PRIVACY POLICY

Information sheet

Pursuant to art. 13, Legislative Decree nr. 196/03 as amended ("Privacy code"), we would like to inform you that your data will be processed, also with electronic instruments, by iKRIX SPA, headquartered in Italy, Via Gian Domenico Cassini n. 12/F/R/2, Genoa, registered in Genoa, tax code and VAT number 02225200993, certified electronic mail address ikrix@pec.it, fax +39 010 81 78321, telephone number +39 010 81 78 320, as the Controller of the data collected on the Website The Clutcher  in accordance with the procedures set out below.

At iKRIX we protect the personal data of our customers and guarantee that the way in which we process your data complies with the provisions of the privacy legislation as per Legislative Decree 30 June 2003, n. 196 referring to the "Code regarding the protection of personal data" (the “Code”) and integrated with the amendments introduced by Legislative Decree 10 August 2018, n. 101 to implement EU Regulation no. 679/2016 (the "GDPR").

This privacy policy describes the purposes for which iKRIX collects, uses, processes and communicates the personal data provided by the user with regard to the access and use of theclutcher.com  website (the “Website”) and services provided through the Website, as well as with regard to the purchase of the products offered on the Website, all in compliance with art. 13 of the Code and General Data Protection Regulation.

The user can contact iKRIX via e-mail at privacy@ikrix.com.

Processing of personal data shall mean any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.

COLLECTED PERSONAL DATA AND PURPOSE OF THE PROCESSING

INFORMATION AUTOMATICALLY COLLECTED THROUGH THE USE OF THE WEBSITE

To customize the user navigation experience, the Website uses profiling cookies, also of third-parties, and similar technologies, through the web platform Google Analytics.

To improve its services, iKRIX may designate third parties, such as web marketing agencies, to carry out profiling activities for their own account.

Cookies are small text files saved by the browser and stored on the user device. Cookies allow the site to function efficiently and/or improve its services.

The user may always delete cookies through the browser settings. Disabling technical/browsing/functional cookies may prevent our website from functioning correctly and/or may not allow you to fully take advantage of the services we offer. For more information regarding their use and the procedure for disabling please visit our Cookie Policy below.

As a consequence of the use of the Website some information could be collected on the basis of iKRIX legitimate interest in improving and offering the full functionalities of its Website, which may include:

  • demographic information;
  • location information
  • information concerning the use of Website functionalities and browsing;
  • elaborations and associations with data owned by third parties;
  • log data and device information.

This information is not collected to be associated with specific individuals. It is used for the sole purpose of collecting anonymous statistical information on the use of the Website, to control its correct functioning and to improve the browsing experience.

The data could be used to determine responsibility in case of hypothetical computer crimes against the Website.

The association with a specific user occurs only following the purchase of a product, the registration on the Website and/or the subscription to the newsletter and enables iKRIX to provide a service in line with the preferences expressed.

INFORMATION PROVIDED DIRECTLY BY THE USER

To access the Website and its content and to make a purchase, no registration is required.

iKRIX shall process the following identifiable, non-sensitive personal data, which must be communicated by the user who decides to purchase a product on the Website:

  • e-mail address;
  • full name;
  • Country
  • full address
  • telephone number
  • tax data needed for each country;
  • billing address if different from shipping address
  • information regarding the payment transactions, partly encrypted, collected by iKRIX in order to be able to verify the correctness of the payment.

The communication of the user personal data is compulsory to purchase, pay and receive the products, as well as to enable our Customer Service to provide customers with after-sale service. It is a necessary condition for the proper and timely execution of the contract. In its absence, it will be impossible to provide the requested services..

With reference to the data necessary for the delivery, please note that they are communicated to the commercial partners who supply the products, as well as to couriers in order to carry out the delivery service.

With reference to the transaction information, please note that payments are received through authorized external payment providers in charge of managing payment data in compliance with the law (Paypal), or directly to iKRIX current account via bank transfer.

At this stage, iKRIX may process the following categories of personal data, obtained through automated processes:

  • historical data, relating to possible previous purchases and order information

iKRIX processes the following identifiable, non-sensitive personal data, which must be communicated by the user who decides to register on the Website creating an account:

  • e-mail address;
  • Full name
  • Gender
  • password (encrypted) provided by the user during the account registration process in order to access the account.
  • Country

At this stage, iKRIX may process the following categories of personal data, obtained through automated processes:

  • data regarding the user activity on the Website (e.g. pages visited, content viewed, clicks...)
  • data regarding purchase history

In his/her personal area, the user may optionally indicate other personal data (telephone number and date of birth).

The data shall be used by iKRIX for the account management on The Clutcher and the improvement of the use of services by the user.

In case the registered user decides to make a purchase, compulsory data and optional data eventually provided during registration will be used, if necessary, for order management, too; the missing data for the order management will be requested during the purchase.

