Privacy policy

Privacy Policy

Ventifive, with registered office in Italy, Lusia 45020 (RO), Via dell’artigianato 742 is committed to protecting the online privacy of the users of his website www.ventifive.com . As such, this Privacy Policy has been written in order to allow you to understand Data Controller’s policy regarding your privacy, as well as how your personal information will be handled when using the Website. This Privacy Policy will also provide you with information so that you are able to consent to the processing of your personal data in an explicit and informed manner, where appropriate.
In general, any information and data which you provide to Data Controllers over the Website, or which is otherwise gathered via the Website in the context of the use of Ventifive’s services as better defined in Section 3 below, will be processed by Data Controllers in a lawful, fair and transparent manner. To this end, and as further described below, Data Controllers take into consideration internationally recognised principles governing the processing of personal data, such as purpose limitation, storage limitation, data minimisation, data quality and confidentiality.

INDEX

1. Data controller and Data Protection Officer
2. Personal Data processed
   • Name, contact details and other Personal Data
   • Job applications
   • Data concerning your location
   • Special categories of Personal Data
   • Other persons’ Personal Data
   • Browsing data
   • Cookies
3. Purposes of processing
4. Grounds for processing and mandatory / discretionary nature of processing
5. Recipients of Personal Data
6. Transfers of Personal Data
7. Retention of Personal Data
8. Data subjects’ rights
9. Amendments

1. DATA CONTROLLER AND DATA PROTECTION OFFICER

Ventifive as identified at the beginning of this Privacy Policy, are the Data controllers regarding all personal data processing carried out through the Website.
To get in touch with Ventifive’s Data Protection Officer, please contact: info@ventifive.com

2. PERSONAL DATA PROCESSED

When you use the Website, Data Controllers will collect and process information regarding you (as an individual) which will identity you – according to your choices on how to use the Services- 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 the physical, physiological, mental, economic, cultural or social an identified or identifiable natural person (“Personal Data”).
This information may be collected both when you choose to provide it (e.g., when you subscribe to our newsletter or when you create a personal account for receiving Services provided by Data Controllers) or simply by analysing your behaviour on the Website.
I Dati Personali trattati attraverso il Sito sono i seguenti:

a. Name, contact details and other Personal Data

In various sections of the Website – including, in particular, if you decide to create an account on the Website – you will be asked to submit information about yourself, such as your name, phone / mobile numbers, e-mail address, date of birth, country of residence and address. Additionally, when subscribing or signing up to receive Services, you might be asked to provide information as to your preferred mode of payment – PayPal, or credit card.
In addition, whenever you participate in surveys and other promotions which may be available on the Website, as well as whenever you communicate with Data Controllers through the contact details provided in the Website or with Customer Care, Data Controllers may collect additional information which you choose to provide.

b. Job application

When registering to apply for a position within Ventifive on the Website at https://www.ventifive.com/it/tutto-su-ventifive#job (“Work with us”), you will also be asked to provide your e-mail address and your job application (“Application”) when you will provide us information such as resume, cover letter, professional qualifications and your professional profile links on social networks.
When receiving your Application, Ventifive, even you may have not indicated in your Application, may assess your professional social media accounts (e.g. LinkedIn) or professional websites, where publicly available, to gain insight as to your suitability for position applied for.

c. Data concerning the Location

Under your previous and explicit consent, your navigation programme on Internet (“Browser”) may share with the Website an approximation of your geographic location through information on wireless access points close to you and on your IP address of your device.
In both cases, it is an optional use of a Personal Data processing but extremely useful to Data Controllers for proving you even more useful Services. If you think that sharing your approximate location through your Browser is invasive, you may revoke at any time your consent changing the settings of your Browser (or settings of you operating system). To have more information we invite you to read specific privacy notice of your Browser.

d. Special categories of Personal Data

Certain areas of the Website (e.g., “Work with us”) may include free text fields, where you can provide Data Controllers some information, which may contain Personal Data.
Where these fields are completely free, you may use them to disclose (inadvertently or not) more sensitive categories of Personal Data, such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The content you upload in these fields may also (inadvertently or not) include other types of sensitive information relating to you, such as your genetic data, biometric data or data concerning your health, sex life or sexual orientation.
Data Controllers ask that you do not disclose any sensitive Personal Data on the Website, unless you consider this to be strictly necessary. As it is totally optional to provide this information, if you nonetheless choose to do so, please mind that Data Controllers, complying with the applicable law, require your explicit consent to process this sort of Personal Data (which can be provided, e.g., by the flag in your Application).

