Privacy Policy
1. WHY THIS POLICY
Pursuant to the European Data Protection Regulations 2016/679 (hereafter "GDPR"), this policy has the purpose of describing the processing of personal data of users/visitors/customers of Scarabeo Ceramiche S.r.l., hereinafter "Scarabeo", and its website scarabeosrl.com.
2. DATA CONTROLLER, DATA PROTECTION OFFICER (DPO) AND CONTACTS
The data controller is the natural or legal person who establishes the purposes and methods of data processing of the data subject.
The Data Controller is:
SCARABEO CERAMICHE S.R.L.
LOCALITA’ PIAN DEL TRULLO SNC
01034 FABRICA DI ROMA (VT) - ITALY
Tel: + 39 0761 540028
Fax: + 39 0761 540286
Website: http://www.scarabeosrl.com
e-mail: Info@scarabeosrl.com
The Data Protection Officer (DPO) is the person in charge of assisting the data controller in the proper management of the processing of the data subjects' data.
This person can be contacted for observations and requests at the following addresses:
SCARABEO CERAMICHE S.R.L.
FAO: Data Protection Officer (DPO) –
LOCALITA’ PIAN DEL TRULLO SNC – 01034 FABRICA DI ROMA (VT) Italy
e-mail: privacy@scarabeosrl.com
Tel: + 39 0761 540028
 
3. TYPES OF DATA PROCESSED, LEGAL BASIS AND PURPOSE OF THE PROCESSING
In order to receive information on the goods sold by Scarabeo S.r.l., it is necessary to process the personal data of the users collected directly from the forms on the website or emails sent or other means of communication like telephone and fax.
Type of data processed
The data processed are those necessary to identify and contact the customer (like Full Name, Email).
Purposes of processing and legal basis
A. Processing for sales purposes
The data acquired will be used for the collection of data of the data subject to provide him or her with information on the terms and conditions necessary to purchase a product sold by Scarabeo S.r.l.
Legal basis of the processing: for the purpose of selling products, the legal basis for data processing is the need to get in touch with the potential customer or supplier in order to proceed with the stipulation of a sales contract or the carrying out of pre-contractual procedures.
For these purposes the provision of data is mandatory. In the event that data are not provided or they are incomplete, it will not be possible to fulfil the customer's requests.
B. Processing for commercial and marketing purposes
The data acquired may also be used for email communications (including automated methods) relating to:
○    Updates on the products you have requested information about.
○    Updates on the business of Scarabeo S.r.l.
○    Sending of the periodic newsletter.
○    Sending of commercial offers and offers relating to products sold by Scarabeo S.r.l.
Legal basis of the processing: for commercial and marketing purposes the basis is the consent of the data subject.
This consent is optional. If denied, it will not prejudice in any way the purchase of goods but the data subject will not be informed of offers and other information useful for subsequent purchases.
Even after giving consent, at any time the data subject can easily withdraw consent for the processing free of charge, directly from a link provided in the email message or by writing to privacy@scarabeosrl.com.

4. METHOD OF USE
With regard to the aforementioned purposes, the processing of your personal data takes place through manual, computerised and online tools with logic strictly related to the purposes themselves and in any case in such a way as to guarantee the security and confidentiality of the data.
The documentation is archived both electronically and possibly in paper archives.
The data will never be transferred or sold to third parties for any reason besides the purposes specified herein.
For example: we will not sell the data of data subjects to databases of third parties that could send them spam or other commercial communications.
Scarabeo S.r.l.'s contractors and service providers will follow these same procedures for the pursuit of these purposes.
Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorised access. The same standard is required of the contractors and service providers of Scarabeo S.r.l.
5. RETENTION PERIOD
The data will be kept only for the time strictly necessary to achieve the purposes for which they were collected, and, in any case, in compliance with current regulations.
The retention periods required for storage are of two types:
A.    If the data subject has purchased a good supplied by Scarabeo S.r.l.: the data will be kept for the time required by current regulations on the sale of movable property.
For example, compliance with the retention periods required by law for the storage of invoices.
