Leonex International SRLS (hereinafter the “Data Controller”) is constantly committed to protecting the online privacy of its users. This document has been drafted pursuant to Art. 13 of EU Regulation 2016/679 (hereinafter: the “Regulation”) to enable you to understand our privacy policy and how your personal information is handled when you use our website (hereinafter the “Site”), and—where necessary—to allow you to give your express and informed consent to the processing of your personal data.
In accordance with the Regulation, processing activities carried out by the Data Controller will be based on the principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimization, accuracy, integrity, and confidentiality.
TYPES OF PERSONAL DATA WE PROCESS
a. Data provided during registration
The Data Controller will process the personal data necessary to register you correctly on the Site, enabling you to access our e-commerce platform and related services. Such data is provided directly by the data subject and may include personal details and contact information, such as—but not limited to—first name, surname, date of birth, email address, and telephone number.
Subject to your authorization, or through the use of cookies, we may store authentication or payment-related data; you may delete this data at any time, and it will be used solely for the purpose of fulfilling the contract.
b. Data collected to provide the service
To purchase our products, we will ask you for the data necessary to fulfill the contract, such as shipping and billing details.
To provide our service, we may need to process special categories of data, pursuant to Article 9 of the Regulation.
c. Browsing data
During the use of the platform, IT systems acquire data that, by their nature, do not serve to identify users but could potentially do so in limited instances if processed or associated with data held by third parties.
This category includes, for example, IP addresses, URI (Uniform Resource Identifier) addresses of requested resources, the time of requests, the characteristics of the device used, the size of exchanged files, and other types of information. This data is anonymous or aggregated; it does not ordinarily allow for your identification and is used to identify anomalies and issues. The data may be retained to protect our legal rights, but—except in such cases—it will not be stored for longer than seven days.
PURPOSES, LEGAL BASIS, AND EXPLANATION
Below, we outline the purposes for which we will use your personal data, the legal basis pursuant to Article 6 of the Privacy Regulation, and a brief explanation of each purpose. Purpose | Legal Basis | Explanation a) Registration, authentication, and use of the site | Performance of the contract b) Order processing | Performance of the contract c) Storage of your payment details | Consent | We may ask to save your details to speed up the purchasing process. We will not save anything without your consent. d) Communication to our business partners and third parties | Consent | If you authorize us, we may share data with operational partners (logistics and couriers), but data will never be transferred to third parties for advertising or commercial purposes. Newsletter | Consent | By entering your email in the newsletter section, you allow us to send you news and information on topics that interest you. Profiling | Consent | If you authorize us, we may use your data to analyze your interests in order to place you in specific categories or predict your behavior. e) Sending direct marketing communications | Legitimate interest | We will send you emails to update you only regarding our products or services if you have previously made a purchase from us. This allows us to make new products or services more easily accessible and keeps you informed. Our emails will not be frequent or intrusive, and you have the opportunity to opt out at any time. f) Maintenance and improvement of the service and your experience, management and market planning | Legitimate interest | We use anonymous and aggregated data as much as possible for any form of service improvement or planning; We may also require your personal data; however, it will be used solely by us. g) Detecting or preventing fraudulent activity (Legal obligation and legitimate interest): We may need to process your personal data in the event of malicious activity on our site. h) Compliance with orders from judicial or other public authorities (Legal obligation). i) Retention of accounting records (Legal obligation).
Some products may involve access to special categories of data pursuant to Article 9 of the Privacy Regulation; therefore, we may request your consent in order to provide you with additional services linked to these products. Such data will generally be processed using encryption, anonymization, and pseudonymization techniques.
WHAT HAPPENS IF YOU CHOOSE NOT TO PROVIDE YOUR DATA?
Providing your personal data for purposes (a) and (b) is necessary to enable you to register on the platform and to conclude the contract. Therefore, without this data, we will be unable to provide you with our services.
Consent for purposes (c) and (d) is optional and entails no negative consequences for your user experience. However, please note that consenting to these purposes allows us to grow and provide you with better, more cost-effective services.
TO WHOM WE DISCLOSE YOUR DATA
Based on legitimate interest—and as further specified in point 2 of this notice—we disclose your personal data to other companies within our group to enhance organizational efficiency, while implementing all necessary technical and legal safeguards.
Furthermore, we disclose data to our service providers as required for service delivery or, where legitimate interest applies, in accordance with Article 2.
Such providers may include: delivery services, IT companies, legal consultants, payment processing companies, and marketing firms. Where providers process personal data on behalf of the Data Controller, they will be appointed as data processors pursuant to Art. 28 of the GDPR.
TRANSFERS TO THIRD COUNTRIES
Some personal data may be shared with entities outside the European Economic Area; we ensure that such transfers comply with Regulation 679/2016 by implementing safeguards—such as transfers to countries covered by an adequacy decision, reliance on Standard Contractual Clauses approved by the European Commission, consent, or other appropriate legal bases.
DATA RETENTION
Personal data will be retained solely for the purposes outlined in paragraph 2 and in compliance with the principle of data minimization.
We may need to retain your data to defend your rights or our own (pursuant to Art. 2946 et seq. of the Italian Civil Code) and to comply with obligations regarding the maintenance of accounting records. Therefore, we retain this data for as long as necessary, but in any case for no longer than 10 years.
We also retain your data whenever required by law or by an order from public authorities. We retain your data for marketing purposes for two years following the last commercial contact. You retain the right to withdraw your consent at any time by submitting a request to the Data Controller.
