1. OBJECTIVE AND RESPONSIBLE BODY

This Privacy Policy outlines the principles according to which the personal data of users in Italy collected through or through the link to our website (www.iconeway.com) or provided by the user will be processed. The Privacy Policy applies regardless of the domains, systems, platforms and devices (fixed or mobile) used to access the website. The website provider and the data controller of the personal data collected through the website is V-ITA SpA, with registered office in Via Torino 2 - 20123 Milano - Italy. You can contact us by e-mail at info@iconeway.com. The term "user" refers to all customers and visitors to our website.

2. FUNDAMENTAL PRINCIPLES AND DETAILS OF DATA PROCESSING

We process users' personal data in accordance with applicable data protection laws and regulations. This means that users' personal data is only processed when there is a legitimate basis for the processing, as illustrated below. When you place an order for the purchase of products using the website or when you submit a request, the processing is necessary for the execution of this contract or in order to carry out the steps requested by the user before entering into a contract. .

We may also process data for purposes of our legitimate interest, for example to: [administer, improve and optimize our website and internal operations (including problem-solving processes, data analysis, testing, research and questionnaires); ensure effective customer service and technical support; identify and prevent cases of fraud; and protect the rights, property and safety of our companies, our group companies, our customers or others].

With the user's consent, we can use the personal data collected through cookies and the user's personal data to send him commercial communications (such as our newsletter) (as far as possible based on the consents issued). The consent to the processing can be revoked at any time, without compromising the legitimacy of any data processing carried out on the basis of the consent before the revocation.

Users' personal data may be transmitted to third parties where necessary for billing purposes (for example, in the case of payment service providers) or as necessary for compliance with contractual obligations towards customers. This includes the transmission of the customer data contained in the orders to the local reseller selected by the customer, for the completion of an order, or to companies in our group, including V-ITA SpA, for the purpose of providing customer assistance and completing the 'order. We can also transmit the user's personal data to our other suppliers (including those indicated in more detail below).

We are authorized to provide information on personal data processed, and to allow access to such personal data to law enforcement or authorities in response to emergencies, as required by current law, and to process such data in compliance with our legal obligations.

When the user contacts us (using, for example, a contact form or via email), his data is stored for the purpose of processing the request and for any response if questions arise.

Below are further details relating to the purposes of processing user information, the methods of processing and their disclosure.

3. DATA SECURITY

We implement organizational, contractual and technical security measures corresponding to the most advanced technologies, in order to ensure compliance with applicable laws relating to data protection and in order to ensure that the data we process is protected from manipulation, loss , destruction or access by unauthorized persons, whether accidental or intentional.

4. TRANSFER OF PERSONAL DATA TO OTHER COUNTRIES

In order for V-ITA SpA to process the user's order, the user's personal data will be transferred and stored in other countries, including countries outside the European Economic Area ("EEA").

In the event of the transfer of the user's personal data to any third party based in a country outside the European Economic Area (EEA), and if the European Commission has not approved the adequacy of that country (for example, the United States), we will take and arrange all security measures reasonably necessary to ensure sufficient protection of such personal data and related rights.For example, by signing data processing agreements with third parties who process personal data on our behalf and, where applicable, ensuring that this agreement complies with the terms established by the contract provided for by the European Union for the export of personal data for processing by persons outside the EEA (available here).

5. USER RIGHTS

Upon request, the user can receive free information on the personal data we process. He also has the right to request the rectification of inaccurate data stored and the deletion of his personal data, to assert his rights relating to the transferability of personal data, to restrict or revoke the authorization to process the data and to submit a complaint to the '' competent supervisory authority, in the suspicion of illegal data processing. The consent to the processing can be revoked at any time, without compromising the legitimacy of any data processing carried out on the basis of the consent before the revocation.

6. CONSERVATION OF USER DATA

The data stored by us is deleted as soon as the specific purpose has been achieved and to the extent that storage is not required by law.

7. CHANGES TO THE PRIVACY POLICY

We reserve the right to modify the Privacy Policy, in order to adapt it to changes in the law or changes to the website or our data processing. However, this only applies to data processing statements. Where the user's consent is required or in cases where the Privacy Policy includes provisions that require a contractual relationship with the user, changes will be made only with the user's consent. Users are therefore required to update themselves regularly on the contents, in particular when it concerns further personal information.