e. Other persons’ Personal Data

As mentioned in the previous section, certain areas of the Website (such as Work with us, or when you insert your e-mail to subscribe to the newsletter, or when you purchase products on the Website and write a “happy birthday” message annexed to the order) allow you to insert text messages or information, which Data Controllers may have access. These messages and information may include Personal Data related to other persons.
In those situations, you will be considered as an independent data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify Data Controllers against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, brought by the third parties whose information you provide through the Website.
As Data Controllers do not collect this information directly from these third parties (but rather collects them, indirectly, from you), you must make sure that you have these third parties’ consent before providing any information regarding them to Data Controllers; if not, then you must make sure there is some other appropriate grounds on which you can rely to lawfully give Data Controllers this information.

f. Browsing data

The Website’s operation, as it is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While Data Controllers do not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information must also be considered Personal Data.
This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on. These data are used to compile statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website. Save for this last purpose, these data are not kept for more than 50 business days.

g. Cookies

Definitions, characteristics, and application of standards Cookies are small text files that may be sent to and registered on your computer by the websites you visit, to then be re-sent to those same sites when you visit them again. It is thanks to these cookies that those websites can “remember” your actions and preferences (e.g., login data, language, font size, other display settings, etc.), so that you do not need to configure them again when you next visit the website, or when you change pages within a website.
Cookies are used for electronic authentication, monitoring of sessions and storage of information regarding your activities when accessing a website. They may also contain a unique ID code which allows tracking of your browsing activities within a website, for statistical or advertising purposes. Some operations within a website may not be able to be performed without the use of cookies which, in certain cases, are technically necessary for operation of the website.
When browsing a website, you may also receive cookies from websites or web servers other than the website being visited (i.e., “third-party cookies”).
There are various types of cookies, depending on their characteristics and functions, which may be stored on your computer for different periods of time: “session cookies”, which are automatically deleted when you close your browser, and “persistent cookies”, which will remain on your device until their pre-set expiration period passes.
According to the law which may be applicable to you, your consent may not always be necessary for cookies to be used on a website. In particular, “technical cookies” – i.e. cookies which are only used to send messages through an electronic communications network, or which are needed to provide services you request – typically do not require this consent. This includes browsing or session cookies (used to allow users to login) and function cookies (used to remember choices made by a user when accessing the website, such as language or products selected for purchase).
On the other hand, “profiling cookies” – i.e., cookies used to create profiles on users and to send advertising messages in line with the preferences revealed by users while browsing websites – typically require specific consent from users, although this may vary according to the applicable law.
Types of cookies used by the Website

• Browsing or session cookies, which are strictly necessary for the Website’s operation, and/or to allow you to use the Website’s content and Services
• Analytics cookies, which allow Data Controllers to understand how users make use of the Website, and to track traffic to and from the Website.
• Function cookies, which are used to activate specific Website functions and to configure the Website according to your choices (e.g., language), in order to improve your experience.
• Profiling cookies which are used to observe the preferences you reveal through your use of the Website and to send you advertising messages in line with those preferences.
• Geo-location cookies they are used to allow you, based on your browser settings, to enjoy some features, such as the option to find your nearest stores and their addresses, opening times and contact details, and to make the most of the services available on our website and in our Stores (e.g. buy from store, click and collect, reserve in store, back in store, etc.). You will be located through your IP Address or your mobile device. If you do not wish to share your location with us, then you can turn off the location permission settings in your browser or in your device. If you wish to restrict the location data we use, you can do that through your browser and give us just your address or ZIP code.

Data Controllers also use third-party cookies – i.e. cookies from websites / web servers other than Ventifive, owned by third parties. These third parties will either act as independent data controllers regarding their own cookies (using the data they collect for their own purposes and under terms defined by them) or as data processors for Data Controllers (processing personal data on Data Controllers’ behalf).
For further information on how these third parties may use your information, please refer to their privacy policies:

• Google: https://www.google.com/policies/privacy/partners/ https://tools.google.com/dlpage/gaoptout
• DoubleClick – Google: https://policies.google.com/privacy?hl=en
• Insider: http://useinsider.com/privacy-policy/
• Criteo: https://www.criteo.com/it/privacy/
• Adform: https://site.adform.com/privacy-policy-opt-out/
• Facebook: https://it-it.facebook.com/about/privacy/update
• Lengow: https://www.lengow.com/it/note-legali/
• Tooso: https://tooso.ai/privacy-policy.html
• Fanplayr: https://fanplayr.com/files/en/Fanplayr-GDPR-Compliance.pdf
• Quantcast: https://www.quantcast.com/privacy/
• Web Geo Service: https://www.webgeoservices.com/privacy-policy/

Cookie settings
You can block or delete cookies used on the Website via your browser options. Your cookie preferences will be reset if different browsers are used to access the Website. For more information on how to set the preferences for cookies via your browser, please refer to the following instructions:

• Internet Explorer
• Firefox
• Chrome
• Safari

You may also provide set your preferences on third-party cookies by using online platforms such as AdChoice.
CAUTION: If you block or delete technical and/or function cookies used by the Website, the Website may become impossible to browse, certain services or functions of the Website may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Website.