B.    If the user has not become a customer of Scarabeo S.r.l.: if the contact with the data subject has not led to a purchase and he or she has not consented to the sending of informative materials and newsletters, his or her data like Full Name and Email will be kept for a period of 24 months, to register the successful contact with Scarabeo S.r.l. Additional personal data that the data subject has provided will be anonymised and used for statistical purposes.
C.    If the data subject has subscribed to the Scarabeo S.r.l. newsletter: if the data subject has requested for the period of time he or she remains subscribed. After your request for cancellation of the subscription, your data will be kept for a period of 24 months.
6.  DATA RECIPIENTS AND SUPPLIERS OF SERVICES
The personal data provided are processed by employees, contractors, suppliers and other authorised personnel according to the directives and instructions of the data controller, Scarabeo S.r.l.
In particular, some data may be disclosed to some of the following parties:
-    Employees for the functions of Customer Care, Sales, Marketing, Invoicing and Accounting.
-    External consultants (e.g. accountants, lawyers, etc.) who act on the basis of specific instructions for the purposes and methods of the processing.
-    Public or private correspondence (e.g. Poste Italiane, Bartolini, etc.).
-    IT service providers like: server, cloud, email, certified email.
Other computer services necessary for the fulfilment of the purposes set out in this policy are provided by companies with headquarters in the United States, whose relations with the European Union with respect to the protection of personal data are regulated by the Privacy Shield, which guarantees the same protection of data as envisaged under European Regulations.
Some of the services used include but are not limited to:
●    Cloud, chat, email provided by Google, which is owned by the parent company Alphabet Inc. (terms, conditions and privacy policy here).
●    Newsletter: provided by MailChimp (terms, conditions and privacy policy here).
●    CMS of the website: provided by Wordpress (terms, conditions and privacy policy here). 
The Data Controller Scarabeo S.r.l. may use additional specialised external companies. These companies will be chosen according to their professionalism and guarantee of compliance with the regulations on data protection. If these suppliers do not reside in the territory of the European Union and an agreement is not in force between the EU and the country in which they are based, it will be ascertained that they guarantee the same standards as the GDPR through BCR (Binding Corporate Rules) or contractual agreements.
These service providers will act according to the directives of the data controller to better protect the data of the data subject. These parties will act as "data processors" or "appointed processors" of your data or, where the law permits, will operate as separate "data controllers". Where required, therefore, consent also covers the activities of these parties.
The personal data of the data subject will be used only with the methods and procedures strictly necessary to carry out the aforementioned activities and will not be disclosed to third parties for reasons beyond the specified purposes.
Further information can be requested from the data controller Scarabeo S.r.l. The updated list of Data Processors is available at the Scarabeo S.r.l. headquarters, subject to the direction and coordination of 
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7. RIGHTS OF THE DATA SUBJECT
The data subjects have the right:
●    To know who the data processors are.
●    To access their data and know what personal data Scarabeo S.r.l. has.
●    To request their erasure, modification, correction, updating.
●    To request the restriction of processing and to oppose it.
●    To deny consent (e.g. for the newsletter and commercial communications) without this precluding further existing relationships.
●    To request the right to be forgotten.
●    To request the portability of data where technically possible.
If data subjects feel that their rights have been disregarded, they also have the right:
●    To lodge a complaint with the Privacy Authority.
●    To lodge a complaint with the judicial authority having jurisdiction.
The requests will be taken into consideration and will receive an answer in the time required and in any case within 30 days. If it is not possible to provide a timely response within 30 days, you will still receive a communication explaining the reasons for the delay and the new deadline for receiving the requested response.
In any case, any acceptance or refusal of the request will be explained.
Requests can be sent to the following contacts:
SCARABEO CERAMICHE S.R.L.
FAO: Data Protection Officer (DPO) – 
LOCALITA’ PIAN DEL TRULLO SNC – 01034 FABRICA DI ROMA (VT) Italy
PEC certified email: presidenzascarabeo@pec.it email: privacy@scarabeosrl.com
Telephone: + 39 0761 540028