Further information regarding the data retention period and the criteria used to determine such periods may be obtained by writing to: info@leonex-international.com
YOUR RIGHTS
You have the right to access your personal data at any time, pursuant to Art. 7 of the Privacy Code and Arts. 15–22 of the GDPR. In particular, you may request access (Art. 15 of the Regulation), rectification (Art. 16 of the Regulation), erasure (Art. 17 of the Regulation), restriction of processing (in the cases provided for by Art. 18 of the Regulation), and data portability (in the cases provided for by Art. 20 of the Regulation), as well as lodge a complaint with the competent supervisory authority (the Italian Data Protection Authority/Garante per la Protezione dei Dati Personali). You also have the right to withdraw your consent at any time, pursuant to Article 7 of the Regulation; please note that the withdrawal of consent does not affect the lawfulness of processing based on consent prior to such withdrawal.
You may submit a request to object to the processing of your data pursuant to Art. …Article 21 of the Regulation, setting out the reasons justifying the objection: the Data Controller reserves the right to evaluate your request, which would not be accepted if there are compelling legitimate grounds for the processing that override your interests, rights, and freedoms.
HOW TO EXERCISE YOUR RIGHTS OR REQUEST INFORMATION ABOUT THE PRIVACY POLICY
For any information or assistance, as well as to exercise the aforementioned rights, we are at your disposal at the email address info@leonex-international.com.
CHANGES
This privacy policy is effective as of May 22, 2023. The Data Controller reserves the right to modify or simply update its content, in whole or in part, including in response to changes in applicable regulations. The Data Controller will inform you of such changes, and they will become binding as soon as they are published on the Site. Therefore, the Data Controller invites you to visit this section regularly to review the most recent and updated version of the privacy policy, ensuring you remain informed about the data collected and how the Data Controller uses it.
COOKIE POLICY
WHAT IS A COOKIE?
Cookies are small text strings that websites visited by the user send to their device (usually the browser), where they are stored and subsequently retransmitted to the same sites during the user’s next visit. While browsing a site, the user may also receive cookies on their device sent by different sites or web servers (so-called “third parties”); these may host certain elements (such as images, maps, sounds, or specific links to pages on other domains) that appear on the site the user is currently visiting.
WHY DOES LEONEX-INTERNATIONAL.COM USE COOKIES?
Cookies are used for various purposes, such as performing computer authentication, session monitoring, storing information regarding specific configurations, or targeted advertising.
WHICH COOKIES ARE USED?
The Site uses the following cookies, which can be deselected—with the exception of third-party cookies, for which you must refer directly to the respective selection and deselection procedures indicated via links:
Technical navigation or session cookies that are strictly necessary for the Site’s operation or to enable you to access the requested content and services. Functionality cookies—that is, cookies used to enable specific Site features and a set of selected criteria (such as language) in order to improve the service provided.
PLEASE NOTE: disabling technical and/or functionality cookies may render the Site inaccessible, or cause certain services or features of the Site to become unavailable or malfunction; furthermore, you may be required to manually modify or re-enter certain information or preferences each time you visit the Site.
Third-party cookies—i.e., cookies from sites or web servers other than that of Leonex International SRLS, used for the specific purposes of said third parties. Please note that these third parties (listed below, along with links to their respective privacy policies) typically act as independent data controllers for the data collected via the cookies they serve; therefore, you should refer to their personal data processing policies, privacy notices, and consent forms (regarding the selection and deselection of their respective cookies), as specified in the aforementioned Provision. For the sake of completeness, we also note that Leonex International SRLS makes every effort to track the cookies present on its Site. These are regularly updated in the table below, which provides transparency regarding the cookies sent directly by Leonex International SRLS and their purposes. Regarding third parties that send cookies via our Site, we provide links to their respective privacy policies below; as previously stated, we delegate to these third parties the responsibility of providing the privacy notice and obtaining your consent, as required by the Provision. This responsibility applies not only to cookies sent directly by the third parties but also to any additional cookies sent via our Site through the use of services utilized by those third parties. Indeed, Leonex International SRLS has no control over—and is unaware of the characteristics and purposes of—such cookies sent by service providers used by the aforementioned third parties. Below are links to information regarding third-party cookies:
Google: https://www.google.com/policies/privacy/partners/
Google Adwords: https://policies.google.com/technologies/cookies
Facebook: https://www.facebook.com/policies/cookies/
Bing: https://privacy.microsoft.com/it-it/privacystatement
Hotjar: https://www.hotjar.com/legal/policies/cookie-information
Specifically, the cookies sent by Leonex International SRLS via the Site are listed below:
| Technic – HotJarhttps://www.hotjar.com/legal/policies/ cookie-information | _hjIncludedInSample | This cookie is used to assess website navigation issues. | 1 year |
| Technic – Google Analyticshttps://developers.google.com/ana lytics/devguides/collection/gajs/cookie-usage | _ga | This cookie is used to evaluate site performance and traffic, and to distinguish unique users. | 2 years |
| Technic – Google Analyticshttps://developers.google.com/ lytics/devguides/collection/gajs/cookie-usage | _gid | This cookie is used to evaluate site performance and traffic, and to distinguish unique users. | 24 hours |
| Analytics – MailChimphttps://mailchimp.com/help/additional-tracking-options-for-campaigns/ | This cookie is used to evaluate orders, purchases, conversions, and sales statistics in aggregate form. |
HOW CAN I DISABLE COOKIES?
You can allow, block, or delete cookies (in whole or in part) using the specific functions of your browser. For more information on how to set your cookie preferences via your browser, you can consult the relevant instructions:
Internet Explorer
Firefox
Chrome
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