Herd Of Wolves, Inc., 16192 Coastal Highway, Lewes, Delaware 19958, email@example.com
(hereinafter “HOW”, in its capacity as Data Controller, as required by law, hereby gives you all the information related to the processing of your personal data.
A. PURPOSE OF THE PROCESSING.
HOW shall process your personal data for the following purposes:
a) Performing of a contract, complying with the legal obligation or for business administration purposes, specifically:
1. In order to fulfill all our obligations deriving from a contract with you, such as, but not limited to, receiving and processing your order, communicating with shipping companies, with banks and other financial institutions, for customer care purposes, and to protect our rights under such contract. In this case, your personal data will be processed based on the necessity to perform a contractor in order to enter into a contract with you at your request.
2. To comply with all applicable law and regulation, such as where applicable, communicating with the public administration for financial and fiscal reasons. In this case, your personal data will be processed based on a legal obligation.
3. To properly organize and carry out internal operations necessary to run our business, such as internal accounting and financial organization. In this case, your personal data will be processed based on a legitimate interest to run a profitable and well-organized business.
You are not obligated to provide us with your personal data for purposes A.1, A.2 and A.3, nevertheless if you fail to provide us such data we will not able to provide you the services or goods you require.
b) Marketing activities: to perform marketing activities and send you commercial communications, such as: promotions, discounts, direct selling proposals, market analysis and customer satisfaction surveys, commercial and promotional emails and/or other communications, newsletters, periodical publications, and any other commercial material and/or information, through email, app, SMS, phone, push notifications, etc.
In this case, your personal data will be processed based on your consent. You are not obligated to provide us with your personal data nor your consent for this purpose, nevertheless if you fail to provide us such personal data and such consent we will not able to send you the commercial communications mentioned above.
c) Profiling: To perform automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, hobbies and consuming preferences, in order to send you information materials that are more suitable to your personal interests and personalized offers and promotions.
In this case, your personal data will be processed based on your consent. You are not obligated to provide us with your personal data nor your consent for this purpose, nevertheless if you fail to provide us such personal data and such consent we will not able to send you personalized commercial communications, promotions and offers suitable to your personal interests and hobbies.
B. RECIPIENTS OF YOUR PERSONAL DATA
In order to allow us to pursue the above-mentioned purposes, your personal data may be disclosed to the following categories of recipients:
a) in our company to all persons on a need-to-know basis, i.e. people managing the orders, sending marketing material, e-commerce managers and employees, employees dedicated to the shipping of the goods, etc. All these persons shall access only the data necessary to their function and assignment, which means that not everyone shall access all your data.
b) To the subjects whose activities are necessary to perform our contract with you, or necessary to enter into a contract with you at your request, such as shipping companies, suppliers, banks, insurance companies, etc.
c) to third-party companies to which HOW has outsourced certain activities and/or services, such as administrative services, accounting services, consulting services, e-commerce services, software developing services, etc. which will act as Data Processors.
d) To the public administration, police or other Authorities if required to do so by law, regulation or by court order or similar acts with equivalent force.
C. RETENTION PERIOD
Your personal data will be stored for contractual and business administration purposes and for legal purposes for the period required by law (e.g. for fiscal purposes, for the minimum period required by the law to store fiscal data) and, if longer, the period necessary to protect our rights and exercise them.
- Your personal data will be stored for marketing purposes, if you have given your consent, for a maximum of 24 months.
- Your personal data will be stored for profiling purposes, if you have given your consent, for a maximum of 12 months.
D. YOUR RIGHTS UNDER THE LAW
The law guarantees you certain right. According to where you are, your data protection law may be different. In the European Union, and/or if you are a physical person located in the EU, the General Data Protection Regulation (GDPR) grants you the following rights: the right to access to and request rectification or erasure of personal data or the restriction of processing or to object to processing. You also are entitled to data portability and you have the right to lodge a complaint with your national Data Protection Authority. You also have the right not to be subject to a decision based solely on automated processing, including profiling. You have the right to revoke, at any time, the consent you have provided, and in order to do so you may write an email to HOW. If you want to know more about your rights, they are listed in sec 16 through 22 of the GDPR (Regulation (EU) 2016/679 of April 27, 2016).
E. DATA TRANSFER
Your data will be processed in our legal head office, in the USA.