Our Privacy Policy for Chogan Group Spa websites

Foreword

Chogan respects the privacy of every individual who visits its websites and uses its services. This Privacy Policy informs you in format of Please note that this policy applies to websites belonging to Chogan Group SPA (chogan.it, chodit.it, chogangroup.com, chogangroupspa.com) containing a link to this policy and to websites of Chogan itself.
In accordance with Art. 13 of EU Reg. 679/2016 the following information is therefore provided

1. Data Controller:

   Chogan Group S.p.A.
   Registered office: Via A. Olivetti 24 00131 – Roma – RM; Headquarters: Via Riccheo 5/7,76121 – Barletta (BT), P.IVA 07872640722
   Mail [email protected]

2. Data Protection Officer

   Chogan Group did not appoint a Data Protection Officer.

3. Purpose the processing, legal bases

   The data provided by the Data Subject through the Website will be processed for the following purposes:

   1. to allow registration on the Website and to access the services reserved to registered users (as well as to comply with all the accounting-administrative and legal activities connected to "Registering");
   2. in the instance of an online purchase ("Sale");
      1. to enable the conclusion of the purchase agreement and the correct execution of transactions related thereto;
      2. for the fulfilment of tax obligations;
   3. to respond to specific requests of the Data Subject and to provide customer support services;
   4. with the data subject's prior consent, to send promotions, discounts, concessions on the part of Chogan Group S.p.A. , as well as to send commercial or informative communications ("Newsletter"), to carry out market research, also aimed to assess the degree of satisfaction of users (customer satisfaction) and to notify the user about all the initiatives regarding products and/or services in connection with Chogan group and/or third parties, including products offered for sale on the Website by means of automated systems, email or sms ("Direct Marketing ") ;
   5. with the data subject's prior consent, to analyze their habits and consumption choices ("profiling"), by Chogan through the detection of the type and frequency of purchases made online for the sending of advertising and/or informative material of specific interest to the user in the methods described in point d) above ("Profiling") ;

4. The legal basis of processing:

   • referred to in (a), (b), (c) is the necessity of the processing itself for the execution of a contract of which you are a party or for the execution of pre-contract conditions adopted upon your request, as well as the fulfillment of legal obligations.;
   • your consent referred to in points d), e);

5. Personal data disclosure and consequences of data disclosure refusal

   Data provisioning for the purposes set out in points a), b) and c) of article 3 above is purely optional. However, as this processing is necessary to allow registration to the Website and the reserved services, including the e-commerce service, as well as to fulfil your requests or provide you with assistance, your refusal to provide the data will make it impossible to register on the Website, and/or to conclude an online purchase, and/or to receive a reply or assistance. You may refuse your consent to the marketing and profiling processing referred to in points d) and e) of the previous paragraph without any prejudice to the provision of the other services. The provision of data always remains optional and not necessary for processing relating to marketing activities (article 3, letter d) and profiling (article 3, letter e). Consent is given by means of specific check-boxes or boxes in which the Data Subject may express his/her choice among the options avaible. The lack of consent will not have any consequence on the possibility of registering to the Website and/or making purchases on the same and will only imply the consequences described below:

   • failure to consent to the processing of personal data for the purposes of article 3, letter d), will result in the impossibility of receiving commercial or informative communications ("newsletters"), promotions, discounts, concessions from Chogan, as well as the impossibility of carrying out market research, also aimed to assess the degree of satisfaction of users (customer satisfaction) and to notify the user about all the initiatives regarding Chogan products and/or services;
   • failure to consent to the processing of personal data for the purposes of article 3, letter e), will result in the impossibility for the Data Controller to analyse your consumption choices (so-called "profiling"), by detecting the type and frequency of purchases made online and, if indicated, the areas of interest optionally requested and selected by the user in the registration form for the sending of advertising and/or informative material of specific interest to the user.

   The Interested Party may revoke, in any event, the consent given (or object to the processing) The Interested Party may revoke any consent given in any event (or object to the processing) for the purposes described in points (d) "Marketing" and (e) "Profiling" of Article 3, by contacting Chogan at [email protected] or through the "change privacy settings" function available in "My Profile" section.

