Privacy Policy

PERSONAL DATA PROCESSING POLICY FOR COMMERCIAL PURPOSES

In accordance with articles 13 and 14 of EU Regulation 2016/679 – General Data Protection Regulation (hereinafter, the “Regulation”), we hereby inform you that Gruppo UNA S.p.A., as data controller, will process certain personal data relating to you, or to the person who will enjoy the benefits of the Gift Card (as defined below), for the purposes set out below.

Who will process the personal data?

The data controller of your personal data is Gruppo UNA S.p.A. (www.gruppouna.it), with headquarters in Milan, Via Gioacchino Murat, 23 (hereinafter, also, the "Company"). 

What personal data will we process?

The following categories of personal data will be processed (hereinafter referred to as the “Data” or “your Data”):

a) personal information (e.g. first name, last name, and date of birth);
b) contact details (email address).

It should be noted that the purchaser of the Gift Card (as defined below) may provide Data relating to the person who will enjoy the benefits of the Gift Card: in this case, this personal data processing policy is provided to the latter in accordance with article 14 of the Regulation.

Why do we process the Data?

Your Data may be processed for the purposes and on the basis of the following legal grounds:

  • (F1) – The purchase of gift cards for Gruppo UNA services ("Gift Card"): the data processing is for the purpose of the purchase of the Gift Card and its related use to benefit from Gruppo UNA services.
  • (F2) Administrative and accounting purposes: processing takes place for the purpose of fulfilling the administrative and accounting requirements resulting from the sale of the Gift Card, as well as to allow compliance with the related regulatory obligations that are applicable from time to time.
#Categories of DataLegal basisProviding the Data
F1a); b);The need to perform a contract to which the data subject is a partyThe provision of your data is necessary to achieve the purpose indicated above; if you do not provide it, you will not be able to purchase the Gift Card.
F2a)Compliance with regulatory obligationsThe provision of your data is essential to achieve the purpose indicated above; if you do not provide it, you will not be able to purchase the Gift Card.

How do we process your Data?

Your data will not be made public. The processing will be carried out using procedures and methods, including computerised methods, relevant to the purposes pursued. Your data may be disclosed, within our company organisations, to staff authorised to carry out processing operations and trained in this regard, as well as to designated third party companies responsible for processing, who are entrusted with the execution, on our behalf, of certain technical and organisational operations strictly necessary for the performance of the aforementioned activities.

Your data will be stored in full compliance with the security measures required by privacy legislation (considered adequate to avoid compromising the confidentiality, integrity and availability of data).

Who will we disclose the Data to?

The Data will not be distributed but may be disclosed to third parties, where strictly necessary, solely for the purposes set out above. In particular, the Data may be disclosed to:

  • third-party companies (for example companies providing commercial and/or promotional services), who perform certain activities on our behalf and with whom we have agreements governing the processing of personal data.

For the aforementioned purposes, your Data will be transferred to countries outside the European Union or the European Economic Area (in particular, to the USA); this transfer is carried out on the basis of the safeguards provided for in the Regulation, and in particular on the basis of standard contractual clauses signed between the Data exporter and the importer. 

How long will we process the Data for?

Your Data will be retained for the time strictly necessary to pursue the purposes indicated above. Once this period has elapsed, it will no longer be used for the aforementioned purposes.

In detail:

Purpose

Retention time
F1For the duration of the validity of the Gift Card (as established by the contractual regulations)
F2For ten (10) years from the last accounting entry

Your rights

Privacy legislation (Articles 15 to 22 of the Regulation) guarantees you the right to access your Data at all times, to have it corrected and/or supplemented, if inaccurate or incomplete, deleted if it is processed unlawfully, and the portability of the data that you have provided to us, if processed automatically on the basis of your consent or for the contractual services you have requested, within the limits of the provisions of the Regulation (Article 20). 

Privacy legislation also gives you the right to request the restriction of the processing of data, if the conditions are met, and to object to the processing on grounds relating to your particular situation. 

The Data Protection Officer is available if you require any clarification about the processing of your Data and if you wish to exercise your rights: you can contact them at privacy@gruppouna.it.

This does not affect your right to contact the Data Protection Authority, including by lodging a complaint, where deemed necessary, to protect your Data and your rights.