The security and privacy of personal data is fundamental to our company.

We process personal data for each business process in accordance with Regulation (EU) 2016/679 – “General Data Protection Regulation” (hereinafter also referred to as “GDPR“) and other applicable data protection provisions.

This policy, provided pursuant to Article 13 of the GDPR, describes how we use and manage the personal data we collect when you visit our website www.fabe.it (“Website”) or access services made available telematically.

This information is provided exclusively for the Website, to the exclusion of any third-party websites that may be consulted exclusively via external links made accessible during navigation on the Website. Access to such websites remains beyond the scope of our company’s activities and controls. In such cases, the privacy policies of said third-party websites will apply.

Before providing us with your personal data, we invite you to read this policy and any further information that may be provided on the pages of the Website in relation to particular services or data processing, as well as the “Terms and Conditions of Sale” https://fabe.it/en/conditions-of-sale/.

If you have any questions concerning this policy or our use of your personal data, please contact our Data Protection Officer at claudio@fabe.it

1. Data Controller and data protection officer

The Data Controller is FABE S.r.l. (hereinafter referred to as “Fabe“), with registered offices at Viale Aldo Moro, 32/B – 24054 Calcio (Bergamo) – VAT N. IT01946690169, enrolled in the Bergamo Business Register with N. 04795470154 and EAI N. BG-183435 – 

The Data Protection Officer can be contacted by email at claudio@fabe.it

2. Purposes and legal bases for processing personal data

In order to purchase products and use our services, we ask you to provide us with your personal data by entering them in the appropriate forms on the Website.

Registering on the Website will allow you to create your personal account in order to benefit from a simplified purchasing procedure, to keep track of the orders you have made and to store and update your personal data and any other information you have provided that is necessary or useful for making the purchase. The conditions of use of the “Create Account” service are contained in the “Terms and Conditions of Sale” https://fabe.it/en/conditions-of-sale/ to which reference is made.

The email address, telephone number and other forms of electronic communication you provide may be used to verify your account, to provide you with the products and services you have requested, and to send you relative communications.

The personal data you provide may be used for the purposes and on the legal bases set out below.

1. Processing carried out for the purpose of fulfilling any pre-contractual measures requested by you, executing purchase orders and/or offering you services

We may use your data to:

• respond to messages and requests received through the contact addresses on the Website.
• manage the process of registering with the Website by filling in the relevant form.
• manage your account to identify you and enable you to purchase products and use the services made available on the Website.
• manage the purchase of products made by you, as well as the related payments and invoicing activities, in accordance with the “Conditions of Sale”.
• manage the shipping of the products you have purchased.
• handle any complaints regarding item warranties.

The legal basis for the above-mentioned processing is the need to fulfil pre-contractual measures to be adopted at your request and the fulfilment of contractual obligations (Art. 6, paragraph. 1, b of the GDPR).

1. Processing to comply with legal obligations to which we are subject

We may use your personal data to:

• fulfil tax and administrative requirements related to the execution of the purchase order and/or the pre-contractual measures requested.
• fulfil further legal and/or regulatory obligations to which Fabe is subject or requests from the Authorities or other competent institutions.

The legal basis for such processing is the fulfilment of legal obligations (Art. 6, paragraph 1, c of the GDPR).

C.   Processing for the fulfilment of our legitimate interests

We may use your personal data to:

• manage, protect and improve the functionality of the Website and the relative browsing service.
• send you communications regarding the products and services requested, including any recommendations or instructions related to the product purchased.
• send you promotional and commercial communications relating to products similar to those you have already purchased, unless you have denied your consent.
• establish, exercise or defend a legal claim.

The legal basis for such processing is the pursuit of our legitimate interests (Art. 6, paragraph 1, f, of the GDPR).

The sending of promotional and commercial communications relating to similar products is carried out in accordance with Article 130, c. 4 of the Privacy Code (Italian Legislative Decree n. 196/2003).

