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Roberto Borghesi d.o.o. has its registered offices at Prečna Ulica 1, 6210 Sežana, Slovenia. In this Privacy Policy, we use the term Roberto Borghesi (and " we ", " us " and " our ") to refer to the head office of Roberto Borghesi at the registered address above.
Please take a moment to read the following policy which explains how we collect, use, disclose and transfer the personal information that you provide to us on our websites, mobile applications (together the “ Platforms ”), when you visit Roberto Borghesi boutique or contact us by telephone or when you interact with us over social media platforms. It also explains how we collect information through the use of cookies and related technologies when you use our Platforms.
Part 1 – Introduction
The protection of your data is important to us, so we have made it our mission to safeguard and protect your data and your rights in relation to data.
Personal data such as names, addresses, email addresses and telephone numbers are always processed in accordance with the General Data Protection Regulation, as well as with the country-specific data protection regulations relevant to us. This Privacy Policy contains information about the type of data that we collect, the extent to which we collect data and its purpose, and also about the rights that you have, provided that personal data has been collected or processed.
Throughout the Privacy Policy, we use various legal and technical terms. An explanation for these can be found in the section entitled “Definitions”.
As the persons responsible for data processing, we have taken various different technical and organizational measures to ensure the personal data that we process is protected as completely as possible. Internet-based data transfer can however create security gaps, which means that absolute protection cannot be guaranteed. For this reason, you also have the option to communicate personal data to us through alternative methods, i.e. by telephone.
This Privacy Policy applies to personal data of our customers and suppliers, as well as of the visitors to our website.
The company which is responsible for data processing (“ Roberto Borghesi ” or “we”) in accordance with the relevant Data Protection Laws (including the General Data Protection Regulation (Regulation (EU) 2016/679)) (“GDPR”) is:
Prečna Ulica 1
6210 Sežana – Slovenia
tel. +386(0)31425958
www.robertoborghesi.com
Important: Please note that this Privacy Policy may change from time to time. Please use this page to keep yourself up-to-date, as any possible future amendments will be made here.
If you do not agree with a certain aspect of our Privacy Policy, you are entitled to certain legal rights, where applicable. These are described in the respective section below.
Part 2 – Summary: Our Privacy Policy at a glance
What personal data do we collect?
User data:
If you are a customer of Roberto Borghesi d.o.o. we must collect and use certain personal data in order to provide the right services to you, e.g.: (1) to deliver goods or services (2) to complete gemological services, as well (3) as to provide you with information about Roberto Borghesi updates, features and offers which could be of interest to you.
A detailed description of which personal data we collect in this way can be found in the section entitled “Our Privacy Policy in detail”.
Supplier data:
We require certain information from our suppliers and providers in order to ensure that operations run smoothly. This includes taking contact details for the responsible person in your company in order to communicate with them. We also require further information such as your bank details, so that we can pay you for the services that you have provided (subject to contractual agreement).
A detailed description of the personal data that we collect about you can be found in the section entitled “Our Privacy Policy in detail”.
Visitors to the website:
We collect a limited amount of data from visitors to the website. This is to facilitate navigation on our websites and to better manage the services that we offer to you. The data we collect in this way comprises information about how you use our website and how often you access it.
Further information about the data that we collect about you when you visit our website can be found in the section entitled “Our Privacy Policy in detail”.
From whom is personal data collected?
User data:
We generally only collect your personal data directly from you.
Supplier data:
We only collect your personal data directly from you in the course of working together with you.
Visitors to the website:
When you visit the website, we automatically collect data using cookies in accordance with the cookie settings in your browser. We also collect data from you when you contact us via the websites, for example when you enter information into a contact form or use the chat function. Generally, we may collect certain data automatically as soon as you access our website or read or click on an email from us. More information about cookies and the choices that you can make relating to these can be found in the corresponding section in this Privacy Policy.
Why we collect personal data and what we use it for
User data:
We collect and use information about our customers (i.e. users) primarily to make sure that the contractual agreement between you and Roberto Borghesi is properly implemented in order to ensure a smooth business relationship. For example, we require personal data in order to process sale so that we can provide the products or services that you have ordered.
More information about how we use your personal data can be found in the section entitled “Our Privacy Policy in detail”.