8. COLLECTION OF ACCESS DATA (LOG FILE)

We automatically collect your website login information. We collect data with each request for access to the server on which our website is hosted (server log file). The access data includes the name of the acquired web page, the file, the date and time of acquisition, the volume of data transmitted, the notification of successful transmission, the type of browser and its version, the operating system of the user, the referring URL (the site used before this visit), the IP address and the requesting provider. We usually process log data anonymously, without reference to other information that identifies the relevant user or to any other creation of a profile and only for statistical evaluations, for operational, security and optimization purposes of our website. However, we reserve the right to verify log data later and to use that data with other information that could identify a user if we have reasonable grounds to suspect abuse or illegal activity.

9. NEWSLETTER AND CONSENT

We send newsletters, e-mails and other electronic notifications with promotional information, which we will collectively refer to as "newsletters", only with the consent of the recipient. Subscription to our newsletters implies consent to receive newsletters.

10. COLLECTION OF ACCESS DATA (LOG FILE)

Cookies are information transmitted by our web server or by third party web servers to the user's devices, which are stored for subsequent retrieval. We use cookies to allow the use of certain sections of our website and to track user activity on the site, which allows us to familiarize with user preferences, establish business purposes and improve the use of our website. website.

We use the following cookies:

Absolutely necessary cookies - These cookies activate services that the user has specifically requested. These cookies are necessary to allow navigation on the website and the use of its features, such as access to secure areas. Without the use of cookies, the requested services, such as shopping carts or online billing, cannot be provided. Analytical or performance cookies - These cookies collect anonymous information on the pages the user has visited. These cookies collect information on how visitors use the site, such as which pages they visit most frequently, how they move around our site and if they receive error messages from web pages. These cookies do not collect data that personally identify the user. These cookies help us improve the way our site works by ensuring, for example, that users find what they are looking for easily.

Functional cookies - These cookies remember the choices the user has made to improve his experience. These cookies are used to recognize the user when he returns to our website. They allow the website to remember the choices made (such as user name, language or geographic region) and to provide better and more personal features, such as a personalized greeting. They can also be used to remember changes to text size, fonts and other customizable parts on our site. They can also be used to provide services requested by the user, such as watching a video or commenting on a blog. The information collected by these cookies can be made anonymous and cannot track the user's browsing activity on other websites.

Targeting or promotional cookies - These cookies collect information on the user's browsing habits, in order to personalize advertising based on interests. These cookies record the visit to our websites by the user, the pages visited and the links followed. They are also used to offer more relevant advertising of greater interest to the user. These cookies are also installed by third parties (including advertising networks) with our permission. These cookies store the visit to our website and the pages visited and the information is shared with other organizations, such as advertisers, and can be used to send advertisements to third party sites or applications based on online activity.

In most cases it is possible to use our websites without cookies. However, it should be noted that in case of refusal of cookies, the functionality of our website may be limited and access to some features may not be allowed. Users who do not want to allow the storage of cookies on their PCs are required to disable the corresponding option in the browser settings. You can delete stored cookies from your browser settings. Cookies are not used for purposes other than those mentioned on this page. The cookies for online advertising of companies can be managed through the site for the U.S.A. http://www.aboutads.info/choices/ or the website for Europe http://www.youronlinechoices.com/.

11. GOOGLE ANALYTICS

We use Google Analytics, a service offered by Google Inc. ("Google"), to collect user click-through data (such as IP address, date and time of visit, referring URL, pages visited on our websites and information relating to the browser used). Google uses cookies, text files that are stored on users' devices and that allow the use of the website to be analyzed. The information generated by the cookie and the use of our website by users is usually transferred to a Google server in the United States and stored there.

Google uses this information on our behalf, in order to evaluate the use of the website by users, with the aim of compiling reports relating to the activities within the website and to provide additional services regarding the use of the site. web and the Internet. Pseudonymous usage profiles of users may be created from the processed data.

We use Google Analytics only with the IP address anonymization function enabled. This means that the IP addresses of users are shortened by Google within member states of the European Union or in other contracting states of the European Economic Area. Only in exceptional cases will the entire IP address in the United States be transferred to the Google server and shortened on site.

The IP address transmitted by the user's browser does not integrate with other data from Google. Users can also prevent the storage of cookies by setting their browser to do so; users can also block the collection of data generated by cookies and related to their use of the website for Google, as well as the processing of such data by Google, by downloading and installing the browser plug-ins available at following link: https://tools.google.com/dlpage/gaoptout?hl=en.

For more information about Google's use of data for promotional purposes, settings and the possibility of raising objections, please refer to the Google website: https://www.google.com/intl/ en / policies / privacy / partners / ("Use of data by Google with reference to the use of the sites or apps of our partners"), http://www.google.com/policies/technologies/ads (" Use of data for promotional purposes "), http://www.google.com/settings/ads (" Control of information used by Google to display advertising ") and http://www.google.com/ads/ preferences / ("Improvement of the advertising proposed to the user").

