Kivu Limited registered office Primrose Cottage, Fleet Hill,Finchampstead
Wokingham RG40 4LH UK, email firstname.lastname@example.org (hereinafter referred to as “Company” or “Data Controller” or “Kivu”), in the capacity as the Data Controller, collects and processes the personal data provided by users (hereinafter referred to as “Users”) on the website [*] (hereinafter referred to as “Website” ), in accordance and with the purposes stated in this disclosure, conforming to the European Regulation on the protection of personal data 679/2916 (hereinafter referred to as “Privacy Regulation” and Legislative Decree 196/2003, as previously modified and/or integrated from Legislative Decree 101/2018 (hereinafter referred to as the “Privacy Code”).
The Company processes personal data provided spontaneously by Users during their interactions with the Website and in particular:
- Personal contact information provided by the User in order to register on the Website, via creation of a personal account
- Data provided by the User at the time of use of the service or Website functions
- Data provided by the User contextually, upon requesting information or assistance
- Data related to purchases made on the Website
- Navigation data related to the use of the services offered by the Website, collected via cookies conforming to the cookies disclosure available at this link.
(hereinafter, collectively referred to as “Data”).
Data relating to health and categories of personal data, according to Article 9 of the Privacy Regulation, are not processed. Data of minors will be processed as outlined in the ensuing paragraph 8.
The information indicated above will only be processed when necessary in order to obtain the result outlined in paragraph 3 of the current disclosure.
The User’s data are processed digitally and/or in print and are protected by adequate and suitable security measures to guarantee confidentiality and security. In particular, the Company applies appropriate organizational and technical measures to protect the Data in its possession against loss and theft, as well as the use, disclosure, or unauthorized modification of those mentioned above.
- Allow the User to undertake the activities stated in the Website’s Conditions of Use and Sales, including purchases made on the Website
- Allow the User to exercise the Website’s services and functions, including activation of the guarantee on products purchased
- Allow the User to submit information and assistance requests
- Comply with legal obligations and regulations
(hereinafter, collectively referred to as “Contractual Purposes”)
- Subject to the User’s consent, send newsletters and commercial communications via traditional and distance communication methods including; email, SMS, MMS, social networks, instant messages, mobile applications, banners, fax, post and telephone for the promotion and/or sale of products and/or commercial services offered by the Company
(hereinafter, collectively referred to as “Marketing Purposes”)
- Subject to the User’s consent, analyze User preferences, characteristics and consumer habits with the purpose of sending newsletters and the commercial communications mentioned above, to offer personalized services
(hereinafter, collectively referred to as “Profiling Purposes”)
- Undertake functional activities relating to company divestiture and branch transfer, acquisitions, fusions/mergers or other transformations and for the execution of such operations
(hereinafter, collectively referred to as “Legitimate Business Interest Purposes”)
Processing of the Data for Contractual Purposes is compulsory as it is required to allow the User to register on the Website and subsequently use the services offered, including the purchase of products. Where the User does not wish to communicate his or her Data for these purposes, the use of the services and purchases via the Website, will not be possible.
The Marketing Purposes and Profiling Purposes disclosures are optional and subject to the User’s prior consent. Where consent is not given, the Company is unable to notify the User of product and service updates and it is not possible to send newsletters and advertising material in line with the interests and preferences of the aforementioned. Authorized consent can be revoked according to the information stated in paragraph 8. Processing for Legitimate Business Interest Purposes is implemented in accordance with Article 6, letter f) of the Privacy Regulation, in pursuit of the Company’s and counterparties’ legitimate interest, to undertake financial operations as well as and being adequately balanced in the User’s interest as the disclosure occurs when strictly necessary in the execution of the services outlined.
Communication of Data
For purposes stated in paragraph 3, the Company can communicate the User’s Data where strictly necessary, in relation to each type of disclosure, both to internal subjects, and within the confines outlined in paragraph 6, and outside of the European Union, and in particular to:
- company collaborators/employees/suppliers with related tasks or contractual obligations, inherent in the commercial relationship with Users;
- third-party assistance and consultation service providers to the Company in reference to sector-related activities, by way of example; technological, accounting, administrative, legal, insurance, IT;
- Post Offices, mailers and couriers for the delivery of products purchased by the User and/or other material relevant to the undertaking of the Company’s services;
- institutional banks for the management of revenue and payments deriving from the execution of the contracts with the User;
- competent authorities or other subjects with recognized and authorized access to the Data, according to law and regulation.
The User’s personal information will not be disclosed.
Transfer of Data abroad
The User’s Data can be freely transferred even beyond the European Union and, in particular, the UK. Data transfer to countries located outside the European Union will occur, and in each case, in accordance with the relevant and appropriate guarantees relating to the purpose of the transfer itself, according to the applicable regulations in Articles 45 and 46 of the Privacy Regulation. In any case, the User will have the right to obtain a copy of the implemented security measures upon explicit request to the Data Controller, whose location is stated in paragraph 10 of the current disclosure.
Minors / Under 18s
The Website is not suitable for subjects under the age of 18. Kivu does not collect nor knowingly process personal information belonging to any under 18s who may use the Website.
The User’s Data are stored for the time necessary to determine the purposes to which the data was collected, as indicated in the current disclosure and, in any case, relating to:
- Contractual Purposes: the Data are retained for a period equal to the duration of the contract (including any renewals) and subsequently ten years following termination, resolution or withdrawal of the agreement; while considering, cases where preservation for an ulterior period is requested due to litigation, request from relevant authorities or in accordance with the applicable regulations;
- Marketing Purposes: the Data are kept for 24 months post-collection;
- Profiling Purposes: the Data are kept for 12 months post-collection;
- Legitimate Business Interests: the Data are stored for ten years of post collection.
Upon expiration of the aforementioned time periods, the User’s data will be deleted, anonymized and/or aggregated.
The User’s Rights
The User, may exercise the following rights in any moment and free of charge: a) obtain the confirmation of the existence or non-existence of Data concerning him/her and receive copies; (b) find out where the Data came from, the purposes for which it was processed, and the methods used, as well as the logic behind processing carried out with electronic tools; (c) request that the Data be updated, corrected or – if he/she wishes to – completed; (d) obtain the cancellation, anonymizing or blocking of data processed in violation of the law, as well as object to the processing on legitimate grounds; (e) withdraw consent to the processing of his/her Data, without prejudice to the legality of the processing which occurred before consent was withdrawn; (f) request that the Company limit the extent to which the Data is processed; (g) object to his/her Data being processed for Legitimate Interest Purposes; (h) request that his/her Data be deleted, without undue delay, and (i) obtain the portability of his/her Data.
It is understood that the User shall have the right to file a claim to the Supervisory Authority where requirements are met.
Should the User have doubts, observations or complaints regarding the collection or processing of the Data or should they wish to exercise one of their rights listed in paragraph 9 previously, they may directly contact the Data Controller via the Contact section on the Website or send an email to the following address email@example.com.
Modifications and updates