PRIVACY POLICY
the processing of personal data by bravomaestro

 

OUR PRIVACY POLICY

This Privacy Policy is provided pursuant to Regulation (EU) 679/2016 and the subsequent national adaptation legislation (hereinafter, as a whole “GDPR”) and describes how the companies of the Bravomaestro Group (referred to in the “Data Controllers” section below, jointly in this Privacy Policy “bravomaestro”) collect and process the personal data of users or customers through his website, in particular www.bravomaestro.academy, or more generally every time that express reference is made to this Privacy Policy.
The term “personal data” means any information concerning a identified or identifiable physical person. For example, personal data is the name, an identification number, location data, an online identifier.
bravomaestro may amend, supplement or periodically update this information, also in consideration of possible regulatory changes which are applicable or provisions from the Guarantor for the Protection of Personal Data. The changes and substantial updates to the Privacy Policy will be applied and brought to the attention of the interested parties as soon as they are adopted by updating the link to the Privacy Policy in the Site footer and by emailing the registered users. In case of changes that significantly affect the rights of the registered user, the communication will be made with reasonable notice.

PURPOSES OF PROCESSING AND LEGAL BASIS

The data are processed for the following purposes.
a) Based on the contractual need in order to:
– manage orders and perform related activities (ex: sales and after-sales customer assistance, communications with the customers on the status of their orders, responses to their information requests, management of payments, etc.);
– managing user accounts when registered with the Site in order to use the related services;
– allow access to specific and additional services requested from time to time by the user (e.g. registration to courses held by bravomaestro);
– manage product shipments and create waybills;
– follow specific user requests.
b) Based on the consent expressed by the user, specifically collected each respective time, in order to carry out market research, as well as to contact the user and send commercial communications and promotional offers, in addition to sending the Newsletter described below, with regard to products, services and/or events of bravomaestro, through SMS, telephone, paper mail or other means, including through a prior analysis of consumer behaviour aimed at customising commercial messages.
After making a purchase on the Site, the user will receive the Newsletter regarding similar products or services. The user has a right to oppose to such processing right away (i) by using the appropriate link at the end of each email, (ii) changing his preferences in the “My account” section on the Site, or (iii) by using the contact details indicated below in the section “Rights of the data subject”.
In any case, the user may exercise his right to object to such processing in the manner indicated above. The foregoing also applies to the sending of the Newsletter following the provision of data at events or in any case following a purchase.
c) Based on the legitimate interest of bravomaestro, specifically:
– for the analysis and improvement of its services;
– for statistical and/or research and development activities, also by analysing data deriving from the use of services and products or consumer behaviour;
– in order to defend their rights in the course of court, administrative or extrajudicial proceedings, and in disputes arising in connection with the services offered;
– in the case of extraordinary transactions, merger, sale of a business unit, acquisitions, etc.
d) Based on the need to fulfill the legal obligations to which bravomaestro is subject.
The provision of data for the purposes referred to in paragraph (a) above is mandatory, as it is necessary to process the sale and delivery of products and services purchased, or for registration at the sites. Refusal to provide personal data for processing makes it impossible to perform the services required for the purchase of goods and services on the Sites.

CATEGORIES OF DATA PROCESSED BY BRAVOMAESTRO

Below is a description of the categories of data we deal with:
– Data supplied directly by the interested party: all personal data entered on the Site (to proceed with online purchases or to register), or in any case provided to bravomaestro in any manner (e.g. in the context of promotional activities, or on the occasion of participation in the courses, etc.). Examples of data provided directly by the interested parties are: name; address and telephone number. More generally, all the data provided to allow the execution of a purchase order, the carrying out of research of products on the Site, the compilation and use of the profile on the Site, the facilitation of the delivery of products with the communication data relating to numbers or contact addresses (eg telephone, email, addresses), participation in courses, etc.
– The data provided by third parties constitute all the personal data bravomaestro collects from other sources (postal service companies, couriers, data entry companies, etc.) to perform its services. Examples of data provided by third parties are the data related to updates or corrections received during delivery by couriers, transport partners or third parties, the data on web pages visited that we may receive from other commercial operators with whom bravomaestro collaborates for certain initiatives, the names of the recipients of the orders, if different from the buyer.
– Data collected automatically: these are browsing data and/or collected using the so-called “cookies”. During their normal operation, the computer systems and software procedures used to operate this site acquire certain personal data whose transmission is implicit in the use of internet communication protocols. This information is not collected with the aim of linking it to identified users, although, by its nature, it might enable user identification through processing and linking with data held by third parties. This category of data includes IP addresses or domain names of computers used by persons who connect to the site, the URI (Uniform Resource Identifier) of requested resources, the time of request, the method used to submit the request to the server, the size of the file received in reply, the numerical code indicating the status of the reply provided by the server (successful, error, etc.) and other parameters regarding the user’s operating system and computer environment.

