Privacy Policy

DATA CONTROLLER

ELLIEME GLOW., with registered office at Largo delle Coffe 5 VAT 01892260090 cap. 17100 / Savona

DATA PROTECTION OFFICER
Email address info@elliemeglow.com

SOURCE OF DATA COLLECTION
Website www.elliemeglow.com, mobile app or other mobile devices, surveys and market research conducted with automated tools.

PURPOSE OF PROCESSING
LEGAL BASIS FOR PROCESSING
DATA RETENTION PERIOD

A) Contractual purpose:
• Execution of the sales contract in which you are a party (non-registered website user);

As a result of the contract, as described above: to avail the services provided by the Company through physical points (stores) or through the website www.elliemeglow.com("Website"). For example, after-sales assistance services; participation in prize events; website registration; request for information in the "contact us" section of the Website or through instant messaging services; reviews, within the reserved area or in dedicated sections, on tested products; any other service made available to you by the Company.
Execution of a contract in which you are a party (or pre-contractual measures taken at the request of the data subject, e.g., request for information through dedicated sections of the website www.elliemeglow.com
Art. 6(1)(b) GDPR.
Throughout the contractual duration and, after termination, for a maximum period of 10 years from their collection.

To fulfill administrative-accounting obligations required by applicable national regulations.
Necessity to fulfill a legal obligation
Art. 6(1)(c) GDPR.
Throughout the contractual duration and, after termination, for a maximum period of 10 years from their collection.
B) Direct marketing purposes: automated contact (email and instant messaging) for the sending of advertising materials, newsletters, promotional and commercial communications relating to products and/or events of the Company, as well as conducting market research and statistical analysis.
Consent (optional and revocable at any time) given by individuals who have reached the age of 16.
Art. 6(1)(a) GDPR.
24 months from the registration/creation of your Ellieme Glow account, or until the revocation of the consent you have given for this purpose if earlier.
C) Profiling purposes: analysis of your preferences, purchasing habits, related behaviors and/or interests in order to send you personalized commercial communications.
Consent (optional and revocable at any time) given by individuals who have reached the age of 16.
Art. 6(1)(a) GDPR.
For the analysis of your consumption habits, if authorized by you, your purchases with a historical depth not exceeding 12 months will be examined.
D) Communication/transfer of data to third parties (specifically, companies belonging to the same Group as the Company).
Your personal and contact data will be communicated to the aforementioned third parties for marketing activities (e.g., automated contact methods such as SMS, email, social networks, instant messaging apps) related to their products.
Consent (optional and revocable at any time) given by individuals who have reached the age of 16.
Art. 6(1)(a) GDPR.
For the technical time necessary to transmit such data to the aforementioned parties or until the revocation of the consent if earlier.

After the above-mentioned retention periods have expired, the Data will be destroyed, deleted, or anonymized in accordance with the technical procedures for deletion and backup.

2.1 - CATEGORIES OF PERSONAL DATA PROCESSED FOR CONTRACTUAL AND LEGAL PURPOSES
Personal identification data, contact information, contractual data (e.g., customer code, product code, order number), tax information, data related to purchased products, website registration data, mobile app or other mobile device data, browsing data, requested information.

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2.2 - CATEGORIES OF PERSONAL DATA PROCESSED FOR MARKETING PURPOSES
Personal identification data, contact information, contractual data (e.g., product code, total spent), data related to purchased products, mobile app or other mobile device data, browsing data, data related to requested samples and conducted tests. The data must relate to individuals who have reached the age of 16.

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2.3 - CATEGORIES OF PERSONAL DATA PROCESSED FOR PROFILING PURPOSES
Personal identification data, contractual data (e.g., product code, total spent), data related to purchased products, data related to viewed and/or added-to-cart but not purchased products, website registration data, mobile app or other mobile device data, browsing data, data related to requested samples and conducted tests. The data must relate to individuals who have reached the age of 16.

