Privacy Policy

Notice pursuant to articles 12 et seq. of EU Regulation 679/2016 (GDPR)

Shorr Kan s.r.l., with registered office in Turin, Via Sestriere 28/a (hereinafter “SK”, also referred to as the “Controller”), as controller of the processing of personal data pursuant to the GDPR and to the rules laid down by the Italian Personal Data Protection Code (where not conflicting with EU legislation), recognises the importance of personal data protection and considers its safeguard one of the objectives of its business.

Before communicating any personal data, SK invites you to read this privacy policy (the “Privacy Policy”) carefully, as it contains important information on the protection of personal data and on the security measures adopted to ensure its confidentiality in full compliance with EU Regulation 679/2016 (GDPR) (the “Applicable Legislation”) and with Italian Legislative Decree 101/2018, including subsequent amendments of 19 September 2018 transposing it in Italy. This Privacy Policy is moreover given solely for the website www.shorr-kan.com (the “Website”) and does not apply to other websites that may be visited through external links; it is to be understood as the notice given pursuant to article 13 of the Applicable Legislation to those who interact with the Website.

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SK informs you that the processing of your personal data will be based on the principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimisation, accuracy, integrity and confidentiality. Your personal data will therefore be processed in accordance with the legislative provisions of the Applicable Legislation and the confidentiality obligations set out therein.

Below is the index of this Privacy Policy, so that you can easily find the information concerning the processing of your personal data.

Controller and data protection officer

With reference to the Applicable Legislation, please note that the Data Controller is SK, whose details are shown on the website in the Contact page, on the Home Page and/or on other web pages of the same.

SK’s Data Protection Officer is Avv. Cristiano Michela, Corso Siccardi 11 bis, 10122 Turin, Italy.

The personal data processed

“Personal Data” means any information concerning an identified or identifiable natural person, with particular reference to an identifier such as a name, an identification number, location data, an online identifier or one or more characteristics of their physical, physiological, mental, economic, cultural or social identity.

The Personal Data collected by the Website is the following:

Browsing data

The Website’s IT systems collect certain Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected in order to be associated with you, but which by its very nature could, through processing and association with data held by third parties, allow you to be identified. This includes the IP addresses or domain names of the devices used to connect to the Website, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to your operating system and computing environment.

This data is used in order to obtain anonymous statistical information on the use of the Website and to monitor its correct functioning; to allow — given the architecture of the systems used — the correct delivery of the various functions you request; and for security reasons this data is retained by the Website’s Controller for the strictly necessary period and in any case in accordance with the applicable legal provisions.

Data provided voluntarily

Through the Website you have the option to voluntarily provide Personal Data such as your name and email address in order to contact SK through the “Contact us” form or other similar services. Users are free to provide their personal data, but failure to provide it may make it impossible to obtain the requested service. SK will process this data in compliance with the Applicable Legislation, assuming that it relates to you or to third parties who have expressly authorised you to provide it on the basis of a suitable legal basis legitimising the processing of the data in question. With regard to the latter case, you act as an independent data controller, assuming all obligations and responsibilities established by law. In this sense, you grant the broadest indemnity in respect of any dispute, claim, request for damages arising from processing, and so on, that SK may receive from third parties whose Personal Data has been processed through your use of the Website in breach of the Applicable Legislation.

Cookies and similar technologies

SK collects Personal Data through cookies.

Purposes, legal basis and mandatory or optional nature of the processing

The Personal Data you provide through the Website will be processed by SK for the following purposes:

1. Purposes relating to the performance of a contract to which you are a party or to the performance of pre-contractual measures adopted at your request (e.g. a contact request through the Contact form or by email, newsletter subscription);
2. Purposes of statistical research and analysis on aggregated or anonymous data, therefore without any possibility of identifying the user, aimed at measuring the operation of the Website, measuring traffic and assessing usability and interest;
3. Purposes relating to compliance with a legal obligation to which SK is subject;
4. Purposes necessary to establish, exercise or defend a right in legal proceedings or whenever the judicial authorities exercise their jurisdictional functions.

The legal basis for the processing of Personal Data for the purposes referred to in point a) is the provision of a service or the response to a request, which do not require consent under the Applicable Legislation.

The purpose referred to in point b) does not involve the processing of Personal Data, while the purpose referred to in point d) constitutes lawful processing of Personal Data under the Applicable Legislation since, once the Personal Data has been provided, the processing is indeed necessary to comply with a legal obligation to which SK is subject.
Providing your Personal Data for the purposes listed above is optional, but failure to provide it may make it impossible to respond to your request or to comply with a legal obligation to which SK is subject.

Methods of processing

Tools and logic. In relation to the purposes referred to above, processing takes place by manual, electronic and telematic means, with logic strictly related to the aforesaid purposes and, in any case, in such a way as to guarantee the security and confidentiality of the data, with your commitment to promptly notify us of any corrections, amendments and updates. Said processing may be carried out on behalf of the Data Controller for the purposes and by the methods described above, and in compliance with criteria suitable to guarantee security and confidentiality, by companies, firms, bodies and external collaborators appointed as Processors and solely in respect of the processing they carry out.
Special categories of data. None of your personal data held by the Data Controller falls within the definition of “special categories of data” under article 9 of EU Regulation 2016/679.

Recipients

Your Personal Data may be shared, for the purposes specified, with:

1. Parties necessary for the provision of the services offered by the Website, including by way of example the sending of emails and the analysis of the Website’s operation, which typically act as SK’s data processors;
2. Persons authorised by SK to process Personal Data who have undertaken to maintain confidentiality or who have an appropriate legal obligation of confidentiality (e.g. SK employees); (a. and b. are collectively the “Recipients”);
3. Judicial authorities in the exercise of their functions when required by the Applicable Legislation.

Transfers

Some of your Personal Data is transferred to Recipients that may be located outside the EU. SK ensures that the electronic and paper-based processing of your Personal Data by the Recipients takes place in compliance with the Applicable Legislation. Indeed, transfers are based either on an adequacy decision or on the Standard Model Clauses approved by the European Commission.

Data retention

SK will process your Personal Data for the time strictly necessary to achieve the stated purposes. Without prejudice to the above, SK will process your Personal Data for as long as permitted by Italian law in order to protect its own interests (art. 2947(1)(3) of the Italian Civil Code).

Your rights

Within the limits of the Applicable Legislation, you have the right to ask SK, at any time, for access to your Personal Data, its rectification or erasure, or to object to its processing, to restrict processing, and to obtain the data concerning you in a structured, commonly used and machine-readable format.

Requests should be sent by email to: privacy@shorr-kan.com

Under the Applicable Legislation, you always have the right to lodge a complaint with the competent supervisory authority (the Italian Data Protection Authority, Garante per la Protezione dei Dati Personali) should you consider that the processing of your Personal Data is contrary to the legislation in force.

Amendments

This Privacy Policy has been in force since 01/05/2019. SK reserves the right to amend or simply update its content, in part or in full, including as a result of changes to the Applicable Legislation. SK will give notice of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website. SK therefore invites you to visit this section regularly in order to become acquainted with the most recent and up-to-date version of the Privacy Policy, so that you are always informed about the data collected and the use SK makes of it.