agreement), including investigating potential violations; (iii) investigate, detect, prevent or take action regarding illegal or other wrongful activity, suspected fraud or security concerns; (iv) to establish or exercise our rights to defend against legal claims; (v) to prevent damage to the rights, property or safety of us, our customers, Users or third parties; or (vi) for the purpose of cooperating with law enforcement and/or where we believe it is necessary to enforce intellectual property or other legal rights.


Processing and storage methods

Personal data may be processed by means of both paper and computer files (including portable devices) and processed in a manner strictly necessary to fulfil the purposes indicated above. The processing will be carried out in compliance with the provisions of Article 32 GDPR 2016/679 on security measures, by specially appointed persons and in compliance with the provisions of Article 29 GDPR 2016/ 679.

We would like to inform you that, in accordance with the principles of lawfulness, purpose limitation and data minimisation, pursuant to Article 5 GDPR 2016/679, subject to your free and explicit consent expressed in writing, your personal data will be kept for the period of time necessary to achieve the purposes for which they are collected and processed. In light of applicable regulations, we will retain records containing customers' personal data, account opening documents, communications and anything else required by applicable laws and regulations.


Special categories of personal data

Pursuant to Articles 9 and 10 of EU Regulation No. 2016/679, you may provide the controller with data that can be qualified as 'special categories of personal data', i.e. data revealing 'racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, data concerning a person's health or sexual life or sexual orientation'. These categories of data may only be processed with your free and explicit consent, given in writing.


User Rights

At any time, you may exercise, pursuant to Articles 15 to 22 of EU Regulation No. 2016/679, the right to:

a. request confirmation of the existence of your personal data;

b. obtain information on the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data have been or will be disclosed and, where possible, the storage period;

c. obtain rectification and deletion of data;

d. obtain restriction of processing;

e. obtain portability of data, i.e. receive them from a data controller, in a structured, commonly used and machine-readable format, and transmit them to another data controller without hindrance;

f. oppose to processing at any time and also in the case of processing for direct marketing purposes;

g. to request from the data controller access to and rectification or erasure of personal data or restriction of processing concerning him or her, or to object to their processing, in addition to the right to data portability;

h. revoke consent at any time without affecting the lawfulness of the processing based on the consent given before revocation, without prejudice to the company's right to discontinue those services for which consent is required;

i. file a complaint with a supervisory authority.


However, please note that these rights are not absolute and may be subject to our legitimate interests and regulatory requirements.

If you wish to exercise the above rights or receive further information, please contact the Data Controller at the references indicated above.


Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.


A "cookie" is a small piece of information that a website or smartphone application assigns to your device while you are viewing the website or application. Cookies are very useful and can be used for a variety of purposes, including allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences, and making it faster and easier for you to interact with our services. Cookies are also used to ensure that the advertisements displayed are relevant to you and your interests and to compile statistical data on the use of our Services.


Our sites and smart phone applications use the following types of cookies:

a. “session cookies” stored only temporarily during a browsing session to allow normal use of the system, deleted from the device when the browser is closed;

b. “persistent cookies” which are only read by the site or applications, stored on the User's device for a set period and not deleted when the pages are closed. Such cookies are used when we need to know who the User is for repeat visits, for example to enable us to store preferences for future access;

c. “third-party cookies” set by other online services that track content on the page you are viewing, for example, by third-party analytics companies, which monitor and analyse your access to our website and our smart phone applications.


Cookies do not contain any information that identifies you personally, but Personal Information that we store about you may be linked by us to information stored and obtained by cookies. You can remove cookies by following the instructions in your device preferences; however, if you choose to disable cookies, some features of the Site and application may not function properly and your user experience may be limited.


We also use a tool called “Google Analytics” to collect information about the use of the Site and the App. Google Analytics collects information such as how often Users access the Site and App, what pages they visit, when they do so, etc. We use the information for the sole purpose of improving our Site and services. Google Analytics collects the IP address assigned to you on the date you visited the pages instead of your name or other identifying information. We do not combine the information collected through Google Analytics with personally identifiable information. Google's ability to use and share the information it collects about your visit to our Sites or Apps is limited to the Google Analytics Terms of Use and Privacy Policy.


Collection of third-party information

Our policy only covers the use and disclosure of information collected from you. To the extent that you disclose information about yourself to other parties or sites on the Internet, different rules may apply to the use or disclosure of the information you transmit to them. Accordingly, we encourage Users to read the terms and conditions and privacy policy of each third party to which they choose to disclose their information.


This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals who do not work for us and who we do not manage, including third parties who may disclose information as provided in this Privacy Policy.


How do we take care of information?

We care deeply about implementing and maintaining security and user information. We adopt industry-standard policies to ensure the security of the information we collect and maintain, prevent unauthorised use of that information, and require any third parties to comply with similar security requirements in accordance with this Privacy Policy. Although we have taken all reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorised access to or misuse of our Site or applications, and we make no warranty, express, implied or otherwise, that we will prevent such access.


Transfer of data outside the European Economic Area

Note: some recipients of data may be located outside the European Economic Area. In this case, we will only transfer data to countries approved by the European Commission as offering an adequate level of data protection, or enter into legal agreements to ensure an adequate level of data protection.


Advertisements

We may use third party advertising technologies to serve advertisements when you access the Site or our applications. These technologies use customer information about your use of the Services to deliver advertisements (e.g., place third-party cookies on your web browser).


Marketing

We may use Personal Information such as your name, e-mail address, telephone number, etc. internally or by using third party contractors for the purpose of providing you with promotional materials relating to our services, which we believe may be of interest to you.

Out of respect for the User's right to privacy, means are available within such marketing materials to opt-out of receiving further marketing offers from us. If the User unsubscribes, we will remove his/her email address or telephone number from our marketing distribution lists.

Note: Even if you unsubscribe from receiving marketing emails from us, we may send you other types of important email communications without offering you the opportunity to opt-out of receiving them. These communications may include customer service announcements or administrative notices.


Corporate Transaction

We may share information in the event of a corporate transaction (such as the sale of a significant part of our company, a merger, consolidation or sale of assets). In such a case, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.


Minors

We are aware of the importance of protecting children's privacy, especially in an online environment. Under no circumstances do we allow minors to use our services without the prior consent of a parent or legal guardian. We do not knowingly collect personal information from minors. If a parent or guardian becomes aware that a child has provided us with Personal Information without their consent, they should contact us at info@laviagentile.com.


Updates or amendments to this Privacy Policy

We reserve the right to periodically change or revise the Privacy Policy; material changes will be effective immediately upon viewing the updated Privacy Policy. The latest revision will be set out in the "Last Modified" section. Your continued use of the Platform following notification of such changes on our website constitutes your acceptance of and consent to such changes to the Privacy Policy and your agreement to be bound by its terms.



Last modified, November 15th, 2022

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