Flou

 

PRIVACY POLICY

Information document pursuant to and for the purposes of Article 13 of Regulation (EU) 2016/679 (GDPR)

 

Why this information

Pursuant to Regulation (EU) 2016/679 (hereinafter, "GDPR"), this page describes how personal data are processed. This information is provided pursuant to Article 13 of GDPR and is not to be considered valid for other third-party websites that may be reached through links on this website, for which no liability is accepted.

 

Processable personal data

Personal data: any information related to an identified or identifiable natural person («data subject»); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity (C26, C27, C30 of GDPR).


1. WHO IS THE DATA CONTROLLER? HOW TO CONTACT THEM?

The data controller is Flou S.p.A., with registered office in Milan, Via Tommaso Grossi 2, in the person of its pro-tempore Legal Representative, who may be contacted for any information by e-mail privacy@flou.it or telephone No. +39 0362 3731.


2. PURPOSE OF PROCESSING, LEGAL BASIS, PERIOD OF DATA RETENTION AND NATURE OF DATA PROVISION

Purpose of processingLegal basisPeriod of data retentionNature of data provision
E) Subscription to the Flou newsletter
to receive advertising material or for the purposes of market research, satisfaction surveys or commercial and promotional communication, by newsletter (e-mail).

In order to compare and, if necessary, improve the automated communication results, the Data Controller uses systems with reports. Thanks to the reports, the Data Controller will be able to know, for example: the number of readers, openings, unique "clickers" and "clicks"; the devices and operating systems used to read the communication; details of the activity of individual users; details of e-mails sent, delivered, not delivered and forwarded. All these data are used for the purpose of comparing, and possibly improving, the communication results.
Processing is based on consent to the processing of personal data (C42, C43) art. 6 par. 1 lett. a) of GDP.Until consent is withdrawn (or opting out).The provision of data is optional. Failure to provide the necessary data will result in the impossibility of receiving direct marketing communications.

3. TO WHOM WILL PERSONAL DATA BE DISCLOSED?

Personal data are disclosed, also on the basis of the purposes of specific areas, to subjects who will process them by acting as independent Data Controllers, or Data Processors (art. 28 GDPR) and processed by natural persons (art. 29 GDPR) acting under the authority of the Data Controller and the Processors on the basis of specific instructions on the purposes and methods of processing, for specific purposes based on the area of reference. The data will be disclosed to the following categories of recipients:

The list of Data Processors can be obtained by writing to privacy@flou.it or to the other addresses above.


4. WILL DATA BE TRANSFERRED TO NON-EEA COUNTRIES?

Personal data will not be transferred to non-EEA countries. In particular, note that the data will be stored in Italy for the purposes of hosting, managing, developing and maintaining the site. All third parties to whom the data may be disclosed are based in Italy.


5. IS THERE AN AUTOMATED DECISION-MAKING PROCESS?

Personal data are subject to traditional manual, electronic and automated processing. Note that the decision-making process is not fully automated. Profiling, which may be carried out with the express consent of the data subject as stated in the purposes, will be performed through the intervention of the operator who processes the profile of the data subject and analyses their habits and consumption choices, in order to improve the data controller’s commercial offer and services (non-automated profiling).


6. WHAT ARE YOUR RIGHTS? HOW CAN YOU EXERCISE THEM?

You may assert your rights as stated in art. 15 et seq. of GDPR, by contacting the Data Controller at the e-mail address privacy@flou.it or at the contacts above. You have the right, at any time, to obtain access to your personal data (art.15), their rectification (art.16), their erasure (art.17), restriction of processing (art.18). The data controller shall (art. 19) communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed. The controller shall inform the data subject about those recipients if the data subject requests it. You have the right to object (art.21), at any time, to the processing of your data based on legitimate interest, and in cases where the legal basis is consent, you have the right to withdraw the consent given, without prejudice to the lawfulness of the processing based on the consent given prior to the revocation. If you wish to stop receiving automated direct marketing communications (e-mail), please send an e-mail to privacy@flou.it with the subject line "unsubscribe from automated" or use our automatic unsubscribe systems for e-mails only (opt-out). If you believe that the processing of personal data carried out by the Data Controller is in breach of the provisions of Regulation (EU) 2016/679, you have the right to lodge a complaint with the Supervisory Authority, in particular in the Member State in which you normally reside or work or in the place where the alleged breach of the Regulation has occurred (Privacy Guarantor), or to take appropriate legal action.


7. CHANGES TO THE POLICY

The Data Controller reserves the right to modify, update this policy or to add or remove parts of it. In order to facilitate the verification and modification of the text, the policy will contain the date of its updating.

Update date: 28 September 2021