Privacy Policy

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PRIVACY POLICY

Information on the processing of personal data (pursuant to art. 13 of EU Regulation 2016/679 – GDPR)

1. Data controller

The Data Controller is:

Simonelli Roberto – Individual business
Località Montevico 4/A – 27040 Pietra de’ Giorgi (PV) – Italy
VAT number 04669850960
C.F. SMNRRT70C24B832T
E-mail: info@ice-key.it

A Data Protection Officer (DPO) has not been appointed, as the legal requirements are not met.

2. Type of data processed

Through the site www.ice-key.it only personal data necessary for the management of orders and commercial relationships are processed, such as:

  • identification data (name, surname);

  • contact data (email address, telephone number);

  • shipping and billing address;

  • tax code or VAT number (where required for invoicing);

  • data relating to purchases made;

  • any data provided via the contact form.

The site does not directly collect or process health data or particular categories of data pursuant to art. 9 GDPR.
Any particular data entered voluntarily by the user as part of digital services connected to ICE-KEY devices (e.g. dedicated platforms or applications) and not to the site are governed by specific privacy information relating to such services.

The site may process navigation data collected through cookies and analysis tools, as indicated in the Cookie Policy.

3. Purpose of processing and legal bases

Personal data is processed for the following purposes:

a) order management and conclusion of the sales contract;
b) invoicing and accounting and tax obligations;
c) shipment management;
d) customer support and request management;
e) protection of the Data Controller's rights in court;
f) sending promotional communications or newsletters, using automated tools (e.g. e-mail), subject to the free, specific and revocable consent of the interested party.

The legal bases of the processing are:

  • Article 6, par. 1, letter. b) GDPR – execution of a contract (purpose a, c, d);

  • Article 6, par. 1, letter. c) GDPR – fulfillment of legal obligations (purpose b);

  • Article 6, par. 1, letter. f) GDPR – legitimate interest of the Data Controller in the protection of his rights (purpose e);

  • Article 6, par. 1, letter. a) GDPR – consent of the interested party (purpose f).

4. Nature of the provision

The provision of data for the purposes referred to in points a), b), c) and d) is necessary for the conclusion and execution of the sales contract.

Failure to provide it will make it impossible to process the order.

The provision of data for marketing purposes is optional and failure to consent does not affect the purchase of the products.

5. Treatment methods

The processing takes place using IT and telematic tools, in compliance with the security measures provided for by the art. 32 GDPR.

The site is created via the Wix.com platform, which provides technical infrastructure and hosting services and acts as Data Controller pursuant to art. 28 GDPR.

The data are processed by authorized personnel or by subjects appointed as Data Processors pursuant to art. 28 GDPR.

6. Data retention

Personal data is stored:

  • for the duration necessary for the execution of the contract;

  • for the terms established by tax and civil legislation (accounting obligations);

  • for marketing purposes, the data will be retained until the interested party withdraws consent or until the newsletter service is terminated. The interested party may revoke consent at any time via the unsubscribe link (if present in the communication) or by writing to info@ice-key.it.

7. Data communication

Personal data may be communicated exclusively to:

  • providers of technical services, hosting and platform management (e.g. Wix);

  • administrative and tax consultants;

  • couriers and shippers for the delivery of products;

  • competent authorities in the cases provided for by law;

  • electronic payment service providers (e.g. PayPal), who operate as independent data controllers according to their own privacy policies.

The data is not subject to dissemination.

8. Data Transfer

The data is processed mainly within the European Union.
Some technology providers (e.g. hosting platforms or digital services) may involve transfers to third countries. These transfers take place in compliance with the articles. 44 et seq. of the GDPR, on the basis of an adequacy decision of the European Commission or through the adoption of Standard Contractual Clauses (SCC).

The site uses services provided by Google LLC, which may involve data transfers to the United States. These transfers take place in compliance with the guarantees provided by the GDPR, also through adherence to the EU-US Data Privacy Framework or the adoption of Standard Contractual Clauses.

9. Rights of the interested party

The interested party can exercise the rights provided for by the articles at any time. 15–22 GDPR, including:

  • right of access;

  • right of rectification;

  • right to cancellation;

  • right of limitation;

  • right of opposition;

  • right to data portability;

  • right to withdraw consent.

To exercise your rights you can write to: info@ice-key.it

The interested party also has the right to lodge a complaint with the Guarantor for the Protection of Personal Data pursuant to art. 77 GDPR.