Sease S.r.l. (hereinafter, "Sease") provides the following information in compliance with articles 13 and 14 of European Regulation 2016/679 (or General Data Protection Regulation, hereinafter "G.D.P.R.") and subsequent Italian adaptation legislation (hereinafter indicated, jointly with the G.D.P.R., as the "Applicable Privacy Law"), making it available to all users who use Sease’s website (hereinafter, the "Website") at the address https://www.sease.it
Indeed, while consultating the Website, information relating to users may be collected; according to the Applicable Privacy Law, this information is personal data.
The information is provided exclusively for the aforementioned Website and does not concern any other websites that can be reached by the user through the Website’s links.
The Data Controller of the user’s data is Sease S.r.l., with registered office in Via Enrico Toti 2, 20123, Milano (MI). firstname.lastname@example.org Tel. +39 02 35 945 444
Types of processed data
Personal data automatically acquired when visiting the Website
- Navigation data. Sease automatically collects data on the device (PC, tablet, mobile phone or other mobile devices) and the user’s connection, including, for example, the IP address, the date and time of access, information on the hardware and software, device event information, unique identifiers, crash data, and the pages viewed by the user before or after using the Website.
These data are collected, even if the user has not logged into the account created on the Website, or, in any case, even if the user has not created any account on the Website.
- Data relevant to the use of the Website. Sease collects information on how the user has used the Site, including, for example, the pages of the Website or other content viewed, any searches performed, third-party applications on the Website that are used by the user (for example, the map and other features of Google Maps present in the "Contact" section) and links to other websites and applications that the user has clicked.
Personal data provided directly by the user
Data required to use the account created on the Site, and to make purchases on the Site
- Data provided for account registration. When a user registers on the Site by creating an account, Sease collects the information required for account creation, namely e-mail address, first name, last name, address, zip code, city, country, and phone number (for individuals), business name and VAT number (for businesses), and shipping address.
- Data provided for account registration. When a user registers on the Site by creating an account, Sease collects the information required for account creation, i.e., e-mail address, first name, last name, address, zip code, city, country, and phone number (for individuals), business name and VAT number (for businesses), and shipping address.
- Transaction Data. Sease collects information related to the transactions you make on the Site, including any data you provide for account registration, as well as the payment instruments used, the date and time of payment, amounts paid, and other details related to the transaction. This information is necessary for the smooth and proper performance of the contract entered into between Sease and you, and to enable you to finalize your purchases made on the Site.
- Shipping Data. Sease collects information about shipments of products purchased by the user on the Site, such as the user's billing address, user-buyer address, and order numbers
- Dati forniti mediante richieste d’informazioni via e-mail. Se l’utente, per richiedere informazioni, invia in modo esplicito e volontario posta elettronica agli indirizzi indicati sul Sito, Sease acquisisce l’indirizzo e-mail dell’utente e gli eventuali altri dati personali dell’utente (e/o di terzi) inseriti nella comunicazione elettronica.
- Dati forniti per l’attivazione del servizio di newsletter. Se l’utente decide di attivare il servizio di newsletter offerto da Sease, quest’ultima raccoglie l’indirizzo e-mail dell’utente.
Personal data collected via cookies
The processing purposes include ensuring the operation of the Website; fulfilling the contractual obligations towards the user and providing the user with the services that Sease provides through the Website; protecting the user’s vital interests; complying with current legislation or fulfilling legal obligations and other needs of public interest.
The user’s personal data are processed as follows:
- to conclude and execute the contract for the purchase of products that Sease sells on the Website;
- to provide the services offered on the Website;
- to manage requests sent to the e-mail address;
- to operate, monitor and improve the Website and the services provided by Sease through its Website;
- to enable account management and payment processing;
- to keep the Sease’s website services safe, secure and operational;
- to communicate the user information relevant to the account and fix any account problem;
- to resolve disputes with the user, to recover payments and other sums due or necessary to provide Sease’s Website services;
- to prevent, detect, mitigate and investigate fraud, security breaches and potentially prohibited or illegal activities.
To pursue Sease's legitimate interests in such a way that these interests do not prevail over the user’s fundamental rights and freedom.
The user’s personal data are processed as follows:
- to identify and solve problems that the user may have while using the Website (for example, blocked or non-functioning pages) and to provide the user with a better experience;
- to collect statistical information, in aggregate form, on the number of users who visit the Website (as unique visitors) and on the ways in which users visit the Website;
- to carry out surveys and market research; to send customized promotional and commercial communications to registered users (that is, communications on products that are deemed of interest to the user based on the analysis of purchases made and information on user navigation on the Website, such as the products viewed or placed in the cart).
To carry out marketing operations after getting the user’s consent.
- If the user has subscribed to the newsletter and provided his/her consent, which can be withdrawn at any time according to the methods that will be described later, his/her data can be processed for the following:
- to send the user (by e-mail) marketing information, advertising, information on promotions and special discounts and updates on the services offered by Sease.
