Privacy Policy

2. How Do We Process Your Information?

In summary: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your personal information for other purposes with your express consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts: We may process your information so you can create and log in to your account, and keep your account in working order.
• To deliver and facilitate delivery of services to the user: We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users: We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send you administrative information: We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To fulfill and manage your orders: We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• To request feedback: We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications: We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see 'WHAT ARE YOUR PRIVACY RIGHTS?' below.
• To protect our Services: We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends: We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To save or protect an individual's vital interest: We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. What Legal Bases Do We Rely on to Process Your Information?

In summary: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, such as with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. Accordingly, we may rely on the following legal bases to process your personal information:

• Consent: We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract: We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests: We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for the following business purposes:
  • Sending users information about special offers and discounts on our products and services
  • Analyzing how our Services are used so we can improve them to engage and retain users
  • Diagnosing problems and/or preventing fraudulent activity
  • Understanding how our users use our products and services to improve user experience
• Legal Obligations: We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests: We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions, provided that certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
• We may disclose anonymized information for approved research or statistical projects, subject to ethical oversight and confidentiality commitments

4. When and with Whom Do We Share Your Personal Information?

In summary: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do so. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of third parties with whom we may share personal information are as follows:

• Data Analytics Services
• Payment Processors
• Social Networks
• Website Hosting Service Providers
• Sales and Marketing Tools
• Ad Networks
• Communication and Collaboration Tools
• Data Storage Service Providers
• Government Entities

We also may need to share your personal information in the following situations:

• Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• When we use Google Maps Platform APIs: We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). Google Maps uses GPS, Wi-Fi, and cell towers to estimate your location. GPS is accurate to about 20 meters, while Wi-Fi and cell towers help improve accuracy when GPS signals are weak, such as inside buildings. This data helps Google Maps provide directions, but it is not always perfectly accurate.

5. Do We Use Cookies and Other Tracking Technologies?

In summary: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to collect information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also allow third parties and service providers to use online tracking technologies on our Services for analytics and advertising purposes, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these technologies by submitting a request as described below in the section 'DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?'.

Specific information on how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across all Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

6. Is Your Information Transferred Internationally?

In summary: We may transfer, store, and process your information in countries other than your own.

Our servers are located in Germany. Please be aware that your information may be transferred to, stored, and processed by us at our facilities and by those third parties with whom we may share your personal information (see 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?' above), in the United States and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law.

European Commission’s Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

7. How Long Do We Keep Your Information?

In summary: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us to keep your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. How Do We Keep Your Information Safe?

In summary: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. Do We Collect Information from Minors?

In summary: We do not knowingly collect data from or market to children under 18 years of age or equivalent age specified by law in your jurisdiction.

We do not knowingly solicit data from or market to children under 18 years of age or equivalent age specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age or equivalent age specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or equivalent age, please contact us at info@casapoppi.it.

10. What Are Your Privacy Rights?

In summary: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal effects or similarly significantly affects you is taken solely by automated means, we will inform you, explain the main factors, and offer you a simple way to request human intervention. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS POLICY?' below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority (Garanti Privacy).

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner (FDPIC).

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS POLICY?' below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, by replying to our emails with the word "Disattiva Newsletter", or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS POLICY?' below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.
• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at info@casapoppi.it.

11. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to browser DNT signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is no industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

12. Do United States Residents Have Specific Privacy Rights?

In summary: If you are a resident of one of the United States, you may have the right to request access and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or request deletion of your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The following table shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples for each category and does not necessarily reflect the totality of the specific personal information collected from you. For a full inventory of all personal information we process, please refer to 'WHAT INFORMATION DO WE COLLECT?'.

We may also collect other personal information outside of these categories in instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for the following periods:

• Category A - As long as the user maintains an account with us.
• Category B - As long as the user maintains an account with us.
• Category C - As long as the user maintains an account with us.
• Category E - 1 year.

Sources of Personal Information

Learn more about the sources of the personal information we collect in 'WHAT INFORMATION DO WE COLLECT?'.

How We Use and Share Personal Information

Learn more about how we use your personal information in the section 'HOW DO WE PROCESS YOUR INFORMATION?'.

We collect and share your personal information via: Beacon/Pixel/Tag.

Will Your Information Be Shared with Anyone Else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not sold or shared any personal information to third parties for business or commercial purposes in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for business or commercial purposes in the preceding twelve (12) months:

• Category A. Identifiers
• Category B. Protected classification characteristics under state or federal law
• Category C. Commercial information
• Category E. Internet or other electronic network activity information

The categories of third parties to whom we disclosed personal information for business or commercial purposes can be found under 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute and, in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal information.
• Right to access your personal information.
• Right to correct inaccuracies in your personal information.
• Right to request the deletion of your personal information.
• Right to obtain a copy of the personal information you previously shared with us.
• Right to non-discrimination for exercising your rights.
• Right to opt out of the processing of your personal information if it is used for targeted advertising, the sale of personal information, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling").

How to Exercise Your Rights

To exercise these rights, you may contact us by visiting https://casapoppi.it/it/contattaci or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Verification Process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will use the personal information provided in the request solely to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you make a request through an authorized agent, we may need to collect additional information to verify your identity before processing the request and the agent will need to provide a signed permission from you to make the request on your behalf.

13. Do We Make Updates to This Policy?

In summary: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

14. How Can You Contact Us about This Policy?

If you have questions or comments about this policy, you may email us at info@casapoppi.it or by post to:

CASA POPPI DI CUOMO DAVIDE
Registered Office: Via del Lavoro 1, Torre del Greco - 80059 (NA)
Operational Headquarters: Contrada Pietrapiana snc, Rocca Imperiale - 87074 (CS)
Italy

15. How Can You Review, Update, or Delete the Data We Collect from You?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or request the deletion of your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: https://casapoppi.it/it/contattaci.