Privacy policy

INFORMATION ON THE PROCESSING OF PERSONAL DATA pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR).

 
Data Controller
Niccolò Chiuppesi
Via Tortona, 18 - 20144 Milano
P.IVA 01528330523 - Iscr. REA di Milano 2611585
Controller email address: info@bennuofficial.it
Definitions and References
Personal Data (or Data)
Personal data is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.
Usage Information
This is the information collected automatically through this Application (including by third party applications integrated into this Application), including: IP addresses or domain names of computers used by the User who connects to this Application, URI (Uniform Resource Identifier) addresses, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.). ) the country of origin, the characteristics of the browser and the operating system used by the visitor, the various temporal connotations of the visit (for example, the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User's IT environment.
User
The individual using this Application who, unless otherwise specified, is the Data Subject.
Subject
The individual to whom the Personal Data relates.
Data Processor (or Processor)
The physical person, legal entity, public administration and any other entity that processes personal data on behalf of the Data Controller, as set forth in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, service or other body that, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.
Application
The hardware or software tool by which Users' Personal Data are collected and processed.
Service
The Service provided by this Application as defined in the relevant terms (if any) on this site/application.
European Union (or EU)
Unless otherwise specified, any reference in this document to the European Union shall be deemed to extend to all current member states of the European Union and the European Economic Area.
Cookie
I Cookie sono Strumenti di Tracciamento che consistono in piccole porzioni di dati conservate all'interno del browser dell'Utente.
Tracking Tool
Tracking Tool means any technology - e.g., cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting - that allows Users to be tracked, for example, by collecting or storing information on the User's device.
Types of Data Collected
Among the Personal Data collected by this Application, either independently or through third parties, are: Tracking Tool; Usage Data; email; first name; last name; phone number; province; country; zip code; city; physical address; billing address; shipping address; payment information; device information.
Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informational text displayed prior to the collection of the data itself.
Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected during the use of this Application.
Unless otherwise specified, all Data requested by this Application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In the cases in which this Application indicates some Data as optional, the Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
Users who may have doubts as to which Data is mandatory are encouraged to contact the Data Controller.
The possible use of Cookies - or of other tracking tools - by this Application or by the owners of third party services used by this Application, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy, if available.
The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability towards third parties.
Method and place of processing of collected data
Mode of process
The Owner adopts appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The treatment is carried out through computer and/or telematic instruments, with organizational methods and logics strictly related to the indicated purposes. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller, may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.
Legal basis of the process
The Data Controller processes Personal Data relating to the User if one of the following conditions exists:
  • The User has given consent for one or more specific purposes; Note: in some jurisdictions, the Controller may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, until the User objects ("out-out") to such processing. However, this does not apply where the processing of Personal Data is governed by European legislation on the protection of Personal Data;
  • the processing is necessary for the execution of a contract with the User and/or the execution of pre-contractual measures;
  • the processing is necessary to comply with a legal obligation to which the Controller is subject;
  • the processing is necessary for the performance of a task carried out in the public interest or in the exercise of public authority vested in the Data Controller;
  • the processing is necessary for the pursuit of the legitimate interest of the Owner or third parties.
However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.
Location
The Data are processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For further information, please contact the Data Controller.
The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the location of the processing, the User may refer to the section on Personal Data processing details.
The User has the right to obtain information on the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or formed by two or more countries, such as the UN, as well as on the security measures adopted by the Data Controller to protect the Data.
L’Utente può verificare se abbia luogo uno dei trasferimenti appena descritti esaminando la sezione di questo documento relativa ai dettagli sul trattamento di Dati Personali o chiedere informazioni al Titolare contattandolo agli estremi riportati in apertura.
Preservation period
Data is processed and stored for the time required by the purposes for which it was collected.
Therefore:
  • Personal Data collected for purposes related to the performance of a contract between the Controller and the User will be retained until the performance of such contract is completed.
