In general, any information and data which you provide to Giochi Preziosi over the Website, or which is otherwise gathered via the Website by Giochi Preziosi, in the context of the use of Giochi Preziosi’s services (“Services”) as better defined in Section 3 below, will be processed by Giochi Preziosi in a lawful, fair and transparent manner. To this end, and as further described below, Giochi Preziosi takes into consideration internationally recognised principles governing the processing of personal data, such as purpose limitation, storage limitation, data minimisation, data quality and confidentiality.
- 1. Data controller
- 2. Personal Data processed
- a. Name, contact details and other Personal Data
- b. Special categories of Personal Data
- c. Other persons’ and Minors’ Personal Data
- d. Browsing data
- 3. Purposes of processing
- 4. Grounds for processing and mandatory or discretionary nature of processing
- 5. Recipients of Personal Data
- 6. Transfer of Personal Data
- 7. Retention of Personal Data
- 8. Data subjects’ rights
- 9. Amendments
1. Data controller
2. Personal Data processed
When you use the Website, we inform you that Giochi Preziosi will process your Personal Data, that may be constituted by an identifier such as your name, the email address an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity which allows you to be identified identifiable (hereinafter “Personal Data”).
Your Personal Data can be collected by Giochi Preziosi both when you choose to provide it (e.g., when you create a personal account in order to receive the Services provided by Giochi Preziosi) or simply by analysing your behaviour on the Website.
Personal Data which can be processed through the Website are as follows:
a. Name, contact details and other Personal Data
b. Special categories of Personal Data
In certain areas of the Website (i.e., through the Customer Service information request form) you may provide certain information to Giochi Preziosi, which may contain Personal Data. Where these fields are completely free, you may use them to disclose (inadvertently or not) certain sensitive categories of Personal Data, such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, for the purpose of uniquely identifying a natural person, or data concerning a natural person’s sex life or sexual orientation. Giochi Preziosi asks that you do not disclose any sensitive Personal Data on the Website, unless you consider this to be strictly necessary. These special categories of Personal Data may only be processed with your explicit consent and in compliance with applicable legislation in force. Giochi Preziosi therefore stresses the importance of expressing your explicit consent to process this sort of Personal Data.
c. Other persons’ Personal Data
Through the Website you may communicate to Giochi Preziosi Personal Data related to other persons. In any situation where you decide to share Personal Data related to other persons, you will be considered as an independent data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify Giochi Preziosi against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, brought by the third parties whose information you provide through the Website. As Giochi Preziosi does not collect this information directly from these third parties (but rather collects them, indirectly, from you), you must make sure that you have these third parties’ consent before providing any information regarding them to Giochi Preziosi; if not, then you must make sure there is some other appropriate grounds on which you can rely to lawfully give Giochi Preziosi this information. Giochi Preziosi reminds you that the use of the Website is intended only for persons who are 18 years of age. If you are underage, Giochi Preziosi invites you to visit the site together with a parent. If, through the modalities described in the paragraph above, you communicate to Giochi Preziosi Personal Data regarding minors you guarantee - assuming all inherent legal responsibilities – that such specific processing is based on the consent of the holder of parental responsibility over the minor.
d. Browsing data
The Website’s operation, as is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While Giochi Preziosi does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information must also be considered Personal Data. This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on. These data are used to compile statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website. Save for this last purpose, these data are not kept for more than 14 months.
3. Purposes of processing
Giochi Preziosi intends to use your Personal Data, collected through the Website, for the following purposes:
- To allow you to create and maintain a registered personal account; to save your collection within your personal account; to verify your identity and assist you, in case you lose or forget your login / password details for the Website, and to provide any other Services which you may request (“Service Provision”);
- For future marketing, promotional and publicity purposes, including to carry out direct marketing, market research and surveys, via e-mail, SMS, mms, app, bot, regular mail, over the phone, and/or through Giochi Preziosi’s official social media pages, as well as for broader marketing activities, including prize events, games and competitions, regarding Giochi Preziosi’s products and services, as well as those of selected third parties (“Marketing”);
- To create a profile of you as a Website user, through the use of profiling cookies and by collecting and analysing information on the preferences you select and choices you make in the Website, as well as your general activities on the Website when you log-in with your personal account. This profile will be used to give you information about other websites / services which Giochi Preziosi believes you may be interested in, and to show you information and advertisements which may be relevant to you and your interests. All algorithms involved in this processing are regularly tested, to ensure the processing’s fairness and control for bias (“Profiling”);
- For compliance with laws which impose upon Giochi Preziosi the collection and/or further processing of certain kinds of Personal Data (“Compliance”);
- To prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website (“Misuse/Fraud”).
