Dear User, this document's purpose is to provide you with all the necessary information regarding the processing of your personal data carried out in the context of the offer of products and services of Rolland Srl, as well as during the consultation and navigation of the www.oway.com site (the "Site").
Who is the Data Controller of your data?
Rolland S.r.l. (VAT No. 00820241206), with registered office in via Gaibara 9/4 BOLOGNA and administrative and operational headquarters in Granarolo dell'Emilia (BO) - loc. Cadriano, Via G. Di Vittorio n. 11 (the "Company" or "Rolland"): e-mail: privacy@oway.it ; telephone +39 051 767552.
What data will be processed?
We will process the following categories of personal data relating to you:
- Automatic browsing data: i.e. data that, when users browse, are automatically acquired, such as Internet Protocol (IP) addresses, domain names of the computers used to visit the Site, addresses in Uniform Resource Identifier (URI) notation of the requested resources, various details of the requests sent to the Site server, generic geographical position as indicated by the IP address and other parameters relating to the user's operating and IT system, the transmission of which is essential to the regular, proper operation of the Internet and the Site itself. This is information that is not collected to be associated with identified persons, but which by its very nature could, through processing and association with data held by third parties, allow it to be identified. For more information on the cookies used on the Site and on the purposes related to the processing of data obtained through these technologies, we invite users to read the Cookie Policy.
- Data provided voluntarily by the user: i.e. data such as first names, last names, telephone numbers, addresses, e-mails and any other information voluntarily provided to the Company by the user in the context of the purchase of its products, the compilation of the forms on the Site, sending paper correspondence or e-mails to references available on the Site or elsewhere, trade fairs and/or events organized by the Company or sending/delivering curriculum vitae.
- Data provided for the execution of the commercial contractual relationship: i.e. data such as first names, last names, tax code, addresses, e-mails, purchases made, as well as any further information necessary for the execution of the commercial contractual relationship with suppliers and customers, as well as consequent to the purchase of Company products, also through the appropriate e-commerce on the Site. We specify hereby that on the Site you can choose to make purchases as a "Guest" or as a "Registered User".
What are the purposes and legal bases for the processing of your data?
Your data will be processed to pursue following purposes:
PURPOSES Implement and improve the IT services of the Site and prevent commission of computer crimes
FURTHER INFORMATION The automatic navigation data may be used by the Company in order to ensure the proper correct functioning of the Site to implement and improve the browsing experience, to evaluate the ways in which users interact with the Site, as well as, where necessary, to detect and prosecute any perpetrators of offences committed against the Site and/or its users.
LEGAL BASIS The legitimate interest of Rolland in the proper functioning of the Site and in the prosecution of offences committed to the detriment of the Site itself or its users.
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PURPOSES Management of your profile as a "Registered User" of the Site and registration of the purchase history.
FURTHER INFORMATION If you decide to register in the appropriate section of the site, the processing of Your data, including username and password, will be used to identify you as a registered user. Your data will be entered into the Rolland customer management IT system and associated with the history of purchases made by you through the Site. The processing will be carried out to allow You to take advantage of a faster online ordering method and access the various features, products and services that the Site makes available to you as a Registered User, such as for example the storage of preferred shipping addresses, the verification of the status of orders in progress, the display of previously purchased products, the modification of personal data, etc. If you intend to cancel your Registered User account, You may do so by contacting our customer service.
LEGAL BASIS Execution of the contract for the supply of a service requested by you.
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PURPOSES Purchase of products and services, including on the Site
FURTHER INFORMATION In the context of the purchase of products, including on the Site, information necessary for the execution of the contract is required such as nationality, first name, last name, e-mail, address, telephone number, tax code.
The processing of the aforementioned data is required for:
- contacting you about any problems related to the execution of the contract and, in general, to offer you the assistance and support you need (e.g. shipping, invoicing, customer support, etc.);
- managing payment for products purchased, for example:
- delivering the products purchased at the address indicated by you.
LEGAL BASIS
- Execution of the contract to which you are a party in respect of everything related to the processing of data for the purposes of payment, the shipment of products, and, in general, for the correct fulfilment of the contract.
- Legitimate interest of Rolland in the prevention and prosecution of any fraud or scam.
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PURPOSES Processing of requests received by customer assistance
FURTHER INFORMATION You can write to the e-mail address support@oway.com to communicate with customer support. The personal information concerning you, which may be transmitted by you in requesting assistance, will be processed only to provide you with the support and assistance you need.
LEGAL BASIS
- Legitimate interestof Rolland to process user requests.
- Execution of the contract to which you are a party.
