Privacy Policy

This website (hereinafter referred to as the Application) collects certain Personal Data from its Users.

Data Controller

Pandora srl – Corso Buenos Aires, 20 – 20124 Milan

Data Controller Email Address: info@primolino.it

Categories of Data Collected

Among the Personal Data collected by this Application, either independently or through third parties, are: Cookies, Usage Data, email address, first name, last name, and telephone number.

Comprehensive details regarding each category of data collected are provided in the dedicated sections of this privacy policy or via tailored informational notices presented prior to data collection.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically while utilizing this Application.

Unless specified otherwise, all Data requested by this Application is mandatory. Should the User decline to provide such Data, it may preclude this Application from delivering the requested Service. In instances where this Application explicitly designates certain Data as optional, Users are at liberty to withhold such Data without any impact on the availability or operational excellence of the Service.

Users seeking clarity on which Data is mandatory are cordially invited to contact the Data Controller.

The deployment of Cookies—or other tracking tools—by this Application, or by the owners of third-party services utilized by this Application, serves, unless otherwise stated, to provide the Service requested by the User, in addition to the further purposes detailed herein and in the Cookie Policy.

The User assumes full responsibility for any third-party Personal Data obtained, published, or shared through this Application, warranting that they are duly authorized to disclose or disseminate such data, and indemnifying and holding the Data Controller harmless from any and all liability toward third parties.

Methods and Place of Processing the Collected Data

Processing Methods

The Data Controller undertakes appropriate security measures designed to prevent unauthorized access, disclosure, alteration, or destruction of Personal Data.

Processing is carried out using information technology and/or digital telematics tools, following organizational procedures and practices strictly aligned with the stated purposes. In addition to the Data Controller, in certain instances, access to the Data may be granted to authorized personnel involved in the administration of this Application (administrative, commercial, marketing, legal teams, and system administrators) or designated external service providers (such as third-party technical support partners, postal couriers, hosting providers, IT companies, and communications agencies) appointed, where necessary, as Data Processors by the Data Controller. An updated list of these Data Processors may be requested from the Data Controller at any time.

Legal Basis for Processing

The Data Controller processes Personal Data relating to the User where one of the following conditions applies:

the User has granted consent for one or more specific purposes; Please note: under certain jurisdictions, the Data Controller may be entitled to process Personal Data without the User’s consent or any other of the legal bases specified below, until the User objects to ("opts out" of) such processing. However, this does not apply whenever the processing of Personal Data is governed by European data protection legislation;
processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures;
processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.

It is always possible, at any time, to request that the Data Controller clarify the specific legal basis for each processing activity, and in particular to determine whether the processing is mandated by law, required under a contract, or necessary to enter into a contract.

Place of Processing

Data is processed at the Data Controller’s operating offices and in any other locations where the parties involved in the processing are situated. For further details, please contact the Data Controller.

The User’s Personal Data may be transferred to a country other than their own. To obtain further information regarding the location of such processing, Users may consult the section detailing the processing of Personal Data.

The User is entitled to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organisation governed by public international law or set up by two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to safeguard the Data.

Should any of the aforementioned transfers take place, Users may consult the relevant sections of this document or make inquiries to the Data Controller using the contact details provided herein.

Retention Period

Data is processed and retained for the duration strictly necessary to fulfill the purposes for which it was collected.

Therefore:

Personal Data collected for purposes relating to the performance of a contract between the Data Controller and the User shall be retained until the execution of such contract has been fully completed.

Personal Data collected for purposes attributable to the legitimate interests of the Data Controller shall be retained until such interests have been fully satisfied. Users may obtain further information regarding the legitimate interests pursued by the Data Controller within the relevant sections of this document or by directly contacting the Data Controller.

Where processing is based on the User’s consent, the Data Controller may retain Personal Data for a longer period until such consent is withdrawn. Furthermore, the Data Controller may be obliged to retain Personal Data for an extended duration in compliance with a legal obligation or pursuant to an order from an authority.

Upon the expiration of the retention period, Personal Data shall be deleted. Consequently, following this date, the rights of access, erasure, rectification, and data portability can no longer be exercised.

Purposes of the Processing of Collected Data

User Data is collected to enable the Data Controller to provide its Services, as well as for the following purposes: Analytics, Contacting the User, Interaction with social networks and external platforms, Content commenting, Commercial affiliation, Payment management, Address management and sending email communications, Hosting and backend infrastructure, SPAM protection, Remarketing and behavioral targeting, and Displaying content from external platforms.

To obtain further detailed information regarding the purposes of processing and the specific Personal Data relevant to each purpose, Users are invited to consult the dedicated sections of this document.

Details Concerning the Processing of Personal Data

Personal Data is collected for the following purposes and through the following services:

Contacting the Guest

Contact Form (This Application)

By completing the contact form with their details, the User consents to their use in responding to requests for information, bespoke quotations, or any other inquiry specified within the form's subject.

Personal Data collected: first name, last name, email address, company name, allocated budget, selected service required, and telephone number.

Analytics

The services featured in this section enable the Data Controller to monitor and analyze web traffic, thereby tracking User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google utilizes the Personal Data collected to track and examine the use of this Application, compile reports, and share them with other services developed by Google.

Google may use the Personal Data to contextualize and personalize the advertisements within its advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy – Opt Out.

Video Content

Display of content from external platforms

This type of service enables users to view and interact with content hosted on external platforms directly from the pages of this Application. Should such a service be integrated, it may still collect web traffic data for the pages on which it is installed, even when Users do not actively engage with it.

Vimeo Video (Vimeo, LLC)

Vimeo is a video content visualization service provided by Vimeo, LLC, enabling this Application to seamlessly integrate such media within its pages.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy.