12. GOOGLE MARKETING AND REMARKETING SERVICES

We use the marketing and remarketing services (“Google Marketing Services”) of Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA ("Google"). Google's marketing services allow us to show advertisements tailored to the user on our website, in order to offer users only those advertisements that potentially meet their interests. We talk about "remarketing" when you show users advertisements for products they have shown interest in on other websites. For these purposes, when you call up our website or other websites on which Google marketing services are active, a direct code is executed by Google, and the re-marketing tags (graphic elements or invisible codes , also known as "web beacons") are integrated into the website. With their help, an individual cookie, for example a small file, is stored on the device (technologies equivalent to cookies can be used). Cookies can be set for various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com and googleadservices.com. This file records the web pages that the user has visited, the contents he considers interested and the offers he clicked, as well as the technical information relating to the browser and the operating system, with reference to the websites, at the time of the visit. and other information relating to the use of the online offer. The IP address of users is also recorded (for more information on the processing of IP addresses by Google, please read section 11 above).

User data is processed under a pseudonym within the limits of Google's marketing services. This means that Google does not store and process the names or e-mail addresses of users, but that it processes the relevant data relating to cookies within user profiles under a pseudonym. This means, from Google's point of view, that advertisements are not managed and shown for a specifically identified person, but for the owner of the cookie, regardless of who is the owner of that cookie. This does not apply if a user has given specific permission to Google to process data without using a pseudonym. The information collected by “DoubleClick” regarding users is transmitted to Google and stored on Google's servers in the United States.

The Google marketing services used by us include the “Google AdWords” online advertising program. With regard to Google AdWords, each AdWords customer receives a different "conversion cookie". Therefore, cookies cannot be tracked across the websites of AdWords customers. The information collected using the cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers see the total number of users who clicked on their ads and were redirected to a page with a conversion tracking tag. However, they do not receive any information that allows the personal identification of users.

We include third party advertising through Google's "DoubleClick" and "AdSense" marketing services. DoubleClick and AdSense use cookies that facilitate the display of online advertisements for Google and its partner websites, based on user visits to the website or other sites.

Another Google marketing service we use is "Google Tag Manager", which allows further analysis and marketing services from Google, to be included on our website (such as "AdWords", "DoubleClick" or "Google Analytics").

For more information about Google's use of data for promotional purposes, please visit the overview page: https://www.google.com/policies/technologies/ads/, Google's privacy policy is available at the following link https://www.google.com/policies/privacy/. If you do not want to receive Google marketing services, you can use the opt-in and opt-out options at the following link: http://www.google.com/ads/preferences/.

13. FACEBOOK REMARKETING

Our website uses the "Facebook pixels" of the social network Facebook, managed by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you reside in Europe, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland (“Facebook”). Facebook pixels allow Facebook to refer to visitors to our site as a target group for displaying advertisements, called "Facebook Ads". Consequently, we use Facebook pixels only to display Facebook advertisements that we have activated for those Facebook users who have also shown interest in our website. This means that Facebook pixels allow us to ensure that our Facebook advertisements correspond to the potential interests of users and that they do not bother them. Facebook pixels also allow us to determine the effectiveness of Facebook advertisements for statistical and marketing purposes, since we can see if users have been redirected to our website after clicking on a Facebook advertisement.

The Facebook pixels are integrated directly by Facebook when our sites are called up and store a cookie, a small file, on the device. In the event of subsequent access to Facebook or a visit to Facebook during the connection, the visit to our site will be marked on your profile. The data collected is made completely anonymous, so that no information can be provided regarding the identity of the users. However, the data is collected and processed by Facebook, thus allowing a connection to the respective user profile. Data processing by Facebook is implemented within the guidelines for the use of Facebook data. For more information about the operation of remarketing pixels and to obtain general information on the display of Facebook advertisements, refer to the Facebook data use policy: https://www.facebook.com/policy.php.

The collection of data by Facebook pixels and their use to show Facebook advertisements is not mandatory. To withdraw consent, visit the page created by Facebook and follow the instructions for setting up advertising based on usage: https://www.facebook.com/settings?tab=ads or use the US website http: / /www.aboutads.info/choices/ or the European site http://www.youronlinechoices.com/. These settings are not platform dependent, e.g. they are used for all devices, such as desktop computers and mobile devices.

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