If the user has subscribed to the newsletter, with the user's consent (revocable at any time, in the manner to be described later) his or her data may be processed to send the user (via e-mail) marketing information, advertising, information on special promotions and discounts, and updates on services offered by Sease.
Duration of processing
Personal data will be kept for a limited period of time, which varies according to the purpose for which they are processed, after which the data will be definitively canceled or, in any case, made anonymous in an irreversible way.
The specific retention times of the user's personal data are recorded in the Sease’s processing activity register, which is implemented pursuant to article 30 of the G.D.P.R.
The user's personal data are kept (according to the criteria referred to in recital 39 and in article 5, paragraph 1, letter e) of the GDPR) for a period proportionate to the operational needs of the Website, as well as the provision of services that Sease provides through its Website (it being understood that the user can always exercise the rights recognized by the Applicable Privacy Law, as specified below).
The user's personal data may be stored (according to recital 65 of the GDPR) for longer periods than those just written only if the longer retention period is necessary for the Organization to fulfill the applicable legal, administrative and accounting obligations or to ascertain, exercise or defend its right in court, or to pursue other needs of public interest (for example, in the case of ascertained orders from Public Authorities or Judicial Authorities relating to the retention of personal data following of an investigation).
If the user has given consent to the processing of his/her data for marketing purposes, the user can withdraw his/her consent at any time (see below).
The data processing carried out by Sease involves personnel that are duly trained and authorized by Sease. The data will be communicated externally only when this is indispensable with respect to the processing purposes indicated above. As part of the execution of the Website services and to execute a sales contract, the data may be processed by Sease's suppliers who have been evaluated and chosen by Sease for their proven reliability and competence.
Sease, therefore, will communicate the users' personal data only and exclusively to the subjects and for the purposes given below.
Execution of shipments and payments; fight against illegal acts, fraud and security breaches
- Sease will communicate the users' personal data (within the limits of what is necessary to satisfy the related processing purposes) to third parties who provide Sease with services, particularly third parties involved in processing payments, preventing and detecting potentially illegal acts, fraud and security breaches (and mitigate their negative effects on users), and in collecting invoices.
- More precisely, Sease will communicate users' personal data, if necessary, to the following: e-mail service providers, Internet Service Providers, companies specializing in IT and telematic services, companies providing customer assistance services, companies offering marketing services, companies specializing in market research and data processing and bank operators.
- Sease will communicate users' personal data (within the limits of what is necessary to satisfy the related processing purposes) to third parties who provide shipping services, with whom delivery addresses, contact information and order numbers will be shared in order to facilitate the delivery of purchased items and the communications related to the delivery.
- These communications of user data allow the regular and adequate execution of the service provided by Sease.
Application of the law, judicial proceedings and methods authorized by law
Sease may communicate users' personal data to courts, public authorities, governmental authorities or authorized third parties, in the event and to the extent that it is required or authorized to do so by law, or if such communication is reasonably necessary. These communications will have the following purposes:
- to fulfill Sease's legal duties;
- to respond to claims made against Sease;
- to comply with verified requests relating to a criminal investigation or an alleged illegal activity or any other activity likely to expose Sease or users to legal liability;
- to protect the rights, property or personal safety of Sease, its employees, users or the general public.
Legal bases of the treatment
Sease processes the personal data only if one of the conditions established by current legislation occurs (so-called "legal bases" or "conditions of lawfulness"), and specifically as follows:
a) For the need to execute a contract of which the user is a part.
This legal basis legitimizes the processing of personal data that takes place in the following activities:
- conclusion and execution of a contract for the purchase of the products offered on Sease’s Website;
- logging in the Website and using the services reserved for registered users;
- provision of the services offered on the Website.
The provision of the user's personal data for these activities is optional and, depending on the case, is required for the conclusion or execution of a contract. The user can choose whether to provide or not provide his/her data, but, if the user doesn’t provide the requested data, it will not be possible to conclude or execute the contract and the user's requests. This means that the user will not be able to purchase the products and use the services of Sease, log in to the Website, use the Website services and consequently Sease will not be able to manage the user’s requests.
b) Due to the need to fulfill a legal obligation imposed on us by law.
This condition of legitimacy authorizes Sease to process the data to fulfill the legal obligations to which it is subject. In particular, in the event of the conclusion of a contract for the purchase of goods from the Website, the processing of user data will take place to fulfill the legal obligations to which Sease is required in accordance with the tax provisions and other regulations to which Sease is subject.
The user can decide whether to provide us with the data and conclude a contract with Sease, and, if he/she does so, the data will necessarily be processed to implement the relevant legal obligations Sease is required to comply with.
c) On the basis of the user's consent.
We carry out the following treatments only if the user has given his/her express consent:
- sending our newsletters by e-mail;
- conducting opinion polls and market research;
- customizing the contents of the Website and sending customized marketing communications.