At any time, the user shall have access to his/her personal data to modify them, request that iKRIX delete their personal data where possible, exercise the rights set forth in the law. In case the user, during the registration, declares he/she wants to receive newsletters, selecting the non compulsory option of subscribing to our newsletter and providing the required consent, the provided e-mail address will also be used to communicate promotions and marketing content.

The user can choose not to receive marketing communications at any time, by clicking on the dedicated unsubscribe link at the bottom of any marketing e-mail. Alternatively, the user can send an e-mail to privacy@ikrix.com with "Unsubscribe" in the subject, expressing their wish to stop receiving marketing communications

PURPOSE OF PROCESSING

Users’ personal data, freely communicated and acquired directly and/or through third parties in the course of the activity carried out by iKRIX for the website Theclutcher.com, are collected electronically in relation to the purpose for which they are processed.

A) Without the express consent of the user (art. 24 lit. a, b, c and art. 6 lit.b of the Code, and GDPR), for the following purposes related to the activation and operation of the services furnished by iKRIX for Theclutcher.com:

  • to fulfil pre-contractual, contractual and fiscal obligations (e.g. to allow order management, invoicing and product delivery, also through Customer Service, to provide the customer with the procedures for the execution of this contract and the necessary communications);
  • to fulfill the obligations required by laws, regulations and Community legislation, or provisions issued by authorities empowered to do this by law;
  • to prevent or find out abuse and fraudulent conduct harmful to the website;
  • to exercise the Data Controller rights, e.g. the right to legal defense.

The supply of the data as required during the activation of Services is mandatory, since strictly necessary to pursue the purposes in question.

B) Only upon specific and distinct consent (articles 23 and 130 of the Code and art. 7 GDPR), for these marketing purposes:

  • to send, via e-mail or other digital communication channels, newsletter, commercial communications and/or advertising materials for products and services offered by iKRIX, also according to the preferences expressed by the user;

The supply of the data for the above purposes is optional. Failure to provide consent shall not have any consequences on the purchase of products and/or the supply of Services.

 

METHODS OF DATA PROCESSING

The processing of personal data is performed through the operations listed in Art. 4 of the Code and in Art. 4 n. 2 GDPR: collection, recording, organization, consulting, communication, storing, processing, modification, selection, retrieval, comparison, utilization, interconnection, blocking, erasure and destruction of data, mainly carried out using electronic means by ensuring the use of adequate measures for the safety of the data processed and by guaranteeing the confidentiality of such data.

 

DATA TRANSMISSION

iKRIX undertakes to treat as confidential all personal data and information provided by the user and to not reveal them to unauthorized persons, or use them for reasons other than those for which they were collected. Personal data will be transmitted, after the signing of a commitment to confidentiality of data, only to delegated and/or appointed subjects who carry out activities necessary for the execution of the contract between supplier and customer, whether they are iKRIX employees or third parties, such as for example consultants, suppliers of products, transport services and payments, and used exclusively for this purpose. Personal data may be transmitted to Public Administrations, judicial authorities and subjects to whom the communication is mandatory for the performance of the institutional functions within the limits established by the law or regulations.

 DATA TRANSFER

User personal data, memorized on electronic supports, is preserved and archived on servers placed on the European Union territory. iKRIX software is protected by encrypted access and through appropriate passwords, complying with appropriate safety requirements. In any case, it is expressly understood that the Data Controller may move its servers to extra-EU territories. In this case, iKRIX ensures that the extra-EU data transfer will occur pursuant to applicable provisions of the law, only after the signing of the standard contractual clauses provided by the European Commission.

 DURATION OF DATA STORAGE

In any case the collected data will be kept for a period of time depending on the processing purpose. At the end of the processing period, all data will be safely deleted or otherwise rendered anonymous in an irreversible way.

USER'S RIGHTS

At any time, the user has the right to request information regarding his/her personal data owned by the Data Controller. In particular, as data subject, the user enjoys the rights provided by articles. 7 of the Code and 15 of the GDPR, and precisely:

i. to receive confirmation of the existence or not of personal data concerning himself/herself, even if not yet registered, and their intelligible communication;

ii. to obtain the following information: a) the source of personal data; b) the purposes and method of processing; c) the method applied in the case of processing carried out with the aid of electronic means; d) information identifying the Data Controller, the Processors and the designated representative of the company, pursuant to art. 5, paragraph II of the Code and art. 3, paragraph 1 of the GDPR; e) subjects or categories of subjects to which personal data may be provided or who may be made aware of it as supervisors or officers;.

iii. to obtain: a) the updating, correction or, when they are interested, additions to the data; b) the cancellation, transformation into anonymous form, or blocking of data processed in violation of law, including those that need not be retained for the purposes for which the data were collected or subsequently processed; c) certification that the parties to which the data have been transferred or disseminated have been notified of the operations specified in points a) and b), also regarding their content, except for the case where notification proves impossible or requires the use of means clearly disproportionate to the right being protected;

iv. to fully or partially object: a) for legitimate reasons, to the processing of personal data, even if pertinent to the purpose of collection; b) to the processing of personal data for the dispatch of advertising or direct sales material or for the conduction of market research or business information, through automated calling systems, e-mail and/or traditional methods of marketing, telephone and/or mail..

