Privacy policy

 PRIVACY POLICY

(EFFECTIVE DATE: 30.03.2024)

The website InuitGoggles.com (the “Site”) is operated by Pietro Del Franco  as the data controller (the “Company” or “we”) as indicated in this privacy policy (the “Privacy Policy”).

To learn more about how we handle your personal data, please read the following sections of this Privacy Policy carefully.

1. INTRODUCTION TO HOW WE USE YOUR PERSONAL DATA

This Privacy Policy describes how the Company collects and processes the personal data of users of the Site (hereinafter, “user,” “users,” “data subject,” or “you”) in compliance with the European Union General Data Protection Regulation 2016/679 (the “GDPR”), Legislative Decree 196/2003, as last amended and supplemented (the “Privacy Code”), and applicable data protection laws in the United States and Canada.

As described below, the Company processes your personal data to provide you with its products and services and to enable you to participate in engagement programs, contests, and events organized by the Company for its customers. If you wish to receive the latest news, offers, and promotions about the world of the Company, we will process – with your consent – your personal data to send you marketing communications, including personalized ones based on your preferences and interests. In any case, we will process your personal data securely, adopting all appropriate security measures and allowing access to your personal data only to authorized persons and third parties located both within the European Union, the United States, and Canada, in compliance with applicable data protection laws.

All personal data provided by you through this website will be used exclusively for the purposes and in the manner described below.

2. WHAT PERSONAL DATA DO WE USE AND WHERE DO WE COLLECT IT FROM?

The Company processes personal data collected directly from you and from other sources, as indicated in the categories of personal data listed below (collectively referred to as “Personal Data”):

a) Personal Data provided directly by you

The Company processes the following categories of Personal Data provided directly by you:

  • Identifiable information provided during the registration process, creating an account on the Site, or when completing a purchase order or participating in the Company's engagement programs, contests, and events, such as your name, email address, user ID, password, gender, country of residence, postal address, and phone numbers;
  • Financial information and credit card data for purchasing products through the Site;
  • Information contained in any correspondence or request sent by you to the Company or requested by the Company if you report problems with our service on the Site or with the purchased products;
  • Information related to your public social network profile if you decide to access the Site through social network applications or link your Company account to your public profiles available on social networks, and share your actions through the Site on these channels via the corresponding plug-ins (e.g., Facebook Connect, Like, share on Facebook, etc.). If you choose to share such information, the Personal Data posted on your social network profile will be collected by the website and processed for the corresponding functions. Therefore, using such a plug-in involves sharing the corresponding actions and information on the relevant social networks.

b) Personal Data obtained from automatic tracking systems when browsing the website and using related services

The Company processes the following categories of Personal Data collected through automatic tracking systems when browsing the website and using related services:

  • Information related to the use of the website. For security reasons, the Company processes log files for each session when the user logs into their account, as well as payment transaction information that will be processed through the Company’s electronic payment provider;
  • Browsing information collected during browsing of the website. The Company uses certain technologies (e.g., cookies and automatic tracking systems) that automatically collect certain information related to how the user uses the Site, such as the IP address or other unique code of the device (computer, mobile phone, or other devices) used by the user to browse the Site, identifying whether they are a registered user or not, and technical information that may include the URL from which the user came, browser information, language settings. This information helps us continually improve the browsing experience and the mechanisms for purchasing the Company’s products and services and monitor the proper functioning of the Site. This information includes only statistical data related to the actions performed by the user and is not intended to be associated with the user's identifying data. In any case, browsing data can identify the user only if combined with identifying personal data.

For more information on the use of Personal Data collected through cookies and tracking systems, please read the Company’s Cookie Policy carefully available here.

3. FOR WHAT PURPOSES AND WHY DO WE USE YOUR PERSONAL DATA?

The Company processes your personal data for the following purposes:

3.1 Contractual Purposes - We need to be able to provide you with our products and services

The Company processes your Personal Data for purposes necessary for providing services and products offered through the Site, particularly for the following Contractual Purposes:

  • To allow the user to register on the website and create their account;
  • To provide the services available through the Site (e.g., managing the registration process and account access, managing the account, reminder for products in the cart, etc.);
  • To manage the sale of products and online orders and provide products and services;
  • To process payments and electronic payments, including for billing obligations;
  • To provide post-sale services and assistance (including, for example, fraud prevention, returns, warranty, and customer support), also sending users operational communications related to the provision of the service or products, sale, and post-sale assistance;
  • To fulfill the user's requests (e.g., managing information requests, booking eye exams, providing the “share with a friend” function, informing about the “available again” function, etc.);
  • To allow you to participate in the Company’s engagement programs;
  • To allow participation in contests, sweepstakes, and initiatives promoted by the Company.

