SCRIBO – Scrittura Bolognese S.r.l., with its registered offices in Italy, 40122 Bologna, Via San Lorenzo 5 – Tax Code and VAT n° 03569341203 and operative offices in Italy, 40123 Bologna, Via Frassinago 18/2 (hereinafter “Scribo”) it’s an Italian company with limited responsibility who manufactures and sells writing products.
This Privacy Policy, which is written in compliance with the Regulation (EU) 2016/679 (General Data Protection Regulation – “GDPR”) and the Italian Legislative Decree 2003/196 as modified by the Italian Legislative Decree 2018/101 (Privacy Code), describes the process of the personal data made by Scribo through the website which include a link to this Privacy Policy, as below: http://scritturabolognese.com/ecommerce/en/privacy-policy-web/
This Privacy Policy also applies to Scribo’s marketing and commercial initiatives.
This Privacy Policy may be amended from time to time, so please check it regularly to keep yourself informed on updates.
In this page you will find the following information:
1. WHAT KIND OF PERSONAL DATA RELATED TO ME DOES SCRIBO PROCESS AS DATA PROCESSOR?
2. FOR WHAT PURPOSE AND ON WHAT LEGAL BASES AND HOW LONG DOES SCRIBO USE AND COLLECT MY PERSONAL DATA?
3. WITH WHO SCRIBO SHARES MY PERSONAL DATA?
4. ARE MY PERSONAL DATA TRANSFERRED ABROAD?
5. ARE MY PERSONAL DATA SECURE, AND WHERE THEY WILL BE STORED?
6. YOUR RIGHTS AS A DATA SUBJECT
7. DETAILS CONTACT
1. WHAT KIND OF PERSONAL DATA RELATED TO ME DOES SCRIBO PROCESS AS DATA PROCESSOR?
Customer care (via telephone or e-mail)
When you contact us for asking our services, assistance or for any other requests, Scribo collects information to identify you, as your name, your company’s name, your e-mail address, your address, your telephone number. Some of this information are necessary, other are optional.
Scribo website
We collect information about how you browse or place orders on our website, including the information that your browser or your device send to our server when you visit the website. To collect this information, Scribo may use cookies and similar technologies. You can find more information about cookies in our Cookie Policy.
Website newsletter
On our website you have the possibility to sign you up for the newsletter in order to receive updates about our products and our handwriting and calligraphy courses. In order to send to you the e-mail we need some information such as: your name and surname and your e-mail address.
2. FOR WHAT PURPOSE AND ON WHAT LEGAL BASES AND FOR HOW MUCH TIME DOES SCRIBO USE AND COLLECT MY PERSONAL DATA?
In most cases, Scribo will use your personal data on the following legal basis:
Consent: to send you marketing communication (newsletter) via electronic means, such as e-mail, text messages or personal messages.
Legitimate interests: where processing is necessary for Scribo’s legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests, and Scribo may verify that a favourable balance of interest test has been carried out (i.e. for the defence of our rights in court proceeding).
Performance of a contract: when processing is necessary to execute a contract in which you are party or in order to take steps at your request prior to entering into a contract.
Legal obligation: when processing is necessary for compliance with a legal obligation to which Scribo is subject, such as a tax or other regulatory obligations and requirements.
We only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, Scribo takes into account the amount, nature, and nature of the personal data, the potential risk due to unauthorised use or disclosure of your personal data, the purposes for which Scribo processes your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
The table below includes a general overview of relevant purposes for which Scribo processes your data in the context of various activities, the relevant legal basis and the retention period.
