Our Privacy Policy

PRIVACY POLICY

Information regarding the processing of personal data pursuant to article 13 of the European General Data Protection Regulation No. 679/2016, (GDPR)

Dear User, this page provides you with information on how personal data are managed through the site. When collecting, processing and storing personal data, we comply with all legal requirements, in particular the provisions of the EU Data Protection Regulation (European General Data Protection Regulation 2016/679 “GDPR”).

This Policy applies exclusively to processing carried out through the collection or acquisition of data via this website. The purpose of the privacy policy is to provide the utmost transparency regarding the information that the website gathers.

1. DATA CONTROLLER AND DATA PROTECTION OFFICER

The companies that jointly fulfil the role of Data Controllers for the data collected and received through the website are 4 flying s.r.l. with registered offices in Campagnola di Zevio (VR) Viale Edison, 6, contact@4-pack.com, and the company 4 flying ltd, with registered offices in London, 31-35 Kirby Street, contact@4-pack.com.

The DPO of 4 FLYING S.R.L. can be contacted at the following address: infoprivacy@4-flying.com.

The Companies have entered into a Joint Data Controller Agreement, which is limited exclusively to the processing of data acquired through the use of the website by users and the subsequent processing of data for the purposes illustrated in this policy.

2.LEGAL BASIS, METHODS AND PURPOSE OF PROCESSING:

The data collected through this website are processed for pre-contractual requirements, for the legitimate interests of the Joint Data Controllers in the promotion of services and products, and for marketing and profiling activities, in accordance with the consent granted.

The data will be processed for the purposes set out in the following point, in compliance with current privacy regulations and on the basis of the principles of correctness, lawfulness and transparency, carried out in compliance with the principles of pertinence, completeness and non-excessiveness of the data processed.

Processing may consist of the following operations: collection, registration, organisation and storage, consultation and use, processing, modification, selection, extraction, comparison, interconnection, transmission and communication, erasure and destruction, blocking and restriction.

Processing will be carried out by the Joint Data Controllers, by external data processors and by persons specifically authorised and trained for the correct processing of data.

3.DATA COLLECTED, PURPOSE OF PROCESSING AND PERIOD OF CONSERVATION

During navigation on our website, navigation data are gathered through the use of log files that store information gathered in an automated manner during visits from users. The following information may be collected:

– internet protocol (IP) address.

– type of browser and parameters of the device used to connect to the website.

– name of the internet service provider (ISP).

– date and time of visit.

– web page of origin from where the visitor entered (referral) and the page from where they exited.

– number of any clicks made.

– operations carried out on the website.

For security purposes (anti-spam filters, firewalls and virus detection), automatically recorded data may also include personal data such as IP address, which could be used, in accordance with relative current legislation, to block attempts to damage the website or to cause damage to other users, as well as any activity that is in any way damaging or that constitutes a crime.

Furthermore, you can also send us your contact details (e.g. name, surname, address, telephone, email address, etc.) by entering data in the “contact us” section.

The data will be processed for the following purposes:

The sending of contact data (identification and general information) via the “Contact Us” form for registration in the Company’s CRM, activation of the services requested, customer care and contact management (for the fulfilment of a contract or management of the pre-contractual relationship); period of conservation: duration of the contract plus 10 years from termination.
The fulfilment of legal and regulatory obligations (to fulfil legal obligations); period of conservation: 10 years or as provided for by current regulations.
The exercising of rights in legal proceedings; period of conservation: for the duration of the legal dispute.
Direct marketing purposes: for example, the sending – either through automatic means of contact (such as sms, mms, e-mail, social networks, instant messaging apps, push notifications) and traditional means (such as telephone calls with an operator and traditional mail) – of advertising and commercial communications regarding services/products offered by the Company or information regarding company events, as well as surveys on customer satisfaction, market research and statistical analysis (with your non-mandatory consent, which may be revoked at any time); period of conservation: until revocation of consent for contact and general data, 5 years for purchase-related data.
Profiling and retargeting purposes: (with your prior consent, which may be revoked at any time) analysis of your preferences, habits, behaviour, interests, also through the installation of analytical and profiling cookies, in order to send you personalised commercial communications/targeted promotional actions/offers and services tailored to your needs/preferences, also on third party sites (retargeting); period of conservation: until consent is revoked for contact and personal data, 5 years for data relating to purchases.

At the end of the aforementioned periods of conservation, the data will be destroyed, erased or rendered anonymous.

