REFIT ITALY and Bullish surl

Bullish surl (hereinafter "Refit") is concerned with the protection of your personal data and respect for your privacy.

Here's how we do it:

Our duty and your privacy:

This information concerns you if you are already a customer of ours, if you are registered on our site, if you have subscribed to our newsletter or if you are visiting our website.

INDEX:

- Who we are

- Our responsibility

- Your commitment

- When and how we collect your personal data

- The types of data we collect

- Why we collect your data

- Use of the site and management of services

- Customer support

- Marketing

- Profiling

- What do we mean by legal basis

- How we treat your data

- Your choices and your rights

- Where your data is stored

- How long will we keep your data

- Third parties who may process your data

Who we are:

In the management of your data relating to the registration on the site and the sale of products, the data controller is Bullish surl, CF / VAT number 04134750753, with registered office in Via Piave, 22A \ B, 73046 Matino (LE).

Our responsibility:

If you are already a customer, you are registered or you are simply visiting the website www.refititaly.it, or you have subscribed to our newsletter, we inform you that your data will be legitimately processed according to our decisions regarding the methods and purposes of the processing itself. .

Your commitment:

We only ask you to read this information carefully to be fully informed on how we process your personal data.

When and how we collect your personal data:

As soon as you interact with www.refititaly.it, we start collecting data. Their collection can take place either through your specific communication, or automatically while using the website.

Here's how the collection takes place:

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The types of data we collect:

Contact details

Your first and last name, shipping and billing address, telephone number, e-mail address.

Identification data

Your IP address, login information, browser type and version, time zone, plug-in types, geolocation information about where you might be, operating system and relative versions, etc.

Data relating to the use of www.refititaly.it

Your navigation path within the site www.refititaly.it (Clickstream analysis), your views of products and services, page loading and response times, download errors, navigation duration, behavior and other actions, etc. ..

And what about sensitive data?

We do not collect any type of sensitive data that may concern you (i.e. personal data that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data relating to health or sexual life or sexual orientation).

Why do we collect your data?

We can process your data only for certain reasons and, in any case, always in the presence of a legal basis that allows us to do so. This is why we process your data:

Use of the site and management of services:

The data is processed to allow registration on the Site, access and execution of the services reserved for registered users and the possible sending through the Site of a purchase order for the products available on the Site with the consequent conclusion with Refit of the relative sales contract, including any administrative and accounting formalities. In this case the legal basis is the contract and the legitimate interest.

Customer support

Notification of changes to our services, customer support via live chat, telephone or email, including the correction of any bugs. In this case, the legal basis is the contract.

Marketing

The data is processed for sending advertising material and newsletters, to carry out commercial information activities, by telephone, SMS, e-mail, as well as with traditional methods (eg sending catalogs by paper mail), on promotional and commercial initiatives. of Refit, for carrying out market research and surveys for the detection of customer satisfaction.In this case, the legal basis is your consent.

Profiling

For the sole purpose of offering you offers as far as possible in line with your interests, we will perform some analyzes on aggregate data without carrying out any profiling activity on your specific habits. In this case, the legal basis is the legitimate interest.

In any case, there is no automated decision-making process that concerns you.

What do we mean by legal basis:

Consent

It is the authorization to process your personal data for a specific purpose.

You can change your mind whenever you want!

You can revoke your consent at any time by sending us an e-mail to the following addresses: refit.italy@gmail.com or by clicking on the opt-out button.

If you decide to withdraw your consent and there are no other reasons that authorize us to process your personal data, we will stop processing. Instead, if another legal basis authorizes us, we will continue the treatment always respecting your rights.

The contract

The processing of your data is necessary for the preliminary information to the purchase and for the execution of the related contract.

The legitimate interest

The processing of your data is possible on the basis of our legitimate interests or those of third parties, as long as they do not prevail over your rights and freedoms. Legitimate interests may concern:

• collecting information from your behavior on our website and / or applications;

• deliver, develop and improve our services;

• allow us to improve, customize or modify our services and offers;

• verify the effectiveness of our marketing campaigns;

• improve data protection.

How we treat your data:

The data processing takes place mainly electronically, with the exception of the shipping activities of the products which can also be carried out with manual tools.

