Privacy Policy

"PRIVACY POLICY"

According to Legislative Decree 196/03 and Regulation (EU) 2016/679 and subsequent additions and amendments.

“OWNER”, RESPONSIBLE AND EMPLOYEES IN CHARGE OF THE PROCESSING

With regards to Privacy, the consultation of this website by the user involves the assumption of information of personal data. For these purposes, the Data Controller of the personal data you have provided is the Company Dreampell srl in the person of the legal representative Lorenzo Fallani with legal and operational headquarters (not open to the public) in Scandicci via del Padule 56.

Within the Company itself, the personal data collected are processed by the employees who operate as “Officers”, following the relative specific instructions and indications given.

Place of data processing

The processing connected to the web services of the website www.dreampell.it, takes place at the headquarters of the Data Controller in Scandicci Via del Padule 56 and are only handled by technical staff in charge of the processing Office, or by any persons in charge of occasional operations of maintenance. No data deriving from the web service is communicated or disseminated. Personal data provided by users, who submit their requests to send information material, are used only to perform the service or provision requested and are disclosed to third parties only if necessary for this purpose.

Privacy Policy for website visitors

This Privacy Policy is intended to describe the management methods of this website, with reference to the processing of personal data of users/visitors who consult it. This is information that is also provided pursuant to art. 13 of Legislative Decree 196/03 – Code regarding the protection of personal data and subsequent additions and modifications – to those who connect to the corporate website of Dreampell srl and use the related web services starting from the address www.dreampell .it

The website [https://www.dreampell.it] is owned and managed by Dreampell srl which guarantees compliance with the legislation on the protection of personal data (Legislative Decree 196/03 and subsequent additions and amendments).

What is meant by personal data and processing of personal data

The processing of personal data refers to any operation or set of operations, carried out even without the aid of electronic tools, concerning the collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, cancellation and destruction of data, even if not registered in a database.

Type of data processed and purpose of the processing

1) Navigation data

The computer systems and software procedures used to operate this website acquire, in normal operation, some personal data which is then implicitly transmitted in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but by their very nature could allow users to be identified through processing and associating with data held by third parties. All our activities are governed by strict ethical principles and commitment to protecting the privacy of all visitors to our website. For this reason, the way in which we collect and store data is closely linked to the way in which our website and related services are used.

2) Data provided voluntarily by users/visitors

If users/visitors, connecting to this website, send their personal data to access certain services, or to make requests via e-mail, this involves the acquisition by Dreampell srl of the sender’s address and/or any other personal data that will be processed exclusively to respond to the request. The personal data provided by users/visitors will be disclosed to third parties only if the communication is necessary to comply with the requests of the users/visitors themselves.

3) Cookies

Various technologies can be used on our website to improve them and make them easier to use, effectively and safely. These technologies allow us, or third parties who work for us, to automatically detect data. Examples of such technological solutions are cookies. Cookies are not used to transmit information of a personal nature, nor are so-called c.d. persistent cookies of any kind, or systems for tracking users. The use of so-called session cookies (which are not stored permanently on the user’s computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow safe browsing and efficient site. The so-called Session cookies used on this site avoid the use of other IT techniques that are potentially prejudicial to the confidentiality of users’ browsing and do not allow the acquisition of the user’s personal identification data.

Data provided by you

In addition to the automatically collected data, we also process the data provided by you. Below is an example but not exhaustive list: your contact details, including company name and VAT number or for natural persons: name and surname and tax code, address, e-mail address and fax, website and date of birth, your telephone number or mobile number for natural persons, if necessary for further questions or requests for information.

All this data has been provided by you. This information will be used for the purposes described in this Notice. You have the right to rectify your personal data at any time or to prevent its processing. (see Section Rights of the interested party).

How the collected data is used: purposes

We will use your personal data for purposes related to the production of leather goods for the luxury brand market.

Subject to your explicit consent, we can contact you via the contact details provided by you (by ordinary mail, e-mail, SMS, telephone or other electronic means) for marketing, advertising and surveys on behalf of Dreampell srl.

In order to be able to communicate information of your interest, data on your interaction with Dreampell will be analysed, used and combined.

We may provide your contact details to third parties for marketing, advertising and opinion polling purposes. In the Rights Section of the interested party, you can read information about your rights, for example on how to withdraw your consent or how to correct your personal data.

