INFORMATION ON THE PROCESSING OF PERSONAL DATA pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) by mrmoris.com

Preface

This information is provided for the website ‘mrmoris.com’ (Site).

The Data Controller is Mr. Moris SRL, with registered office in Via di Pozzo Pantaleo 26/28/30 – 00146 Rome, VAT number 13821101006 (Data Controller or Company).

Data processor:

– Mr Moris S.r.l., a company incorporated under the laws of Italy, with registered office at Via di Pozzo Pantaleo 26/28/30 – 00146 Rome, Italy, email: online@mrmoris.com Tax Code and VAT No. 16228131005 REA No. RM – 1643082, registered with the Companies’ Register of Rome, as owner of the domain www.mrmoris.com.

Purchases on Site

Subject to your prior consent, your personal data will be processed to enable you to make purchases on the Site.

Registration

The information and data requested in the event of registration will be used to allow you both to access the reserved area of the Site and to use the online services offered by the Company to registered users.

Marketing

Subject to your consent, the Company may process the personal data you provide in order to send you advertising material and/or newsletters relating to its own products or those of third parties.

Soft spamming

The Company may use, for the purpose of the direct sale of products offered for sale through the Site, the e-mail and/or telephone number provided by you in the context of a purchase on the Site, even without your consent and through third-party services (e.g. WhatsAPP), provided that it is for a product similar to the one that was the subject of the previous sale (so-called soft spamming). You may however refuse this processing at any time by communicating your opposition to the Company.

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In compliance with the GDPR, we hereby inform you that the Company will process your personal data under the following conditions.

Article 1. Purpose and legal basis of processing. Compulsory or optional provision of data. Consequences of refusal to process.

Personal data are processed for the following purposes:

1. to allow registration on the Site and access to the services reserved for registered users, as well as to allow compliance with obligations arising from the law or regulations in force, in particular, in the areas of administration, accounting, public security. The legal basis for the processing is the Company’s need to execute pre-contractual measures adopted at the request of the data subject or to fulfil a legal obligation;
2. in the case of placing an online purchase order, to enable the conclusion of the purchase contract and the proper execution of the transactions related to the same (and, where necessary under sector regulations, to fulfil tax obligations). The legal basis for the processing is the Company’s obligation to perform the contract with the data subject or to fulfil legal obligations;
3. limited to the e-mail addresses that you provide in the context of a purchase through the Site, to allow the direct offer by the Company of similar products (so-called soft spamming), provided that you do not object to such processing in the manner provided for in this policy. The legal basis of the processing is the legitimate interest of the Company in sending this type of communication. This legitimate interest can be considered equivalent to the interest of the person concerned in receiving ‘soft-spam’ communications;
4. subject to your consent, for sending newsletters and carrying out market surveys, also aimed at assessing the degree of user satisfaction, and sending advertising material relating to the Company’s products and/or those of third parties, by means of systems such as e-mail (marketing purposes). The legal basis of the processing is the consent of the person concerned;
5. if the chat service is operational, allow the activation of the service, through which the user can contact and be contacted by the Company, subject to your consent, during your navigation on the Site. The legal basis is the legitimate interest of the Company in carrying out this type of activity. This legitimate interest can be considered equivalent to the interested party’s interest in using the Site’s chat service;
6. to answer your questions via the customer care service. Providing this information is optional, but your refusal will make it impossible for the Company to answer your questions via this service. The legal basis for the processing is the legitimate interest of the Company in responding to your requests. This legitimate interest is equivalent to the user’s interest in receiving replies to communications sent to the Company;
7. to respond by e-mail, telephone to your requests. Providing the data is optional, but your refusal will make it impossible for the Company to respond to your requests. The legal basis for the processing is the legitimate interest of the Company in responding to your requests. This legitimate interest is equivalent to your interest in receiving a reply to communications sent to the Company.

The provision of data for the purposes referred to in points a) and b) is purely optional. However, since such processing is necessary in order to make a purchase on the Site, your refusal to provide such data will make it impossible to make such a purchase via the Site.

Consent to the processing of your data for marketing purposes is purely optional. Failure to consent will only entail the consequences described below.

Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to the Company’s products and/or those of third parties, and will also make it impossible for the Company to conduct market surveys, including those aimed at assessing the degree of user satisfaction, and to send you newsletters.

With the foregoing in mind, it is understood that the Company may nevertheless use your personal data for the sole purpose of properly fulfilling its obligations under applicable laws and its obligations arising from the contractual relationship between you and the Company.

If you have registered on the Site, you may in any case change your consent for the purposes described above at any time by accessing your personal page.