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PURPOSES Processing of your requests by means of filling in the "General information”, "For hairdressers”, "For Distributors” and "Work With Us" forms.
FURTHER INFORMATION In the "Contacts" section of the Site, there are a series of forms that you can fill out online to send us requests for information or collaboration. The data you have entered will be used to process your request, in particular:
- Form "General Information". You are requested to append the following data to your message: your first name and last name, the country from which you write, Your address. These data are needed to find your request for information and to verify the origin of the message.
- Form "For hairdressers". You are requested to append the following data to your message: first name and last name, e-mail address, telephone number, and your salon data (name, city, website). We would also like to ask for information on how you found out about Organic Way, and how long you have used Oway products. The data processing is for the purposes of evaluating and finding your request to become a Head SPA Organic Way / a Green Chemistry Salon / carry out a training course in Italy / abroad. To process your request, on this occasion your data may be transferred to the Distributor, an independent data controller, who deals with the marketing of the products in your relevant area. Based on your request, this Distributor may be located in a non-EU country which is not considered adequate by the European Commission and, therefore, that does not have adequate safeguards regarding the security of your personal data.
- Form "General Information". You are requested to append the following data to your message: your first name and last name, the country from which you write, Your address. These data are needed to find your request for information and to verify the origin of the message.
- Form "For Distributors". You are requested to append the following data to your message: first name and last name, your position in the company, e-mail address, telephone number, as well as information relating to the company (name, country, indications of other brands distributed, general info). We also ask for information on how you found out about Organic Way. The processing of the aforementioned data is for the purposes of evaluating and finding your request.
- Form "Work With Us". You are requested to append the following data to your message: first name and last name, e-mail address, telephone number, residential address. You can also attach your Curriculum Vitae. The data you send, as well as those contained in the CV, will be used only to evaluate and verify Your application.
LEGAL BASIS
- Legitimate interest of Rolland to find the requests that come through the Site.
- Adoption of pre-contractual measures taken at your request.
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PURPOSES vvMarketing
FURTHER INFORMATION
- Newsletter: with your consent your data to manage your subscription to our newsletter. You can unsubscribe at any time by following the instructions at the bottom of each communication (by clicking on "unsubscribe from the newsletter ").
- Direct marketing: with your consent, we will use your purchase data to send you promotional communications on our products or services, customized according to your purchase habits through the use of different means of communication (e-mail, SMS, MMS, WhatsApp, Messenger, Instagram, Direct).
- Profiling: with your consent, we will use your purchase data to process your personalized profile and send you targeted promotional communications on our products or services through the use of different means of communication (e-mail, SMS, MMS, WhatsApp, Messenger, Instagram, Direct).
- Soft Spam: we may use your e-mail address to send you promotional communications concerning products/services similar to those of your previous purchase.
LEGAL BASIS Your explicit consent, by affixing the flag in the appropriate boxes available on the site.
In the case of soft spam only, your consent is not necessary, based on the exception established by Article 130.4 of Italian Legislative Decree 196/2003
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PURPOSES Research and obtain products and services to support social media activities
FURTHER INFORMATION Rolland makes use of suppliers of various products and services, in relation to which information such as tax code, first name and last name, address, contact references or other personal identification elements necessary for the establishment and/or execution of the commercial relationship may be collected.
The data are used for the sole purpose of carrying out the commercial contractual relationship, making payments relating to the products/services received, managing relationships with suppliers, keeping accounts, etc.
LEGAL BASIS Execution of the contract to which you are a party and/or adoption of pre-contractual measures in your interest
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PURPOSES Compliance with legal obligations and/or orders by a Public Authority
FURTHER INFORMATION Your data may also be processed in the fulfilment of obligations to which Rolland is subject based on current legislation such as for example the storage of accounting records or to comply with an order of a Public Authority.
LEGAL BASIS Compliance with a legal obligation to which Rolland is subject.
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PURPOSES Search for the Oway salon closest to you
FURTHER INFORMATION Through the specific function of the Salon Locator, you can search for the Oway salon closest to your geographical position.
LEGAL BASIS Your explicit consent by clicking the "Locate me" button.
What are the categories of recipients of your data?
In carrying out its business activity Rolland makes use of external persons, who are suppliers of products and services of the Company, or of other companies belonging to the same business group to which Rolland belongs.
The above services may involve the disclosure of your data to the following categories of companies:
- Companies of the same business group to which Rolland belongs, suppliers of specific services and appointed external managers of the processing of personal data pursuant to Article 28 GDPR.
- Companies that operate to enable us to send you the products you have purchased, such as payment service providers, warehouses, packaging companies and order shipping.