Supplier data:
We use your personal data primarily for two reasons: The first is to make sure that the contractual agreement between you and Roberto Borghesi is properly implemented in order to ensure a smooth business relationship. The second is to ensure compliance with legal regulations.
More information about how we use your personal data can be found in the section entitled “Our Privacy Policy in detail”.
Visitors to the website:
We use your data to primarily facilitate navigation on our website.
More information about cookies, such as how we use them and which options are available to you can be found in in the section entitled “Our Privacy Policy in detail”.
Disclosure of personal data
User data
We transmit your personal data for the following reasons: (1) to payment service providers in our online store (2) to companies that dispatch emails for us and/or (3) or to companies that provide us with business services.
An overview of the possible categories of recipient to whom your personal data can be disclosed can be found in the section entitled “Our Privacy Policy in detail”.
Supplier data
Unless you have specified otherwise, we can disclose your information to any of our group companies as well as associated third parties, e.g. service providers and organizations which we use and provide services for.
An overview of the categories of recipient to whom your personal data can be given can be disclosed in the section entitled “Our Privacy Policy in detail”.
Visitors to the website
Unless you specify otherwise, we can give your information to web analytics service providers, affiliate networks, marketing automation platforms and social media services, in order to ensure that you only receive appropriately targeted advertisements.
In general, we reserve the right to also transmit your data to other countries outside the EU or EEA. In this case, we will however ensure a minimum level of data protection corresponding to the GDPR level of protection, through the appropriate arrangements.
Duration for which we store personal data
The criteria for the duration of storage for personal data is the respective legal retention period, after which the data will be deleted. In addition to this, we save the respective data only provided that they are still necessary for the fulfillment of a contract.
More information about our basic procedures relating to storage of personal data can be found in the section entitled “Our Privacy Policy in detail”.
Rights of the person affected – which rights do you have in relation to your personal data stored by us?
Even if we already hold your personal data, you are entitled to various rights with regard to this information. If you would like to talk to us regarding this, please do not hesitate to contact us. We will make every effort to take care of your query as soon as possible and every case will be treated in accordance with applicable legal regulations. Please note that we may record our communication in order to better solve the issues raised by you.
Insofar as we save your personal data, certain legal rights apply (the “rights of the person affected”), which we will outline here. More information about individual rights can be found in the section entitled “Our Privacy Policy in detail”.
Right to access information
At any time, you have the right to request us to confirm which information we have saved about you, and to request that this information be changed, updated, or deleted. We can then comply with your request. We also have the following options:
o We may ask you to confirm your identity, or request further information, and
o provided that this is permitted by law, we can decline your request. In this case, we will explain the reasons for doing so.
Right to objection:
If we use your data because we believe this is in our legitimate interests and you do not agree, you have the right to object. We will respond to your request within 30 days. In certain cases, we are entitled to extend this period. We will usually only disagree in very narrowly defined circumstances.
Right to revoke consent:
If we have obtained your consent to process your personal data for specific activities (for example, in order to send you advertisements), you can revoke this consent at any time.
Right to correction
You have the right to request that the personal data concerning you be immediately corrected or amended.
Right to deletion
In certain situations (for example, if we have unlawfully processed your data) you have the right to request us to delete your personal data. We will reply to your request within 30 days (in certain cases, we may however have the right to extend this period) and we will only disagree in very specific, narrowly defined circumstances – for example, if the data is absolutely necessary in order to continue to provide our services to you or to ensure the protection of our intellectual property. If we agree to your request, we will delete your data, but we will generally assume that you wish your name to be included in the list of persons that do not want to be contacted. In this way, we minimize the chance that you will be contacted in the future should your data be collected separately under other circumstances. If you do not wish this, please let us know.
Right to restrict processing
Instead of requesting deletion, you can also request from us that the processing of your data be restricted or blocked. We will also reply to this request within 30 days, except if we still need the data, for example in order to continue to provide our services to you or to ensure the protection of our intellectual property.
Right to data portability
Should you wish, you have the right to transfer your data from us to another person responsible. We will support you by transferring your data directly for you or by providing you with a copy in a standard machine-readable format.
Rights relating to automated decisions (profiling)
Under certain circumstances, you have the right not to be subject to a decision that has been based exclusively on automated processing and that will have legal effect against you. However, under certain circumstances we may have a legitimate interest in such automated decision-making.
