POLICY FOR THE PROCESSING OF MY PERSONAL DATA
Version of 03/07/2023
Who is the controller for the processing of your data? Who are the processors?
De Agostini UK LTD with registered office C/O Royds Withy King Llp, 69 Carter Lane, London, England, EC4V 5EQ, A., hereinafter "De Agostini", “we” or “us”, will be the controller for your personal data.
You can contact us by writing to firstname.lastname@example.org or De Agostini UK LTD, C/O Royds Withy King Llp, 69 Carter Lane, London, England, EC4V 5EQ.
If you want to know more on the processing of your personal data, please carefully read the sections below of this privacy information notice.
What personal data do we process and how do we collect them?
We collect a variety of information about you when you visit our Site, including:
Data provided directly by you:
a) identifiable information provided during the registration process, the creation of an account on our Site, or when filling out our surveys, including name and surname, e-mail address, user ID, gender, age range, password, country of residence, postal address, type of purchased product or service, and phone numbers for deliveries;
b) financial information and data related to your credit card for the purchase of products through our Site; and
information contained in any correspondence or requests sent by you to us or asked you by us if problems with our service on the c) Site or purchased products are reported.
Data obtained from automatic tracking systems:
In addition to the personal data that you provide us directly and those generated from the relationship with you, we collect data automatically through cookies, or data storage and recovery devices, on browsing and use made by our users when accessing our Site, or our emails or SMS.
In these cases, the information collected refers to context data such as:
a) information relating to your usage of the Site;
b) navigation information collected when you surf our Site.
For what purpose do we process your personal data?
a) Contractual Purposes and equivalent:
In the event that you purchase one of our products or join one of our services including the Lead Service relating to the delivery of specific communications on certain topics, register to our Site creating a personal account, we will process your personal data, in order to maintain our contractual relationship with you and to manage your registration.
b) Law Related Purposes:
We may process your personal data to comply with legal and regulatory obligations.
c) Marketing Purposes:
Only with your prior consent, we may process your personal data to carry out commercial surveys and send you, through traditional and other means, including email, SMS, MMS, social network, mobile applications, banner, mail and phone, commercial communications about our products and services or those of third-party companies.
Also, unless you denied your consent either on the collection of your personal data or in any subsequent communication, we may process your personal data to send you, through email, commercial communications about our own products and services similar to those already purchased by you (“Soft opt-in Exemption”).
Also, with your specific prior consent, your personal data processed for Marketing Purposes may be transferred to other companies as further explained in “To whom will your data be communicated?” section.
d) Profiling Purposes:
We may use your personal information to create profiles for the purpose of providing you with personalized content and marketing communications. This may involve using your information to analyze your preferences and interests, and to predict your needs and behaviors. If we use your personal information for profiling purposes, we will only do so with your explicit consent.
e) Legitimate Interest Purposes:
We may process your personal data to create a "light commercial profile" based on our legitimate interest to analyze your characteristics and preferences according to non-invasive categories of personal data, such as spending volume, purchased product/service, shop of purchasing, age range, information on your purchasing and status (the “Segmentation Purposes”).
Likewise, in response to our legitimate interest in knowing the satisfaction of our customers or users, regarding our products and/or services and the attention provided, we may process your personal data to carry out or send you satisfaction or quality surveys.
Also, in response to our legitimate interest for business purposes, we may process your personal data to carry out activities which are functional to the transfer of branches, acquisitions, mergers, divisions or other changes and to perform such operations.
Finally, we may process your personal data to improve your experience as a user of our Site.
On what legal basis do we process your personal data?
Processing of your personal data for Contractual Purposes or equivalent is necessary for the performance of the contract entered with you. Likewise, the processing of personal data for Law Related Purposes is necessary to comply with a legal obligation. As such, the processing for Contractual Purposes or equivalent and Law Related Purposes is mandatory. If you do not provide your personal data, it would not be possible for us to provide the products or services that you request.
Processing of your personal data for Marketing Purposes and Profiling Purposes is not mandatory and is subject to your prior consent which, in any case, can be revoked. While for the purpose of Soft opt-in Exemption above, it is performed according to the local provision implementing article 13, par. 2 of the EU Directive 2002/58. If you deny, or subsequently unsubscribe from our communications, we will not be able to process your personal data for such Marketing Purpose.
