The online store of Hantano (the “Hantano Store”), which can be accessed via the site www.hantano.com and via any other site managed by Hantano S.r.l. through the URL hantano.com, is dedicated to electronic sales and is managed by Hantano S.r.l. (hereafter referred to also just as “Hantano”), as autonomous Data Controllers (hereafter referred to also just as “Controllers”). With this privacy policy (hereafter referred to as the “Privacy Policy”), which refers to the site hantano.com (hereafter referred to as the “Site”), Hantano propose to provide users with information about the data controllers, the personal information collected through the Site, the purposes and procedures for which such information is processed, the third parties involved in the processing, its possible transfer abroad, the security measures adopted to protect and safeguard the data gathered, and the procedures through which users can verify the processing of data concerning them and exercise the rights granted to them by Legislative Decree No. 196 of 30 June 2003 (hereafter referred to as “Legislative Decree 196/2003”).
The Privacy Policy was drawn up in accordance with Article 29 of Recommendation 2/2001, adopted on 17 May 2001 by the Working Group on Personal Data Protection, in relation to the minimum requirements for online data collection in the European Union, and also constitutes a disclosure to data subjects pursuant to Article 13 of Legislative Decree 196/2003.
The Privacy Policy is applicable exclusively to the Site, and not to other websites that may be viewed by users via links present on the Site.
TYPE OF PERSONAL DATA COLLECTED AND PROCESSED
Browsing data
When users visit and view the Site, Hantano do not generally collect personal data from them, with the exception of “browsing data”. The technological platform through which the Site is made available to users automatically records some browsing data (the transmission of which is implicit in the use of internet communication protocols), such as the name of the internet access provider, the site of origin, pages visited, date and duration of the visit, etc. Such information allows users to access the Site and use certain services, and may be aggregated and used anonymously for statistical purposes and to verify that the Site is functioning properly.
Hantano do not collect these browsing data in order to associate them with other information about the users and subsequently identify the users. However, browsing data, by their very nature, may allow identification of the users after they have been processed and associated with other information. Browsing data may therefore be used by Hantano in order to ascertain any liability concerning computer crimes committed to the detriment of the Site or through the Site. With the exception of this possibility, the browsing data described above are stored only temporarily, in compliance with applicable regulations.
Data provided voluntarily by users
Hantano collects and processes personal data that users provide voluntarily when interacting with the functionalities and services of the Site. In the sections of the Site where users’ personal data are collected, a disclosure is published pursuant to Article 13 of Legislative Decree 196/2003.
PURPOSES OF THE PROCESSING
Hantano process users’ data for the following purposes:
- • management of browsing on the Site;
- • management of Site security;
- • compliance with legal and regulatory obligations;
- • exercise of rights in judicial proceedings.
TLG process users’ data for the following purposes:
- • management of sales and transactions performed in the context of the Hantano Store;
- • management of orders;
- • sale and delivery of products;
- • management of returns and guarantees, and other activities necessary for the sale of products via the Hantano Store.
NATURE OF THE PROVISION OF DATA
With the exception of browsing data (which are automatically collected by the system), the transmission of data by users for the aforementioned purposes is optional. Failure to transmit data for commercial purposes will not affect your ability to access the functionalities offered by the Site, except that it will be impossible to buy products.
PROCESSING METHODS
Users’ personal data are processed using IT and electronic tools, mainly via electronic and automated means and, in certain specific transactions, using paper documentation. In accordance with LD 196/2003, specific security measures are observed to prevent data loss, unlawful or improper use, and unauthorised access.
PARTIES INVOLVED IN THE PROCESSING
Users’ personal data are processed by parties designated as processors or tasked with processing, in accordance with the provisions of Articles 29 and 30 of LD 196/2003. In addition to the above, the data may be brought to the attention of third parties such as freelancers, consultants and, more generally, third parties that cooperate with Hantano to pursue the aforementioned purposes, or third parties that have been tasked with activities on an outsourcing basis.
In any case, Hantano undertake to provide such third parties only with the data necessary to perform the duties and activities assigned to them; it also undertakes to do everything in its power to ensure that third parties use the data received exclusively for the purposes indicated by Hantano and in compliance with the applicable regulations on personal data processing.
Users’ personal data may also be brought to the attention of third-party companies in the event of mergers or demergers, acquisitions, disposals of companies or business units, or other extraordinary corporate transactions. Users’ personal data may also be brought to the attention of legitimate recipients pursuant to law or regulations, for example in the event of a request by the competent public authorities or judicial authorities or, more generally, in the context of judicial proceedings, as well as to protect and defend the Site and the rights of Hantano . Such parties shall process the data as autonomous data controllers or processors, depending on the case in question.
Your data will be transferred outside of the European Union only in accordance with all the safeguards set forth by EU privacy law. In particular, personal data may be transferred to service providers located outside of the EU, with whom it has been contractually agreed that such data shall be granted the adequate level of protection required by EU law.
An updated list of all Data Processors may be requested from the Data Controllers identified below, the email address hello@hantano.com
The Data shall not be disseminated.