Right of appeal to a regulatory body
You also have the right to lodge a complaint with a local regulatory body. Details about this can be found in the section entitled “Our Privacy Policy in detail”.
Use of cookies
Our websites/web services use “cookies”. Cookies are small text files that are saved on the hard drive of your PC (client) for a defined period.
Most cookies we use are deleted at the end of the browsing session (known as session cookies).
Other cookies stay on your computer and allow us to recognize your computer on your next visit (permanent or persistent cookies).
Cookies usually contain a “cookie ID”. This is a pseudonymized date in the form of a unique cookie identification. It consists of a series of characters that can be used to associate websites and the servers with a specific Internet browser (client) in which the cookie is saved.
Cookies are generally distinguished into first and third party cookies. First party cookies will only be assigned by the website that you are currently on (for example, the website under the domain bedbur.com).
Roberto Borghesi uses first party cookies for essential website functions, like for storing website settings, restoring sessions and for securing your session data. However, most areas of our website essentially work without the use of cookies.
Within this process, access only occurs in impersonalized form and exclusively when you visit our website. Other websites cannot access this information.
Third party cookies are set by a third party provider that has been authorized by Roberto Borghesi , i.e. not by the actual website that you are currently viewing.
By using cookies, we can adjust our offers to best meet customer preferences and can make browsing our site as convenient as possible for you (advertising, conversion tracking and personalization).
In addition, we use third party providers in order to collect online statistics (analytics) as a basis for measuring the success of our advertising offers and subsequently improving them. Even when cookies from third party providers are used, data is only accessed in an anonymized form.
An overview of third parties on our websites can be found in the section entitled “Our Privacy Policy in detail”.
All essential services from our website/web services essentially work without the use of third party cookies.
You may prevent the installation of cookies anytime by selecting the option “Do not accept cookies” in your browser. In addition, you can at any time delete cookies via your Internet browser or another software program. This can be done with any standard Internet browser.
Part 3: Our Privacy Policy in detail
A. Detailed information about the processing of user and supplier data
What personal data do we collect?
User data:
We collect some data about our customers and users that we require to implement contracts and for license management. We therefore require your email address in order to create a user account, which is required to deliver our products or services. We may also require further information from you (e.g. name, postal address, country of residence), for instance for signing up for emails, or downloading trials or subscribing to services. . You may also provide us with further data – this is optional. The specific data collected depends on the form or input mask used, or as requested by our support staff over the phone.
If for any reason we require additional personal data from you, we will let you know.
Supplier data:
We only collect data about suppliers insofar as this is necessary, in order to maintain a streamlined business relationship. We collect data about our contact person in your organization, and some names, telephone numbers and email addresses. We also collect bank data for the purpose of making payments to you. We can also collect additional information that someone from your organization has shared with us. In certain circumstances, e.g. if you have been in contact with our financial department or billing department, our telephone calls with you may be recorded, regardless of local regulations and requirements.
From whom is personal data collected?
We generally only collect your personal data directly from you.
Why we collect personal data and what we use it for
User data:
In general, we use data on our users and customers in the following ways:
a) Advertising measures
We may send you information at regular intervals that we believe to be of interest to you, and also inform you of certain discounts and special offers to which you are entitled as a result of your business relationship with us.
We require your consent for some aspects of these activities that are not covered by our legitimate interests (in particular for data collection using cookies and direct marketing to you through our digital channels). According to the circumstance, we will ask for your explicit consent via “opt-in” or silent consent via “soft opt-in”(see below).
Consent via “soft opt-in” is a specific form of consent that applies if you have had business dealings with us before (e.g. you have ordered a product from us or registered a domain with us) and we may advertise other products or services within this context. For consent via “soft opt-in”, we will consider your consent as provided, as long as you do not withdraw it.
You can revoke your consent at any time. More information about this can be found in the section that describes our Privacy Policy in detail.
