- Scope and Responsibility
- Data Collection
- Data Usage
- Data Disclosure
- Data Security
- Data Retention
- Legal Rights
1. Scope and Responsibility
My full contact details are:
Leonardo La Malfa
Via Palombaro, 136, 98057, Milazzo (ME), Italy
My website may contain links to third-party websites, plug-ins and services or applications. Clicking on those links may allow third parties to collect and/or share your data. I do not control these third-party websites and am not responsible for their privacy notices. When you leave this website, you are encouraged to read the privacy notice of every website you visit.
2. Data Collection
I may need to collect personal data by law or to provide you with services under the terms of a contract. If you fail to provide such data when requested, I may not be able to perform said contract or provide you with any or some of my services.
The term “personal data” refers to any information about an individual from which that person can be identified. Personal data does not include information where such identity has been made anonymous, namely “anonymized data”. I may collect, use, store and transfer different kinds of your personal data which can be grouped together as follows:
- Identity data includes first name, last name, username or similar identifier, along with title, date of birth and gender.
- Profile data includes username and password, orders, interests, preferences and feedback.
- Contact data includes telephone numbers as well as billing, delivery and email addresses.
- Financial and transaction data includes bank account and payment details, along with other information on services you have purchased from me.
- Technical data includes login data, IP address, time zone and location, browser type and version, operating system and other technology on the devices you use to access my website.
- Usage data includes information on how you use my website and services.
- Marketing and communication data includes preferences in receiving marketing and other communications from me.
The term “aggregated data” refers to information, derived from an individual’s personal data, that is not legally considered personal as it does not directly or indirectly reveal that person’s identity. I may collect, use and share aggregated data, such as statistical or demographic data, for any purpose. For instance, I may aggregate your usage data to calculate the percentage of users accessing a specific feature of my website.
The term “special categories of personal data” refers to such information about an individual as race or ethnicity, religious, political or philosophical beliefs, sexual orientation or life, health, genetic or biometric data. I do not collect any special categories of personal data about you.
I may use different methods to collect your data, including:
- Direct interactions with me, during which you may provide me with different kinds of your personal data by filling in forms or communicating with me by phone, email, post or otherwise, including when you request services, resources or marketing materials, create an account on my website or give me feedback. I may also record phone conversations we have.
- Automated interactions with my website, during which I may automatically collect technical data about your devices and browsing behavior by means of cookies, analytics, server logs and similar technologies.
- Third party services and public sources, including payment reputation databases or other background check agencies.
3. Data Usage
I will use your personal data for fair and lawful purposes only, such as:
- Performing a contract we entered into and providing you with the requested services.
- Developing the services on offer and improving your overall experience.
- Complying with a legal or regulatory requirement.
I may use your personal data to gain insights on what you may want, need or may be interested in. This is a marketing strategy that enables me to decide which services, offers and other information may be relevant for you. You may receive marketing communications from me if you have requested information from me, purchased my services or otherwise provided me with your details. I do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you. In any case, you will receive such communications by electronic means only if you have opted in to receive them and have not subsequently opted out. You have the right to withdraw such consent at any time by following the opt-out links on any marketing message I send you or by contacting me.
A cookie is a piece of information stored on your device that records how you have used my website. On your next visit, it can tailor your options based on such information. You can control what information websites can use and what content they can show you by setting your browser to save and read cookie data, to clear it on exit or to block cookies altogether. You can also set your browser to allow and prevent all or some cookies or to alert you when websites try to save or read cookie data. If you disable or block cookies, please note that some parts of my website may not function properly or become inaccessible.
I will use your personal data only for the purposes behind its collection, unless I need to use it for another purpose which reasonably proves to be compatible with the original purpose and fully compliant with the relevant legal framework. Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
It is important that the personal information I hold about you is accurate and current, so please keep me informed of any changes to your personal data during your relationship with me.
5. Data Disclosure
I will not share your personal data with any company, group or other third parties for marketing purposes nor will I sell or otherwise disclose your personal data to any third party, unless in connection with any legal proceedings or where required by law.
I do not transfer your personal data outside the European Economic Area (“EEA”). Please refer to my GDPR Policy for more details.
6. Data Security
I have implemented appropriate security measures to prevent your personal data from being altered or disclosed, accidentally lost, used or accessed in an unauthorized way. I have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where I am legally required to do so. Please read my Data Security Policy for further information.
7. Data Retention
I will only retain your personal data for as long as necessary to fulfil the purposes for which I collected it, including to comply with any legal, accounting or reporting requirements. In order to determine the appropriate retention period for personal data, I consider the amount, nature and sensitivity of your personal data, the potential risks from unauthorized use or disclosure of your personal data, the purposes for which I process your personal data and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available upon request. Please be aware that I am legally obliged to keep client records containing such personal information as identity, contact, financial and transaction data for at least 10 years after they cease being clients for tax purposes.
Under certain circumstances, you can ask me to delete your data. Please see below for further information. In some circumstances, I may anonymize your personal data for research or statistical purposes, in which case I may use this information indefinitely without further notice to you.
8. Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data – this enables you to receive a copy of the personal data I hold about you and to check that I am lawfully processing it.
- Request correction of your personal data – this enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide me with.
- Request deletion of your personal data – this enables you to ask me to delete or remove your personal data where there is no good reason for me to continue processing it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing it (see below), where I may have processed your information unlawfully or where I am required to do so to comply with local law. However, please be advised that I may not always be able to comply with your request of deletion for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data – this enables you to object to processing of your personal data where I am relying on a legitimate interest and you feel it impacts on your fundamental rights and freedoms. You also have the right to object where I am processing your personal data for direct marketing purposes. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data – this enables you to ask me to suspend the processing of your personal data under the following scenarios:
- If you want me to establish the accuracy of your data.
- If my use of your data is unlawful but you do not want me to delete it.
- Where you need me to hold your data even if I no longer require it because you need it to establish, exercise or defend legal claims.
- If you have objected to my use of your data but I need it to verify whether I have overriding legitimate grounds to use it.
- Request the transfer of your personal data – this enables you, or a third party you have chosen, to receive your personal data in a machine-readable format. Note that this right only applies to automated information which you initially provided consent for me to use or where I used such information to perform a contract with you.
- Withdraw consent to processing of your personal data – this enables you to withdraw your consent at any time where I am relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain services to you. I will inform you if this is the case at the time you withdraw your consent.
- Submit a complaint to the Italian Data Protection Authority, known as “Garante per la protezione dei dati personali” – this enables you to submit a complaint at any time to the Italian DPA. However, I would appreciate the chance to deal with your concerns before you approach the DPA, so I urge you to contact me in the first instance.
If you wish to exercise any of these rights, please contact me.
You will not be required to pay a fee to access your personal data or to exercise any of your other rights. However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request under these circumstances.
I may need to request specific information from you to help me confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This security measure ensures that your personal data is not disclosed to any third party who has no right to receive it. I may also contact you to ask for further information in relation to your request to speed up my response.
I try to respond to all legitimate requests within one month. Occasionally, it may take longer than a month if your request is particularly complex or you have made a number of requests. In such cases, I will notify you and keep you updated.