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INTERPHONE PRIVACY POLICY


This policy has been drawn up in accordance with Articles 13-14 of Regulation (EU) 2016/679 and is intended for all users and visitors to the website interphone.com. This document cancels and replaces in full the previously published documents.

Please note that this website complies with Regulation (EU) 2016/679 (GDPR), which protects individuals with regard to the processing of their personal data. Your data will be processed in accordance with the principles of fairness, legality and transparency, and your confidentiality and rights will be protected.

See the Privacy Policy dedicated to the App here

Consult the Privacy Policy dedicated to the GPS Angel App here


1. Who processes my data?

Through the use of this website, your personal data will be processed by the following independent Data Controllers:

CELLULARLINE S.P.A. (headquartered in Reggio Emilia at Via G. Lambrakis 1/A, tax code and VAT no. 09800730963 and number of registration on the Companies Register of Reggio Emilia no. 315329; tel. +39 0522 334002), owner of the website, domain names and brands “Cellularline” and “Interphone”. Cellularline informs that it has designated, pursuant to art. 37 EU Reg. 2016/679, your Data Protection Officer ("DPO") who can be contacted via email at: privacy@cellularline.com.

•  T-Data S.r.l. (with registered office in Campogalliano, Via Strasburgo 31, tax code and VAT number IT03854490368 and registration number at Business Register of Modena IT03854490368; tel. 0331 109004; e-mail: support@t-data.it), which deals with the management of orders, sales and delivery of "Cellularline" and "Interphone" branded products marketed on the site, as well as the management of returns, the legal guarantee and other activities necessary for the sale of products through the site. Here you can view the seller's information.

2. Why is the data used, on what legal basis and for how long?


A. MANAGEMENT OF USER ACCESS AND BROWSING

Detailed information on the processing of browsing data and cookies can be found in the Cookie Policy.

B. REGISTERING ON CELLULARLINE WEBSITE

By registering on the website, users can access all the services provided for registered users, which are available in the reserved area. The login credentials for the reserved area of the website www.interphone.com are also valid for the services available in the reserved area of the website www.cellularline.com. Registration is optional.

Legal basis

The legal basis for the processing of this data is the contract between the user and Cellularline for the use of our services, including website purchases and management of the standard warranty.

Storage period

The data relating to a registered account will be processed until the account is deleted by the user. This can be done at any time by accessing the reserved area of the website, or upon express request by the user.


C. CONSENTING TO ACTIVITIES PRELIMINARY TO THE STIPULATION OF A PURCHASE CONTRACT BETWEEN THE USER AND T-DATA S.R.L

With an e-commerce purchase by an unregistered user, Cellularline will collect and make available to T-Data S.r.l the data necessary to complete the order.

Legal basis

The legal basis for the processing of this data is the fulfilment of the pre-contractual measures adopted at the request of the Data Subject.

Storage period

Details of orders made by an unregistered user will be kept by Cellularline for the time necessary to complete the order.


D. MARKETING ACTIVITIES

D1. NEWSLETTER

Registration for newsletters is completely optional.

The newsletter and DEM service is conducted through automated systems. This may involve mailing campaigns provided by MagNews (Diennea), the company appointed as the external Data Processor. The content of marketing communications may relate to: products of Cellularline S.p.A., contexts using products available from the online shop, images, videos or other multimedia content relating to the products or brands of Cellularline S.p.A.

Legal basis

This data is collected on the basis of consent. The legal basis for this data processing is the consent given at the time of the newsletter subscription request.

Conservation period

The processing of contact details for this purpose will take place until such time as the user declares that they no longer wish to receive the service (using the link in each e-mail or, for registered users, using the section in their personal area), or if the e-mail address is no longer active.

D2. AUTOMATIC BASKET RECOVERY FEATURE

Basket recovery invites are only sent to registered users who have used the e-commerce website, having logged in and not finished their purchase. This service involves sending messages through marketing automation tools managed by Klaviyo, an external company appointed as a Data Processor.

