2. Type of data processed and sources
When a user visits the Site, we collect web-browsing activity and data about the device used to access the Site, such as IP addresses, domain names used and information regarding the user’s operating system. These and other data, such as number of visits and time spent on the Site, are used by Kalaca only for statistical purposes and in anonymous form to monitor and improve Site performance, and to monitor for any illegal or unauthorized activity on the Site or carried out through the Site. With respect to how Kalaca uses “cookies” for data collection, please refer to the below section on cookies.
Kalaca also collects personal information actively provided by users such as name, sex, place and date of birth, country of residence, and e-mail address. To process purchases made through the Site, other information may be collected, such as identification codes (e.g. tax code, VAT number), contact information (e.g., address, phone number), and other information. In addition, Kalaca collects a user’s personal information when a user interacts with the Site and requests services from Kalaca, for example when a user subscribes to the Site or the newsletter, purchases products (which includes all activities pertaining to the sale and after-sale services, such as for example fraud prevention, managing of returning items, guarantee, customer support, interaction with Kalaca customer service), takes part in initiatives realized through the Site, requests information or sends communications or feedback to Kalaca, and so that Kalaca can comply with applicable laws.
With your consent, Kalaca may use your personal information to perform survey/market research, to understand your preferences and interests and to send you, through e-mail, sms and mms, promotional information and material on Kalaca’s and Kalacas companies’ products, for special price initiatives and promotions and for events organized by Kalaca/Kalaca companies or that the same participate in, including relevant invitations, as applicable. You can always opt-out from receiving these promotional messages. If you provide Kalaca with personal information of third parties (for example the ‘send to a friend’ tool allowing you to send information on the Site and Kalaca’s/Kalaca companies’ products and initiatives to a friend), you are responsible for complying with applicable privacy and anti-spam laws, and may only use such features in full compliance with these laws.
3. Information disclosure and sharing
Disabling cookies may limit the ability to use the Site and prevent from benefitting fully from the features and services offered on the Site. Most browsers automatically accept cookies, but the user can usually change settings to disable this function. It is possible to block all types of cookies, or agree to receive only some of them disabling others. The “Options” or “Favorites” sections in the browser menu permit to accept or avoid receiving cookies and other tracking technologies, as well as to receive notification from the browser when these technologies are used. Alternatively, it is possible to manage cookies consulting the “Help” section of the toolbar present in most browsers. It is also possible to select the browser from the list below and follow the instructions:- Internet Explorer; – Chrome; – Safari; – Firefox; – Opera. From mobile:- Android; – Safari; – Windows Phone; – Blackberry.
5. User privacy rights
User has the right to request access to, review of or a copy of user data, request Kalaca to stop collection, processing or use of user data, ask that personal information be updated, supplemented, amended, deleted and user may oppose use of personal information for marketing purposes. Any request on personal information processing by Kalaca and to enforce privacy rights, user may contact Kalaca at: Polpo Holdings, LLC 2601 S Bayshore Dr STE 250, Miami Florida 33133-5457.
The company Polpo Holdings, LLC (herein after “Data Controller”) provides you with the following information on the processing of your personal information.
1. Personal information collection and purpose of processing. The personal information you provided by filling in the form or collected after you visited our stores (including, personal details (name, surname, date of birth, if any, gender, country of residence), contact details (country of residence, e-mail), data regarding the purchases made by the client (type, quantity and price of the products purchased by the client) are processed for the following purposes:
a) users’ registration to “Kalaca&Me” and use of the services dedicated to the registered users;
b) research, market analysis, periodic sending of promotional materials on products, services and promotion of the Kalaca world, including events organized by Polpo Holdings, LLC, or to which Kalaca participates as well as invitations to said events, also customized performed through traditional (mail and calls from operators) or automated (email, fax, text/SMS and MMS messaging) contact means as well as customized treatment in every Kalaca store in Italy and abroad);
c) creation of group and individual profiles – analysis of your interests, preferences and purchasing habits, also based on the detailed purchases made in Kalaca stores in USA and abroad. This processing is carried out in compliance with applicable privacy legislation.
