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Privacy policy

INFORMATION PURSUANT TO ART. 13 AND 14 OF E.U. REG. 679/2016 (GDPR)

This Information Notice describes which of your personal data are collected by the shop-egosan website, for which purposes and in which way they are processed, in addition to the information necessary to exercise your rights under GDPR.

In general, we collect your data when you create an account at the online Shop Egosan (hereinafter the "Store"), when you purchase products offered for sale at the Store, when you send us emails or ring us for assistance. We wish to inform you that the personal data collected during these processes will be treated in order to respond to your requests, to enable you to benefit from the services offered by the Store by means of access to reserved areas (for example fulfil your orders and perform instrumental activities, including operations necessary for administrative and tax purposes as indicated below.

1. Who processes your data
Your data will be processed by two social entities, both of them independent Data Controllers for the service described below. Santex S.p.A. with registered office in Via San Giovanni sul Muro 1, 20121, Milan, email privacy@santex.it (Santex) and Zerogrey S.r.l. with registered office in Via L. Colli, 15 10128 Turin, C.F. (tax ID) 08003340018 (Zerogrey). Santex is the controller of your personal data, where collected, for the management of the Store’s accounts, managing the sending of the products purchased by you, for the management and maintenance of the Store, providing you with the necessary pre- and post-sales assistance, and managing the process of returning purchased products. Zerogrey controller of your personal data, where collected for the purposes of: fulfilling and managing your orders and complying with tax requirements.

2. Which data we process Your contact and account information.
We will store the contact information you provide to us (e.g. first name, surname, address, email, country of residence, phone number, date of birth, gender) when you create an account at the Store. Your payment and invoicing data. We will store your payment and invoicing data you provide to us (e.g. credit card number, postal code and address when you purchase a product, for the purpose of managing your purchase orders and shipping the products). If you would like it, we may also store your payment and invoicing data to make purchases in the future easier for you. Information about use of the site. Your use of our sites involves processing of data about the browser and device that you are using and your IP address (this is the number that identifies a specific device on the internet and is necessary for your device to communicate with the sites). We can analyse which site you came from, what you have done and not done on our site based on the preferences you expressed for cookies.

3. From where do we take your data? Directly from you.
For example, if you register to make a purchase at the Store, create an account, ask a question, or interact with our call centers. If you do not provide us with your details you will not be able to register yourself at the Store and you will not, therefore, be able to make any purchases of products offered for sale in the Store. When you register with your social account, in particular your Facebook account, we will obtain the personal data you choose to share through these social media services based on their privacy settings. We may also use social media plug-ins on the site; as a consequence, data will be shared with the social media service and possibly shared on your social profile. Please refer to the privacy policy of these third-party social media providers to find out more about these policies. Through the use of features of the Store. We use cookies and other technology, such as pixel tags on our sites, in our emails in order to collect data about your usage and better direct the promotion. To find out more, please see our Cookie Policy. Third-party data is provided directly by you. Any indication (for example for a product shipment) of personal and contact details of any third party other than you represents a processing of personal data for which you are the autonomous owner, thereby assuming all the obligations and responsibilities provided for by current legislation on personal data. In this way, you guarantee to Santex and Zerogrey that any data from third parties that will be indicated by you has been provided by you with your consent, relieving the latter from any dispute, claim, request for compensation for damages that may be received by Santex or Zerogrey deriving from any interested third party from the aforementioned communication.

4. Why and for how long we process your data 

a) To provide you with the products and services you have purchased and to send you communications concerning your order and payments.
For example, we will use your data to process your order, confirm your purchase and manage ancillary services such as shipping of the products purchased. Without your data, we will not be able to manage and process your order. The legal basis for this processing is the performance of the sales contract to which you are a party from the moment you accept the terms and conditions of sale of the Store. The storage period of your data is equal to the period needed to process your order.

b) To enable you to register at the Store.
We will process your personal data to enable you to create an account at the Store, whether or not you make a purchase at the Store. The legal basis for this processing is the performance of a contractual/pre-contractual request by you. The storage period for your data, in addition to that required to process your possible order, will be equal to the period of activity of your account, which in any case will be deactivated after 24 months from your last access or your last action on the account.

c) To provide you with the necessary after-sales service in compliance with the applicable product warranty legislation.
For example, we will use your data to provide you with assistance, to manage the return and/or repair of products purchased by you at the Store in accordance with the applicable legislation. The legal basis for this processing is to comply with the legal obligations and the storage period is equal to that required by law (in particular by the Consumer Code).

d) To correctly manage your administrative position.
We process your data for the accounting, administrative and tax purposes, directly related to the business activity of the owners and required by the applicable legislation (in particular, that regarding tax, anti-money laundering, banking, and public security).