Legal basis

This data is collected on the basis of the Data Controller’s legitimate interest. The data subject still has the right to object to receiving these messages by the option of unsubscribing in the messages received.

Storage period

The details on products added to the basket and the user’s contact details are processed for this purpose for up to 96h after the basket has been abandoned on the e-commerce website.

D3. UP-SELLING AND CROSS-SELLING

Up-selling and cross-selling involve promotional and marketing messages only sent to registered users who have used the e-commerce website, having logged in and finished their purchase.

This service involves sending messages through marketing automation tools managed by Klaviyo, an external company appointed as a Data Processor. The contents of the message may involve products sold on the platform, including ones related or connected to purchases made by the user.

Legal basis

This data is collected on the basis of the user’s consent, which is completely optional. The data subject still has the right to object to receiving these messages by the option of unsubscribing in the messages received or in the preferences section which can be accessed in the members’ area. Any refusal to grant consent may mean it is not possible to receive information on promotions, discounts and offers.

Storage period

The details on purchases made and the user’s contact details are processed for this purpose for up to 6 months after the purchase is made on the e-commerce website, or until the user expresses their desire to no longer be a member of the service, or the email address is no longer active.

D4. SOCIAL MEDIA CAMPAIGNS

Marketing activities may also be carried out by sharing your personal data, acquired when browsing the site and purchasing products, with digital platforms and social networks, as part of campaigns (e.g. retargeting, prospecting, Custom Audience), in order to tailor and customise ads within the digital platforms themselves. 

The Controller may also process the user's contact data and the data communicated by the user during the interaction with the digital platforms and social networks - such as the information provided by the user to the social media according to the privacy settings selected, on such social media - in order to show marketing ads and content consistent with the user's interests, based on the preferences and consumption habits identified through cookies and/or other tracking systems of the social media operators, including Meta Platforms Ireland Ltd. ("Meta") and/or as a result of the analysis that the social media operators perform on their users

Legal Basis

This activity is carried out on the basis of consents for profiling purposes, which are absolutely optional, always revocable and expressed by the user: a. during registration with the website (for Custom Audience campaigns), b. through cookie preferences (for retargeting campaigns), c. directly through the privacy settings of their profile on the social network (for prospecting activities). 

Storage Period 

The user's data processed for this purpose refer to the last 2 years of activity on e-commerce, and in any case until the user expresses the wish to no longer subscribe to the service, or the e-mail address is no longer active.


E. EXTENDED WARRANTY

If the extension of the warranty on “Interphone” products is requested, the details of the related products may be requested and processed, together with any other information that is essential for the warranty contract. This data will be processed for warranty management purposes.

Legal basis

The basis for the processing of data for the warranty is the contract, while for market research, the legal basis is the legitimate interest (Article 6, letter f of Regulation (EU) 2016/679).

Conservation period

The data processed for the warranty contract will be kept for 10 years.
 

F. CUSTOMER CARE

F1. HANDLING REQUESTS FOR ASSISTANCE

The users' data may be processed for assistance and customer care activities, to reply to requests for information or to respond to complaints, reports and objections. The service involves the use of services managed by GUURU Solution AG, an external company appointed as Data Processor, based in Switzerland, a non-EU country that guarantees an adequate level of data protection (art. 45 GDPR).

Legal basis

Processing is carried out on the basis of the need to comply with a request from the data subject (Art. 6.1.b GDPR).

Storage periods

Data is processed for as long as necessary to fulfil the requests and then stored for a further 5 years.

F2. MANAGEMENT OF REQUESTS BY USERS TO EXERCISE THEIR RIGHTS

If you request the exercise of your rights as indicated in paragraph 7 of this policy, you may be asked to provide identification details which will be processed in accordance with the legal obligations by which CELLULARLINE is bound, in order to reply to the request, to verify its authenticity and to take the necessary actions.
Any refusal to provide data for this purpose will mean that CELLULARLINE will be unable to fulfil the request of the user, who may not, therefore, exercise their rights.