If applicable, the person concerned enjoys the rights provided by artt. from 16 to 21 GDPR (right of rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object to the processing), as well as the right to lodge a complaint with the authority in charge.

 

MODALITIES FOR THE EXERCISE OF THE RIGHTS

To exercise his/her rights, as well as to receive information regarding the subjects where data is stored or to whom data is communicated, or rather regarding the subjects that, as data processors or persons in charge, may learn about personal data, the user can contact at any time iKRIX at the e-mail address privacy@ikrix.com.

 MINORS

This website and the goods of services are not intended for minors; therefore, the owner does not intetionally collect personal data referring to minors. Should any information about minors accidentally collected, the owner will promptly delete it, if required by users.

 CHANGES TO THE PRESENT DOCUMENT

This privacy policy may be subject to changes over time. Therefore, we invite you to periodically check the contents of this policy and to refer to its last update.

 

COOKIES POLICIES

The website The Clutcher. The use of cookies and similar technologies by iKRIX S.p.A. in its capacity as Data Controller, acts in compliance with relevant legislation..com uses so-called cookies

WHAT ARE COOKIES AND WHAT IS THEIR PURPOSE?

Cookies are small text files sent to the browser and saved on the user device while browsing a website. Cookies allow the site to function efficiently and provide information to the site owner for statistical or advertising purposes, primarily to personalise and improve the user navigation by remembering his/her preferences.

WHICH COOKIES DO IKRIX USE AND FOR WHAT PURPOSES?

iKRIX uses various types of cookies, each of which has a specific function.

NAVIGATION OR TECHNICAL COOKIES: Navigation cookies are needed for the correct functioning of the website. From the first access, they allow the user to view content on his/her device by recognising the language and market of the country from which he/she has connected. If the user is registered, cookies allow he/she to be recognised and to access the services offered and the dedicated areas.

FUNCTIONAL COOKIES: Functional cookies are not essential to the functioning of the website, but rather improve navigation experience. These cookies allow the user to be recognised the next time he/she accesses the website, so that he/she does not have to enter the requested information each time. This happens through a precise request of the user (e.g. Remember me). Furthermore, if the user adds items to the Shopping Bag and closes the session without completing the purchase and without eliminating those items, functional cookies allow the user to continue the shopping experience the next time he/she accesses the website, finding the same selected articles (within a limited period).

ANALYTICAL COOKIES: Analytical cookies are used to collect aggregate information regarding the details of the user's navigation on the website. They can be data regarding the number of visitors, the most visited pages and the time spent on the website. The results of these analyses are anonymous and are exclusively treated for statistical purposes only. For more information please read here https://policies.google.com/technologies/types.

 PROPRIETARY AND THIRD PARTY PROFILING COOKIES: These cookies are used to profile users so as to be able to send commercial messages that meet the preferences expressed while browsing or to improve the browsing experience and the purchase process. These cookies allow the user to find  The Clutcher offers also on other affiliate websites and external channels (retargeting). The Clutcher.com uses: Google Adwords, Criteo, Yahoo, Google Double Click, Bing, Facebook, Awin (https://www.awin.com/gb/legal).

 SOCIAL NETWORK COOKIES: These cookies allow the user to interact with social networks and other external platforms directly from iKRIX website (the user can share a product on social networks). The information acquired by these actions is subjected to the privacy policy of the various social networks. To find out more about the policies regarding the use of social network cookies, it is possible to consult the respective privacy and cookies policy.

HOW CAN THE USER DISABLE COOKIES?

The user may at any time modify the settings and preferences regarding the various types of cookies through his/her browser. The majority of browsers are configured to control and potentially disable cookies through the settings. Please note that disabling certain types of cookies may affect the functioning of the website and/or limit the services offered by iKRIX.

For more information on cookies, including how to manage and disable third party cookies or marketing/retargeting cookies, please visit the following websites:

  • www.YourOnlineChoices.com
  • www.AllAboutCookies.org

For more information on how to disable cookies from you browser:

  • www.AllAboutCookies.org/manage-cookies/

For more information on how to disable analytic cookies and for the options of tracking by Google Analytics through websites, you can download the Add-On Google Analytics Opt Out Browser: tools.google.com/dlpage/gaoptout.

 

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