Privacy policy

As provided for in European Union Regulation No. 679/2016 (hereinafter "GDPR") and in particular in Article 13 thereof, we hereby provide you with the information required by law regarding the processing of your personal data. Note for minors: We do not intentionally process data of minors under 14 years of age; however, if you are 14 years old or younger, please obtain permission from your parent/guardian before providing your personal information. The website www.duobedifferent.com (hereinafter the "Website") is owned and managed by START S.A.S., which complies with applicable data protection laws and constantly strives to improve the protection of its customers. This personal data protection policy informs you about the processing of your personal data in relation to the website www.duobedifferent.com, how they are managed, and how services are made available through the Website by START S.A.S.

DATA CONTROLLER

WHAT IS PERSONAL DATA?

Personal data is information that refers to an identified or identifiable natural person, such as name, surname, gender, email address, telephone number, date of birth, postal address.

WHAT PERSONAL DATA IS PROCESSED?

1. If the user creates their personal user account, fills in the Website registration fields, or gives us their consent, we process the personal data thus provided, in particular the data as defined in section 2.
2. Navigation data
   The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user's computer environment. This data will be recorded anonymously and in aggregate form and will be used, always in aggregate form, solely to obtain anonymous statistical information on the use of the site and to check its correct functioning and are deleted, always in aggregate form, immediately after processing. The data could be used to ascertain responsibility in case of hypothetical cybercrimes against the site.

WHEN DO WE PROCESS YOUR DATA?

We process your personal data when you create your personal user account, when you order products through our website, or when you subscribe to our newsletter. Unless otherwise specified in the following provisions, the legal basis for this data processing is Article 6, paragraph 1 b) and a) GDPR (performance of a contract and consent).

PURPOSES OF DATA PROCESSING

1. Account
   To make purchases on our site, you must create a personal account (hereinafter "user account"). You can store personal information in the user account and facilitate shopping in our online store. To create a personal user account, we need your personal details, first name and surname, and, where applicable, address and telephone number. In addition, users must provide their email address and a password of their choice. The email address provided by users also serves as login data for the user account. Furthermore, users can store their personal data within the user account and thus conveniently shop in the online store. The information can be updated at any time in the personal area of the user account ("User Profile"). When registering, the User will be asked to enter personal data, some of which - from time to time expressly identified as such - it will be mandatory and indispensable to provide for registration purposes (e.g. the email address at which to receive Newsletters). The other data may or may not be provided, at the User's discretion, and failure to provide them is in no way detrimental for registration purposes, but may allow only partial use of the Services. Of course, the user can delete their user account at any time and without giving reasons. The easiest way to do this is to send an email to startabbigliamento@gmail.com. The legal basis for this data processing is Article 6 paragraph 1 b) GDPR (performance of a contract).
2. With regard to ordering products in our online shop, the processing of your personal data is intended to enable and optimize order fulfillment, including payment and delivery. When payment is made by credit card, we receive the payment ID and the last four digits of the credit card number from our payment service provider. This serves for authentication and allocation of your order and thus for your security. The personal data necessary for payment is collected directly by the payment service provider. The legal basis for the aforementioned data processing is Article 6 paragraph 1 b) GDPR (performance of a contract) and Article 6 paragraph 1 f) GDPR (legitimate interest, based on our interest in offering you a secure credit card payment option). Among other things, we also check all previous orders placed from your customer account. The system also checks whether the delivery address is different from the billing address, whether it is a new delivery address or whether the order needs to be delivered to an intermediate center. After choosing the payment service provider, you will be asked for the data necessary to use such services. This payment information is forwarded directly to the respective payment service provider and is not stored by START S.A.S. We save the billing and delivery address data in your user account so that you no longer need to enter them the next time you make a purchase. This data can be changed at any time in the future. If you do not agree to the payment method(s) offered, you can inform us in writing by letter or email to startabbigliamento@gmail.com. We will then review the decision in light of your comments. Personal data processed in connection with orders will be deleted at the latest after the expiry of the statutory warranty periods, unless this conflicts with statutory retention obligations.
3. Newsletter
   We offer all users of our community (users of www.duobedifferent.com) the opportunity to receive our newsletter. To activate it, the user can register with their email address on the dedicated page. The user can revoke their consent at any time and without giving reasons. The easiest way to do this is to click on the "Unsubscribe" link, which can be found in every newsletter. The Newsletter may also contain advertising banners, advertisements and promotional offers from both the Company and third parties. The legal basis for this process is Article 6, paragraph 1 a) GDPR (consent).
4. Contact via contact form
   If you send us inquiries using the contact form, we will process the information you provide, including your contact details, in order to process the request. In the event of subsequent requests, this additional data will also be stored. The legal basis is Article 6.1 b) GDPR (performance of contract - the processing of user data is necessary for the performance of the contract to answer questions or requests) as well as Article 6 paragraph 1 f) GDPR (balancing of interests - based on our interest in processing inquiries from users of our website). As the Data Controller, START S.A.S. informs that the personal data of Users, with their consent, may be processed by START S.A.S. for the following purposes: a) sending informative, promotional and advertising material relating to START S.A.S. brands (by way of example but not limited to: sending newsletters, promotions, etc.); b) carrying out statistical studies and research; c) collecting data and information in general and in particular on consumer trends and preferences and processing them using electronic tools in order to identify the products that may be of most interest to them, so as to send them promotional communications expressly addressed to such products (so-called profiling).