Our advertising as a whole is based on entities that we consider to be especially helpful to our customers and users. However, we are aware that we do not always do things the right way for everybody. We may use your data to display you advertisements and other Roberto Borghesi content on other websites, e.g. Facebook. If you do not wish your data to be used in this way, please change the cookie settings in your browser, as described above. Even if you deactivate advertisement cookies, it’s possible that you may continue to receive Roberto Borghesi advertisements. If this happens, it is because the advertisement is targeted towards an anonymous target group and not towards you specifically.
b) Functionality of our products and services and security of our intellectual property rights
We are dependent on protecting our intellectual property rights, not least for the purposes of being able to offer you our products and services at their usual standard of quality and at attractive prices. In order to guarantee effective protection of our intellectual property and enable you, depending on the product, to use our software or service on several computers, each installation of our software or service is linked to your user account, where certain data must be obligatorily saved (minimum email address). It is only in this way that we can provide you with updates for your software or service. To guarantee smooth operability of our products or service, you are therefore required to provide us with the above mentioned data
c) Assertion, exercise or defense of legal rights
In unusual cases, we may also use your personal data in order to assert, exercise or defend legal rights.
We may use your personal data for these purposes if it corresponds with our legitimate interests. More information about what this means can be found in the section entitled “Our Privacy Policy in detail”.
Supplier data:
We will only use your information in order to conduct our business relationship with you in an optimal manner. To this end, we save your data in our database so that we can contact you in accordance with our agreement and can use your services. In unusual cases, we will use this data for the assertion, exercise or defence of legal rights.
Disclosure of personal data
We may share your personal data with the following categories of people in a variety of ways and for a variety of purposes, as appropriate and in accordance with local laws and regulations:
All company groups
Tax authorities, audit authorities or other authorities, if we in good faith believe that we are required by law or other regulation to disclose such information (for example, because of a request from a tax authority or in connection with an anticipated legal dispute)
External service providers that provide services in our name (including external email providers, auditors and accountants, technical support, e-commerce providers)
Marketing technology platforms and suppliers
If in future we merge with or are acquired by another company (or should meaningful discussion about such a possibility take place), we may disclose your personal data to the (future) new company owners.
In general, we reserve the right to also transmit your data to other countries outside of the EU or EEA. In this case, we will however ensure a minimum level of data protection corresponding to the GDPR level of protection, through the appropriate arrangements.
Duration for which we store personal data
We process and save personal data solely for the duration necessary for achieving the purpose for which the data was stored, or as stipulated in laws and requirements set by the European directive and regulation provider or another legislator to which we are subject.
If the storage purpose ceases to apply or if a storage period prescribed by European directive and regulation provider or another competent legislator expires, the personal data will be deleted routinely and in accordance with the statutory provisions.
How we protect your personal data
We will adopt all reasonable and appropriate measures to protect the personal data we have stored from misuse, loss or unauthorized access. To this end, we have taken a range of technical and organizational measures. This includes measures to deal with any suspected breaches of data.
If you believe that your personal data has been misused or has been lost or has been accessed without authority, please inform us immediately. Our contact details can be found in Part 1 of this Privacy Policy.
B: Detailed information about the use of our website
As mentioned above, we collect a limited amount of data from visitors to our websites in order to facilitate navigation of our websites and to better manage the services that we offer to you. You can use our websites without having to provide any personal data.
General data and information collection
Our websites collect a variety of general data and information each time one of their pages is loaded. This general data and information is saved to our server log files. Data that may be collected includes (1) browser types used and their versions, (2) operating system used, (3) the website from which an accessing system reaches our websites (what is known as a “referrer”), (4) subpages on our websites that are accessed by an accessing system, (5) date and time of visit to websites, (6) an Internet Protocol Address (IP address) and (7) any other similar data and information, that could serve as hazard prevention in the event of an attack on our IT systems.
No conclusions are drawn about the person concerned during the use of this general data and information. This information is required in order to (1) correctly transmit the content of our website, (2) optimize content of and advertising for our website, (3) guarantee the permanent functional operability of our information technology systems and technology for our website, and (4) in the event of a cyber attack, provide law enforcers with necessary information for prosecution. This anonymously collected data and information is therefore evaluated by us statistically and also with the aim of increasing data protection and data security in our company ultimately to ensure an optimum level of protection for the personal data processed by us.
