PRIVACY POLICY

Protecting your personal data is important to us.

When you interact or use the services of our site www.thecloser.shop (hereinafter the "Site") we may collect and process information about you ("personal data").

This Privacy Policy document contains important information on how we process your personal data and on your rights concerning the your personal data which will be processed by our Site.

For any questions or requests, feel free to contact us at our e-mail address which has been set up for the aforementioned purpose: privacy@thecloser.shop 

Who decides why and how your personal data is processed?

The Data Controller of your personal data is The Closer Shop S.r.l. with registered office in Milan, via Filippo Turati, 29, 20121, VAT number 11757550964 (“The Closer” or the “Company”).
 

What personal data do we collect?

The Company will process the data you provide when purchasing products on our Site. We will also process your data when you create an Account with us, and your data will be collected automatically during your navigation on the Site.

Personal data you provide to us

We collect your personal data, such as name, surname, gender and date of birth and your e-mail address, so that we can create your profile on the Site. To make a purchase on the Site, we may request additional information, such as contact details and your address for the shipment of the products and any billing for those products; we also collect data relating to the means of payment used.

We may also collect additional personal data when you need to contact us or to contact our Customer Care. We will also collect data via e-mail or other contact channels on the Site, when you send us requests connected with the purchase of products or the use of our services. 

The Collection of Data Associated With Navigation

When you browse our Site we automatically collect certain types of information, such as your IP address, the date and time of access to our Site, the browser you use and information on the operating system of your device. This information is implicitly transmitted to the Data Controller when using the Site. This transmission of your data is in line with the Internet communication protocols. This information is not collected on behalf of, nor is it associated with identifiable interested parties, but by the very nature of using the Internet and the Site, the released information could allow users to be identifiable. We also collect information about your clicks and the pages that have been shown to you.

If you are using a mobile device, we collect data that identifies your device, your phone settings and features, and other related system activities.

Why do we collect your personal data and under what conditions are we authorised to process it?

Your data will be processed to allow you to access the services provided by our Site and to guarantee that you have a better shopping experience. With your consent, we also use your data to inform you about special offers and other products and services that we feel may be of interest to you.

The Collected Data Will Allow You to Browse the Site Correctly and obtain information on Its Use

The data acquired during navigation will be used to allow you to navigate correctly on the Site, to obtain anonymous statistical information on the Site’s use, and to check to make sure the Site is functioning correctly.

The data processing is necessary for the execution of pre-contractual measures adopted at your request.

Furthermore, with your consent, the data collected may also be used in order to track your browsing on the internet and create profiles based on your habits and preferences, and to send you personalized promotional messages tailored to your interests. 

Allow you to purchase products, create a profile and access services reserved for members

Your data will be collected for the fulfillment of purchased orders, and for related activities such as the shipment and delivery of products, billing, payment management etc. Your data will also be used to create your profile on the Site, for the activation of any services exclusively requested by you (eg order tracking, wishlist ...), as well as to manage your participation online and social initiatives; Our aim is to provide subscribers with favourable discounts and other benefits.

This processing is necessary for the execution of the contract to which you are a party or for pre-contractual measures adopted at your request.

Direct marketing activities

Your data may be collected for direct marketing purposes. This means we will use automated contact methods such as text messages, mms, e-mails, social networks, instant messaging apps, push notifications to accomplish the aforementioned. 

We will also use traditional methods such as phone calls with a phone operating service as well as the traditional postal service. We will use promotional and commercial communication. These specific communications will relate to services and products offered by the Company or to report corporate events, as well as to detect the degree of customer satisfaction by carrying out market surveys and statistical analyzes.

For the above purposes, your specific consent is required. However, your consent is not necessary in cases where the Company has a legitimate interest in sending e-mails for direct sales and / or the promotion of our products similar to those you have already purchased such as cd. soft-spam. The Customer can object to such marketing uses by sending an email to privacy@thecloser.shop or by clicking on the appropriate link for opposition to receiving such communications contained within each promotional email.

Profiling activity

Your personal data (such as, for example, age, gender, geographical origin ...) can only be collected with your specific consent. Your data may be collected to analyze and evaluate your preferences, habits and interests in order to send you personalized commercial communications, targeted promotional actions, offers and services in line with your needs and preferences.