METHODS AND PLACE OF PROCESSING

Personal data is processed with automated tools for the time strictly necessary to achieve the purposes for which it was collected. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access. The database is accessible only by authorized persons through methods that guarantee its protection and confidentiality, thanks to the adoption of security measures designed to prevent data loss, illicit or incorrect use and unauthorized access. Despite all the measures adopted to safeguard your information, we cannot guarantee, given the current state of technology, that unauthorized access or misuse of services by third parties can be excluded. PLACE OF DATA PROCESSING The processing connected to the Services of this Site takes place at the headquarters of the Data Controller and is handled only by the technical staff of the Data Controller specifically appointed as authorized personnel, or by any persons appointed for occasional maintenance operations. No data deriving from the web service is communicated or disseminated. The personal data provided by Users who send requests for membership to the Services are used solely for the purpose of performing the requested service or provision and are communicated to third parties only if this is necessary for that purpose. In its capacity as data controller, START S.A.S. may proceed, directly or through any external data processors indicated on the Site, to save the Users' personal data on specific servers and to carry out all other processing operations through the personnel - of the controller and of the processor - specifically appointed as authorized personnel, or through any external persons appointed during maintenance operations.

DATA PROCESSORS

For the operation of our website, we engage external data processing service providers (e.g., order fulfillment, newsletter software, data centers). If necessary, these service providers also process personal data. The service providers are carefully selected and monitored by us. Data is processed exclusively in accordance with our instructions and is also bound by this data protection declaration. Only with the express authorization of the User will START S.A.S. proceed to use their data for the same activities as in the previous point with the aid of automated tools without the intervention of an operator and/or for other purposes authorized from time to time by the User. The updated list of all Data Processors is available at each Data Controller's office and can be requested at the following email address: startabbigliamento@gmail.com. This list may be subsequently supplemented and/or updated as needed.

RETENTION PERIOD

Personal data will be kept only for the time necessary to achieve the purposes indicated herein or as required by law (applicable civil, fiscal and tax obligations). The data entered by you pursuant to section 3.1 will therefore be deleted at the latest after 10 years from the expiry of any retention periods provided for by commercial and tax law. Automatically recorded data, as defined in section 3.2, will therefore be deleted or anonymized after 24 months.

YOUR RIGHTS

As a data subject, pursuant to Articles 15-21 of the GDPR, you have the right to: a) obtain confirmation of the processing of your personal data; b) access your personal data and know its origin (when the data is not obtained directly from you), the purposes and aims of the processing, the data of the subjects to whom it is communicated, the retention period of your data or the criteria useful for determining it; c) obtain the updating and rectification of your personal data so that it is always accurate and precise; d) obtain the erasure, in the cases provided for by Article 17 of the GDPR, of your personal data or request the restriction of processing; e) obtain a copy of your personal data. You can therefore know what personal data we hold about you, its origin and how it is used, request its update, rectification or integration as well as, in the cases provided for by current provisions, its erasure, the restriction of processing or object to its processing. If you wish, you can request to receive the personal data we hold about you in a format readable by electronic devices and, where technically possible, we may transfer your data directly to a third party indicated by you. Any requests will be processed at the latest within one month of receipt, subject to the possibility of extending this period for a further two months, if necessary, taking into account the complexity and number of requests received by the Data Controller.