The user can decide whether to provide his/her personal data for these activities. Failing this, the user will not receive Sease newsletters regarding news and commercial promotions, personalized marketing communications, and Sease will not carry out opinion polls and market research.
d) For a legitimate interest of Sease or of a third party.
The data are processed on the basis of this condition of lawfulness in the following cases:
- analysis and statistical surveys to improve the commercial offer and services of the Website. In this case, processing is carried out on the basis of our legitimate interest in acquiring useful information to improve the quality and effectiveness of the commercial proposals and services offered by the Website. The provision of data for this type of processing is optional.
- prevention and repression of fraud, counterfeiting and abusive behavior. In this case, processing is carried out on the basis of the legitimate interest of Sease, the prevention and repression of fraudulent activities that may compromise the profitability of the Website and the safety of its users. The provision of data for this type of processing is optional, but it is the necessary to send an order and conclude a purchase contract and, failing that, this will not be possible.
- personalization of the contents of the Website for marketing purposes. In this case, processing is carried out on the basis of our legitimate interest in increasing the profitability of the Website by personalizing the users' browsing experience. The provision of data for this type of processing is optional. Failure to provide it, with opposition to the activity in question, will only make it impossible to view the personalized contents of the Website.
- to ensure the correct technical functioning and security of the Website. In this case, the processing is carried out on the basis of Sease's legitimate interest and to prevent and resolve situations that could compromise the functioning of the Website and its services and the user’s safety. The provision of data for this type of processing is optional, but it is required for browsing and using the Website and, failing that, this will not be possible.
- The protection of rights. In this case, processing is carried out on the basis of the legitimate interest of Sease or of a third party to protect their rights. The provision of data for this type of processing is optional, but it is required for browsing and using the Website and, failing that, this will not be possible.
Rights of the interested parties
Pursuant to the Applicable Privacy Law, - at any time, free of charge and without particular charges and formalities – the user has the right to the following:
- To object to data processing carried out for direct marketing purposes (such as sending newsletters via e-mail, sending promotional SMS, performing opinion polls, sending commercial/promotional communications via personalized e-mail);
- To obtain confirmation that Sease is processing their personal data;
- To access their personal data collected by Sease, and know the origin of the data, the purposes of the processing, the retention period (or the criteria useful for determining it) of the data, as well as information regarding the third parties to whom the data are being communicated;
- To withdraw consent at any time, in the event that this constitutes the basis of the processing. In any case, take note that the withdrawal of consent does not affect the lawfulness of the processing carried out before the withdrawal itself;
- To update or rectify their personal data collected by Sease, so that they are always exact and accurate;
- To exercise the right to be forgotten or arrange for the personal data collected by Sease to be deleted from Sease's databases and/or archives, including any backups. The user data will be deleted if:
- the data are no longer necessary for the purposes of the processing, or if the user has withdrawn his/her consent to data processing, if he/she has opposed the processing of his/her data (in the cases specified below), if his/her data have been processed unlawfully or if the Applicable Privacy Law provides for such cancellation; and furthermore if
- the processing of user data is not necessary for Sease for one of the reasons referred to in article 17, paragraph 3 of the G.D.P.R. (including, in particular, the fulfillment of a legal obligation that requires such processing; the pursuit of public interest needs; the assessment, exercise or defense of a right in court);
- to limit the processing of personal data by Sease, in the cases referred to in article 18, paragraph 1 of the G.D.P.R. (for example, where the accuracy of the data has been disputed);
- for the data processed to pursue needs of public interest or to pursue the legitimate interests of Sease, the user can object to their data processing at any time, unless Sease demonstrates that such data are processed for inescapable legitimate interests or for ascertaining, exercise or defense of their right in court;
- for data processed with the user's consent, or to fulfill contractual obligations towards the user and provide him/her with Sease services, the user has the right to receive such data in a proper format, commonly used and readable by an automatic device. The user can then transmit these data to third parties, without Sease being able to prevent this in any way;
- be notified, within a reasonable time, of any corrections, cancellations or limitations on processing ordered by Sease, as well as any revocation of such measures and the reasons underlying the revocation (for example, for limitations on processing, the expiry of the period of limitation, or the disappearance of the circumstances that caused the limitation of the processing: for example, for verifying the accuracy of the user's personal data).
The user can exercise these rights by sending a written request to Sease and emailing it to email@example.com
Once the aforementioned e-mail has been received, Sease, through the data controller, will satisfy the user's request without delay, and, in any case, at the latest within one month of receiving the request. This deadline may be extended by two months, if necessary, taking into account the complexity and number of requests. In the event of an extension, within one month of receiving the request, Sease will inform the user of the extension of the deadline and the reasons for the extension.
Sease reminds the user that, if he/she is not satisfied with the response, he/she can contact and lodge a complaint with the Guarantor Authority for the Protection of Personal Data (http://www.garanteprivacy.it/) in the ways provided for by the Applicable Privacy Law.
Date of last update: September 28th 2023