Please note that you may also object to the processing of your personal data via the link at the bottom of any promotional e-mail sent by the Company.

Payment card data

In order to make a payment using one of the payment cards offered on the Site, the user must enter the confidential data of the payment card directly on a page that will communicate via secure encryption protocol with the payment service provider (who will act as the autonomous data controller), without passing through the Company’s server, which will therefore not process this data in any way. The data will be acquired in encrypted format.

With reference to the payment card data, please note that the processing of your personal data is necessary to enable the conclusion of the online purchase contract with the Company. Failure to provide this data, therefore, will not allow you to complete the online purchase process.

PayPal

On the Site it is also possible to purchase via the PayPal payment tool. In this case, you will be redirected to a page outside the Site, where you will have to indicate the personal data requested by PayPal – which will act as autonomous data controller – to complete the purchase process. The personal data will not pass through the Site’s server, which, therefore, will not process such data in any way. The processing of your personal data is necessary to allow the conclusion of the online purchase contract with the Company. Failure to provide this data, therefore, will not allow you to complete the online purchase process.

Comnpay

On the Site it is also possible to purchase via the Comnpay payment tool. In this case, you will be directed to a page outside the Site, where you will have to indicate the personal data required by Comnpay – which will act as autonomous data controller – in order to complete the purchase process. The personal data will not pass through the Site’s server, which, therefore, will not process such data in any way. The processing of your personal data is necessary to allow the conclusion of the online purchase contract with the Company. Failure to provide this data, therefore, will not allow you to complete the online purchase process.

Special or judicial data

The company does not process special or judicial data.

Article 2. Methods of processing

The processing of your personal data will mainly be carried out with the aid of electronic or otherwise automated means, in the manner and with the tools suitable to guarantee their security and confidentiality in accordance with the GDPR.

The information acquired and the manner in which it is processed will be relevant and not excessive in relation to the type of services rendered. The data will also be managed and protected in environments whose access is under constant control.

Article 3. Communication and disclosure of data

Your data may be disclosed:

• to all those entities (including public authorities) that have access to personal data by virtue of regulatory or administrative measures
• companies or third parties in charge of printing, enveloping, shipping and/or delivery and/or collection services for products purchased through the Site
• to post offices, couriers or forwarding agents entrusted with the delivery of products purchased through the Site
• banking institutions and companies operating national or international payment circuits through which online payments are made for products purchased through the Site
• companies, consultants or professionals that may be entrusted with the installation, maintenance, updating and, in general, the management of the Company’s hardware and software or which the Company uses for the provision of its services
• to external companies in charge of sending advertising communications on behalf of the Company
• the company in charge of carrying out customer care activities
• to entities handling online payment transactions
• to all those public and/or private subjects, natural and/or legal persons (legal, administrative and tax consultancy firms, Judicial Offices, Chambers of Commerce, Chambers and Labour Offices, etc.), if the communication is necessary or functional for the correct fulfilment of the obligations deriving from the law.

The data concerning you will not be disseminated, except in anonymous and aggregate form, for statistical or research purposes.

Art. 4. Data controller

The Company, in its capacity as Data Controller, can be contacted at the contact details given in the epigraph.

Art. 5. Retention of personal data

The user’s data will only be stored for as long as is necessary to ensure the proper provision of the services offered and in any case within the time limits laid down by law or by the provisions of the Data Protection Authority.

In the event that the Website account is closed at the user’s initiative, the data in it will be retained for administrative purposes for a period not exceeding 90 days, without prejudice to any specific legal obligations on the retention of accounting documents or for public security purposes.

In any case, it is understood that personal data will be stored and processed for marketing purposes for the period of time permitted by law and by the requirements of the Personal Data Protection Authority. At the end of this period, the Company may ask the user to renew his/her consent to the processing of his/her data for such purposes or render the same anonymous and store them solely for statistical or historical purposes.

Article 6. Rights of the data subject

Pursuant to Article 13 of the Privacy Regulation, the Company informs you that you have the right to:

• request from the Company access to and rectification or erasure of your personal data or restriction of their processing or to object to their processing, as well as the right to data portability
• withdraw consent at any time without prejudice to the lawfulness of the processing based on the consent given prior to withdrawal
• file a complaint with a supervisory authority (e.g. the Data Protection Authority).

The above rights may be exercised by making a request to the Company at the above-mentioned contacts without formalities.

Art. 7. Modifications

The Company reserves the right to make changes to this policy at any time, giving appropriate publicity to users of the Site and ensuring in all cases adequate and similar protection of personal data. In order to view any changes, you are invited to consult this policy on a regular basis.