Privacy Policy

Creative Company Srl, with registered offices in Via Virgilio, 3 00193 Roma (RM), VAT number 15027801008 and C.F. 15027801008 (hereinafter, also the “Organisation”), as the organisation responsible for the processing of personal data of users (hereinafter, the “Users”) who browse and use the services available on the website creativecompany.it (hereinafter, the “Site” and the “Services”) presents below the privacy policy pursuant to art. 13 of EU Regulation 2016/679 of 27 April 2016 (hereinafter, the “Regulation”, or also the “Applicable Law”).

This Site and the Services are reserved for individuals who are over 18 years of age. The Data Controller therefore does not collect personal data relating to persons under the age of 18. At the request of the Users, the Data Controller will promptly delete all personal data involuntarily collected and relating to subjects under the age of 18.

The Data Controller takes into great account the right to privacy and protection of the personal data of its Users. For any information in relation to this privacy statement, Users can contact the Data Controller at any time, using the following methods:

Attention Creative Company Srl:

• By sending a registered letter with return receipt to the registered offices in Via Virgilio, 3 00193 Roma (RM)

• By sending an e-mail message to info@creativecompany.it

1. Purpose of data processing

Users’ personal data will be lawfully processed by Creative Company Srl pursuant to art. 6 of the Regulation for the following processing purposes:

a) contractual obligations and provision of the Services, to allow navigation of the Site or to execute the Conditions of Use of the Site, which are accepted by the User when registering on the Site and/or when using the Services and to fulfill the specific requests of the User. User data collected by Creative Company Srl for the purposes listed above include: name, surname and nickname voluntarily chosen, age, province of residence/domicile, gender, email address, as well as all information and personal data of the User eventually and voluntarily published. Unless the User gives Creative Company Srl specific and optional consent to the processing of their data for further purposes, the User’s personal data will be used by Creative Company Srl for the exclusive purpose of ascertaining the User’s identity (also through validation of the e-mail address), thus avoiding possible scams or abuses, and contacting the User for service reasons only (e.g. sending notifications relating to the Services). Without prejudice to the provisions elsewhere in this privacy statement, in no case will Creative Company Srl allow the Users’ personal data to be accessible to other Users and/or third parties.

b) administrative-accounting purposes, or to carry out organisational, administrative, financial and accounting activities, such as internal organisational activities and activities functional to the fulfilment of contractual and pre-contractual obligations;

c) legal obligations, or to fulfill obligations established by law, by an authority, by a regulation or by European legislation.

The supply of personal data for the processing purposes indicated above is optional but necessary, since failure to provide them will make it impossible for the User to browse the site, register on the Site and use its Services.

The personal data that are necessary for the fulfilment of the processing purposes described in this paragraph 1 are indicated with an asterisk in the registration form on the Site.

2. Additional processing purposes: marketing (delivery of advertising material, direct sales and commercial communications)

With the unrestricted and optional consent of the User, some of the User’s personal data (i.e. name, surname and email address) may also be processed by the Data Controller for marketing purposes (delivery of advertising material, direct sales and commercial communications) , that is, the Data Controller can contact the User by mail, email, telephone (landline and/or mobile, with automated call or call communication systems with and/or without the mediation of an operator) and/or SMSs and/or MMSs to propose to the User the purchase of products and/or services offered by the same Organisation and/or by third-party companies, to present offers, promotions and commercial propositions.

In the event of lack of consent, the ability to register on the Site will not be affected in any way.

In the event of consent, the User may at any time revoke said consent by making a request to the Data Controller in the manner indicated in paragraph 7 below.

The User can also easily refuse further delivery of promotional communications via email by clicking on the appropriate link for the withdrawal of consent, which can be found in each promotional email. Once the consent has been revoked, the Data Controller will send the User an email message to confirm that the consent has effectively been revoked. If the User intends to revoke his/her consent to the delivery of promotional communications by telephone, while continuing to receive promotional communications via email, or vice versa, he/she can send a request to the Data Controller in the manner indicated in paragraph 7 below.

The Organisation notes that, following the exercise of the right to revoke the delivery of promotional communications via email, it is possible that, for technical and operational reasons (e.g. the compilation of contact lists already completed shortly before receipt by the Data Controller of the revocation request), the User continues to receive some additional promotional messages. Should the User continue to receive promotional messages after 24 hours have elapsed from the exercise of the right of revocation, please report the problem to the Organisation, using the contacts indicated in paragraph 7 below.

3. Additional processing purposes: newsletters

With the unrestricted and optional consent of the User, some of the User’s personal data (i.e. name, surname, address and e-mail address) may be processed by the Data Controller also for the purpose of sending newsletters. Therefore, the User may receive newsletters from the Organisation relating to their area of interest, and/or in relation to news and promotions on the Site and/or initiatives of the Organisation.

In the event of lack of consent, the ability to register on the Site will not be affected in any way.

In the event of consent, the User may at any time revoke said consent by making a request to the Data Controller in the manner indicated in paragraph 7 below.