Data processing activities for Contractual Purposes are necessary for providing the requested products and services. If you do not want your Personal Data to be processed for these purposes, the Company will not be able to provide the requested products and services.

3.2 Legal Purposes - We must ensure compliance with legal obligations

The Company may process your Personal Data to ensure compliance with legal obligations, particularly for the following Legal Purposes:

  • To comply with the requirements of laws, regulations, protocols, and national and European legislation;
  • To implement the decisions of public authorities.

Data processing activities for Legal Purposes are necessary as required by current laws. If you do not want your Personal Data to be processed for these purposes, you will not be able to use the Website.

3.3 Marketing Purposes - You can decide if we can use your personal data for our marketing activities

With your prior consent, the Company processes Personal Data for the following marketing purposes:

  • To send commercial and promotional communications and periodic updates (e.g., via email, phone, SMS/MMS, postal service, social networks, and newsletters) regarding products, services, initiatives, and events of the Company. Additionally, under Art. 130, paragraph 4, of the Privacy Code, if you are already a customer of the Company, the Company may send you commercial communications via email about similar products, events, and services already provided, unless you object to such processing at the time of collection and on each occasion. Indeed, you can choose at any time not to participate by following the instructions available in each communication;
  • To conduct statistical analyses on the customer base.

Data processing activities for Marketing Purposes are discretionary, subject to the user's prior consent or objection, under the circumstances mentioned in the above Art. 130, paragraph 4, of the Privacy Code. You can freely decide not to provide Personal Data for Marketing Purposes, as well as subsequently revoke your consent to the processing of Personal Data already provided: in this case, the Company will not send you marketing communications to update you on offers and promotions on products, services, and initiatives of the Company.

3.4 Segmentation and Profiling Purposes - You can decide if you want more tailored marketing communications

If you have consented to the processing of your Personal Data for Marketing Purposes, the Company may process Personal Data for Segmentation Purposes to analyze Personal Data related to spending volume, product category, date of birth, and purchase methods concerning activities carried out for Marketing Purposes. This activity is carried out by the Company based on its legitimate interest in providing a service aligned with your needs, adequately balanced with your rights given the limited amount of Personal Data processed. The processing of Personal Data for Segmentation Purposes falls within the Legitimate Interest Purposes referred to in the next paragraph.

If you consent to install cookies and other technologies through the banner shown on our website, in addition to the above, the Company processes your Personal Data for profiling purposes to analyze your interests and preferences, including browsing data with specific reference to the pages visited and products viewed on the Site, to offer personalized services and send targeted marketing communications. This activity is carried out by the Company based on its legitimate interest in providing a service aligned with your needs, adequately balanced with your rights given the consent provided through the cookie banner and in line with our Cookie Policy. This activity will help the Company provide you with offers more in line with your profile. The legitimate interest lies in the Company’s need to optimize marketing communications and is balanced by the need to provide you with information we consider relevant to you.

3.5 Legitimate Interest Purposes - The Company's rights and your rights are adequately balanced, except in the case of your objection

In addition to processing for segmentation and profiling purposes, the Company also processes your personal data for additional legitimate interest purposes, particularly:

  • To exercise or defend rights in legal proceedings or in administrative or out-of-court proceedings involving the rights of the Company, group companies, and/or their representatives, shareholders, members, and directors;
  • To enable the technical management of the Site and its operational functions, including resolving any technical problems, conducting tests, updates, and upgrades that cannot be carried out using non-personal data;
  • To prevent or identify fraudulent activities or abuses of the Site or against the Company group and/or users of the Site;
  • To carry out a possible merger, sale of assets, transfer of all or a significant part of its business, or financing operation, disclosing and transferring Personal Data to third parties or parties involved in the transaction as part of the transaction;
  • To conduct surveys and market research related to the Company’s products and services by mail, phone, or email;
  • To anonymize Personal Data to conduct statistical analyses.