4. Grounds for processing and mandatory / discretionary nature of processing
Giochi Preziosi’s legal bases to process your Personal Data, according to the purposes identified in Section 3, are as follows:
- Service Provision: processing for these purposes is necessary to provide the Services and, therefore, is necessary for the performance of a contract with you. It is not mandatory for you to give Giochi Preziosi your Personal Data for these purposes; however, if you do not, Giochi Preziosi will not be able to provide any Services to you.
- Marketing: processing for these purposes is based on your consent. It is not mandatory for you to give consent to Giochi Preziosi for use of your Personal Data for these purposes, and you will suffer no consequence if you choose not to give it (aside from not being able to receive further marketing communications from Giochi Preziosi). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
- Profiling: processing for this purpose is based on your consent. It is not mandatory for you to give consent to Giochi Preziosi for use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from greater personalisation of your user experience regarding the Website). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
- Compliance: processing for this purpose is necessary for Giochi Preziosi to comply with its legal obligations. When you provide any Personal Data to Giochi Preziosi, Giochi Preziosi must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
- Misuse/Fraud: Information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potentially criminal purposes).
5. Recipients of Personal Data
Your Personal Data may be shared with the following list of persons / entities (“Recipients”):
- Entities which act typically as data processors on behalf of Giochi Preziosi, such as: i) persons, companies or professional firms providing Giochi Preziosi with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services; ii) entities engaged in order to provide the Services (e.g., hosting providers or e-mail platform providers); iii) persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
- Persons authorised by Giochi Preziosi to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of Giochi Preziosi);
- Other companies within the Giochi Preziosi Group for internal administrative purposes, including the processing of clients' or employees' Personal Data; and
- Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;
6. Transfers of Personal Data
Some of your Personal Data may be transferred to Recipients located in several different countries. Giochi Preziosi implements appropriate safeguards to ensure the lawfulness and security of these Personal Data transfers, such as by relying on adequacy decisions from the European Commission, standard data protection clauses adopted by the European Commission, or other safeguards or conditions considered adequate to the transfer at hand. More information on these transfers is available upon written request to Giochi Preziosi at the address indicated in Section 8 below.
7. Retention of Personal Data
Personal Data processed for Service Provision will be kept by Giochi Preziosi for the period deemed strictly necessary to fulfil such purposes (e.g., to keep your collection of Gormiti within your account). In any case, as these Personal Data are processed for the provision of the Services, Giochi Preziosi may continue to store this Personal Data for a longer period, as may be necessary to protect Giochi Preziosi’s interests related to potential liability related to the provision of the Services.
Personal Data processed for Marketing and Profiling will be kept by Giochi Preziosi from the moment you give consent until it is withdrawn. Once consent is withdrawn, Personal Data will no longer be used for these purposes, although it may still be kept by Giochi Preziosi, in particular as may be necessary to protect Giochi Preziosi’s interests related to potential liability related to this processing.
Personal Data processed for Compliance will be kept by Giochi Preziosi for the period required by the specific legal obligation or by the applicable law.
Personal Data processed for preventing Misuse/Fraud will be kept by Giochi Preziosi for as long as deemed strictly necessary to fulfil the purposes for which it was collected.
8. Data subjects’ rights
As a data subject, are entitled to exercise the following rights before Giochi Preziosi, at any time:
- Access your Personal Data being processed by Giochi Preziosi (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
- Correct or update your Personal Data processed by Giochi Preziosi, where it may be inaccurate or incomplete;
- Request erasure of your Personal Data being processed by Giochi Preziosi, where you feel that the processing is unnecessary or otherwise unlawful;
- Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing;
- Exercise your right to portability: the right to obtain a copy of your Personal Data provided to Giochi Preziosi, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller;
- Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent Giochi Preziosi from processing your Personal Data; or
- Withdraw your consent to processing (for Marketing and Profiling).
You can withdraw consent for Marketing (for communications received via e-mail) by selecting the appropriate link included at the bottom of every marketing e-mail message received.
Consent for Profiling carried out by cookies may be withdrawn as described in Section 2(f).
Aside from the above means, you can always exercise your rights described above by sending a written request to Giochi Preziosi at the following address: firstname.lastname@example.org
In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through the Website is unlawful.