3. PURPOSES OF PROCESSING

Data Controllers intends to use your Personal Data, collected through the Website, for the following purposes:

• •To verify your identity and assist you, in case you lose or forget your login / password details for any of your personal account; to purchase a name Card; to consult the chronology of your orders; to send you newsletters you have subscribed to as a service, containing only informative and not marketing content; to finalise purchase orders and deliver products bought on the Website; to save your favourite order;
• To examine applicant’s resumes / CVs and to get in contact with applicants who have submitted their application via the Website (“Recruitment“);
• For future marketing, promotional and publicity purposes, including to carry out direct marketing, market research and surveys, via e-mail, SMS, over the phone, through push notifications, pop-up banners, instant messaging, through an operator, through Data Controllers’ official social media pages, regarding Ventifive’s products and services, as well as those of selected third parties (“Marketing“);
• For future marketing, promotional and publicity purposes, by sending you direct e-mail marketing communication regarding products and services provided by Ventifive and which are similar to those you have previously purchased or requested via the Website (“Soft Spam”);
• To create a profile of you through the use of profiling cookies and by collecting and analysing information on the preferences you select and choices you make in the Website as well as your general activities on the Website as a registered user, therefore by collecting information on your previous order, whish-list and navigations. This profile will be used to give you information about other websites / services which Data Controllers believe you may be interested in, and to show you information and advertisements which may be relevant to you and your interests. All algorithms involved in this automated or semi-automated processing are regularly tested, to ensure the processing’s fairness and control for bias (“Profiling”);
• For compliance with laws which impose upon Data Controllers the collection and/or further processing of certain kinds of Personal Data (“Compliance”);
• To prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website (“Misuse/Fraud”).

4. GROUNDS FOR PROCESSING AND MANDATORY/ DISCRETIONARY NATURE OF PROCESSING

Data Controller’s legal bases to process your Personal Data, according to the purposes identified in Section 3, are as follows:

• Service Provision: processing for these purposes is necessary to provide the Services and, therefore, is necessary for the performance of a contract with you. It is not mandatory for you to give Data Controllers your Personal Data for these purposes; however, if you do not, Data Controllers will not be able to provide any Services to you. The same applies to the newsletter service that you specifically request when you insert your e-mail address and that you may revoke at any time following the indications on Section 8 of this privacy policy.
• Recruitment: processing for this purpose is needed in order for Data Controllers to be able to consider offering you a position and, therefore, is necessary to take steps at your request before (potentially) entering into a contract. It is not mandatory for you to give Data Controllers your Personal Data for these purposes; however, if you do not, Data Controllers will not be able to consider your applications.
• Marketing: processing for these purposes is based on your consent. It is not mandatory for you to give consent to Data Controllers for use of your Personal Data for these purposes, and you will suffer no consequence if you choose not to give it (aside from not being able to receive further marketing communications from Data Controllers). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
• Soft Spam: processing for these purposes is based on Data Controllers’ interest in sending you direct e-mail marketing communication regarding products and services provided by Data Controllers and which are similar to those you have previously purchased through the Website. You can block these communications, and you will suffer no consequence if you do so (aside from not being able to receive further communications from Data Controllers), by objecting through the link provided at the bottom of all such communications.
• Profiling: iprocessing for this purpose is based on your consent. It is not mandatory for you to give consent to Data Controllers for use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from greater personalisation of your user experience regarding the Website). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
• Compliance: processing for this purpose is necessary for Data Controllers to comply with its legal obligations. When you provide any Personal Data to Data Controllers, Data Controllers must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
• Misuse/Fraud: Information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potentially criminal purposes) and allow Data Controllers to defend themselves in subsequent legal proceedings that may arise.

5. RECIPIENTS OF PERSONAL DATA

We share your Data with the following parties (hereinafter referred to as the “Recipients”):