| Purpose/Activity | Data Category | Legal basis | Retention period |
|
Client registration To register you as a client |
(1) Identity data
(2) Contact data |
Performance of a contract | 10 years from the end of the contract. |
|
Supplier registration To register you as a supplier |
(1) Identity data
(2) Contact data |
Performance of a contract | 10 years from the end of the contract. |
|
Processing orders and managing payment To process and deliver your orders (online and offline) including: (1) Manage payments, fees and charges (2) Collect and recover money owed to us |
(1) Identity data
(2) Contact data (3) Financial data (4) Transaction data |
(1) Performance of a contract
(2) Legitimate interest to collect and recover the debts and the amounts due. |
10 years from the end of the contract
From the moment which the debt or the amount due is received. |
|
Regular communications (not marketing related) To manage our relationship with you which will include notifying you about changes to our Terms and Conditions |
(1) Identity data
(2) Contact data
|
(1) Performance of a contract
(2) Legal obligation, including the requirement to notify you about changes |
10 years from the end of the contract
|
|
Marketing communications (newsletter) To send you our newsletter and commercial information regarding our new products or services. |
(1) Identity data
(2) Contact data
|
Consent | Consent revocation |
3. WITH WHO SCRIBO SHARES MY PERSONAL DATA?
Scribo works with different commercial partners that support our business. These companies supply us some services such as issuing of receipt for the electronic invoicing, payment services, hosting services and web agency.
Sometimes these companies have access to some of your personal data in order to supply their services. They are not allowed to use your personal data for their own purpose, and they are nominated as data controller or data processor, where exist a specific agreement for the process of your personal data or standard clauses.
4. ARE MY PERSONAL DATA TRANSFERRED ABROAD?
Scribo as data controller may share your identification data, your contact data with suppliers of services like for example services for the delivery of the newsletter or shipping companies. This transfer of data may be carried out also in country outside the European Economic Area (EEA).
Whenever Scribo transfers your personal data outside of EEA, Scribo contractually ensures a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
a. we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see: European Commission: Adequacy of the protection of personal data in non-EU countries.
b. where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see: European Commission: Model contracts for the transfer of personal data to third countries.
c. where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see: European Commission: EU-US Privacy Shield.
Please contact us if you need more information regarding the specific mechanism that we used by us when transferring your personal data outside of EEA.
5. ARE MY PERSONAL DATA SECURE, AND WHERE THEY WILL BE STORED?
We understand that the security of your personal data is important. We provide reasonable administrative, technical, and physical security controls to protect your personal information. All information you provide us is stored on secure servers. Unfortunately, the transmission of information via internet is not completely secure. Although we will do our best to protect your personal data, we cannot warrant or guarantee the security of your data transmitted to us; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. In case you would like to have more information on the specific security measures taken in order to save your data than please contact us.
Scribo puts in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on Scribo’s instructions, and they are subject to a duty of confidentiality.
Finally, we have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Your personal information and data files are stored on Scribo’s servers and the servers of companies we engaged to provide services to us. Your personal information may be transferred across national borders because Scribo has servers located worldwide and the companies we engaged to support us are located in different countries around the world (for example United States). As set forth in paragraph 4 below the data that we collect from you may therefore be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for Scribo or for one of Scribo’s suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order and the provision of support services.
6. YOUR RIGHTS AS A DATA SUBJECT
YOUR RIGHT TO ACCESS
You have the right to access your personal data, including requesting information on whether Scribo processes your data, which data are processed, and you may also request a copy of the data that you or a third person provided to Scribo and which data is being processed by Scribo.
If you request that Scribo confirms whether or not Scribo processes your personal data, then you have the right that obliges Scribo to confirm that it processes your personal data or does not process your personal data.
Your right to obtain confirmation whether Scribo processes (or does not process) your personal data
1. does not include data that is anonymous;
2. includes the personal data that concerns you;
3. does not include personal data that does not concern you; and
4. includes pseudonymous data that can be clearly linked to you.
Scribo shall give you access to your personal data if
1. you request Scribo to confirm whether or not it processes your personal data, and
2. Scribo confirms that it processes your personal data, and
3. you request access to your personal data.
Scribo shall give you a copy of your personal data if:
1. you request Scribo to confirm whether or not it processes your personal data, and
2. Scribo confirms that it processes your personal data, and
3. you request a copy to your personal data.