4. CONSENT TO THE PROVISION OF DATA, THEIR USE AND THE CONSEQUENCES OF REFUSAL TO GRANT CONSENT.

Your personal data will be processed:

4.A without express consent (art. 6 GDPR) for the following service purposes:

To conclude contracts for the services/products offered by the Joint Data Controllers.
To fulfil pre-contractual, contractual and tax obligations deriving from existing relations with you.
To comply with obligations resulting from laws, regulations, European Community rules or orders from the Authorities (such as pursuant to anti-money laundering legislation).
To exercise the rights of the Joint Data Controllers, for example the right to legal defence.

4.B. only with specific and clear consent (art. 7 GDPR) for the following marketing purposes:

The sending via email, mail and/or SMS and/or telephone newsletters, commercial communications and/or advertising materials, also through automated means of contact, regarding products or services offered by the Joint Data Controllers, as well as customer satisfaction surveys regarding the quality of services.
The carrying out of profiling and retargeting.

Provision of data for the purposes referred to in point 4.A is voluntary. However, refusal to provide this information will render all forms of contact with the Joint Data Controllers impossible, and we will not be able to guarantee the relative services.

Provision of data for the purposes referred to in point 4.B is voluntary and can be revoked at any time. You may therefore decide to not provide any data, or to later deny permission for the processing for said purposes of previously provided data: in this case, you will not be able to receive newsletters, commercial communications or advertising materials regarding the services and products offered by the Joint Data Controllers.

In order to stop receiving the newsletter, you may click on the “unsubscribe” link found in each newsletter or access your personal profile and remove the consent flag.

5. COMMUNICATION AND RECIPIENTS OF THE DATA

We may disclose your personal information if we are required to do so by law, if you violate our Terms and Conditions of Service, or if it is necessary to do so to ensure the functioning of the Joint Data Controllers’ business, to persons appointed and instructed by the Joint Data Controllers themselves, to specifically designated external Data Processors acting on behalf of the Joint Data Controllers (e.g. accountants, consultants, IT technicians etc.), to IT Operators or System Administrators.

6. TRANSFER OF DATA ABROAD

Personal data collected through navigation of the website online and through insertion on the Contact Us page are also sent to the company 4 Flying Ltd based in London EC1N 8TE – 31-35 Kirby Street. Said transfer is, however, carried out with a suitable level of protection for personal data transferred from the European Union, as established in the European Commission’s IMPLEMENTING DECISION (EU) no. 2021/1773 of 28 June 2021 pursuant to Directive (EU) 2016/680 of the European Parliament and of the Council with regard to the adequate protection of personal data by the United Kingdom.

7. THIRD-PARTY SERVICES

In general, third-party suppliers engaged collect, use and disclose your information to the extent necessary to enable them to perform the services they provide.

8. USER RIGHTS

Pursuant to Regulation (EU) 679/2016 (GDPR) and national legislation, Users can, in accordance with the means and within the limitations provided for by current legislation, exercise the following rights:

Information: data subjects will be informed in a timely and transparent manner as to whether and how their data will be processed. This applies both when personal data is collected directly from the data subject and when data is collected by other third-party subjects.
Access: data subjects may at any time request information on the personal data stored and/or processed as well as a copy of said data.
Rectification: data subjects may at any time request the rectification or completion of false or incomplete personal data, for example, if a name or address is incorrect.
Erasure: data subjects may request the erasure of their personal data, insofar as there are no conflicting obligations or rights, e.g. conservation obligations for tax/commercial reasons. The data subject also has the right to be “forgotten”, with the consequence that other data controllers are informed of the request for erasure, to the extent that the Joint Data Controllers have communicated the personal data to them.
Restriction of processing: data subjects may request that the processing of their personal data be restricted.
Opposition: data subjects may oppose the processing of their personal data for marketing purposes at any time. Opposition is in any case possible under certain conditions, in view of the particular personal circumstances of the data subject.
Automated decision-making: with a view to efficient business transactions, data subjects are subject to automated decision-making only if said process is lawful, e.g. for the fulfilment of a contract. Data subjects are informed of the corresponding automated decision-making procedures.
Right to lodge a complaint with the Supervisory Authorities (Italian Data Protection Authority – www.garanteprivacy.it)
as well as, more in general, to exercise all rights that are recognised by current legislation.

Requests are to be made to the following address:

infoprivacy@4-flying.com in Italian or to contact@4-pack.com in English

9. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this privacy policy at any time. Modifications and clarifications will take effect immediately after their publication on the website.