Privacy Policy

User privacy is very important to the Elah Dufour Group. For this reason, Elah Dufour, in its capacity as Data Controller of personal data, undertakes to strictly comply with the current legislation on the subject, starting with EU Regulation 2016/679 and Legislative Decree no. 101/2018.

Our company policy on the protection of personal data is outlined below with regard to the use of this website.

1. PURPOSES OF THE PROCESSING
Personal data is collected and used for the following purposes:

(a) for registration on the website and for the purposes related to the use of the website, as well as for the use of the services reserved for registered users including, by way of example and not limited to, the possibility of entering a competition, taking part in promotional events or taking advantage of customer assistance services.
The legal basis for this processing is the performance of a service voluntarily requested by the website visitor.

(b) marketing purposes including sending advertising material, commercial communications by post, by phone calls with an operator, e-mail (newsletters with commercial initiatives, prize competitions and other events), text messages, calls without an operator (if the mobile number has been provided), notifications on the website, social media platforms, surveys connected to promotional activities. We may use tools that detect whether an e-mail has been opened and certain related technical information (tracking pixel) in order to verify the correct delivery of communications, measure campaign performance, improve and optimise the content and frequency of communications, personalise content based on user interactions and carry out aggregate statistical analyses.
The legal basis for marketing processing and for the related tracking pixel processing (individual tracking) is the consent given by the user, which is optional and revocable at any time.
For processing aimed at aggregate statistical measurements that cannot be traced back to individual users, the legal basis is the legitimate interest of Elah Dufour S.p.A. as Data Controller, which ensures that the data is anonymised and does not allow individual identification.

(c) profiling purposes through the analysis of consumer preferences and behaviour, including through surveys, and of browsing preferences on the website or other interactions with the user, in order to create user segments and personalise communications. The analysis will be carried out with automated tools to evaluate or predict aspects concerning the data subject and define a profile in order to direct personalised direct marketing activities.
The legal basis for this profiling is the consent given by the user, which is optional and revocable at any time.

(d) market research purposes aimed at analysing the market, understanding general trends, assessing brand perception, collecting statistical data, evaluating new products or business lines.
The legal basis for this processing is the consent given by the user, which is optional and revocable at any time.

2. METHODS AND DURATION OF PROCESSING
The processing of personal data is carried out mainly using electronic procedures and media for the time strictly necessary to achieve the purposes for which the data were collected and, in any case, for no longer than five years (two years if used for marketing and market research purposes, one year if used for profiling) and, always, in compliance with the principles of lawfulness, fairness, non-excessiveness and relevance provided for by current privacy legislation. Data obtained from e-mail tracking activities will be kept for the periods indicated according to the purpose for which they are used.

3. TYPE OF DATA PROCESSED
The personal data that will be processed are:

• data collected when registering on the website;
• data collected at the time of registration in specific areas of the website instrumental to the use of specific functions and to be able to benefit from the advantages and/or services reserved for registered users;
• data collected through e-mail tracking (for example: opening of the e-mail, clicks on links contained in the message, date and time of the interaction, IP address, device used, operating system, e-mail client, approximate geographical location derived from the IP address).

Only common personal data is collected, such as personal details and contact data, and data relating to the user's preferences and requests.

As regards the cookies on this website, please refer to the specific information on the website.

4. COMPULSORY OR OPTIONAL NATURE OF DATA PROVISION
The personal data required for registration on the website identified with an asterisk in the registration forms are necessary to allow registration, the others can be optionally communicated. The mobile phone number, if communicated, may be used for certain specific purposes such as, by way of example but not limited to, for contact via SMS and/or other instant messaging systems in the context of prize events, competitions, games, surveys.

5. SUBJECTS WHO MAY BECOME AWARE OF THE DATA
Personal data may be processed by our specifically appointed internal staff. Furthermore, for certain processing instrumental to the pursuit of certain purposes, the data may be processed by external companies as data processors. Personal data will in no case be disclosed.

6. RIGHTS OF THE DATA SUBJECT
The data subject can ask the Data Controller for access to data concerning him/her, the correction of inaccurate data, the integration of incomplete data, the limitation of processing in the cases provided for by art. 18 GDPR, as well as opposition to processing or cancellation, for reasons related to his/her particular situation, in the case of legitimate interest of the Data Controller. Furthermore, in the event that the processing is based on consent or on the contract and is carried out with automated tools, the data subject has the right to receive the data in a structured format, as well as, if technically feasible, to transmit them to another controller without impediments. The data subject has the right to revoke the consent given at any time in relation to processing for e-mail tracking, marketing, profiling and market research purposes.

To revoke consent to e-mail tracking while continuing to receive communications (marketing, newsletters), to change your preferences regarding the processing of your data (stopping or activating profiling and market research purposes) or to stop receiving any informational e-mails/newsletters, you can click in the footer of the e-mails/newsletters you receive if you have a profile registered on this platform, or send a request to privacy@elah-dufour.it. Please note that each of our e-mails/newsletters allows you to update your preferences or to unsubscribe completely from our systems via the dedicated link in the footer of the communication.

7. DATA CONTROLLER AND DATA PROCESSORS
Data Controller is: Elah Dufour with operational headquarters in Strada Serravalle 73, 15067 Novi Ligure (AL).
The Data Controller has appointed a Data Protection Officer (DPO), who can be contacted by e-mail at privacy@elah-dufour.it.
It is possible to request from the Data Controller a list of the persons appointed as Data Processors for the various types of activity (competitions, e-commerce purchases, physical events).
Any communication or request for information can be sent to the following e-mail address: privacy@elah-dufour.it