Upon your request Scribo will give you access to the following information:
1. the purposes of the processing;
2. the categories of personal data concerned;
3. the recipients or categories of recipient to whom the personal data have been or will be communicated, including the disclosed recipients in third countries or international organisations;
4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
5. the existence of your right to request from Scribo rectification or erasure of your personal data or restriction on processing of personal data concerning you or to object to such processing;
6. the right to lodge a complaint with a supervisory authority;
7. where your data are not collected from you, any available information as to their sources;
8. the existence of automated decision-making processes, included the profiling and relevant information about that; the meaning and the consequences of this process on you.
YOUR RIGHT TO RECTIFICATION
You have the right to the correction of your personal data without undue delay. This enables you to ask that any incomplete or inaccurate data we hold about you to be corrected.
Your right to obtain rectification of your data that are inaccurate:
1. does not include data that is anonymous;
2. includes the personal data that concerns you;
3. does not include personal data that does not concern you; and
4. includes pseudonymous data that can be clearly linked to you.
Scribo shall rectify your personal data if:
1. Scribo processes your personal data, and
2. the personal data at hand is inaccurate, and
3. you request the rectification of your personal data.
Scribo shall complete your personal data if:
1. Scribo processes your personal data, and
2. the personal data at hand is incomplete, and
3. you request the completion of your personal data and, if necessary, you provide supplementary information for completion.
Scribo may verify any and all data provided to it. Scribo shall take into account available technology and the cost of implementation, take reasonable steps, including technical measures, to communicate the rectification of your personal data to recipients of such personal data (if any). However, Scribo shall not communicate the rectification of personal data to recipients if the communication to such recipients is either impossible or involves a disproportionate effort.
YOUR RIGHT TO ERASURE (or “right to be forgotten”)
Subject to certain conditions and in certain cases, you have the right to the erasure of your personal data. This means that you may request that we delete your personal data that we may have processed unlawfully or where the use of your data is no longer needed for a purpose. Please keep in mind that Scribo may not be able to meet your request for specific legal reasons that will be referred to you, if applicable.
Scribo shall erase your personal data without undue delay if:
1. Scribo processes your personal data, and
2. you request to obtain the erasure of your personal data, and
3. the personal data is no longer necessary to the purposes for which Scribo collected it;
Scribo shall erase your personal data without undue delay if:
1. Scribo processes your personal data based on your consent, and
2. you request to obtain the erasure of your personal data, and
3. you withdraw your consent on which the processing of your data is based, and
4. there is no alternative legal basis for the processing of your data any further.
Scribo shall erase your personal data without undue delay if:
1. you request to obtain the erasure of your personal data, and
2. the processing by Scribo of such data is unlawful, or
3. if the erasure is required under applicable law, or
4. your data is collected in relation to the offer of an information society service.
Scribo shall, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to communicate the erasure of your personal data to recipients of such personal data (if any). However, Scribo shall not communicate the erasure of personal data to the recipients if the communication to such recipients is either impossible or involves a disproportionate effort.
Please note that there are certain cases when you may not request erasure of your data. The reasons will be communicated to you if your request for erasure cannot be completed.
YOUR RIGHT TO THE RESTRICTION OF PROCESSING
You may also request the restriction of the processing of your personal data. For instance, you may request that we suspend the processing of your personal data where our use of the data is unlawful, but you do not want us to delete it.
Your right to request the restriction of the processing of your personal data
1. does not include data that is anonymous;
2. includes the personal data that concerns you;
3. does not include personal data that does not concern you; and
4. includes pseudonymous data that can be clearly linked to you.
Scribo shall restrict the processing of your personal data for a period, if you request to obtain such restriction of the processing of your personal data to verify and/or challenge the accuracy of such data.
Scribo shall restrict the processing of your personal data upon your request to obtain such restriction due to unlawful data processing.
Scribo shall restrict the processing of your personal data if
1. you request to obtain the restriction of the processing of such data, and
2. Scribo does not need such data for the purposes of its processing, and
3. you require your data for establishment, exercise or defence against a legal claim.