Registration on our website
You can register your personal data on several of our websites, for instance by setting up a user account or signing up to a newsletter. The specific personal data you submit to Roberto Borghesi is dependent on the type of input mask used for registration. The personal data submitted by the person concerned will be collected and stored for the sole purpose of internal use and purposes by Roberto Borghesi . We may arrange for disclosure to one or more contract processors, who also use the personal data exclusively for an internal use that is attributable to us.
When registering on a Roberto Borghesi website, the IP address provided by your Internet service provider (ISP), date and time of registration will also be stored. This data is stored against the background that the misuse of our services can only be prevented in this manner and that this data may enable committed criminal offences to be investigated. In this respect, the storage of this data is necessary for Roberto Borghesi security reasons. This data will not be passed on to third parties unless required to do so by law or for the purpose of criminal prosecution.
Registration by voluntarily submitting data also enables us to offer you content or services that may only be offered to registered users due to the nature of the offer. Registered users are free to modify personal data submitted during registration or have them deleted in entirety from our database.
Upon request, we will provide you at any time with information about which personal data we have stored about you. We will also correct or delete personal data upon your request or notification, as long as this does not conflict with any legal storage obligations.
Subscription to our newsletters
Users have the option of subscribing to our newsletters via our websites. The specific personal data you submit to us when signing up to the newsletter is dependent on the type of input mask used.
You can only receive our newsletter if you (1) have a valid email address and (2) have registered for newsletter distribution.
When registering for the newsletter, the IP address provided by your Internet service provider (ISP), date and time of registration will also be stored. The collection of this data is necessary in order to track (potential) misuse of email addresses at a later point in time and therefore fulfils the purpose of legal protection for Roberto Borghesi . Personal data stored within the scope of registration for newsletters will only be used for the distribution of our newsletter. In addition, no data is disclosed to third parties. You can cancel the use of your email address for advertising purposes at any time by clicking “Unsubscribe” at the bottom of the newsletter. You can at any time revoke the consent you have granted for storing personal data in order to receive our newsletter.
Contact options via the website
Our websites contain legally required information, which enables us to be contacted rapidly in a direct manner, for instance by email. If you contact us by email or via a contact form, the personal data submitted by you will be stored automatically. We store this voluntarily submitted personal data for purposes of handling or to communicate with you; we will not pass it on to third parties.
Privacy policy for the payment methods offered - Payment options
During payment, you will be forwarded to the payment page of the respective provider. Data requested for completing the payment will be directly requested through the provider and we cannot view or access this information.
C. Your rights regarding the processing of personal data in detail
Insofar as we store your personal data or process this in additional ways, special legal rights apply (the “rights of the person affected”), which we will briefly outline here.
Right to access information
You have the right to demand a confirmation of which personal data about your person has been stored, at any time and for free. In addition you have the right to receive a copy of this information. The right to access information additionally covers:
the purpose for which the data is processed;
the categories of personal data that are processed;
the recipient or categories of recipients to whom the personal data has been or will be made available, in particular recipients in third countries or international organizations;
where possible, the planned duration for which the personal data will be saved or, where this is not possible to establish, the criteria for determining this duration;
the existence of a right to rectification or deletion of the personal data or to limit processing of this data by the party responsible or right to object to the processing of same;
the existence of a right to appeal through a supervisory authority;
the existence of meaningful information regarding the logic involved, as well as the scope and the desired effects of such processing on you.
You also have a right of access to information on whether personal data has been transferred to a non-EU country or to an international organization. If this is the case, you also have the right to obtain information about the appropriate guarantees in connection with the transmission.
Right to correction
You have the right to request that incorrect personal data concerning you be promptly corrected. You also have the right, taking into account the purposes of the processing, to request the completion of incomplete personal data, also by means of a supplementary declaration.
Right to deletion (Right to be forgotten)
You have the right to request us to promptly delete the personal data concerning you, providing that one of the following reasons applies and as long as the processing is not necessary:
The personal data has been collected or processed for reasons that are no longer necessary.
You revoke your consent on which the processing was based pursuant to Art. 6 Para. 1 Letter a of the GDPR and there is no other legal basis for processing.
You object to the processing pursuant to Art. 21 Para. 1 GDPR and there are no overriding legitimate and justified reasons for the processing on our part, or you object to the processing pursuant to Art. 21 Para. 2 of the GDPR in the case of data processing for advertising purposes.
The personal data has been unlawfully processed by us.