Legal basis

For the performance of legal obligations.

Storage period

The data requested from the Data Subject for this purpose will be processed for the time necessary for the management and closure of the request, and it may be kept for the time necessary to certify that the request has been fulfilled.

G. PURSUIT OF LEGAL PURPOSES

CELLULARLINE may process the personal data collected through browsing the website and through using its functions in order to verify, exercise or defend its rights.

Legal basis

For the above purpose, data that was initially collected for a different purpose will be used; such data will be processed on the basis of the data controller’s legitimate interest (Article 6, letter f of Regulation (EU) 2016/679).

Storage period

Up to 10 years from the date of collection or achievement of the purpose for which the data was originally collected.

3. How will the data be processed?

For the above purposes, the personal data will be processed using manual, analogue, computer-based, electronic and telematic instruments and media, which may be automated, in order to connect the data with the data of other persons based on quali-quantitative and temporal criteria which may be recurring or defined on a case-by-case basis, using logic and forms of data organisation which are closely correlated to the purposes of the processing, always in such a way that the data’s security and confidentiality is guaranteed.

4. Am I obligated to provide my data?

Subject to the indications given with regard to browsing data, users are free to provide their personal data. As CELLULARLINE has organised its activities by limiting the collection of personal data based on the principle of strict necessity, for certain operations such as the completion of online forms, any failure to provide data marked with an asterisk (*) may mean that it is not possible to fulfil the requested operation.

Please also note that any consent you provide for marketing operations may be withdrawn at any time, using the link in each e-mail or, for registered users, using the relevant section in their personal area.

5. To whom will they be communicated? Will the data be disseminated?

Dissemination: the dissemination of your personal data may only concern what is indicated for purpose G, regarding the reviews of the purchases that will be published in the appropriate product sheets on this platform.

Communication: The data may be communicated to those subjects, including public authorities, who have access to the data by virtue of regulatory or administrative measures.

Furthermore, your personal data may be made accessible to:

- Employees and/or collaborators authorised and appointed as data processors;

- T-Data for the performance of its activities;

- Cellularline group companies;

- Shopify, as a PaaS (Platform As A Service) provider of e-commerce services;

- Other third-party companies, consultants or professionals appointed as Data Processors, including IT suppliers of modules and services integrated into the Shopify environment, or performing maintenance activities, mailing and marketing automation services, cloud services.

The full list of data recipients is available at CELLULARLINE's registered office.


6 Where will the data be stored?

The data will mainly be stored at the premises of the Data Controller and its suppliers based in the European Union. For marketing automation operations (purposes D2 and D3) the involvement of suppliers based in the United States is foreseen, with data transfer made compliant with Chapter V of EU Reg. 2016/679 through contractual agreements based on the Standard Contractual Clauses approved by the European Commission.

7 What are your rights?

As a data subject, you have a number of rights, pursuant to Articles 15-22 of Regulation (EU) 2016/679, such as:

- Right to access your personal data (once you have received confirmation that your data is being processed by the Controller);

- Right to obtain rectification and integration of one's own data;

- Right to obtain the deletion of one's own data;

- Right to obtain the restriction of the processing of one's personal data under certain conditions;

- Right to receive the personal data provided to the Controller in a structured and commonly used format, and to transmit it to a different Controller;

- Right to object to the processing of personal data if there are reasons related to your personal situation;

- Right not to be subjected to an automated decision-making process;

- Right to obtain notification in the event of a serious breach of your data;

- Right to withdraw consent to processing at any time;

- Right to lodge a complaint before a Supervisory Authority

The Controller is committed to making it as easy as possible for data subjects to exercise their rights.

To request the exercise of rights, or for any doubt or need related to the processing of personal data, you can contact CELLULARLINE SPA by e-mail at privacy@cellularline.com.

8. Policy Update

Policy last updated: April 19th, 2024