Coli Politimi follows all necessary procedures to ensure the protection of your privacy. Thus, we assure you that any personal information that you may need to provide us, will comply with the terms of this privacy statement.
1.1 We are committed to safeguarding the privacy of Coli Politimi visitors and customers; in this policy we explain how we will handle your personal data.
1.2 This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data. We process this data in accordance with the General Data Protection Regulation 2016/679 (GDPR) from the date it applies.
1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive marketing communications and limit the publication of your information. You can access the privacy controls through your account settings in the “My Account Page”.
1.5 In this policy, “we”, “us” and “our” refer to Coli Politimi.
- How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services and provide a better usage experience. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your consent at the time you create an account with us.
2.4 We may process information that you post for publication on our website such as articles, comments, reviews or testimonials (“publication data”). The publication data may be processed for the purposes of enabling such publication. The legal basis for this processing is your consent at the time you submit this data.
2.5 We may process information contained in any inquiry you submit to us regarding goods and/or services (“inquiry data”). The inquiry data may be processed for the purposes of offering a requested product and/or service and it’s strictly used for this purpose and not for marketing unsolicited products in the future. The legal basis for this process is your consent as you contacted us for this purpose.
2.6 We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your contact details, and information contained in communications between us and you. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, providing the requested services and keeping records of those communications. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
2.7 We may process information relating to transactions, including purchases of goods, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your payment details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and keeping proper records of those transactions. The legal basis of this processing is the performance of the requested transaction, namely the supply of the requested goods and/or services.
2.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent.
2.9 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communication with users.
2.10 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Providing your personal data to others
3.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.2 We disclose your account data and customer relationship data to our shipping partners as reasonably necessary for the shipment of your purchases and only for that. We may disclosure your usage data and account data only after your consent to our marketing partner Mailchimp for the specific marketing purposes you consent to choose. We may disclose your usage data to our live chat partner LiveChat if you choose to contact us via their service or/and for the purposes of analyzing the use of our website.
3.3 Financial transactions relating to our website and services are handled by our payment services providers, namely Paypal and 2Checkout. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at:
3.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA). In all instances where data is internationally transferred, all partners involved participate in and comply with the appropriate safeguards, namely with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework.
4.2 The hosting facilities for our website, our payment gateway 2Checkout, our live chat partner LiveChat and our marketing partner Mailchimp are situated in USA.
4.3 You acknowledge that publication data that you submit for publication through our website may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
- Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) usage data will be retained for a maximum period of 26 months.
(b) publication data and notification data will be retained indefinitely and will be deleted only after your request.
5.4 In the cases of account data, inquiry data, customer relationship data, transaction data and correspondence data it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on section 5.2.
5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
- Your rights
7.1 In this Section 7, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting My Account section when logged into our website.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means,
you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us by contacting us by e-mail.
- Third party websites
8.1 Our website includes hyperlinks to, and details of, third party websites.
8.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
- Personal data of children
9.1 Our website and services are targeted at persons over the age of 16.
9.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
- Updating information
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
- About cookies
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
- Cookies that we use
(a) Necessary Cookies – these cookies, related to specific modules make the website usable by enabling basic and critical functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies, so they are by default enabled. These are the Prestashop-XXX Cookies and the cookies used within this category are:
date_add: The date and time the cookie was created (in YYYY-MM-DD HH:MM:SS format). id_currency: The ID of the selected currency currency. last_visited_category: The ID of the last visited category of product listings. ajax_blockcart_display: Whether the cart block is "expanded" or "collapsed". viewed: The IDs of recently viewed products as a comma-separated list. id_wishlist: The ID of the current wishlist displayed in the wishlist block. checkedTOS: Whether the "Terms of service" checkbox has been ticked (1 if it has and 0 if it hasn't) id_guest: The guest ID of the visitor when not logged in. id_connections: The connection ID of the visitor's current session. id_customer: The customer ID of the visitor when logged in. customer_lastname: The last name of the customer. customer_firstname: The first name of the customer. logged: Whether the customer is logged in. email: The email address that the customer used to log in. id_cart: The ID of the current cart displayed in the cart block. checksum: The Blowfish checksum used to determine whether the cookie has been modified by a third party. The customer will be logged out and the cookie deleted if the checksum doesn't match.
(b) Preference cookies – these cookies allows customers to choose their preferred currency and post blog comments (cookies used for this purpose are: id_currency: The ID of the selected currency currency).
- Cookies used by our service providers
- Managing cookies
14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
14.2 Blocking all cookies will have a negative impact upon the usability of many websites.
14.3 If you block cookies, you will not be able to use all the features on our website.
14.4 You can always change your cookies preferences by clicking on the “Control your privacy” button.