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Privacy Policy

This privacy policy is aimed at describing the processing of personal data (“Data”) carried out by TO.TEM S.r.l. (“Company”) through this website (“Website”).

1. WHICH PERSONAL DATA WE PROCESS AND FOR WHAT PURPOSE
a) Browsing data, such as IP address, location, information on the pages visited by the user and the browsing time on each page; these Data are necessary to ensure the functioning of the Website and are not collected to be associated with specific users, but through them or through other information collected, user identification is still possible.
b) Name, surname, tax code, address, telephone number, e-mail address, which will be processed in order to execute the sales contract for the products purchased through the Website.
c) Name, surname and e-mail address, which will be processed, on the basis of the consent of the data subject, to send advertising material, information and updates on the TO.TEM project, including subscription to a newsletter; consent may be withdrawn at any time through the link at the bottom of each email.
d) Cookies, which are small text strings that can be sent and recorded on the user’s computer by the websites visited, to then be retransmitted to the same websites when the user visits them again; for more details, please consult the Cookie policy.

2. METHODS OF PROCESSING
The Data will be processed by automated or electronic means, in compliance with current regulations regarding the processing of personal data.

3. COMMUNICATION OF DATA TO THIRD PARTIES
The Data may be communicated to third parties operating on behalf of the Company by virtue of a contractual relationship, appointed as data processors where applicable.
The Data may also be sent to third parties, if necessary, to comply with legal obligations, orders from public authorities or to allow the Company to exercise its rights before judicial authorities.

4. DATA RETENTION
The Data indicated in section 1 lett. a) will be kept for 1 year following their collection.
The Data indicated in section 1 letter b) will be kept for 10 years following the conclusion of the sales contract.
The Data indicated in section 1 letter. c) will be kept until the withdrawn of consent and will be then immediately deleted.
The Data is periodically checked and updated with the help of the data subject.
As for the retention period of Cookies, please refer to the Cookie Policy.

5. DATA CONTROLLER AND DATA PROTECTION OFFICER
The data controller is TO.TEM S.r.l., with its registered office in Corso Castelfidardo 36, 10129 Torino. Data subjects can contact our DPO at the following email address: dpo@punchtorino.com

6. DATA SUBJECTS’ RIGHTS
Data subjects can exercise the following rights:
• right to access means the right to obtain from the Company whether your Data are being processed and, where applicable, have access to them;
• right to rectification and right to erasure means the right to obtain the rectification of inaccurate and/or incomplete Data, as well as the erasure of Data when the request is legitimate;
• right to restriction of processing means the right to request suspension of the processing when the request is legitimate;
• right to data portability means the right to obtain Data in a structured format, ordinary used and readable, as well as the right to transfer Data to other controllers;
• right to object means the right to object to the processing of Data when the request is legitimate, including when the Data are processed for marketing or profiling, if applicable;
• right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• right to lodge a complaint with a supervisory authority in case of unlawful processing of Data.
Data subjects can exercise the abovementioned rights by writing to the e-mail privacy@totemev.com.

7. SOCIAL MEDIA PAGES OF TO.TEM
The Company has created some pages related to the TO.TEM project on various Social Media (Facebook, Instagram, Youtube, etc.).
When visiting these pages, Social Media collect user Data as data controllers. Further information on the processing of Data by the various Social Media are available on their respective privacy policies.
The Company only has access to information shared by the user as “public” through the interaction with Social Media pages. The Company can also view the Data that users of Social Media pages provide by sending public or private messages; such Data may be used by the Company to provide the information requested by the user.
Social Media will send anonymous statistics to the Company on the use of the pages, containing information such as the number of followers, the number of interactions on a post or advertisement or the demographics of users, which will be used to improve the online content of TO.TEM and to better respond to users’ interests.

8. AMENDMENTS AND UPDATES
This Privacy Policy entered into force on November 19, 2021.
The Company reserves the right to amend or updates the Privacy Policy. Any update will be published on this website and it will be effective upon posting.

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