The processing of your Personal Data concerning the above Legitimate Interest Purposes and Segmentation Purposes is carried out under Article 6, letter f) of the GDPR, to exercise the Company’s legitimate interest, adequately balanced with your interest, as data processing is carried out only to the extent strictly necessary for the performance of these business activities. Such data processing activity is not mandatory, and you may object to such processing at any time through the methods specified in this Privacy Policy. In that case, no Personal Data will be processed by the Company for these purposes, except where the Company demonstrates the existence of overriding legitimate reasons or the exercise of a right of the Company under Art. 21 of the GDPR.

4. HOW DO WE PROCESS YOUR PERSONAL DATA?

The processing of your Personal Data is carried out, with electronic and manual methods, only to the extent necessary to exercise the above purposes.

The Company is committed to protecting users' personal data. The Company informs you that the password is one of the account protection mechanisms. Therefore, users are invited to use a sufficiently secure password and store it in a safe place, limiting access to it on their computers and browsers, and logging out after visiting the Site. All Personal Data provided by users is stored on secure servers, adopting appropriate security measures to protect Personal Data from unauthorized access, ensure the accuracy of Personal Data, and guarantee the proper use of information. Additionally, a secure system is used to authorize credit card payments and identify fraudulent activities. The Company uses the SSL (Secure Sockets Layer) standard to protect the confidentiality of your personal data.

5. WHO DO WE SHARE YOUR DATA WITH?

The Company may share your Personal Data with:

  • Third-party service providers engaged in processing activities providing services or assistance and advice to the Company, particularly - but not exclusively - concerning technological, accounting, administrative, legal, insurance, IT, marketing, and data analysis matters;
  • Group companies of the Company;
  • Persons and authorities whose right to access personal data is recognized by laws, regulations, or provisions issued by legally authorized authorities;
  • A potential purchaser of the Company and entities resulting from mergers or any other transformation involving the Company; and
  • Competent authorities.

The above recipients will process your Personal Data as data controllers, data processors, or persons authorized to process data, as the case may be.

A complete list of data processors is available upon request addressed to the Company through the methods provided in this Privacy Policy.

6. WHERE DO WE TRANSFER YOUR DATA?

The Company may transfer your Personal Data to the recipients listed above, even outside the European Union and, in particular, to the United States and Canada. For transfers from the European Union to countries not considered adequate by the European Commission, the Company has implemented appropriate and suitable safeguards to protect Personal Data. Consequently, Personal Data is transferred in compliance with the requirements and obligations provided by applicable data protection laws under Articles 44 and following of the GDPR. For more information on appropriate or suitable safeguards and how to obtain a copy, the user can contact the Company through the methods provided in this Privacy Policy.

7. HOW LONG DOES THE COMPANY RETAIN YOUR PERSONAL DATA?

The Company retains Personal Data for the time strictly necessary to exercise the purposes for which the Personal Data was collected and subsequently processed, including any retention period required by applicable law.

The Company will process your Personal Data for Contractual and Legitimate Interest Purposes for the duration of the contract (in the case of an account created on the Site, a purchase, or related to services provided by the Company) and for ten (10) years from the completion of the sale or the provided service.

Personal Data processed for legal purposes will be retained for the time strictly necessary to comply with applicable laws.

Additionally, for Marketing and Profiling Purposes, including Segmentation Purposes, Personal Data will be processed for seven (7) years from the last purchase and/or last contact with the user (e.g., entering a contest, participating in an event, opening a newsletter), subject to the right to revoke the consent provided or object to the processing at any time.

8. ARE YOU AT LEAST 16 YEARS OLD?

The processing of Personal Data under this Privacy Policy does not concern individuals under the age of 16. In case of the inadvertent registration of Personal Data related to minors, the Company will promptly delete them upon request from users.

9. HOW TO EXERCISE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

At any time, you can exercise the following rights:

a) Obtain from the Company confirmation of the existence of Personal Data and know its content and origin, verify its accuracy, and request its integration, updating, or correction;

b) Request the deletion, anonymization, or limitation of the processing of Personal Data processed in violation of applicable laws;

c) Object in whole or in part, for legitimate reasons, to the processing of Personal Data;

d) Withdraw consent to data processing (if and to the extent that such consent is necessary);

e) Request the Company to limit the processing of your Personal Data where:

  • You contest the accuracy of Personal Data until the Company has taken sufficient steps to correct or verify its accuracy;
  • The processing is unlawful but you do not want the personal data to be deleted;
  • The Company no longer needs the Personal Data for processing purposes, but you require it for establishing, exercising, or defending a right;
  • You have objected to a processing justified by legitimate interests, pending verification of the Company’s right to continue processing;

f) Object to the processing of Personal Data based on legitimate interest, unless the Company demonstrates the existence of compelling legitimate grounds for processing or for the establishment, exercise, or defense of the Company’s rights;

g) Request the deletion of Personal Data without undue delay;

h) Receive an electronic copy of Personal Data if you wish to transfer the Personal Data to yourself or another provider and the Company’s processing is based on your consent or is necessary for the provision of services and the Personal Data is processed by automated means; and

i) Lodge a complaint with the competent data protection authority.

Under Art. 2-terdecies of the Privacy Code, in case of your death, the above rights can be exercised by another entitled person (the “Successor”) who has a legitimate interest or acts as your agent, or for family reasons worthy of protection. You may expressly prohibit the exercise of some of the above rights by the Successor by sending a request to the email address provided below. Similarly, you may revoke or amend such a declaration at any time.

You can exercise the above rights at any time by clicking here. The Company will respond within a reasonable time (and, in any case, within the limits of applicable law) after verifying the identity of users.

Additionally, the Company offers users tools to update and modify Personal Data. Each registered user can access and update their information (e.g., through the user account). Users can also modify and update their preferences on how they receive emails or other communications from the Company. Users can also request the deletion of their account information.

10. HOW TO CONTACT THE COMPANY?

The data controller of Personal Data is 

For questions or comments about this Privacy Policy or the Company’s data processing, you can contact the Company via the link provided in the previous section.

11. HOW TO CONTACT OUR DATA PROTECTION OFFICER?

The Company has appointed a Data Protection Officer under Art. 37 of the GDPR, who can be contacted at the following email address: info@inuitgoggles.com or at the Company’s address provided in the “HOW TO CONTACT THE COMPANY?” section of this Privacy Policy.

12. HOW TO STAY UPDATED ON CHANGES TO THIS PRIVACY POLICY?

For legal and/or organizational reasons, this Privacy Policy may undergo changes. Therefore, it is recommended to check this Privacy Policy regularly and refer to its latest version. In any case, changes will be communicated in advance, and an updated version of the Privacy Policy will always be available on the Site.

13. USE OF COOKIES

13.1 What are cookies?

A cookie is a small text file, usually consisting of letters and numbers, that is transferred and stored, for a period determined by the manager, on the device used by the user (computer or any mobile device) when the user accesses the website. For example, some cookies uniquely identify the device used, distinguishing it from another.

It should be noted that other similar technologies, used to collect information about the device used by the user, such as pixel tags, web beacons, or social network plug-ins, fall into the general category of “cookies.”

13.2 Why do we use cookies?

Some cookies are absolutely necessary to ensure the proper functioning of the Site and provide the user with a good browsing experience, such as simply moving from one page to another on the Site and providing the services provided within it (e.g., purchasing and paying for glasses). Other cookies are necessary to make browsing easier and faster, for example, remembering registration data or the content of the cart, or making browsing as consistent as possible with the user's preferences and characteristics. Additionally, some cookies are useful for providing the site operator with information that can be used for statistical purposes, such as knowing the number of connected users, sending personalized promotional messages, or ensuring a direct connection with social networks.

13.3 What information do cookies contain?

The information collected in the form of cookies generally concerns information about the user's device, such as IP address, login data, operating system and platform used, time zone setting, country of origin, information about visits to the Site, including URL, duration of visits, search terms typed on the Site, products viewed or added to the cart, page response times, download errors, and information about interactions with pages, such as the number of clicks or navigation paths.

Generally, this information is not sufficient to personally identify the user, but it could be if read in combination with each other or with additional information collected by the Company or third parties.

We have coded and distinguished cookies based on the duration of their storage on the user's device, the entity that installs and manages them, and, most importantly, the purposes for which they are installed.

a) Duration Session cookies are cookies installed when opening the Site and deleted when closing the browser, or when closing the Site or the session expires. The information is therefore temporarily stored and allows, for example, to keep navigation active.