YouTube Video Widget (Google Inc.)

YouTube is a video content viewing service provided by Google Inc. that enables this Application to seamlessly integrate such content within its pages.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy.

Hosting & Infrastructure

These services host the data and files essential for the seamless operation of this Application, enabling its distribution and providing a sophisticated, turnkey infrastructure to deliver its dedicated functionalities. Certain services operate across geographically distributed servers, which may present complexities in identifying the precise location where Personal Data is retained.

Neen Network provides dedicated hosting and backend services managed by Artwork S.r.l.

Personal Data collected: various categories of Data as specified in the service's privacy policy.

Place of processing: Please refer to the privacy policy of Neen Srl – Privacy Policy.

User Rights

Users may exercise specific rights regarding the Data processed by the Data Controller.

Specifically, the User is entitled to:

withdraw consent at any time. The User retains the right to revoke any previously granted consent regarding the processing of their Personal Data.

object to the processing of their Data. Users may object to the processing of their Data where such processing is carried out on a legal basis other than consent. Further details regarding the right to object are set forth in the dedicated section below.

access their Data. The User is entitled to obtain information regarding the Data processed by the Data Controller, specific aspects of the processing, and to receive a copy of the processed Data.

verify and request rectification. The User may verify the accuracy of their Data and request that it be updated or amended.

obtain the restriction of processing. Under certain conditions, Users may request the restriction of the processing of their Data. In such cases, the Data Controller shall process the Data solely for storage purposes.

obtain the erasure or removal of their Personal Data. Provided specific conditions are met, the User may request the deletion of their Data by the Data Controller.

receive their Data or have it transferred to another controller. The User is entitled to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to have it transferred without hindrance to another controller. This provision applies where the Data is processed by automated means and the processing is based on the User’s consent, on a contract to which the User is party, or on pre-contractual measures related thereto.

lodge a complaint. The User is entitled to lodge a complaint with the competent data protection supervisory authority or initiate legal proceedings.

Details Regarding the Right to Object

Where Personal Data is processed in the public interest, in the exercise of official authority vested in the Controller, or for the pursuit of legitimate interests pursued by the Controller, Users are entitled to object to such processing on grounds relating to their particular situation.

Please be advised that, should their Data be processed for direct marketing purposes, Users retain the right to object to such processing at any time without providing any justification. To ascertain whether the Data Controller processes data for direct marketing purposes, Users are invited to consult the relevant sections of this document.

How to Exercise Your Rights

To exercise their rights, Users may direct a request to the Data Controller’s contact details specified herein. Such requests are processed free of charge and addressed by the Data Controller as expeditiously as possible, and invariably within one month.

Cookie Policy

This Application utilizes cookies. To learn more and review the comprehensive disclosure, the User may consult our Cookie Policy.

Additional Information Concerning Data Processing

Legal Defence

The User’s Personal Data may be utilised by the Data Controller in legal proceedings or in the preparatory stages leading to possible legal action, to safeguard against the misuse of this Application or related Services by the User.

The User acknowledges awareness that the Data Controller may be required to disclose Personal Data pursuant to lawful requests by public authorities.

Specific Notices

Upon the User's request, in addition to the information provided within this privacy policy, this Application may provide the User with supplementary and contextual notices regarding specific Services, or the collection and processing of Personal Data.

System Logs and Maintenance

For operational and maintenance purposes, this Application and any third-party services it utilizes may collect system logs—files that record interactions and may encompass Personal Data, such as the User’s IP address.

Information Not Contained in This Policy

Further details regarding the processing of Personal Data may be requested at any time from the Data Controller using the provided contact information.

Response to “Do Not Track” Requests

This Application does not support “Do Not Track” requests.

To determine whether any third-party services utilized honor “Do Not Track” requests, please consult their respective privacy policies.

Amendments to this Privacy Policy

The Data Controller reserves the right to amend this privacy policy at any time, notifying Users accordingly on this page. We kindly invite you to consult this page regularly, referring to the date of the latest modification indicated at the bottom. Should a User decline to accept the amendments introduced to this privacy policy, they are required to cease using this Application and may request the Data Controller to delete their Personal Data. Unless specified otherwise, the preceding privacy policy shall continue to apply to the Personal Data collected up to that time.

Definitions and Legal Framework

Personal Data (or Data)

Personal data constitutes any information that, directly or indirectly—including in connection with any other information, such as a personal identification number—renders a natural person identified or identifiable.

Usage Data

This refers to information collected automatically through this Application (including by third-party applications integrated herein), which may include: the IP addresses or domain names of the computers utilized by the User connecting to this Application, the URI (Uniform Resource Identifier) addresses, the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's response (successful outcome, error, etc.), the country of origin, the features of the browser and operating system employed by the visitor, the various temporal aspects of the visit (such as the time spent on each page), and details concerning the navigation path followed within the Application, with particular reference to the sequence of pages visited, alongside other parameters regarding the User's operating system and IT environment.

User

The individual utilizing this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The individual to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency, or other body that processes personal data on behalf of the Data Controller, as set forth in this privacy policy.

Data Controller (or Controller)

The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data and the measures adopted, including security measures concerning the operation and use of this Application. Unless otherwise specified, the Data Controller is the owner of this Application.

This Application

The hardware or software platform through which the Personal Data of Users is collected and processed.

Service

The Service provided by this Application as defined in the relevant terms (if available) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union within this document shall be deemed to extend to all current member states of both the European Union and the European Economic Area.

Cookies

A small piece of data stored securely on the User's device.

Legal Framework

This privacy policy has been prepared in accordance with applicable legal provisions across multiple jurisdictions, including Articles 13 and 14 of Regulation (EU) 2016/679. Unless otherwise specified, this privacy policy relates exclusively to this Application.