- Professional service providers, such as marketing agencies, advertising partners, web designers, website hosting companies that collaborate with Rolland, solicitors, accountants, etc.
- Local distributors of our products.
- Credit assessment agencies, law enforcement agencies and fraud prevention bodies, to help counter fraudulent activities.
It is hereby understood and agreed that your personal data will be used only for the purposes indicated in this statement and may be disclosed to third parties only if this is necessary in order to fulfil the purposes for which the data are collected. Except for these cases, personal data will not be disclosed unless specific legal obligations, or unless specific consent has been requested from you in advance.
Under no circumstances will your data be otherwise disseminated.
How long and how will your data be stored?
Your data will be stored only for the time necessary to achieve the aforementioned purposes or, alternatively, in accordance with the legal obligations (e.g. accounting and tax) to which Rolland is subject.
In particular:
PURPOSES
STORAGE TIMES
Execution of the commercial contractual relationship with customers
The time necessary to manage the purchase and manage returns, complaints or associated disputes, as well as the additional period established by law.
Execution of the commercial contractual relationships with suppliers
The time needed to manage the contractual relationship, as well as the additional period established by law.
Management of your profile as a "Registered User" of the Site
So long as you decide to continue being a registered user.
Fulfilment of requests to Customer Service and "General Information", "For Distributors" And "For hairdressers” Forms
The time necessary to process the request and possibly longer than required by law.
Reception of curriculum vitae
Your data will be used only to examine your application. If there is no open position at the time of sending the CV, the curriculum vitae may be stored by the HR department for a period not exceeding 1 year.
Profiling
The detail of your purchases will be processed for profiling purposes for a period not exceeding 1 year from the registration of the same purchases.
Marketing
Newsletter: until you request to stop receiving our newsletter.
Purchase history for direct marketing: the detail of your purchases for sending targeted promotional communications will be stored for a period not exceeding 2 years from the registration of the purchase itself.
Location
The data that refer to your location shall be stored for no longer than the duration of the session.
Are you free to give your consent?
In cases where your consent to the processing of your personal data is required for the execution of a service, for example, the newsletter, you may voluntarily choose whether to provide it or not. Failure to consent may make it impossible to provide the service requested by you.
The consent you may have given to the receipt of promotional material is intended to be extended both via communications made through automated tools, such as e-mail, SMS, MMS, WhatsApp, Facebook Messenger and Instagram, Direct, and via those made through non-automated tools, such as telephone agent and traditional mail.
Are you free to disclose your data to us?
You are not obliged to provide us with any personal data; failure to communicate the data, however, could make it impossible to provide you with a specific service and/or to allow you to purchase the products.
What are your rights?
The GDPR expressly grants you the following rights:
- right to withdraw your consent to the processing at any time. The withdrawal of your consent, where exercised, shall be considered extended to all means of communication, automated and non-automated through which Rolland carries out promotional activities. This shall be in any case subject to your right to withdraw consent partially, that is, limited to the promotional activity carried out through some of the media used by Rolland. The withdrawal of your consent does not affect the lawfulness of the processing based on consent before the revocation (Article 7 GDPR);
- right to access your personal data. This right is limited to the time your data is stored by Rolland. Once the data is anonymized or erased, it will no longer be possible for anyone to view it or to permit you to access it;
- right to rectify your personal data, that is, obtain completion of incomplete personal data, including by providing a supplementary declaration;
- right to erase your data subject to the conditions and within the limits set out in Article 17 GDPR;
- right to restrict the processing subject to the conditions and within the limits set out in Article 18 GDPR;
- right to object the processing pursuant to Article 21 GDPR;
- right to receive your personal data in a structured, commonly used and readable format and transmit it to another data controller (so-called right to portability). This right may be exercised subject to the conditions and within the limits of Article 20 GDPR and is limited to the time in which your data is stored at Rolland.
It is also your right to lodge a complaint with the Data Protection Supervisor pursuant to Article 77 of the GDPR if you believe that the processing that concerns you violates the privacy legislation in force.
Will your data be profiled? What does profiling consist of?
Your purchase data will be profiled, subject to the prior indication of your consent.
Profiling consists of collecting personal data through any form of automated processing in order to obtain information regarding certain characteristics that identify you. The profiling carried out by Rolland with your data relates exclusively to your purchasing preferences and habits with reference to the products and services offered by the Company.
The processing of your data will be carried out in order to carry out research on the preferences of our customers and the degree of satisfaction in relation to our products, as well as to allow our marketing departments to identify the offers and products that best suit you by sending you targeted promotional material.
It is understood and agreed that you have the right at any time to object to the processing of your data for purposes related to profiling and direct marketing.