Permanent cookies are cookies that are stored on the user's device for a predetermined period by the manager, even after closing the browser. They allow, for example, to save the username and password or remember the user's preferences so that they do not have to be entered again when opening the Site.

b) Who installs the cookies? First-party cookies are those installed and managed directly by the Company. Third-party cookies, on the other hand, are installed by a manager through a different domain from the one on the Site the user is browsing and are not directly controlled by the Company. This is the case, for example, with statistical analysis cookies installed by Google Analytics or elements of advertising platforms or other services integrated into the Site. The installation of third-party cookies is still subject to the prior authorization of the Company.

c) Purposes of cookies used by the Company on the Site

Strictly necessary cookies (or technical cookies): ensure the proper functioning of the Site and the use of the services existing within it. They allow, for example, to recognize the language of the country from which the user connects and save the choices made on the privacy short notice banner (consent to the use of cookies), thus avoiding having to make the choice again at each access to the Site, for purchasing a product. Additionally, they improve the user experience by storing login data or preselected products in the cart.

They are used exclusively to ensure the basic functionality of the Site and, therefore, their installation does not require the user's prior consent. The user can set their browser to block these cookies, but as a result, some or all parts of the Site will not work.

Analytical cookies: some cookies are installed and managed directly by the Company and are used to analyze how the Site is used, to count accesses, traffic sources, pages viewed, allowing the manager to make changes and improvements to the Site. They can collect data anonymously for statistical purposes only. Other analytical cookies may be installed by third parties to track the user's activity on the Site and obtain useful information for the Company. To help the user make a more informed decision about whether to consent to the collection of such cookies, please read the respective privacy policies of Google (https://policies.google.com/privacy?hl=en) or visit the page https://www.youronlinechoices.com/it/le-tue-scelte

Marketing and profiling cookies: track the user's browsing on the Site, allowing the creation of personalized content on the Site, showing the user products of interest or similar to those already viewed, sending advertising messages in line with expressed preferences: refusal or revocation of consent will not interfere with the possibility of accessing or browsing the Site. Other analytical cookies may be installed by third parties to track the user's activity on the Site and obtain useful information for the Company. To monitor and promote campaigns and relevant content to third-party partners and offer you personalized advertising, the Company has installed and manages a pixel within the site. To help the user make a more informed decision about whether to consent to the collection of such cookies, please read the respective privacy policies of Google regarding Google AdSense (https://policies.google.com/privacy?hl=en), or visit the page https://www.youronlinechoices.com/it/le-tue-scelte

Social network cookies: these cookies allow the user to use the various social network features through the use of plug-ins integrated into our Site, which allow a direct connection with the social network server. The plug-in is managed by a third party. These cookies are not necessary for navigation. For information on the use of cookies by social networks and to provide informed consent, we invite the user to consult the respective privacy policies of the social networks:

Facebook: https://www.facebook.com/about/privacy/

Google: http://www.google.com/intl/en/policies/privacy/

Twitter: https://twitter.com/privacy

Instagram: https://help.instagram.com/1896641480634370?ref=ig

YouTube: https://support.google.com/youtube/answer/7671399?p=privacy_guidelines&hl=en

Pinterest: https://about.pinterest.com/en/privacy-policy

Tumblr: https://www.tumblr.com/privacy/en

13.4 Brief guide on managing cookies: how to install and delete them

Strictly necessary cookies, which enable the basic functionalities of the Site, are automatically installed when the Site is opened, without requiring consent. As for other categories of cookies, which require or do not require consent, the first time the user accesses the Site, they will see a cookie banner (privacy preferences) containing the short privacy notice and a link to the Cookie Policy. If the user has already communicated their preferences through the cookie banner, this banner will no longer be automatically displayed when the user accesses the Site again within 6 months. The user can still view and modify their preferences through the Privacy Center at any time.

However, if the user has already given their consent to the use of cookies, to delete the cookies collected before revocation, the user must delete them through their browser settings. Below are instructions for changing cookie settings on the most commonly used browsers by users:

Google Chrome Mozilla Firefox Microsoft Edge Safari Internet Explorer

The list of cookies and similar technologies used on this site is available here.

13.5 Who has access to the information collected through cookies?

Regarding cookies installed by the Company, only the Company’s authorized personnel, who have been previously trained and instructed to perform these tasks, can access the information collected through cookies. As for third-party cookies, the information is collected and used by the Company and third parties linked to the Company by a contractual relationship. For more information on the processing of personal data and our collaborations with third parties, please refer to the Privacy Policy.

For any questions or concerns regarding our terms of service, please contact us at info@inuitgoggles.com.