2. Provision of personal information. Providing your personal information indicated as mandatory under the registration form for the purposes under letter 1. a) above is necessary; denial thereof would make it impossible you to register with and create an account for “Kalaca&Me”. For the purposes under letters 1. b) and c) above, providing of your information is optional; denial thereof would have no consequences on the possibility to receive our products and services, but we would not be able to inform you on the marketing initiatives and events above described and we could not understand your interests. If you provide us with personal information of third parties (e.g., your family members, other customer or prospects), you should make sure that said third parties are informed and authorized the use of their information as described in this information notice.
3. Processing methods. Your personal information is processed with and without the assistance of electronic means in line with the Italian Privacy Code, including the data security profile on the strength of logics and procedures based coherently upon the aforementioned purposes. Your personal information, in particular, will be processed through the Customer Relationship Management (CRM) system managed by Polpo Holdings, LLC whose servers are located in Italy, and will therefore be subject to Italian law
4. Personal information entry into the CRM system. Your personal information entry into the CRM system is optional and occurred only if you provide your personal information for the purposes under letters 1. b) and c). Once inserted into the CRM system, your personal information may be read, amended and updated by the employees of the Kalaca offices and stores in Italy and abroad expressly appointed as persons in charge of processing.
5. Retention Period. Your personal information processed for the purposes under letter 1. a) will be stored until you ask to revoke your registration to “Kalaca&Me”. Your personal information processed for the purposes under letters 1. b) and c) will be stored until you ask to revoke your registration to “Kalaca&Me” or the consent to the processing of your personal information for the aforementioned purposes with the exception of information relating to the details of your purchases processed for profiling and marketing purposes, which will be retained for 7 years.When the retention period expires that said data will be erased or made anonymous permanently.
6. Personal Information processing, communication and dissemination. Your personal information may be accessed by employees and collaborators of the Data Controller appointed as persons in charge of the processing.
Your personal data may be also processed by the following third parties acting as data processors:
a) third parties that the Data Controller use to provide technical and organizational services functional to the purposes above described, e.g. for marketing, market analysis and research services, information system management, etc.; b) companies affiliated to Polpo Holdings, LLC, LLC or under common control for all the purposes under letters 1. b) and c) above;
Your personal data may be communicated to the following third parties, which act as data controllers:
a) public entities and authorities for their institutional activities and as laws require us to do, including third parties in case of extraordinary operations (mergers, acquisitions, transfer of assets) during our business activities;
b) professionals and associations offering legal, taxation and auditing counsel.
It is understood that, Polpo Holdings, LLC, LLC does not share with other third parties your personal data for their own marketing activities and/or analysis of your interests.
Some of the above listed subjects, e.g. companies affiliated to Polpo Holdings, LLC. or under common control, may be established abroad, outside of Canada or the European Union, in countries not providing for an adequate level of data protection as your home country. Polpo Holdings, LLC, LLC. transfers data abroad after adoption of the precautions set forth by applicable privacy laws. Your personal data will not be disseminated.
The full list of data processors appointed and of the third parties to which data are communicated can be obtained by writing to the Data Controller at the following address: firstname.lastname@example.org.
7. Data Controller. The data controller is:
– Polpo Holdings, LLC., with registered offices at 1209 Orange Street, Wilmington, New Castle County, Delaware 19801 (USA).
8. Data Processor. The data processor is:
– CRM Manager pro tempore, domiciled at Polpo Holdings, LLC., 1209 Orange Street, Wilmington, New Castle County, Delaware 19801 (USA)
9. Personal information rights. Regarding the processing of your personal information, you can obtain confirmation as to whether or not personal information concerning you exists, verify the content, the source and accuracy of your personal information, ask that your personal information be updated, rectified, integrated, erased, anonymized and blocked. Moreover, you may object, in whole or in part to the processing of your personal information for legitimate reasons, and you may object in whole or in part to the processing of your personal information for the purpose of sending advertising materials or direct selling or else for the performance of market surveys or commercial communication performed through automated (email, fax, text/SMS and MMS messaging) or traditional (mail and calls from operators) contact means. In case you prefer the processing being performed only through traditional contact means you can object to the processing of your personal information performed through automated contact means.
You can exercise the aforementioned rights by writing to the Data Controller at the following address:
Address: Polpo Holdings, LLC., CRM Manager 1209 Orange Street, Wilmington, New Castle County, Delaware 19801 (USA).