e) For you to interact with customer service representatives.
We may use your email or your telephone number, as well as your name and/or postal address, to help you in case you need help with the use of products from the Store. The legal basis for this processing is the performance of the sales contract which you entered with Zerogrey when you accepted the Store’s terms and conditions of sale, as well as fulfilling the legal obligations regarding warranties and consumer care. The storage period is equal to the period necessary to process your request. In order to improve customer care, which is subject to applicable laws, Zerogrey may also re-read, record, and listen to conversations with customer care representatives. The legal basis for this processing is Zerogrey's legitimate interest in improving the quality of the services provided to its customers. In addition, Zerogrey may analyze any feedback voluntarily provided through surveys submitted to customers. The legal basis for this processing is the consent of the data subject. In all of the above cases, the data retention period is equal to the period of activity of your account.

f) To prevent or control illegal conduct or to protect and enforce rights.
For example, we may use your data to prevent the infringement of our intellectual property rights (for example, counterfeiting of our and/or our partners' brands) or theft (including credit card cloning and theft that we think may occur during a contest or event) or other unlawful acts, as permitted by applicable law. The legal basis for such processing is the legitimate interest of the data controllers. The period of storage of your data is equal to the time that is reasonably necessary for us to assert our rights from the time we become aware of the unlawful act or its potential commission.

g) To review and improve our products and the Store.
Shop Egosan, completely anonymously analyses your data on the use, preference, and consumption of our products to improve our approach to you and our customers in general, through automated processing that includes profiling. We do this so that we can make better decisions in relation to services, advertising, products, and content that are based on greater awareness of how our customers use our services and to ensure that you have a more personalized experience. For this purpose Shop Egosan may also collect the identifier for the advertising of your mobile device (IDFA - Identifier for Advertising - for iOS and AAID devices - Google Advertising ID - for Android devices) to always provide you with targeted and relevant advertising based on your preferences and interests. The legal basis for this processing is the legitimate interest of the Controller. The storage period of the anonymous data is equal to 12 months from the collection.

5. Nature of personal data provision
For the purposes from a) to f) in the previous paragraph, the provision of data is necessary to allow you to create an account on the site, make purchases in the Store, and receive other services on the site. For the purposes from g) to i), the provision of data is optional; refusal to provide such data will not affect the purposes from a) to f). The interested party may revoke his or her consent at any time, but this will not affect in any way the processing carried out before such revocation.

6. Where your data is processed – transfer of data
The data will be processed and stored at the Zerogrey and Santex offices or at their IT infrastructure, located in Europe. For internal administrative and organizational purposes, we may disclose your data to companies within the Zerogrey group operating within the European Union.

7. Who we share your data with
Notwithstanding that, where required by law, we will obtain your prior consent and carry out any formalities required by law, we may share your data with the following third parties (also as external managers): Our service providers: We may share your data with third parties so that they can provide services to us (for example couriers, call center companies, warehouse management companies, and logistics providers) but in this case, we will enter into an agreement in accordance with Article 28 of GDPR to protect your data. These parties only hold the data necessary to perform their functions and may only use it to perform such services on our behalf or to comply with legal requirements. You can find out the details of these data controllers under Article 28 of GDPR by contacting us by email at privacy@santex.it or privacy@zerogrey.com. Where we believe that we must do so in order to comply with the law or in order to provide legal protection to ourselves or to third parties. Where permitted or required by law, we may also share data requested by a governmental body or other authorized person or organization in order to protect or exercise our or a third party's rights, or in order to limit or prevent fraud (including credit card fraud or other fraud that we believe may occur during a lottery or promotion or event) and other unlawful acts.  

8. Minors
Our Store is not intended for children under the age of 16 but is intended for an adult audience. If you are a parent or guardian and you think your child has submitted data to us, you can contact us.

9. Security measures
We undertake the security measures required by law. We undertake security measures to protect your data. The standard security measures we use depend on the type of data we process and meet the requirements of the law and the standards of European government agencies.

10. Your rights
You can contact Santex or Zerogrey at the email addresses indicated above, to exercise your rights under Articles 15-22 of GDPR and, in particular, to request access to your personal data, to rectify or erase them or restrict their processing, to object to their processing and to request the portability of your data; you may also withdraw your consent at any time (this will not prejudice the lawfulness of the processing based on your consent given before the revocation). When you exercise your right of access, you have the right to know whether your data are being processed, what is the purpose of the processing, what categories of data are being processed, who are the recipients or categories of recipients to whom your data are disclosed (and, if they are resident in a third country, on the basis of which safeguards), the period of storage of your data (or the criteria for determining the period of retention), whether we are processing your data automatically (for example, through profiling) and the logic involved in such processing, the origin of the data (if not initially collected by us). You have the right to lodge a complaint with the Italian Data Protection Authority and to ask the joint data controllers, at any time, for information about the data controllers and the entities authorized by the data controllers to process your data. You can check and deactivate cookies and other profiling tools. To find out how we use cookies and other profiling tools, click here.

11. What we do if we change this information notice
We may make changes to our privacy policy. We will notify you about these changes as required by law. We will also post an updated version on our site. It will have a different date and version number from those shown below. Please check the site periodically for any updates.  

Turin, 7 December 2021