Information to Data Subject based on art. 13 and 14 of EU Regulation 2016/679
1.1 We care and are committed to protecting the personal data of visitors of our website and users of our services. With this document we provide the data subjects with the information on the processing provided for by art. 13 and 14 of the Regulation EU 2016/679 - General Data Protection Regulation ("GDPR").
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service user; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 The Data Controller of the processing is Target94 Sagl, and its legal representative, who can be contacted at the email address firstname.lastname@example.org. In this document we refer as "we", "us" and "our" to Target94 Sagl or the Data Controller.
2. How we use your personal data
2.1 In this Section we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) 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. Our analytics tracking system (Google Analytics) processed these data and produces aggregate anonymous reports for the purposes of analyzing the use of the website and services.
The legal basis for this processing is our legitimate interests of monitoring and enhancing our website and services (article 6.1.f), applicable because the anonymous form of the report does not present any risks for the individual data subjects.
2.3 We may process information contained in any enquiry you submit to us via telephone, email, web or social networks regarding our goods and/or services ("enquiry data"). Enquiry data may include Name, Last Name, language, telephone or fax number, email. Enquiry data may be processed for the purposes of offering and selling relevant services to you.
The legal basis for this processing is to take steps at the request of the data subject prior to entering into a contract (art. 6.1.b).
2.4 Within the Service Data we may process only Name, Last Name, Telephone and email to perform direct marketing activities for goods and services similar to the ones you have already purchased from us.
The legal basis for this processing is the art. 130 of the Italian Privacy Code (D.Lgs 108/18) that allows us to perform direct marketing activities without consent of the data subject, provided that he can exercise the right to stop such processing.
2.5 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions.
The legal basis for this processing is the performance of a contract between you and us (art. 6.1.c) a legal obbligation (art. 6.1.c) that we, as Data Controller, have to maintain proper fiscal records of the transactions.
2.6 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, n7mely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.7 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.8 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.
2.9 Please do not supply any other person's personal data to us, unless we prompt you to do so.
3. Transferring 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 defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.2 In addition to the specific disclosures of personal data set out in this Section, 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 defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. Retaining and deleting personal data
4.1 This Section 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. In general the retention period is set to 10 years.
4.2 Personal data that use for direct marketing purposes will be kept as long as data subject does not request to stop the processing.
4.3 Notwithstanding the other provisions of this Section 4, 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.
5.1 We may update this policy from time to time by publishing a new version on our website.
5.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
5.3 We may notify you of changes to this policy by email.
6. Your rights
6.1 In this Section, we have summarized the rights that you have under GDPR. 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.
6.2 Right to access - 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.
6.3 Right to rectification - 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.
6.4 Right to erasure - 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 compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
6.5 Right to restrict processing - 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 defence 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 defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
6.6 Right to object to processing - 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 defence of legal claims.
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.
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.
6.7 Right to data portability - 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.
6.8 Right to complain to a supervisory authority - 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.
6.9 Right to withdraw consent - 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.
6.10 You may exercise any of your rights in relation to your personal data by written notice to us at our email address email@example.com
7. About cookies
7.1 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.
7.2 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.
7.3 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.
8. Cookies that we use
9. Cookies used by our service providers
10. Managing cookies
10.1 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:
(b) Mozilla Firefox;
(e) Apple Safari; e
(f) Microsoft Edge.
10.2 Blocking all cookies will have a negative impact upon the usability of many websites.
10.3 If you block cookies, you will not be able to use all the features on our website.
11. Our details
11.1 The Data Controller is Target94 Sagl.
11.2 Our principal place of business is at Via Camara 60, CH-6932 Lugano/Breganzona – Switzerland.
11.3 You can contact us:
(a) by post, to the postal address given above;
(b) by telephone, on the contact number published on our website; or
(c) by email, using the email address published on our website.