CONNECTION TO THIRD-PARTY WEBSITES AND SERVICES
The Site may contain banners, advertising messages and advertisements of third parties or Data Controller’s business partners. By accepting the offers from the aforesaid third parties, the user may access web pages pertaining exclusively to such third parties who, being outside of the control of the Data Controller, are in no way bound to comply with the provisions of this Privacy Policy.
Hantano thus invite users to take care when accepting offers of services from third parties, and to read the information provided by the third party regarding its processing of personal data, which the Data Controllers have no control over, nor can be held liable for.
MODIFICATIONS TO THIS DOCUMENT
This Privacy Policy may be modified in order to comply with new legal provisions or altered procedures for data processing by Hantano, or because of changes relating to the Site’s functioning or the performance of services rendered through the Site.
Hantano shall be responsible for promptly informing users of any update by publishing it in this section of the Site. Hantano therefore invite users to periodically consult the Privacy Policy in order to ensure that they have read the most recently published version.
THE DATA CONTROLLER
The Data Controllers are, for the activities under their respective scopes of competence, as indicated in this Privacy Policy:
USERS’ RIGHTS
Users of the Site may exercise the rights pursuant to Article 7 of Legislative Decree 196/2003, which are reproduced in full below. These rights may be exercised informally simply by sending a request to the Data Controllers as identified above, to the email address hello@hantano.com
ARTICLE 7 OF LEGISLATIVE DECREE 196/2003. THE DATA SUBJECT’S RIGHTS
- The data subject has the right to obtain confirmation of the existence or non-existence of personal data concerning them, even if they are not yet recorded, and the communication of said data in an intelligible form.
2. The data subject has the right to be informed of:
a. the origin of the personal data;
b. the purposes and methods of the data processing;
c. the logic applied in the event of processing performed with the aid of electronic instruments;
d. the identification details of the data controller, the data processors and the designated representative pursuant to Article 5, paragraph 2;
e. the parties or categories of parties to which the personal data may be communicated or which may access the data in the capacity of designated representative in the territory of the state, data processor or party tasked with processing the data.
3. The data subject has the right to obtain:
a. an update, adjustment or, where they have an interest therein, supplement to the data;
b. the deletion, anonymisation or blocking of data processed unlawfully, including data that do not need to be stored for the purposes for which the data were collected or subsequently processed;
c. a certification that the operations mentioned under a) and b) have been brought to the attention, including with regard to their content, of those to whom the data were communicated or disseminated, except in cases where this is impossible or requires a use of resources that is manifestly disproportionate to the right being protected.
4. The data subject has the right to object, in full or in part:
a. for lawful reasons, to the processing of personal data concerning them, even if it is pertinent to the purpose of the data collection;
b. to the processing of personal data concerning them for the purposes of sending out advertising or direct-sales material or for the performance of market research or marketing communications.
SUBSCRIBE TO THE HANTANO.COM NEWSLETTER: INFORMATION NOTICE ON PERSONAL DATA PROCESSING
Information Notice on personal data processing
According to applicable laws, Hantano S.r.l., provides you with the following information on the collection, use, disclosure or processing of your personal data.
- The purposes of the processing
The personal data provided by you through the registration form will be collected, used, disclosed or processed to register you to Hantano’s newsletter. By requesting to be registered to the newsletter clicking on the button on the bottom of the registration form, you consent to the collection, usage, disclosure or processing of your personal data. - Data Provision
Your email is necessary to achieve the registration to the Hantano newsletter. If you do not provide data, you will not have the possibility to subscribe the newsletter. There exists risk of personal data leakage and misuse, however, Hantano has implemented a number of security measures to protect your personal data processed by means of electronic or automated tools. - Data processing and storage methods
The data collected will be processed and stored both on paper and automated tools. The data collected for newsletter registration purposes, will be retained until the user asks to revoke his registration to the newsletter. On expiry of the retention terms indicated above, or in case the Data Controller becomes insolvent and cannot continue processing your personal data, your data will be automatically erased. - International data flows, communication and dissemination.
Data will be processed by:
- • employees and associates of the Data Controller designated as data processors or persons in charge of the processing;
- • third parties members or not of the EU, designated as data processors, used by the Data Controller in particular for mailing of newsletter services and management and maintenance of IT systems.
A full list of data processors appointed by the Data Controller can be communicated by writing to the following address: hello@hantano.comYour data may also be disclosed to third parties, independent data controllers,. in particular, professionals or legal or tax advice and assistance firms. Your data will not be disseminated in any way. Your data will be transferred outside of the country or of the European Union, in countries not providing for an adequate level of data protection, only in accordance with the safeguards set forth by applicable privacy laws.
- Data subject’s rights
According to applicable laws, you can at any time request information on personal data collected, used, disclosed or processed by the Data Controller, as well as request for access to such personal data, ask for integration, rectification or erasure, object to their processing and withdraw your consent. In order to exercise your rights above and/or or submit any inquiries or complaints with regard to the processing of your personal data, you may send a request to the Data Controller by writing to this email address: hello@hantano.com. Moreover, you can at any time delete your subscription to the newsletter following the link below at every communication.
Last update: November 2017