  • Personal Data collected for purposes attributable to the legitimate interest of the Controller will be retained until such interest is satisfied. You may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.
When processing is based on Your consent, the Controller may retain Personal Data longer until such consent is revoked. In addition, the Controller may be required to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the storage period, the Personal Data will be deleted. Therefore, at the end of this period, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.
Purposes of Data Processing
The User's Data are collected to allow the Data Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), identify any malicious or fraudulent activities, as well as for the following purposes: Statistics, SPAM protection, Access to accounts on third party services, Contacting the User, Payment management, Platform and hosting services and Viewing content from external platforms.
To obtain detailed information on the purposes of the processing and the Personal Data processed for each purpose, the User may refer to the "Personal Data Processing Details" section.
Facebook permissions required by this application
This Application may require certain Facebook permissions that allow it to perform actions with the User's Facebook account and collect information, including Personal Data, from it. This service allows this Application to connect with the User's account on the social network Facebook, provided by Facebook Inc.
For more information on the following permits, please refer to the
Facebook Permission Documentation
and 
Facebook Privacy Policy
The required permits are as follows:
Basic information
The basic information of the User registered on Facebook which normally includes the following Data: id, name, image, gender and language location and in some cases the Facebook "Friends". If the User has made additional Data publicly available, the same will be available.
Tracking Tool
Tracking Tool means any technology - e.g., cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting - that allows Users to be tracked, for example, by collecting or storing information on the User's device.
Personal Data Processing Details
Personal Data is collected for the following purposes and using the following services:
Access to accounts on third-party services
This type of services allow this Application to collect Data from your accounts on third party services and perform actions with them.
These services are not activated automatically, but require the express authorization of the User.
Facebook Account Login (Facebook, Inc.)
This service allows this Application to connect with the User's account on the social network Facebook, provided by Facebook, Inc.
Permissions Required: Tracking Tool.
Place: United States – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
Mailing list or Newsletter
By registering to the mailing list or newsletter, the User's email address is automatically added to a list of contacts to whom email messages containing information, including information of a commercial and promotional nature, relating to this Application may be sent. The User's email address may also be added to this list as a result of registering with this Application or after making a purchase.
Personal Data Processed: Zip code; city; last name; email; physical address; country; name; phone number; province; Tracking Tool.
Category of personal information collected under the CCPA: identifiers; Internet information.
Payments
Unless otherwise specified, this Application processes all payments by credit card, bank transfer or other means through external payment service providers. In general, and unless otherwise specified, Users are asked to provide payment details and personal information directly to such payment service providers.This Application is not involved in the collection and processing of such information: instead, it will only receive notification from the payment service provider in question that payment has been made.
Apple Pay (Apple Inc.)
Apple Pay is a payment service provided by Apple Inc. that allows you to make payments using your cell phone.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place: United States  – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
Google Pay (Google Ireland Limited)
Google Pay is a payment service provided by Google Ireland Limited, which allows the User to make online payments using their Google credentials.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place: Ireland – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
Platform and hosting services
These services are intended to host and operate key components of this Application, making it possible to deliver this Application from a single platform. These platforms provide the Owner with a wide range of tools such as, for example, analytical tools, for managing user registration, for managing comments and the database, for e-commerce, for processing payments etc. The use of these tools involves the collection and processing of Personal Data.
Some of these services operate through servers located geographically in different locations, making it difficult to determine the exact location where Personal Data is stored.
Shopify (Shopify International Limited)
Shopify is a platform provided by Shopify Inc. that allows the Owner to develop, operate and host a website dedicated to e-commerce.
Shopify is a platform provided by Shopify Inc. that allows the Owner to develop, operate and host a website dedicated to e-commerce.
Place: Ireland – Privacy Policy.
Category of personal information collected under the CCPA: identifiers; business information; Internet information.
This type of processing constitutes a "sale of data" ("sale") under the CCPA. In addition to the information contained in this clause, the User may consult the section describing California consumer rights for information regarding how to opt-out of the sale.