Personal data will be processed for the following purposes: 1. functional to the fulfilment of legal obligations, regulations or required by EU legislation; 2. execution of the contract or to fulfil, prior to the execution of the contract, your specific requests 3. management of customers and any purchase orders and related administrative activities, with related processing, in compliance with current legislation on the matter, invoicing and shipping. 4. preparation of measures aimed at protecting against credit risk, including activities aimed

at identifying the economic reliability/solvency of the Customer, before or during the contractual relationship. Dreampell srl will be able to verify that the bank/postal data provided are correct. 5. relating to the performance of activities aimed at developing market studies and research, carrying out direct sales activities, for sending commercial information, as well as for sending advertising/informative material or through contact systems. The interested party may at any time oppose the processing by sending a request to the dedicated mailbox referred to the email: contact@dreampell.it 6. relating to the performance, by third parties, commercial partners, to which Dreampell srl may communicate/transfer the acquired data, for carrying out activities aimed at developing market studies and research, for carrying out sales activities, for sending commercial information, including interactive ones, as well as for sending advertising/informative material; 7. Management of disagreement (breach of contract, warnings, transactions, credit recovery, arbitration, legal disputes) Processing of personal data: mandatory consent and optional consent. The processing of personal data is generally allowed only with the consent of the interested parties, which must be free, informed, expressed in a specific form and documented in writing. The interested party is free to provide personal data requested from time to time; their failure, partial or incorrect provision could make it impossible to provide the requested services (Article 7 of the GDPR). The acquisition of consent to the processing of personal data is necessary for all the treatments indicated above connected and/or necessary to fulfil legal obligations, to community legislation, to perform obligations deriving from a contract to which the interested party is a part or to fulfil specific requests of the latter, before the conclusion of the contract,. The consent to the processing of personal data for the purposes referred to points 5-6 is optional and may be revoked at any time in the manner described in the “Rights of the interested party” section of this information. Any refusal by the interested party to respond for points 5 and 6 will make it impossible for us to send advertising material and carry out promotional activities. You can revoke your consent at any time to the receipt of commercial communications previously issued, both from Dreampell srl and from third-party companies, in the following ways: by sending a request to contact@dreampell.it

Methods of processing and conservation

Personal data is processed by hard-copying, IT, telematics and automated tools including profiling (Article 22 of the GDPR); Profiling can take place using individual or identification data (e.g. personal data), or aggregated data deriving from individual personal data. All is done in compliance with guarantees of confidentiality and security measures provided for by current legislation, with logics strictly related to the purposes of the processing. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access. The data retention period is linked to the purpose of the processing in progress. Dreampell srl will not retain personal information more than is necessary to fulfil the purposes for which such information was processed, including the security of our processing procedure in accordance with regulatory and legal obligations (e.g. control, accounting and terms of legal retention), the management of disputes and for the determination, practice or defence of legal rights in those countries where we carry out business activities.

Disclosure of information

One of our fundamental principles is our commitment to treat your data with caution and confidentiality. We will never sell your data to third parties. Your data may be disclosed to third parties only in the event that the law requires it and under the condition that it is

permitted by the laws in force. It is possible that we use service providers and data processors who work on behalf of Dreampell srl. They are operators that provide hosting and maintenance services, analysis services, e-mail messaging services, delivery services, payment management, credit check, address verification, etc. These third parties are allowed to access to those personal data they need for the purposes of their specific services. Service providers and data processors have a contractual obligation to treat such information in the most strictly confidential manner. The contract prohibits them from using the data for purposes other than those stipulated in the contract. Dreampell srl has put in place what is necessary for our service providers and the processors who work for it to protect the confidentiality of your data.

CATEGORIES OF SUBJECTS WHO COULD ACCESS THE USER’S DATA

In addition to the employees of Dreampell srl, some processing of the user’s personal data may also be processed by third parties, including the companies to which Dreampell srl entrusts or could entrust certain activities functional to the consultation of the website. These subjects will operate as independent Data Controllers or as Data Processors. In the latter case, the Data Controller will give the Managers adequate operating instructions with particular reference to the adoption of minimum security measures, in order to guarantee the confidentiality, integrity and security of the data. The user’s data may also be disclosed to the judicial, administrative or other public entity entitled to request them, in the cases provided for by law. For the pursuit of the aforementioned purposes, Dreampell srl may communicate and have the personal data of the interested party processed, in Italy and abroad, including countries not belonging to the European Union, to third parties with whom it has relations: the latter will provide them only with the information necessary to perform the requested services, taking all measures to protect your personal data. Personal data may also be known by employees, self-employed, project-based, occasional workers, consultants, temporary workers, collaborators of Dreampell srl who have been specifically appointed/designated, Managers or persons in charge of processing. Accountants and billing staff; those involved in the marketing of goods/services; agents and representatives; the above data may be transferred and communicated to the category of subjects indicated below: companies operating in the sector in which Dreampell srl operates, our subcontractors, our affiliates, mail delivery companies, banks and credit institutions, credit recovery companies , law firms, insurance companies, professional firms and/or companies and/or associations of companies and entrepreneurs who provide us with certain accounting and/or tax services, social security institutions, etc.