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2.4 - CATEGORIES OF PERSONAL DATA PROCESSED FOR TRANSFER TO THIRD PARTIES
Personal identification and contact data.

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3 - MANDATORY NATURE OF DATA PROVISION
The provision of personal data as described in section 2.1 for the purpose A of this information notice (contract execution) is necessary to manage your purchase and provide the services related to the sale as described above and as requested by you. Refusal to provide the aforementioned personal data will therefore prevent the completion of the purchase and the use of the indicated services.
The provision of personal data as described in sections 2.2 and 2.3 for purposes B and C (marketing and profiling respectively) is optional and subject to your consent. You will have the opportunity to revoke such consent by accessing the reserved area of the website ("Privacy Settings") or by writing to the email address info@elliemeglow.com. Such revocation will not affect the lawfulness of the processing based on consent (marketing and/or profiling) given prior to the revocation.
The provision of data for the purpose D of this information notice (transfer to third parties for direct marketing purposes) is optional. Therefore, in case of failure to give consent, your personal data will not be transferred. You will have the opportunity to revoke such consent by accessing the reserved area of the website ("Privacy Settings") or by writing to the email address info@elliemeglow.com. Such revocation will not affect the lawfulness of the processing based on consent given prior to the revocation.

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4 - DATA RECIPIENTS
The data may be processed by external entities operating as independent data controllers under Articles 4 and 24 of the GDPR, such as, for example, authorities and supervisory bodies, as well as, in general, subjects, public or private, authorized to request data, consulting companies and/or professional firms and/or professionals, such as legal, tax, and insurance companies.
The data may also be processed, on behalf of the Company, by external entities appointed as data processors under Article 28 of the GDPR, to whom appropriate operational instructions are given regarding the correct processing of your personal data. These entities are primarily included, for example, in the following categories: companies providing email delivery services; companies providing website maintenance and development services; companies providing support for market research studies; companies providing after-sales services and consumer assistance; shipping and transportation companies; companies providing postal services and other marketing activities; Ellieme Glow for the provision of intragroup services and management of purchases made at each company's stores within the Group.

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5 - AUTHORIZED DATA PROCESSORS
Your data may be processed by employees of the company's business functions assigned to the pursuit of the aforementioned purposes, who have been expressly authorized to process them and have received adequate operational instructions in accordance with Article 29 of the GDPR.

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1. TRANSFER OF PERSONAL DATA TO COUNTRIES OUTSIDE THE EUROPEAN UNION
   Due to the global nature of the company's activities, data may be transferred abroad to countries located within and outside the European Union, to entities that, depending on the case, will act as independent data controllers or data processors. However, it is understood that the transfer of personal data to countries outside the European Union will be carried out in accordance with the measures established by applicable regulations, ensuring an adequate level of protection for the data subjects.

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7 - YOUR RIGHTS AS A DATA SUBJECT - COMPLAINT TO THE SUPERVISORY AUTHORITY
By contacting the company at the email address info@elliemeglow.com, you can request access to the data concerning you (Article 15 of the GDPR), rectification of inaccurate personal data and/or integration of incomplete personal data (Article 16 of the GDPR), erasure of your personal data in the cases provided for (Article 17 of the GDPR), and restriction of processing in the cases provided for by Article 18 of the GDPR.

Furthermore, in accordance with Article 20 of the GDPR, in relation to the processing purposes of this information based on consent or contract and carried out with automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and, if technically feasible, to transmit them to another data controller without hindrance.

You have the right to withdraw your consent at any time for marketing and/or profiling purposes, as well as to object to the processing of data for marketing purposes, including profiling related to direct marketing, by accessing the reserved area of the website (Privacy Settings section) or by writing to the email address info@elliemeglow.com.
Finally, you have the right to lodge a complaint with the Supervisory Authority, namely the Italian Data Protection Authority (https://www.garanteprivacy.it/).

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8 - CHANGES TO THIS NOTICE
The company reserves the right to update and/or modify this notice at any time. For this purpose, the date of the last update is provided below.
Last update: January 20, 2024.