Privacy policy

Personal data processing notice

Under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR)

Introduction

This notice applies to the website proramillenote.it (the Site), owned by PRORAMILLENOTE SRL, Via Monte Cervino, 70, 20862 Arcore (MB), Italy. The company is registered with the Monza Chamber of Commerce (MB) under no. MB-2523001, VAT number 10323920966. Its paid-up share capital is €50,000.00 (the Data Controller). PRORAMILLENOTE SRL acts as Data Controller under the GDPR (EU 2016/679) and Legislative Decree 196/03. Legislative Decree 101/2018 later amended this decree.

Purchases on the site

If you provide your consent, we process your personal data to let you make purchases or request quotes. We also process it to answer your requests for information on the Site.

Registration

We use your registration details to give you access to the reserved area of the Site. We also use them to let you enjoy the online services we offer to registered users.

Marketing

With your consent, we may use the personal data you provide to send you advertising material or newsletters. This material may cover our products or those of third parties.

Profiling

With your consent, we may process your personal data for profiling purposes. This means we analyse your consumption choices by reviewing the type and frequency of your purchases. We use this analysis to send you advertising material or newsletters about products of specific interest to you.

Soft spamming

We may use the email address you provide when purchasing on the Site to offer you similar products directly. We may do this even without your consent, as long as the product is similar to one you already bought (so-called soft spamming). You may object to this processing at any time by notifying us.

In compliance with the GDPR, this notice explains the conditions under which we process your personal data.

Art. 1. Purpose and legal basis for processing personal data.

Mandatory or optional data, consequences of refusal.

We process personal data for the following purposes:

• a) To let you register on the Site and access services reserved for registered users. This also lets us meet legal and regulatory obligations, particularly in administrative, accounting, and public security matters. The legal basis is our need to take pre-contractual steps at your request, or to fulfil a legal obligation;
• b) When you place an online order, this lets us complete the purchase contract and carry out related operations. Where sector rules require it, this also covers tax obligations. The legal basis is our obligation to perform the contract with you, or to fulfil legal obligations;
• c) Limited to the email address you provide when purchasing through the Site, to let us offer similar products directly (so-called soft spamming). This applies unless you object under this notice. The legal basis is our legitimate interest in sending these communications. This interest matches your interest in receiving soft-spam communications;
• d) With your consent, to send newsletters and carry out market research, including user satisfaction surveys. Also to send advertising material about our products or third-party products by email (marketing purposes). With your consent, to build your commercial profile by analysing your purchasing choices and habits. We use this to monitor customer satisfaction. We also use it to send you advertising material of specific interest to you by email (profiling purposes). The legal basis is your consent;
• e) To respond to your requests through our customer care service. Providing this data is optional, but refusing it means we cannot answer your questions through this service. The legal basis is our legitimate interest in responding to user requests. This interest matches your interest in receiving a reply to your messages;
• f) To respond to your requests by email or phone. Providing this data is optional, but refusing it means we cannot respond to your requests. The legal basis is our legitimate interest in responding to user requests. This interest matches your interest in receiving a reply to your messages.

Providing data for purposes a) and b) is entirely optional. However, this processing is necessary to complete a purchase on the Site. If you refuse to provide this data, you will not be able to complete the purchase.

Consenting to processing for marketing and profiling purposes is entirely optional.

Refusing consent leads only to the consequences described below:

• if you do not consent to marketing processing, you will not receive advertising material about our products or third-party products. We will also be unable to carry out market research, including satisfaction surveys. We will not be able to send you newsletters either.
• if you do not consent to profiling, we cannot build your commercial profile by analysing your purchasing choices and habits. We will also be unable to send you advertising material of specific interest to you.

Regardless of the above, we may still use your personal data to fulfil legal obligations. We may also use it to meet contractual obligations arising between you and us.

You may object to the processing of your personal data at any time. Use the link at the bottom of any promotional email we send you.

Data provided for the “refer a friend” service

On the Site, you can recommend the Site or one or more products to your friends. You do this by entering their personal data when prompted.

We will keep this personal data only for as long as needed to document that we completed your request.

To use this service, you must be able to show that you have the right to use your friends’ personal data. We may ask you for this proof at any time.

Data provided for the “send a gift” service

On the Site, you can give one or more products to another person by entering their personal data when prompted.

We will keep this personal data only for as long as needed to document that we completed your request.

To use this service, you must be able to show that you have the right to use your friends’ or contacts’ personal data. We may ask you for this proof at any time.

Social networks

If you choose to register or log in to the Site through Facebook, Google Plus, or Instagram, you agree to this. These social networks will send us the personal data needed for registration or login.