Scribo shall restrict the processing of your personal data if
1. you object to the processing of your personal data that is necessary for the purposes of the legitimate interests that Scribo pursues, and
2. you wait to verify that the legitimate ground of Scribo’s processing of your personal data does not override your objection.
Scribo shall, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to communicate the restriction of processing of your personal data to recipients of such personal data (if any). However, Scribo shall not communicate such restriction to recipients if the communication to such recipients is either impossible or involves a disproportionate effort.
If Scribo restricts its processing of your personal data, then it may
1. store such personal data,
2. process such personal data on the basis of your consent,
3. process the personal data for establishing, exercising or defending a legal claim, or for protecting the rights of another person.
In case you have obtained restriction of processing as per the above than you shall be informed by Scribo before the restriction of processing is lifted.
YOUR RIGHT TO DATA PORTABILITY
Where the processing of your data is either based on your consent or is necessary for the performance of a contract, and the processing is carried out by automated means, then you may request the provision of your personal data that you have provided to us in a standard format, and you may also request such data be transferred to another entity.
Without prejudice to your rights above, you have the right to receive the personal data concerning you, which you provided to Scribo, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance (where technically feasible) from Scribo, where the processing is based on your consent, or is necessary for the performance of a contract, and the processing is carried out by automated means.
Your right to data portability:
1. does not include data that is anonymous;
2. includes the personal data that concerns you;
3. does not include personal data that does not concern you; and
4 . includes pseudonymous data that can be clearly linked to you.
YOUR RIGHT TO OBJECT
Importantly, when we process your data on the basis of our legitimate interests, as specified in the table below, you may object to such processing and request any of those activities be stopped.
YOUR RIGHT TO WITHDRAW CONSENT
Also, you have the right to withdraw your consent at any time where we rely on your consent for processing your data. You may do this at any time by contacting us at info@scritturabolognese.com. Remember that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal and that in some cases we may need time to process request.
Scribo shall, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to communicate your objection/withdrawal of consent to recipients of such personal data (if any). However, Scribo shall not communicate such restriction to recipients if the communication to such recipients is either impossible or involves a disproportionate effort.
YOUR RIGHT TO LODGE A COMPLAINT
Without prejudice to any other administrative or judicial remedy that you may have (such as the right to claim compensation for damages suffered as a result of Scribo’s breach of the GDPR), you have the right to lodge a complaint with the Italian Data Protection Authority, supervisory authority, or another data protection supervisory authority in the Member State of your habitual residence, place of work or place of the alleged infringement if you find that the processing of personal data relating to you infringes the GDPR.
The contact details are as follows:
Italian Data Protection Authority
Piazza Venezia 11 – 00187 Roma;
Phone: +39-06-696771;
e-mail: urp@gpdp.it;
In any case, Scribo would highly appreciate the chance to deal with your concerns before you approach the regulatory authority above, so please contact us in the first instance if you have any problems.
RESTRICTION ON THE ABOVE RIGHTS
Please be advised that, based on GDPR, Member States are allowed to restrict by way of a legislative measure the scope of the rights you may have as per the above. In case such a restriction is applicable in your respect, Scribo will advise you accordingly when you contact us to exercise any of your above rights.
7. YOUR RIGHTS AS A DATA SUBJECT
In order to exercise the above-mentioned rights, please contact us. To this purpose please use the following contact details:
Scribo – Scrittura Bolognese S.r.l.
Registered Office: Via San Lorenzo 5, 40122 Bologna (BO), Italy
Headquarter: Via Frassinago 18/2, 40123 Bologna (BO), Italy
Phone: +39 0510474806
E-mail: info@scritturabolognese.com
VERIFICATION OF YOUR IDENTITY
Scribo may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. Scribo may also contact you to ask you for further information in relation to your request to speed up our response.
WHO CAN I CONTACT IF I HAVE ANY DOUBT?
If you have any question or complaint related to Privacy matter, please write an e-mail to info@scritturabolognese.com.