Deletion of personal data is necessary for complying with a legal obligation under Union law or the law of the Member States to which we are subject.
The personal data was collected in relation to information society services pursuant to Art. 8 Para. 1 of the GDPR.
Provided that one of the aforementioned reasons applies and you wish to have the personal data stored by us deleted, you can contact our data protection officer with your request at any time. They will then ensure that the request for the deletion is promptly complied with.
In principle, we do not release any personal data publicly. However, should we release personal data publicly and as the responsible party be obliged to delete personal data pursuant to Art. 17 Para. 1 GDPR, we will take appropriate measures (also of a technical nature), under consideration of the technology available and the cost of implementation, in order to inform other persons responsible for data processing and who process the published personal data that you have requested that these other persons responsible for data processing delete all links to this personal data as well as its copies and replications, insofar the processing is not necessary.
Right to restrict processing
You have the right to request a restriction on the data processing if one of the following conditions is met:
You dispute the accuracy of the personal data for a period of time that allows us to verify the accuracy of this data.
The processing is unlawful, you reject the deletion of personal data and instead request a restriction of the use of the personal data.
We no longer need the personal data for processing reasons, however, you yourself require the data in order to assert, exercise or defend legal claims.
You object to the processing pursuant to Art. 21 Para. 1 of the GDPR at it is not yet clear whether the legitimate reasons on our part outweigh your legitimate interests.
Provided that one of the aforementioned conditions is met and you wish to restrict the personal data stored by us, you can contact our data protection officer at any time. They will then ensure that the data processing is restricted.
Right to data portability
You have the right to receive the personal data concerning you that you have provided us with in a structured, standard machine-readable format. You also have the right to request us to transmit this information to another person responsible, provided that the processing is based on consent pursuant to Art. 6 Para. 1 Letter a of the GDPR or a contract pursuant to Art. 6 Para. 1 Letter b of the GDPR and providing that the processing is carried out using automated methods.
When exercising your right to data portability pursuant to Art. 20 Para. 1 of the GDPR, you also have the right to have us transfer the personal data directly to another person responsible, as long as this is technically feasible and provided that the rights and freedoms of other persons are not affected by this.
Right to objection
At any time, for reasons specific to you, you have the right to object to the processing of personal data concerning yourself that has been carried out on the basis of Art. 6 Para. 1 Letter f of the GDPR in order to protect our legitimate interests. This also applies to profiling based on this regulation.
In the case of of an objection, we will no longer process the personal data, unless we can prove compelling grounds for processing that outweigh your interests, rights and freedoms as the person concerned or unless the processing is intended to assert, exercise or defend legal claims.
Should we process personal data for direct marketing purposes, you have the right to object at any time to the personal data being processed for this purpose. This also applies to profiling, should this be directly related to this direct marketing. If you object to data processing for direct advertising purposes, we will no longer process your personal data for this reason.
Right to revoke data protection consent
You have the right to revoke your consent to the processing of personal data at any time.
Automated decisions in individual cases including profiling
You have the right not to be subject to a decision based exclusively on automated processing, including profiling, which has a legal effect against you or significantly affects you in a similar way, unless (1) the decision is necessary for the conclusion or fulfillment of a contract between you and us, or (2) is permissible due to Union or Member State law to which we are subject and this law contains appropriate measures to safeguard your rights and freedoms and legitimate interests, or (3) occurs with your express consent.
If the decision (1) is necessary for the conclusion or fulfillment of a contract with you or (2) is made with your express consent, we will take reasonable measures to protect your rights, freedoms and legitimate interests, including at least the right for a person on our side to intervene in the decision making, for you to state your position and for you to challenge this decision.
D. Our legal basis for the processing of your data
Legitimate interest
According to Article 6 (1) f) of the GDPR, we are permitted to process your data even without express consent, provided that if this is necessary to safeguard our legitimate interests or those of a third party, as long as your interests or your fundamental rights and freedoms requiring the protection of personal data, do not outweigh this.
We do not believe that the following activities adversely affect persons in any way. On the contrary, they help us provide more tailored and efficient services to you and are therefore beneficial to all parties. However, you still have the right to object to our processing of your personal data on this basis, as mentioned above.