Displaying content from external platforms

This type of service makes it possible to display content hosted on external platforms directly from the pages of this Application and to interact with them.This type of service may, however, collect data on web traffic relating to the pages where the service is installed, even when users do not use it.

Widget Video YouTube (Google Ireland Limited)

YouTube is a video content viewing service managed by Google Ireland Limited, which allows this Application to integrate such content into its pages.
Personal Data Processed: Usage Data; Tracking Tool.
Place: Ireland – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes a "sale of data" ("sale") under the CCPA. In addition to the information contained in this clause, the User may consult the section describing California consumer rights for information regarding how to opt-out of the sale.
SPAM protection
This type of service analyzes the traffic of this Application, potentially containing Personal Data of the Users, in order to filter it from parts of traffic, messages and contents recognized as SPAM. Google reCAPTCHA (Google Ireland Limited)
Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
Use of the reCAPTCHA system is subject to the Google Privacy Policy and Terms.
Personal Data Processed: Usage Data; Tracking Tool.
Place: ireland – Privacy Policy
Category of personal information collected under the CCPA: Internet information.
SPAM protection
The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to track User behavior. Google Analytics with anonymized IP (Google Ireland Limited)
Google Analytics is a web analysis service provided by Google Ireland Limited ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google.
Google may use the Personal Data to contextualize and personalize the ads of its advertising network.
This Google Analytics integration anonymizes your IP address. The anonymization works by shortening the IP address of the Users within the borders of the member states of the European Union or other countries that are members of the Agreement on the European Economic Area. Only in exceptional cases, the IP address will be sent to Google's servers and shortened within the United States.
Personal Data Processed: Usage Data; Tracking Tool.
Place: Ireland – Privacy Policy  Opt Out.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes a "sale of data" ("sale") under the CCPA. In addition to the information contained in this clause, the User may consult the section describing California consumer rights for information regarding how to opt-out of the sale.
 
Google Analytics (Google Ireland Limited)
Google Analytics is a web analytics service provided by Google Ireland Limited ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google.Google may use the Personal Data to contextualize and personalize ads in its advertising network.
Personal Data Processed: Usage Data; Tracking Tool.
Place: Ireland – Privacy Policy  Opt Out.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes a "sale of data" ("sale") under the CCPA. In addition to the information contained in this clause, the User may consult the section describing California consumer rights for information regarding how to opt-out of the sale.
User Rights
Users may exercise certain rights with respect to the Data processed by the Data Controller.
In particular, the User has the right to:
  • revoke consent at any time. The User may revoke the consent to the processing of their Personal Data previously expressed.
  • oppose the processing of their Data. You may object to the processing of your Data when it is done on a legal basis other than consent. Further details on the right to object are set out in the section below.
  • access to their own Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
  • verify and request correction. The User may verify the correctness of his or her own Data and request that it be updated or corrected.
  • obtain the limitation of the treatment. When certain conditions are met, the User may request the restriction of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
  • obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User may request the deletion of their Data by the Data Controller.
  • receive their Data or have them transferred to another owner. The User has the right to receive his or her Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another controller. This provision is applicable when the Data is processed by automated means and the processing is based on the User's consent, a contract to which the User is a party or contractual measures related thereto.
  • Propose a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.
Details of the right to object
When Personal Data are processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.
Users should note that if their Data were processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether the Data Controller processes data for direct marketing purposes, Users may refer to the respective sections of this document.
How to exercise your rights
In order to exercise the User's rights, Users may address a request to the contact details of the Controller indicated in this document. Requests are filed free of charge and processed by the Controller as soon as possible, in any case within one month.
Cookie Policy
This Application makes use of Tracking Tools. To learn more, the User can consult the Cookie Policy.
More information about the treatment
Legal defense
The User's Personal Data may be used by the Owner in court or in the preparatory phases of its possible establishment to defend against abuse in the use of this Application or related Services by the User.
The User declares that he/she is aware that the Owner may be obliged to disclose the Data by order of public authorities.
Specific disclosures
At the request of the User, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.
System logs and maintenance
For operational and maintenance purposes, this Application and any third party services used by it may collect system logs, i.e. files that record interactions and may also contain Personal Data, such as the User's IP address.
Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.
Response to "Do Not Track" requests
This Application does not support "Do Not Track" requests.
To find out whether any third party services used support them, the User is invited to consult their respective privacy policies.
Privacy policy edits
The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Application as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details in its possession. Therefore, please consult this page frequently, referring to the last modification date indicated at the bottom.
If the changes affect processing whose legal basis is consent, the Data Controller will collect the User's consent again, if necessary.

Legal references
This privacy policy is written on the basis of multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy policy applies exclusively to this Application.
Last edit: September, 20th 2021