Privacy Policy

INFORMATION ON THE PROCESSING OF PERSONAL DATA

pursuant to art. 13 of Regulation (EU) 679/2016 (the "GDPR")

This page describes the characteristics of the processing of users' personal data (the "Users") of the website https://www.whistlebikes.com (the "Site").

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The information you find on this page does not apply to sites, apps and third-party content of any kind, even if they are accessible from the Site by clicking on links on it.

In these cases, the data protection provisions of such third parties may be applicable, which may be different from these and which we advise you to consult before communicating any data.

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1 - Data controller and contact details of the Data Controller

For the purposes of this information, the data controller is Atala SpA, with registered office in via della Guerrina 108, 20900 Monza (MB), Italy, VAT number 02651030278 (hereinafter simply "Atala", the "Company" or the "Owner").

To resolve any doubts about how the Data Controller processes personal data, you can always contact them:

- To the e-mail address marketing01@atala.it

- At the address in via della Guerrina 108, 20900

2 - Data collection methods and types of data processed

Navigation data collected automatically from the Site: access and navigation data

Navigation data collected automatically from the Site: access and navigation data

Whenever Users access the Site, the computer systems and software procedures used to operate the Site acquire, during their normal operation, access and navigation data (for example: information on the browser used by the User, pages visited, date , time and duration of each visit, as well as other parameters relating to the operating system and IT environment of the User - the "Navigation Data").

Data communicated by Users: registration data as a "new user"

Through the "Warranty extension" section, users can register on the Site by entering the e-mail address and password in the first screen. Subsequent to registration, Users are given the opportunity to update their web profile by adding additional personal data (ie name, surname, country, city, gender) (the "Release Data").

The Navigation Data and the Communicated Data, indicated jointly as the Personal Data.

Cookies

The site uses computer techniques for the direct acquisition of personal identification data consisting of "code strings": "cookies".

For all information on cookies activated on the Site and on the related processing of personal data and their characteristics ...CLICK HERE!

3 - Purpose and legal basis of the processing

The Navigation Data will be used: (i) in order to monitor the correct functioning of the Site, (ii) in anonymous and aggregate form, for statistical purposes related to the understanding of how the Site is used by Users, to improve ease of access and increase its attractiveness, as well as (iii) to detect any technical problems as soon as possible.

These treatments find their legal basis in the legitimate interest of the Company in the improvement of its products and digital services, and are compatible with the position of the interested parties since: (a) monitoring the operation of the Site and the statistical data related to its use does not involve direct identification; and (b) the interest of the Company appears reasonably to be also proper to the Users, who will thus be able to use a site that is increasingly performing and optimized.

The Data transmitted voluntarily by the Users, will be used exclusively to: (i) give feedback to the request to extend the warranty for a product purchased by the User; (ii) send an information newsletter to users.

The legal basis of this treatment is the need to respond to Users' requests, carry out pre-contractual and possibly contractual measures adopted at the User's request, and to fulfill the related legal obligations; as well as the specific consent regarding the sending of the newsletter

4 - Recipients of the communication of Personal Data

The Personal Data will be communicated and may be known (i) by employees and collaborators of the Company, duly instructed and / or designated for processing; and (ii) from third parties that provide ancillary or instrumental services to the Company's activities, in relation to the development, provision, maintenance and operational management of the Site, specifically appointed as data processors.

5 - Place of processing and transfer of Personal Data abroad

The processing of the User's Personal Data will take place at the aforementioned registered office of the Company, and the Personal Data will be stored at server sites within the European Union.

Any further transfers of Personal Data abroad will take place, if to countries that do not benefit from a decision of adequacy of the European Commission and that, therefore, do not offer an adequate level of protection to personal data, only (i) after adoption of appropriate guarantees such as, by way of example, the signing of the standard clauses approved by the European Commission, or (ii) the use of an exception to the prohibition of transfers outside the European Union and, therefore, always by way of example, subject to collection of explicit consent and informed of the User, or only to the extent that it is necessary for the execution of a contract concluded between the User and the Company, or between the Company and a third party for the benefit of the User, or the execution of pre-contractual measures adopted at the request of the User.

 

6 - Processing methods, security measures and storage period of Personal Data

The Personal Data will be processed both in paper form and by electronic, computer or automated means, using systems that ensure their protection, security and confidentiality.

Furthermore, the Company has adopted specific and adequate logical, legal, organizational and technical security measures to prevent the loss of Personal Data, their unlawful or unauthorized use and unauthorized access

The Navigation Data - which do not allow the identification of Users - do not persist for more than 1 week and are canceled immediately after their aggregation (except for any need to ascertain the crime by the competent Judicial Authority);

The Relevant Data will be stored for longer periods of time where necessary to: (i) execute contractual / pre-contractual measures and for the entire duration of any contractual relationship with the Company; (ii) fulfill statutory and / or legal obligations; and (iii) to ensure the judicial protection of the Company's rights, in compliance with the ordinary limitation periods.

7 - User rights

Users, as interested (that is, subjects to whom the Data refer), are holders of rights conferred by the GDPR. In particular, pursuant to articles 12-23 of the GDPR, the interested parties have the right to request and obtain, at any time, access to their personal data, information on the processing, rectification and / or updating of personal data, deletion and limitation of the treatment. Furthermore, they also have the right to oppose the processing and to request data portability (ie to receive personal data in a structured format of common use, readable by automatic devices). Finally, the interested parties, if they have lent it, always have the right to withdraw their consent at any time (this, in any case, will not affect the lawfulness of the processing carried out on the basis of the consent given before the revocation) and to propose a complaint to a supervisory authority (in Italy: the Guarantor for the Protection of Personal Data).

8 - Contact details

The above rights may be exercised at any time, by simple request to the Owner, to be transmitted:

- to the e-mail address marketing01@atala.it;

          - at the address Via della Guerrina 108, 20900 Monza

For other information or clarifications on the rights mentioned, it is possible to contact the Companies at the same addresses.

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The Company may modify this information to adapt it to future extensions or future changes to the Site.

Information updated on 7 OCTOBER 2019

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