• Parties whom we have authorised to perform any operation on your Data: they are our employees and our consultants, who have entered into a confidentiality agreement and adhere to specific rules regarding the use of your Data;
• Our Data Processors: they are contractors who perform some operations on your Data on our behalf. They may include providers of security services for our systems, technological hosting platforms and providers of integrated digital services for our website and our Stores, technical maintenance services (such as network and ICT maintenance); accounting, administration, legal, tax and financial consultants and credit collection services. We have entered into an agreement with such parties to make sure your Data will not be used unless appropriate measures have been taken and unless we instruct them to do so;
• System administrators: they are our employees or employees of our data processors, who are in charge of managing our ITC systems and, in such capacity, can have access to, change, suspend or restrict any use of your Data. Such parties have been previously selected and appropriately trained and their work is traced by systems that cannot be changed by them, as laid down by the Italian Supervisory Authority;
• Our Subsidiaries: if, for instance, you are a French citizen, Ventifive might share your questions/enquiries with its local branch to reply in your native language. The same would apply if we wanted to create marketing initiatives based on our market surveys. We have entered into agreements with our subsidiaries and our Online Store regarding the use of your Data;
• Freelance Data Controllers: if authorised by your consent or on some other legal ground (e.g. replying to your enquiry), Ventifive will share some of your Data with such third parties. Your Data will not be shared to allow such parties to contact you for promotional purposes;
• The police or any other authority whose orders are binding on us: this can happen, for instance, when we have to comply with some legal provision or law, or if we need to do so in order to defend ourselves in court. If any regulation, guideline, notice, resolution, ruling, decree, judicial order, mandate, subpoena or judgement of any government or any supranational, federal, state, governmental, district or local authority, any statutory, administrative or regulatory body, any court or agency or any other authority in any part of the world (even outside of your jurisdiction) is binding on us or requests that we disclose your Data, we will not share your Data without your consent, unless we are legally bound to adhere to such regulation, etc.

6. TRANSFERS OF PERSONAL DATA

Considering Ventifive’s worldwide presence and business operations, your Personal Data may be transferred to Recipients located in several different countries.
Data Controllers implement appropriate safeguards to ensure the lawfulness and security of these Personal Data transfers, such as by relying on adequacy decisions from the European Commission, standard data protection clauses adopted by the European Commission, or other safeguards or conditions considered adequate to the transfer at hand.
More information on these transfers is available upon written request to Ventifive at the following address: amn@ventifive.com

7. RETENTION OD PERSONAL DATA

Personal Data processed for Service Provision will be kept by Data Controllers for the period deemed strictly necessary to fulfill such purposes – in any case, as these Personal Data are processed for the provision of the Services, Data Controllers may continue to store this Personal Data for a longer period, as may be necessary to protect Data Controllers’ interests related to potential liability related to the provision of the Services.
Personal Data processed for Recruitment will be kept by Data Controllers for as long as the vacancy for which the CV was submitted is still available or, in case of open positions, for up to 1 year. Data Controllers may contact applicants before the expiration of this period, in order to request an extension of the retention period or an update of the application. In case of no response from the applicants, Data Controllers delete Personal Data collected.
Personal Data processed for Marketing and Profiling will be kept by Data Controllers from the moment you give consent until it is withdrawn. We will remind consent you have given every 24 months. Once consent is withdrawn (or not given, following a renewal), Personal Data will no longer be used for these purposes, although it may still be kept by Data Cotrollers, in particular as may be necessary to protect Data Controllers’ interests related to potential liability related to this processing.
Personal Data processed for Soft Spam will be kept by Data Controllers until you object to this processing through the link you find at the bottom of every Soft Spam e-mail.
Personal Data processed for Compliance will be kept by Data Controllers for the period required by the specific legal obligation or by the applicable law.
Personal Data processed for preventing Misuse/Fraud will be kept by Data Controllers for as long as deemed strictly necessary to fulfill the purposes for which it was collected and until Data Controllers have to keep the data in order to defend themselves in subsequent legal proceedings that may arise, or communicate this data to Supervisory authorities, as may be requested.

8. DATA SUBJECT’ S RIGHTS

As a data subject, are entitled to exercise the following rights before Data Controllers, at any time:

• Access your Personal Data being processed by Data Controllers (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
• Correct or update your Personal Data processed by Data Controllers, where it may be inaccurate or incomplete;
• Request erasure of your Personal Data being processed by Data Controllers;
• Request the restriction of the processing of your Personal Data;
• Exercise your right to portability: the right to obtain a copy of your Personal Data provided to Data Controllers, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller;
• Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent Data Controllers from processing your Personal Data; or Withdraw your consent to processing for Marketing and Profiling.

Please note that most of the Personal Data you provide to Data Controllers can be changed at any time, including your e-mail preferences, by accessing, where applicable, your user profile created on the Website.
You can also withdraw consent for Marketing for communications received via e-mail and object to Soft Spam by selecting the appropriate link included at the bottom of every marketing e-mail message received. The same applies to the Ventifive newsletter which you may have subscribed to, when you have requested it as a Service.
Consent for Profiling carried out by cookies may be withdrawn as described in Section 2(f).
Aside from the above means, you can always exercise your rights described above by sending a written request to Data Controllers at the following address: amn@ventifive.com
In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through the Website is unlawful.

9. AMENDMENTS

This Privacy Policy entered into force on 2018/05/22.
Data Controllers reserve the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. Data Controllers will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website. Data Controllers therefore invite you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how Data Controllers collect and use Personal Data.