6. CATEGORIES OF PERSONAL DATA PROCESSED VIA THE WEBSITE

   The following personal data of the Data Subject may be processed:

   • "Personal information": such as name, surname, date of birth, city, postal code.
   • "Registration and/or Contact Data": e-mail, phone.
   • "Browsing Data": such as IP addresses or domain names of computers used by Users connecting to the Website, the addresses in URI (Uniform Resource Identifier) of the requested resources, the time of the request, the method used in submitting 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 concerning the operating system and user's IT environment. This data is processed for the time strictly necessary to obtain anonymous statistical information concerning the use of the website and to check its proper operation. The data could be used to determine responsibility in case of hypothetical computer-based violations damaging the Website..
   • "Credit card data": such as card number, card holder, expiry date, security codes, these data will be processed directly by the payment service provider and will not be processed in any way by Chogan.
   • "Data provided by the user by filling in the form for consultants": data communicated by filling in the forms for consultants will be processed directly by the consultants themselves and Chogan does not retain or otherwise process any user information when filling in the form.

7. SCOPE OF COMMUNICATION: INDIVIDUALS OR CATEGORIS OF INDIVIDUALS TO WHOM SUCH PERSONAL DATA MAY BE DISCLOSED OR WHICH MAY SEE PERSONAL DATA IN THEIR ROLE AS DATA PROCESSORS OR PERSONS IN CHARGE OF THE PROCESSING

   Your personal data may be processed by our internal and external collaborators (consultants, accountants, etc.) as data processors or persons in charge of the processing. Furthermore, for certain processing operations instrumental to pursue the purposes referred to in the preceding points, the data may be communicated to third parties other than the Company in their capacity as data processors (e.g. delivery of goods, sending of advertising e-mails on behalf of the data controller in case of consent, support in the conduct of market surveys, customer service, technological and commercial partners that support the provision of the service, etc.). Personal data will not be disseminated in any case.

   Please note that any communication of your personal data will take place in full compliance with current regulations concerning privacy and technical and organisational measures established by the Data Controller, in order to ensure an adequate level of security.

8. Methods of processing

   Your Data will be processed by computerised and telematic tools, and also, by manual means, with the proper modalities and means guaranteeing the security and confidentiality of the data themselves and preventing their diclosure, loss or illegitimate use. All access to data will be kept under constant control.

9. Data Retention Time

   The personal data provided by Data Subjects will be processed for the entire duration of the contract and, in general, for 10 years after its termination in order to fulfil all legal obligations (unless further storage requirements are imposed by current legislation – as well as all obligations arising from the contract - e.g. accounting, tax, etc.). The User personal information will be retained only for the time necessary to ensure the proper performance of the services required. In any case, it is understood that personal data will be stored and processed for direct marketing and profiling purposes for 24 months). In the event that the Website account is closed at the User's initiative, the data contained therein will be stored for administrative purposes for a period not exceeding 90 days, without prejudice to any specific legal obligations regarding the conservation of accounting documentation or for public security purposes. At the end of said period, the data will be cancelled or rendered anonymous.

10. Where will my personal data be kept?

    Chogan stores your personal information in a centralized repository in Italy. On it, all security mechanisms have been implemented to guarantee the integrity and security of your data.

    Rights of the data subject
    You have the right to:

    • to access their own personal data (art. 15 GDPR),
    • to update or rectify your personal data (art. 16 GDPR),
    • to request the deletion of your personal data - right to be forgotten (art. 17 GDPR),
    • to restrict the processing of their personal data (art. 18 GDPR),
    • to obtain your personal data in electronic format - right to portability (Art. 20 GDPR),
    • to object, for legitimate reasons, to the processing of your personal data (art. 21 GDPR) - following such a request, the Data Controller shall in no event be entitled to process your personal data, except in the cases of application of laws and regulations..

    The aforementioned rights may be exercised by submitting a request to each of the Data Controllers as follows:
    to Chogan Group Spa by post or e-mail at the addresses given in Section 1 of this policy;

11. Can Chogan change this policy on its websites?

    Data protection laws, directives and case law change all the time. Accordingly, Chogan reserves the right to amend this policy from time to time. We recommend that you visit our website periodically to be aware of the latest version of our policy.