COOKIES

A cookie is a small file sent by a website and stored on the user’s browser while they use an Internet site. Cookies can be stored only for the time you use a particular site (cookies session) or for a longer period of time and independent from the session (persistent cookies). Cookies work in conjunction with the website content and normally have the function of improving the usability and browsing experience on the web (technical cookies). Some types of cookies also allow you to know the contents displayed, the choices selected and any use of the site by the user. This functionality also allows us to offer the most useful and relevant advertising to every single user (profiling cookies). A website can use self-developed cookies (first-party cookies) or cookies developed by third-party companies (third-party cookies).

In addition to allowing an easy use of the Sites, Bravomaestro uses cookies for various purposes, including: (i) identifying the user when logging in; (ii) store the products saved in the cart for purchase; (iii) avoid fraudulent use of accounts or payments; (iv) perform user profiling and then provide information on the products of interest to you, or other personalised contents or offers; (v) provide promotions, content, advertising, related to the user and his preferences and to remember these preferences; (vi) carry out market research; (vii) improve the Sites, the offer of Bravomaestro products, and their marketing, etc.
In particular, bravomaestro uses:
a) TECHNICAL COOKIES: These are cookies necessary for browsing as they allow correct use of the Site and its full functionality. They include cookies which enable the creation of a personalized account, logging in, displaying content in the chosen language at every access, recognising the the user is connecting from (and remembering this setting for future access) and order management. These cookies are strictly necessary for Site operation and their deactivation might impair browsing experience and outcome. In particular, we use technical cookies for the following purposes:
– for the management of dynamic web pages, for the geographical identification of users, and for the management of last access data;
– to guarantee the correct functioning of the web pages;
– for the functioning of the forms (e.g. course registration form);
– for the management of data relating to the amounts and products of the orders
b) ANALYTICAL COOKIES: used to collect information on the number of users and how they visit the site. For example:
– Google Analytics: the site uses the Google Analytics tool to collect information, in aggregate form, on the number of users and how they visit the site. This tool uses third-party technical cookies for its operation. Information on the processing of privacy by Google is available at the following link: http://www.google.com/analytics/learn/privacy.html. Information on the cookies used by Google Analytics, collection and use of this data are available at the following link: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage#gajs. The following link also contains information to deny consent to the use of third-party cookies by Google Analytics: http://tools.google.com/dlpage/gaoptout

c) THIRD PARTY PROFILING COOKIES FOR MARKETING/RETARGETING: these are cookies of third-party companies that allow the collection of information on the user for subsequent communication of more specific and/or personalised promotional material. They include cookies for inserting banner advertisements on the Site relating to third party companies or products chosen or viewed by the user, or similar or like products. These cookies can be deactivated without preventing proper navigation on the Sites, however their deactivation involves the receipt of promotional messages that may not be relevant to the user. For more information on profiling cookies currently installed in the user’s terminal, review the third party privacy information and change the preferences expressed, users can consult the page http://www.youronlinechoices.com/it.

Disabling cookies.

The user can always decide to block, delete, disable cookies or other similar technologies through the settings of their browser or device. There are many different browsers: each different browser (and in some cases even each different version of the same browser) has its own procedure for deleting cookies. Cookie preferences must be set separately for each browser used, as the features and options offered may vary. It is therefore advisable to visit the support pages of your browser for more information. Furthermore, the user can modify the settings related to Bravomaestro cookies, including their activation and deactivation, by accessing the dedicated section in the Sites’ footer, under “Cookie Settings”. Their complete deactivation may preclude many features, or the proper browsing or viewing of the Site or other web pages.