Payment card data

• To pay by card on the Site, you enter your card details directly on a page. This page connects securely with our payment provider, which acts as an independent data controller. This process does not pass through our server, so we never handle this data ourselves. We receive your data only in encrypted form.
• Under Directive 2015/2366/EU on payment services in the internal market (PSD2), please note the following. Completing a card purchase may require your mobile number or another personal detail. To let you complete the purchase, the payment institution handling the transaction will send you an authentication code. You must enter this code during the purchase process to meet the Strong Customer Authentication requirements set by PSD2.
• The legal basis for this processing is our obligation to comply with the law. It does not require your consent.
• Regarding card payment data, we need to process your personal data to complete the online purchase contract with us.
• If you do not provide this data, you will not be able to complete your online purchase.

PayPal

On the Site, you can also pay using PayPal. In this case, we will direct you to a page outside the Site. There, you will enter the personal data PayPal requires (PayPal acts as an independent data controller) to complete your purchase. This data does not pass through our server, so we never handle it.

We need to process your personal data to complete the online purchase contract with us. If you do not provide this data, you will not be able to complete your online purchase.

Bank transfer

If you choose bank transfer as your payment method, we will ask for your bank details whenever a refund is due. We use these details to arrange the payment.

Special category or judicial data

We do not process special category or judicial data.

Geolocation

• When you access the Site, your device (desktop or mobile) may prompt you to allow or deny geolocation.
• You can change your geolocation settings at any time through your device settings.
• We do not collect or store any data about your device’s location.
• The legal basis for this processing is our legitimate interest in providing services relevant to your location. This interest matches your interest in receiving services relevant to where you are.

Art. 2. How we process your data

We mainly process your personal data using electronic or automated tools, apply methods and safeguards that ensure security and confidentiality under the GDPR and collect information and apply processing methods that are relevant and not excessive for the services we provide. We manage and protect your data in environments under constant access control.

Art. 3. Data disclosure and dissemination

We may disclose your data to:

• all parties, including public authorities, who have access to personal data under regulatory or administrative measures
• companies or third parties handling printing, packaging, shipping, delivery, or collection of products purchased through the Site
• postal services, couriers, suppliers (e.g. drop-shipping sales), or forwarders handling delivery of products purchased through the Site
• banks and companies managing national or international payment networks used for online payments for products purchased through the Site
• companies, consultants, or professionals handling the installation, maintenance, updating, and general management of our hardware and software, or of the systems we use to provide our services
• the Data Protection Officer (DPO)
• external companies handling advertising communications on our behalf
• our employees and/or collaborators
• the company handling our customer care activities
• parties managing online payment transactions
• public and/or private parties, individuals or legal entities (legal, administrative, and tax consultancy firms, courts, chambers of commerce, labour offices, etc.), where disclosure is necessary to fulfil legal obligations.

We will not disseminate your data, except in anonymous and aggregated form, for statistical or research purposes.

Art. 4. Data controller; Data Protection Officer

You can contact the Data Controller at:

PRORAMILLENOTE SRL Via Monte Cervino, 70 – 20862 Arcore (MB) – Italy
Phone: +39 039 616593
E-mail: customercare@proramillenote.it
Contact page: Through the contact form.

Below are the contact details of the Data Protection Officer:

• Acting Managing Director

Art. 5. Data retention

• We keep your data only for as long as needed to provide our services correctly.
• This period always complies with applicable regulations.
• If you close your account yourself, we keep your data for administrative purposes for up to 90 days.
• This does not apply where the law requires us to keep accounting records, or data for public security purposes.
• We keep and process your personal data for marketing and profiling purposes for as long as the law allows.
• This also follows the guidance of the Italian Data Protection Authority (Garante).
• After this period, we may ask you to renew your consent for these purposes.
• Alternatively, we may anonymise your data and keep it only for statistical or historical purposes.

Art. 6. Your rights

Under Article 13 of the Privacy Regulation, we inform you that you have the right to:

• Ask us for access to your personal data, and its rectification or erasure.
• Ask us to restrict processing that concerns you, or object to that processing.
• Ask us for the portability of your personal data.
• Withdraw your consent at any time, without affecting the lawfulness of processing carried out before withdrawal.
• Lodge a complaint with a supervisory authority, such as the Italian Data Protection Authority (Garante).

You can exercise these rights by contacting the Data Controller or the Data Protection Officer. Use the contact details above; no specific formality is required.

Art. 7. Changes

We reserve the right to change this notice at any time. We will give Site users appropriate notice and continue to protect your personal data adequately. Please check this notice regularly for any updates.

Art. 8. Newsletter

The Site uses the Brevo Newsletter service to send commercial offers, coupons, and discount vouchers. We do not share your email address with third parties. For more information, see Brevo’s Privacy Policy.

Drafted on 22 February 2022.

See also our cookie policy and code of ethics.