Rights of interested parties

Dreampell srl reminds the interested party that, pursuant to art. 7 of the Privacy Code, Legislative Decree 196/03 and of the 2016/679 regulation and subsequent additions and amendments, it is possible, at any time, to obtain confirmation of the existence or otherwise of the data and to know its content and origin as well as of the logic on which the processing is based, verify its accuracy or request its integration or updating, or rectification. Pursuant to the same article, the interested party has the right to request cancellation, transformation into anonymous form or blocking of data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, to their processing. For treatments related to direct marketing it will always be possible to revoke the consent and exercise the right to object. The opposition, in the absence of any indication to the contrary, will refer to both

traditional and automated communications. In order to exercise the aforementioned rights, a request must be sent to the dedicated mailbox: contact@dreampell.it.

Your rights

If you provide us with your personal data via our websites or other channels, this is done absolutely voluntarily. If you choose not to provide the requested information, you may miss several opportunities available to customers and users. Given the importance of transparency and fairness to us, we offer various options, appropriate to the circumstances, to help you stay in control of your data. These options may include viewing and editing your data online. There may also be the possibility to unsubscribe or to receive information on the data stored by us by writing to the email: contact@dreampell.it

Right to ask for information

You have the right at any time to receive information on your stored personal data, on their origin and on the recipients, as well as on the purposes for which they were stored. Information on stored personal data can be obtained by contacting us at the email address: contact@dreampell.it. The subjects, to whom the personal data refers, have the right to obtain confirmation of the existence or otherwise of such data and to know its content and origin, verify its accuracy or request its integration or updating at any time ( art.7 of Legislative Decree 196/03 and regulation 2016/679)

Right of rectification

You have the right to rectify, integrate, update, delete your personal data stored or to have their storage blocked. We will notify you within four weeks of receiving your request whether, and if so, to what extent we will comply with your request. If, for some reason, we are not able to satisfy your request, we will inform you about it (Article 7 of Legislative Decree 196/03 and Article 12 and 16 of the GDPR).

Right to object and cancel your registration

Pursuant to the same article, one has the right to request cancellation, transformation into anonymous form or blocking of data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, to their processing (Article 21 GDPR). The e-mails sent by Dreampell srl which contain, for example, a newsletter or marketing messages, offer the possibility to stop receiving such e-mails. If you no longer want to receive our e-mails, just write to contact@dreampell.it and we will immediately stop sending you e-mails. If you no longer wish to receive promotional information and sales offers in general, not even by ordinary mail, e-mail, SMS, telephone or other electronic means, or if you wish to withdraw your consent, you can also do so, at any time, by writing to

Dreampell srl, Via del Padule 56 50018 Scandicci (FI), indicating as reference: “data protection”, or by sending an e-mail to contact@dreampell.it. In case of doubt about your identity, you may be asked for an identification document (e.g. a photocopy of your identification document) (Article 17 of the GDPR).

Information security and data integrity

We have adopted appropriate technical and organizational measures to protect personal data from accidental or unlawful events that cause its destruction, loss, alteration, and from unauthorized use, disclosure or access, especially where the processing involves the transmission of data through a network and against any other form of illicit treatment and abuse.

Protection of minors’ personal data

Protection of minors’ personal data is of the utmost importance. Dreampell srl is aware of its obligation to protect the privacy of minors, and refuses to collect data from minors under the age of 16. We encourage parents and other guardians to surf the Internet and send

e-mails with their children and to use the Internet responsibly. If a child under the age of 16 tries to provide information relating to his/her data from the outset, he/she must seek the consent of the parent. The data sent by a minor, or in any case concerning him, detected during his visit (e.g. through cookies) can be used as described above. If a child under 16 tries to send his/her data via the card/form, this will be rejected, with the communication that such requests are not accepted from children under the age of 16. For this reason, we ask that parents and other guardians verify and monitor the use of the Internet by minors, for their safety (Article 8 of the GDPR).

How to contact us

The owner of the processing of personal data is: Fallani Lorenzo at Dreampell srl located in Scandicci, via del Padule 56, Email: contact@dreampell.it

It is possible to know an updated version of this document and the updated list of data processors, by contacting the owner directly.

Changes to this information

Dreampell srl is committed to adopting the fundamental principles of data protection and considers the protection of personal data as a natural duty. We therefore frequently review our data protection policies to ensure they are error free, clearly visible on our website and include all necessary information, and to verify that they are strictly observed, and compliant with principles of the legislation on this matter. This information on the protection of personal data may undergo changes over time to keep it up to date with the evolution and new opportunities of the Internet and to ensure its compliance with current legislation. Without your explicit consent we will never apply restrictive provisions of the rights recognized to you in this statement. Relevant changes to this information will be announced on our website at the same time as the publication of the updated version of the information on the protection of personal data.