Acceptance and waiver of cookies.

At the time of the user’s first access to the Sites and, in any case, until a choice is expressed, the user will be asked to provide his consent to the use of third-party analytical cookies and profiling cookies. In particular, consent can be provided by continuing with navigation.

DATA RECIPIENTS OR CATEGORIES OF RECIPIENTS

The data may be processed by third parties, carefully selected in terms of reliability and competence, who, as data controllers, act in the name and on behalf of bravomaestro on the basis of contractual agreements and specific instructions. This is necessary or appropriate in order to carry out activities, including instrumental or ancillary, related to the purposes of data processing indicated in this Privacy Policy, the main one of which consists in the supply of goods or services requested by the interested party (e.g.: postal service companies, couriers, data entry companies, companies that manage marketing and newsletters, etc.).

In any other case, except as required by applicable law, personal data are not transferred and/or disclosed to third parties.

TRANSFER OF DATA TO NON-EU COUNTRIES

If personal data are transferred to countries outside the European Union, the transfers will take place in compliance with the provisions established by the GDPR in order to ensure an adequate level of protection. In particular, the transfers will take place through the conclusion of Standard Contractual Clauses approved by the European Commission, a copy of which can be obtained through a specific request to be sent to the contact data contained in this Privacy Policy.

DATA RETENTION PERIOD

As soon as the personal data are no longer necessary for the purposes for which they were collected, bravomaestro will delete them, unless the law requires further storage, or the user has not consented to the processing for a longer time, or when they are archived. In particular, following the deactivation of the account or, for unregistered users, of the completion of the order, Bravomaestro will retain the personal data that are necessary to: – fulfill the requests of the authorities within their competence;
– defend or assert any existing or potential claim;
– handle any complaint regarding contracts or orders concluded.
The data retention period necessary to achieve the aforementioned purposes is linked to the limitation period of a claim that in many cases is equal to 10 years. Bravomaestro will retain personal data after such time has elapsed only when required to comply with legal obligations or in the event of disputes and extraordinary claims that reasonably require the retention of personal data.
Regarding the data entered in the “Work with us” section, when submitting a job application online or by other means, if the application is not successful, such data will be stored in the system of the relevant Bravomaestro branch for a maximum of 24 months, in order to allow us to evaluate the candidate for other positions. The user can oppose to this processing at any time by submitting a request to the contacts indicated in the section “Rights of the data subject”.

RIGHTS OF THE DATA SUBJECTI

Under the GDPR, each user has the right to access their personal data and to obtain confirmation of the existence or otherwise of his personal data, even if not yet registered, and to their communication in intelligible form.

In particular, each user has the right to obtain access to his data from bravomaestro, as well as any information regarding the methods and characteristics of the processing.
In addition to the above, the user, in the cases provided by law, has the right to receive his personal data in a structured, plain and readable format, as well as the right to transmit this data to another data controller without impediments. Furthermore, each user has the right to obtain updates, rectification or integration of their data from bravomaestro. The user also has the right to erase his personal data as well as to limit the processing in cases provided by law.
Finally, each user has the right to object, in whole or in part, to the processing of personal data concerning him if the processing is based on the legitimate interest of the controller, as well as for direct marketing purposes.
The requests referred to in the previous points should be addressed to the data controller’s contacts indicated in the “Data Controller” section below. The requests must be addressed to the relevant controller for the relevant activities. If you have doubts or if you want more information about the relevant data controller, contact the Customer Care.

TITOLARE DEL TRATTAMENTO

The controller of the data processing is ABM Solutions Snc (owner of the brand and the bravomaestro website) with registered office in BRA (CN) Piazza Carlo Alberto n. 43, CAP 120042, (ITALY), Tax Code / VAT Number: 03299020044, certified email address amministrazione@pec.abmsolutions.it

If you have doubts or if you want more information about the relevant data controller, contact the Customer Careinfo@bravomaestro.academy