Processing of your requests

Your personal data which was received through the contact channels on the Site, may be processed to manage and respond to your requests regarding the purchase of products, or the use of our services. 

This processing is necessary for the execution of the contract to which you are a party or for pre-contractual measures adopted at your request.


Defending Our Rights In and Outside of the Court System

If necessary, your personal data may be processed to ascertain, exercise or defend the rights of the Company in court or it could be used for the purpose of out-of-court debt collection.

This use of your data is necessary to pursue the legitimate interest of the Company in ascertaining, exercising or defending its rights in court.

Anti-Fraud Controls

Your data will also be used for fraud prevention purposes in relation to purchases made on our Site and to ascertain responsibility in the event of computer crimes against the Site, users or third parties.

This treatment is necessary to pursue the legitimate interest of the Company in preventing and combating fraud, computer and information technology crimes.

 With Whom do we share your personal data?

Authorized and trained personnel will be processing Your personal data for the Company; They will operate according to the principles of correctness, loyalty and transparency and will protect the confidentiality of your data through technical and organizational security measures suitable to guarantee an adequate level of protection.

In some cases, your personal data will be disclosed to other subjects who work on behalf of the Company as Data Processors, who have been given specific instructions on data processing, or to independent Data Controllers. These Data Controllers will pursue their own objectives and purposes.

Generally speaking, the data acquired while browsing our Site may be disclosed to third-party companies that provide the Company with IT assistance services (such as, for example, hosting services related to the use of the Site), as Data Processors.

Furthermore, the data collected for the purposes indicated above may be disclosed to the following categories of recipients who will process your personal data as Data Processors on behalf of our Company:

Finally, your data may be disclosed to authorities and institutions to which the right to access them is granted by provisions of law or regulations (eg public security authorities and police forces).

You can request the list of data processors and further information regarding the recipients of your personal data by writing to privacy@thecloser.shop

 Will your data be transferred outside the EU?

By virtue of the address of the recipients to whom the data may be communicated, your personal data could be transferred outside the European Union; still we at The Closer Shop/Store ensure compliance with all guarantees to protect your data.

The personal data collected through the Site may be transferred to some non-EU countries (including the USA) The transferring of this data is in relation to specific needs related to the headquarters of some recipients of your personal data. This transference is with particular reference to the providers of IT assistance and other services rendered on behalf of the Company. The Company undertakes to safeguard personal data contractually and it guarantees adequate levels of protection in accordance with the applicable regulations, which include the stipulation of standard contractual clauses.

How long do we keep your data?

We keep your personal data just long enough to use it for the primary purposes for which it was collected. At the end of this period we will make sure that your data is anonymized, so that the information can no longer be attributable to you, or we will delete your information altogether.

Your personal data will be stored long enough to fulfil contractual obligations and any obligations imposed by law (eg in tax matters) as it relates to the performance of the sale of products through our Site.

Information relating to your purchases and interactions with us will be processed within 24 months for marketing purposes and within 12 months for profiling activities. This process will begin from the date of the collection of your consent.

Furthermore, the storage of your personal data will be limited to the time necessary to manage your requests received by the Customer Care service and, in the event of a dispute, to assert our rights in court.

What are your rights in relation to your personal data?

At any time at all, you will always have the right to ask the Company for access to your personal data; you can request the rectification of your data; You can ask the Company to cancel or limit the processing of your data; you can also oppose the processing of your data; You can withdraw consent concerning the treatment of your data; you can ask about your data’s portability; you may decide to keep or transmit your personal data to third parties

In relation to the processing of data referred to in this document, where provided for under the law, you can exercise the following rights:

To exercise these rights, you can send a request to the e-mail address privacy@thecloser.shop.

Furthermore, if you believe that the processing of your personal data through the Site is in violation of the provisions of the legislation for the protection of personal data, you will always have the right to lodge a complaint with the Guarantor for the protection of personal data or appeal to the competent Judicial Authority.

Changes to this Privacy Policy

The Company reserves the right to make changes to this Privacy Policy at any time. We will do this by providing information on the Site and, where possible, if technically and legally feasible, we at the Company will communicate with you the Customer through one of your contact details that we are in possession of about any changes, which may have been made. We therefore invite you to consult this page regularly and please refer to the date of the last modification indicated at the bottom.