User data:
We must ensure that our business activities run smoothly, so that we can continue to provide you with our products and services of the usual quality and at a reasonable price. For this reason, we require your data in order to fulfill our contracts with you, to bill you for our services and supply you with our products, to answer your support queries.
We have our own legal obligations and it is in our legitimate interest to insist on their fulfillment. If we believe in good faith that this is necessary, we may therefore disclose your information for the purposes of law enforcement or tax collection or actual or threatened disputes.
Supplier data:
We use and save personal data from persons within your organization to use your services as one of our suppliers or service providers. We also save your financial data so that we can pay you for the services that you have provided. We assume that all the activities in this area to be in our legitimate interest as recipients of your services.
Agreement
Under certain circumstances, we may need your consent to process your personal data in connection with certain activities. Depending on what exactly your data is needed for, we will either ask for your explicit consent via “opt-in” or silent consent via “soft opt-in”.
According to Article 4(11) of the GDPR, consent (via opt-in) is classed as “any voluntary declaration of intent, in an informed and unequivocal manner, in the form of a declaration or other clear affirmative act, with which the person concerned indicates their consent to the processing of personal data concerning themselves”. Put simply, this means that:
you must voluntarily give us your consent without us putting any kind of pressure on you;
you must know what you are granting consent for – we will therefore ensure that we have provided you with sufficient information; and
you must give us your consent in the form of a positive, affirmative act. In most cases, we will provide you with a field that you must mark so that this requirement is clearly and unambiguously fulfilled.
We keep a record of the consent that you have given in this way.
As previously mentioned, in some cases consent by soft opt-in is sufficient. We may advertise products and services that are related to the products we offer and services, provided that you have not actively unsubscribed from these communications.
As previously mentioned, you have the right to revoke your consent to these activities by contacting our Company.
Establishment, exercise or defence of legal rights
Sometimes it may be necessary for us to process personal data in connection to the pursuit or defence of legal claims. This may occur, for example, if we require legal advice in relation to legal proceedings or are legally obliged to retain or disclose certain information in the course of legal proceedings.
Part 4 – Definitions
The Roberto Borghesi d.o.o. Privacy Policy is based on terms used by the European directive and regulation provider at the point when the General Data Protection Regulation (GDPR) was issued. Our Privacy Policy is intended to be easy to read and understandable for the public as well as for our customers and business partners. Therefore, we would like to explain in advance the terms used.
In this Privacy Policy, among others, we use the following terms:
“ personal data”: Personal data is all the information which refers to an identified or identifiable natural person. A natural person is identifiable when they can be identified directly or indirectly, in particular by assignment to an identifier such as a name, an identification number, location data, an online identifier or one or more special characteristics that express the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person.
“ person concerned”: A person concerned is any identified or identifiable natural person whose personal data is processed by us.
“ processing”: Processing is any operation or series of operations carried out with or without the aid of automated procedures in connection with personal data. These include, but are not limited to, the collection, arrangement, storage, adaptation or alteration, reading, retrieval, use, disclosure by transmission, comparison or linking, restriction, deletion or destruction of personal data.
“ profiling”: Profiling is any kind of automatic processing of personal data that involves using this personal data to assess certain personal aspects that refer to a natural person, especially in order to analyze or predict aspects related to work performance, economic condition, health, personal tastes, interests, reliability, behavior, place of residence or relocation of this natural person. As a responsible company, we refrain from using any sort of profiling.
“ Pseudonymization”: Pseudonymization refers to the processing of personal data in a way in which it can no longer be assigned to the specific person concerned without the use of additional information.
“ responsible party”: The responsible party is a natural or legal person, authority, institution or other body that alone or together with others decides on the purposes and means of personal data processing.
“ contract processor” : A contract processor is a natural or legal person, authority, institution or other body that processes the personal data on behalf of the responsible party.
“ receiver”: A receiver is a natural or legal person, authority, institution or other body that discloses personal data, regardless of whether this is relating to a third party or not. However, authorities which may receive personal data under Union law or the law of the Member States within the framework of a particular investigation mandate are not considered as recipients.
“ third party”: A third party is a a natural or legal person, authority, institution or other body other than the person concerned, the responsible party, the data processor and persons authorized to process the personal data under the direct responsibility of the person responsible or the data processor.