The User can also easily refuse further delivery of promotional communications via email by clicking on the appropriate link for the withdrawal of consent, which can be found in each promotional email. Once the consent has been revoked, the Data Controller will send the User an email message to confirm that the consent has effectively been revoked.

4. Additional processing purposes: profiling

With the unrestricted and optional consent of the User, the User’s personal data (i.e. personal and contact data, and information relating to the services which he/she has expressed an interest in) may be processed by the Data Controller also for the purpose of profiling, or to reconstruct the User’s tastes and consumer habits, thereby identifying a consumer profile, in order to be able to send the User commercial offers in line with the profile identified.

In the event of lack of consent, the ability to register on the Site will not be affected in any way.

In the event of consent, the User may at any time revoke said consent by making a request to the Data Controller in the manner indicated in paragraph 7 below.

5. Processing methods and data retention times

The Organisation will process the Users’ personal data using manual and IT procedures, with a modus operandi strictly related to the purposes themselves and, specifically, with a view to guaranteeing the security and confidentiality of the data.

Users’ personal data will be kept for the time strictly necessary to carry out the main purposes illustrated in paragraph 1 above, or in any case as necessary for the legal protection of the interests of both the Users and Creative Company Srl.

In the cases referred to in paragraphs 2, 3 and 4 above, the Users’ personal data will be kept for the time strictly necessary to carry out the purposes illustrated therein and, in any case, for no more than twenty-four (24) and twelve (12) months, respectively.

6. Scope of communication and dissemination of data

The employees and/or consultants of the Organisation in charge of managing the Site and all the services connected to the provision of the Services may become aware of the Users’ personal data. These workers, who have been trained by the Organisation pursuant to Article 29 of the Regulation, will process User data exclusively for the purposes indicated in this information note and in compliance with the provisions of the applicable Regulation.

Third parties who might process personal data on behalf of the Organisation as “External Data Processors” may also become aware of Users’ personal data, such as, by way of example, suppliers of IT and logistical services functional to the operation of the Site and/or the Services, outsourcing or cloud computing service providers, professionals and consultants.

Users have the right to obtain a list of any data processors appointed respectively by each Data Controller, by making a request to the Data Controller concerned in the manner indicated in the following paragraph 7.

Furthermore, the personal data of the Users may be communicated by Creative Company Srl, within the limits where this is necessary and essential to execute contractual obligations, to independent third-party data controllers, such as the managers of payment and logistics services necessary for the delivery of goods sold through the Site. These independent data controllers will process User data exclusively for the purpose of the correct fulfilment of orders relating to the Services.

7. Rights of Interested Parties

Users can exercise the rights guaranteed to them by the applicable Legislation, by contacting the Organisation in the following ways:

• By sending a registered letter with return receipt to the registered offices in Via Virgilio, 3 00193 Roma (RM)

• By sending an e-mail message to info@creativecompany.it

Creative Company Srl will comply with the requests of the Users relating to the data processing referred to in paragraph 1, as well as complying with the requests of the Users relating to the processing referred to in paragraphs 2, 3 and 4.

Pursuant to the applicable Regulation, the Organisation informs Users that they have the right to obtain information (i) on the source of personal data; (ii) on the purposes and methods of processing; (iii) on the logic applied in the case of processing carried out with the aid of electronic devices; (iv) on the identity of the Organisation and its managers and (v) on the recipients or categories of recipients to which the personal data may be communicated or who can be informed about them as managers or staff.

Furthermore, Users have the right to request and receive/obtain:

a) access, updating, rectification or, where of interest, integration of data;

b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected or subsequently processed;

c) the certification that the operations referred to in commas a) and b) have been brought to the attention, including their content, of those to whom the data have been communicated or disseminated, except in the case where this fulfilment proves impossible or involves the use of resources that are manifestly disproportionate to the right to be protected.

Furthermore, Users have:

a) the right to withdraw consent at any time, if the processing is based on their consent;

b) (where applicable) the right to data portability (the right to receive all personal data concerning them in a structured format, commonly used and readable by automatic devices), the right to limit the processing of personal data and the right to cancellation (“the right to be forgotten”);

c) the right to object:

i) in whole or in part, for legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of the data collection;

ii) in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising or direct sales materials or for carrying out market research or commercial communications;

iii) if personal data are processed for direct marketing purposes, at any time, to the processing of their data for this purpose, including profiling to the extent that it is connected to such direct marketing.

d) if they believe that the processing that concerns them violates the Regulation, the right to lodge a complaint with a supervisory authority (in the Member State in which they usually reside, in the one in which they work or in the one in which the alleged violation has occurred). In Italy, the Personal Data Protection Authority (Garante per la protezione dei dati personali) is the Ombudsman for the protection of personal data, based in Piazza di Monte Citorio no. 121, 00186 – Rome.

The Organisation is not responsible for updating all the links that can be viewed in this information note, therefore whenever a link does not connect and/or is not updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites accessible through this link.