D.    Processing for which your consent is necessary

With your express and specific consent, we may use your data to:

• send you, periodically by email, automatically and free of charge, our newsletter or other communications containing promotional, advertising and informative material relating to products, services or initiatives offered by Fabe and its commercial partners.
• provide you with the best possible experience with our products and services by analysing your interests and preferences so that we can suggest and send you, via email, informative and commercial communications, including exclusive and personalised discounts, regarding products or services which are in line with your interests and/or which we consider to be of interest to you. In this case, your data may be subject to automated decision-making processes. The systems we use for this purpose will allow us to create a business profile for you by cross-referencing (i) the data collected during your navigation of the Website; (ii) the data collected through the cookies you have accepted by accessing the Website; and (iii) the information you have given us or that has come into our possession in relation to your demonstrated choices and purchasing habits.

The legal basis for such processing is the consent of the data subject (Art. 6, par. 1, a, GDPR). Please note that said consent may be withdrawn at any time, without prejudice to the lawfulness of the processing carried out before such withdrawal.

3. Categories of personal data

We may collect the following personal data when you use the Website or access our products and services.

Navigation data

During standard operation, the computer systems and software procedures used to operate the Website acquire a range of personal data, the transmission of which is implicit in the use of internet communication protocols. This information is not gathered in order to be associated to specific identified data subjects, but, due to its very nature, could allow identification through the processing, and association with, data held by third parties.

This category of data includes: IP addresses of computers or devices that you use to connect to the Website, addresses in URI (Uniform Resource Identifier) notation for the requested resources, the time of the requests, the method used to make the requests to the server, the size of the file received in response, the http code of the response provided by the server, and other parameters relative to your browser and/or operating system.

We use these data exclusively to gather anonymous statistical information regarding the use of the website and in order to monitor its correct functioning. These data, which are necessary for the use of the Website, do not currently persist for more than 30 days, except in the event of the need to ascertain crimes by the judicial authorities.

Data provided voluntarily by the user

• Registration data: when you register on the Website, you provide us with your personal data (such as, but not limited to, name, surname, VAT number, tax code, address, email address, telephone number) which will be used to activate your personal account necessary to purchase products.
• Data relative to purchase orders: if you decide to purchase a product, we will ask you to provide us with the details of your credit card and/or other payment instrument used by you on the Website, invoicing/receipt data (such as, by way of example, name, surname, VAT number, tax code, address of residence/domicile, email, telephone) and further personal data necessary to proceed with the purchase of the product (e.g. shipping address).
• Other information: we will collect information when, for example, you fill out a form or submit a request for assistance or information through the “Contact Us” section or other sections on the Website.

Information on the Newsletter service

By subscribing to the newsletter, we will collect your personal data (such as name, email address and professional type) required to send you the requested information.

Cookies

Information on the use and management of cookies can be found here https://fabe.it/en/cookie-policy/ .

4. Provision of data and consequences of refusal to provide data

The provision of data for the purposes indicated in this Policy is not compulsory, nor is it required by law: however, failure to provide such data, even partially, will not allow us to complete the registration process, to execute your purchase orders or pre-contractual measures, or to comply with legal obligations.

Please also note that failure to grant your consent to send you our newsletter and other promotional communications or to analyse your interests, or the withdrawal of the same, will not allow us to update you on our activities, offers or initiatives.

5. Data processing methods

Fabe adopts security measures necessary to avoid the risks of dispersal, destruction and loss of confidential and non-confidential information relating to its users, or unauthorised access, or access not in accordance with the law. Processing is carried out using computer and/or telematic tools, with organisational methods and approaches that are strictly related to the purposes indicated.

Processing related to the Website’s web services is carried out exclusively by our technical staff specifically authorised to carry out processing operations and instructed to do so, or by any persons authorised to carry out occasional maintenance operations. Such processing is also carried out by our suppliers who provide technical services for the management and maintenance of the Website and/or services instrumental to the pursuit of the purposes indicated above (see “Recipients of personal data“) and who act as Data Processors or independent Data Controllers.

6. Period of storage

Your personal data will be held for a period of time not exceeding that necessary for the purposes for which they were collected, or subsequently processed, in accordance with legal obligations.

In particular, the data will be kept for the entire duration of the contractual relationship established with Fabe and, after the termination of the same, only for the time necessary to guarantee the fulfilment of all legal obligations.