Your choices and rights:

Your choices

You can decide not to communicate your data to us

In this case, you can continue browsing our site, but we will not be able to provide you with any services without your personal data.

You can ask us not to use your data for marketing reasons

Before starting the processing, we will inform you about our possible intention to use your data for marketing reasons and (if applicable) for the involvement of third parties. You can withdraw your consent to receive promotional messages by clicking on the appropriate link that you will find in all our communications or by sending us an e-mail to the following addresses: refit.italy@gmail.com.

Your rights

You can always exercise your rights by sending us an email to the following addresses: refit.italy@gmail.com.

You have the right to access information about you

This entails the right to ask us for further information regarding:

• the categories of data we process;

• the purposes of the processing;

• the categories of any recipients to whom the data may be disclosed;

• the data retention period or, failing that, the criteria for determining this period;

• the other rights regarding the use of your data.

We will provide you with the information within one month of your request, unless this affects the rights and freedoms of other parties (for example the privacy of another person or intellectual property rights) or if there are legal obligations that prevent it. We will notify you if we are unable to fulfill your request for these reasons.

You have the right to have your data corrected if it is inaccurate or out of date

You have the right to obtain the cancellation of your personal data (right to be forgotten)

You can, at any time, ask us to delete your personal data in our possession, in the event that the storage of your personal data is no longer necessary for the purposes of the processing.

You have the right to transfer your data to another operator (data portability)

We will provide you with a copy of your data in an interoperable format in case you want to transfer it to another operator. In the event of your request and if technically possible, we will directly transfer the data to the new operator. We will not proceed with any transfer, in the event that the portability of your data also involves the dissemination of the personal data of other individuals.

You have the right to object to the processing of your personal data by us

You can always contact the Supervisory Authority to propose your possible complaints. Before doing that, feel free to contact us! We will be happy to resolve any problems relating to the processing of your personal data.

You have the right to object to the use of your data by automated decisions, including profiling

We may use your data to identify information that is potentially relevant to you (for example, to send you personalized emails based on your preferences we have collected). Otherwise, we will only use your data to provide you with our services.

However, we must remind you that:

• You disclose your data to us at your own risk. We try our best but, unfortunately, there is currently no 100% secure data transmission.

• You must always keep your username and password safe, you are the only one who knows them.

• If you have the perception that you have suffered a breach of your data, please contact us immediately at refit.italy@gmail.com.

Where is your data stored?

Your data is processed within the European Union.

From the moment you communicate your personal data to us, you also consent to their transfer, storage and processing by us.

In case we need to transfer and / or store your data outside the EU, you will be adequately informed about this. Even in this case, we will take all appropriate measures to ensure maximum protection.

How long will we keep your data?

We will cease the active processing of your data within 12 months from the last use of the service or from the closure of your account, unless any legal obligations (eg sales invoices) require us to keep your data for a longer time. promotional activities aimed at you, which you can always ask us to stop, we will keep your data for a maximum period of 24 months from your subscription to the service.

Third parties who may process your data:

To carry out our online business we need to use third parties to host applications, communicate with customers, manage e-mails, etc. We assure you that this collaboration takes place with the best subjects on the market that provide this type of services. We only share your data with them when it is necessary to ensure the maximum functionality of our services and in accordance with the security measures and good practices described in this Privacy Policy.

To offer you ScalaPay payment methods, we may at checkout transmit your personal data in the form of contact and order details to ScalaPay, so that ScalaPay can assess whether you are suitable for their payment methods and adapt these payment methods. to your needs. Your transferred personal data are processed in line with ScalaPay's Privacy Policy.

To offer you Paypal payment methods, we may at checkout transmit your personal data in the form of contact and order details to Paypal, so that Paypal can evaluate if you are suitable for their payment methods and adapt these payment methods to your needs. Your transferred personal data is processed in line with Paypal's Privacy Policy.

For more information contact us at the following addresses: refit.italy@gmail.com.

Thank you!

Thank you for reading this information that we have tried to make simple, clear and transparent. In any case, we always try to improve: if you have any suggestions, please write to us at the following addresses: refit.italy@gmail.com.

This information may change in the future: any changes will be communicated to you by e-mail, so that you can have the widest control of your data.