Processing of your personal data for Legitimate Interest Purposes (including Segmentation Purposes) is functional to the pursuit of our legitimate interest, properly balanced with your interests since the processing of Personal Data is limited to what strictly necessary to pursue such purposes. In order to assess the legitimate interest, a weighting has been carried out in which the own benefits as the person responsible for the treatment have been analyzed, as well as the benefits for the data subject and/or third parties and in which it is concluded that our legitimate interest in the treatment prevails on the interests, rights and freedoms of the data subject and/or third parties.
You can object to such data processing at any time, by sending a communication to email@example.com. In such case no data processing will be carried out by us for such purposes, except in case where we demonstrate the existence of legitimate prevailing interest.
How we process your personal data?
We will process your personal data using automated or other means and we will protect them with the implementation of adequate security measures to ensure safety and confidentiality of the personal data. Specifically, we implement technical and organizational measures necessary to ensure that personal data are protected against loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.
How long will we keep your data?
We retain your personal data for the time strictly necessary to achieve the purposes for which your personal data were collected and further processed, including any retention period required under the applicable legislation:
- with regards to Contractual Purposes or equivalent, for the duration of the relationship and, after it ends, for the legal period during which any liability arising from this relationship may arise (10 years);
- with regards to Law Related Purposes, for the duration prescribed for each type of personal data by the relevant laws;
- with regards to Marketing Purposes and Segmentation Purposes, for the duration of the service/product provided to you and/or your registration on our Site through your account and/or participation in our commercial surveys and for 24 months following the termination, deactivation and/or cancellation of the aforementioned activities;
- with regards to Profiling Purposes, for 12 months from their collection;
- with regards to Legitimate Interest Purposes, for as long as you do not oppose to the treatment plus the time thereafter during which any type of liability may arise (3 years). In the event the processing is aimed at carrying out activities functional to the transfer of a company or business, acquisitions, mergers or other transformations, the retention periods above will apply with respect to the main processing performed.
Once these terms have expired, personal data will be deleted/anonymized and/or aggregated.
To whom will your data be communicated?
We might communicate your personal data, only where strictly necessary to each type of processing, in the following categories of subjects:
a) Employees, collaborators and suppliers of De Agostini, within the performance of their tasks and/or contractual obligation and in relation to the commercial relations with you;
b) Sub-suppliers and/or subcontractors within the activities connected to the performance of services and products offered by De Agostini;
c) To Postal Offices and couriers to send and deliver products purchased by you and/or other materials related to our services;
d) To legal, administrative and fiscal consultants, within the limits of what is necessary or functional to our activities, in the ways and manners explained above;
e) To financial institutions for the management of revenues and payments deriving from the performance of the relationship with you.
Also, with you prior consent, your personal data collected for Marketing Purposes may be transferred to other companies of the following categories: publishers, mass-market retailers, toys sellers and consumer goods distributors, so that they can send you commercial communications about their own products and services, for which said companies may, in turn, prepare their own commercial profile with said data and profiles, as well as with your data and profiles that they may have or obtain; in this way their commercial communications could be adapted to you. You can ask us a full list of the companies to which your information will be shared.
Will your data be transferred overseas?
We inform you that we contract the services of providers who may have access to your personal data for the provision of such services and that some of them may be located outside the European Economic Area (EEA).
Whenever we transfer personal data outside the EEA, we will take reasonable steps and appropriate safeguards to keep the personal data safe, according to art. 45 and 46 of European Regulation n. 679/2016 on the processing of personal data (the “GDPR”).
What are your rights when you provide us with your data?
You can always revoke your consent after it is given as well as to enforce your privacy rights, for example you may access your personal data, verify your personal data content, origin, accuracy, ask for your personal data to be integrated, updated, amended, deleted, or blocked for breach of law, as well as object to the processing of your personal data for legitimate purposes. In addition to the rights above, you can ask for a restriction of the processing, your personal data portability and lodge a claim before the relevant data protection supervisory authority.
You can exercise your rights above, at any time, by contacting us at firstname.lastname@example.org. We will respond within a reasonable time frame (and, in any case, within the limits of applicable law).
This document will be effective from the date indicated in the heading.