Invoices and any other documents of an accounting nature will be held for ten years from the date of the last recording.

The identification data related to your credit card or other payment systems available on the Website will not be stored, even temporarily, in our systems.

The data acquired in order to send you the newsletter and other promotional communications and/or profiled communications will be processed until you communicate your wish to revoke your consent, according to the procedures made available from time to time. Withdrawal of consent will require us to immediately cease processing activities for such purposes so that, for example, we cannot update you on activities, offers or initiatives promoted by us. In addition, from that moment, the data obtained to send you our newsletter and other promotional communications may be kept for a period not exceeding 24 months, while the data collected to send you profiled communications will be kept for a period not exceeding 12 months, after which such data will be deleted or made anonymous.

7. Recipients of personal data

Your personal data may be brought to the attention of our employees and/or collaborators who have been duly authorised and instructed to process them for the above-mentioned purposes.

We may also communicate your data to the following recipients:

• external subjects who provide, on our behalf, services of various kinds (e.g., carriers, shippers, service providers for marketing activities, advertising activities, payment services, management of the newsletter service etc.).
• external parties who provide services on our behalf related to the management and maintenance of the Website and related services, as well as the electronic and/or telematic tools used by us.
• persons entrusted with the task of defending us in contentious and/or administrative proceedings, as well as debt collection companies.
• public security and judicial authorities, persons, bodies or other authorities to whom it is mandatory to communicate data under the provisions of the law or orders of authorities.

8. Transfer of data abroad

We hereby inform you that your personal data may be transferred abroad, both within the European Union and to third countries, for the purpose of fulfilling the relationship with you or the pre-contractual measures taken at your request, as well as the fulfilment of obligations imposed by applicable laws.

We hereby inform you that our newsletter service is managed through the “Mailchimp” platform whose servers are located in the United States.

Any transfer of your data abroad will take place in accordance with the provisions of Articles 44 et seq. of the GDPR. In particular, transfer may take place on the basis of an adequacy decision adopted by the European Commission (art. 45 GDPR) or, for Third Countries where there is no Commission decision, on the basis of “adequate safeguards” by which we undertake to ensure a sufficient level of protection of your personal data in accordance with art. 46 of the GDPR.

9. Rights of data subjects

At any time, you will be able to have full clarity on the operations we have reported to you and exercise your rights under Articles 15-22 of the GDPR and in particular:

• the right to access: you may request information regarding processing of your data carried out by ourselves or the confirmation that we are processing your personal data.
• the right to rectification: you may ask us to rectify your personal data if they are incorrect or to supplement incomplete data.
• the right to erasure: you may ask us to erase your personal data.
• the right to restriction: you can ask us to limit the processing of your personal data in the cases provided for by law.
• the right to portability: you may obtain the data that you have communicated to us in a structured format of common use and readable with an automatic device, and you have the right to transmit the data to another subject.
• the right to object: you may object at any time, on grounds relating to your particular situation, to the processing of your personal data, without prejudice to any prevailing legitimate interests on our part.
• Right to withdraw consent: in cases where processing is based on consent, you may withdraw said consent at any time, without prejudice to the lawfulness of the processing based on the consent prior to withdrawal.

Furthermore, should you consider that your rights have been infringed or that the processing carried out by us is in conflict with the legislation in force, you may lodge a complaint with the Data Protection Authority, without prejudice to any other administrative or jurisdictional recourse.

You may exercise the rights described above by writing to claudio@fabe.it

10. Social network sharing buttons

There are buttons on the Website that allow content to be shared via social networks (Facebook, Twitter, WhatsApp, YouTube, Instagram) which may collect third-party cookies installed by the social networks. The Website does not share any information with such widgets.

11. Updates

We may, at any time and at our discretion, amend or update this Privacy Policy in order to reflect any changes in applicable law, to adapt to technological innovations or internal business processes, or for any other reason that renders updating appropriate. New versions of the policy will be duly published on the website and binding as of publication. We therefore invite users to regularly consult this page.

Last updated on: 31/08/2021