HUMANWELLNESS S.A. (hereinafter also “HW”), as the owner of the BeGood.storewebsite, takes special care and attention in collecting and managing the personal data that each User provides, or that are automatically acquired during navigation of the “BeGood.store” website (hereinafter, the “Site”), or when using the services available therein (hereinafter, the “Services”), and hereby intends to explain how personal data are processed in accordance with the applicable privacy statutory provisions set forth in Regulation (EU) 679/2016 (the “GDPR” and hereinafter, the “Regulation”).
Navigation of the Site is free and does not require any registration, except for certain sections in which the User may voluntarily and expressly provide a series of data concerning him/her in order to access specifically identified Services.
If the User intends to provide his/her personal data in order to access such further Services, he/she shall be expressly informed as provided for by the Regulation, and allowed to determine whether or not he/she wishes to proceed with the provision of his/her personal data for processing purposes, as indicated from time to time.
HW does not collect and does not intend to deliberately use personal data of minors, in accordance to the provisions of the law in effect in the User’s country of residence. By accessing BeGood.store.it and using the Services offered by the Website, you declare that you are of legal age.
1. Data Controller
“HUMANWELLNESS S.A.”, with registered office on Via Ferruccio Pelli, 9 - Lugano (CH) is the Data Controller, which, as such, collects and processes the personal data of users who visit and use the Website.
2. Type of Personal Data Collected
The Company which, as Data Controller, collects and processes the personal data of the users who visit and use the Website is “HUMANWELLNESS S.A.”, with registered office on Via Ferruccio Pelli, 9 - Lugano (CH).
Type of personal data collected
No registration is required to access the Site. During your visit to the Site, however, some personal data will be acquired automatically, while others will be gathered only by accessing i) sections that require registration by entering data in online forms; ii) sections dedicated to Services, for the use of which it is necessary to provide your data Services (e.g., your data may be required to access Newsletters, to contact us, to make purchases, etc.).
a. Data Automatically Collected by the Site
Any data relating to the connection to and navigation within the Site (such as IP addresses, domain names of the computers used for navigation and connection to the Site, URL addresses of the resources requested, time of the request, method used to submit a request to the server, size of the file received in response, numerical code indicating the status of the response given by the server and other parameters relating to operating system and computer environment) are not associated with you, but collected for the sole purpose of obtaining anonymous statistical information on Site use, and to check its correct functioning, and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical cyber crimes committed against the Site. If no crime has been committed, the data will be deleted after the time required to provide the Services illustrated on the Site.
b. Data Voluntarily Provided by You
In order to access the Services offered by the Site, some of your personal data may be required for each service, such as:
- your personal data necessary to complete and process your purchase on the Site, such as: first and last name, e-mail address, shipping address, billing address, telephone and payment information;
- your e-mail address when you subscribe to our Newsletter service;
- any personal data you provide to us when you access the “Contact Us” page to provide you with the assistance you require;
- with your consent, we collect and use your personal data for marketing purposes (name, surname, e-mail address and telephone);
- for the registration of your account, we collect your first and last name and e-mail address.
The provision of such data is entirely optional although necessary in order to use the Services requested; therefore, failure to provide such data will prevent us from providing you with the requested Service.
3. Main Purposes and Legal Basis of Processing
Your personal data will be processed by the Data Controller in accordance with the principles laid down in the Regulation for the following purposes:
- to ensure the correct navigation of Site areas, due to the necessary nature of such processing to allow you to navigate the Site and fulfil your legal obligations;
- to process your requests to purchase BeGood products and activities related thereto, in order to process the contract of sale of products or any pre-contractual measures implemented on the basis of your request;
- to respond to your requests received through the Site (“Contact Us”), in order to implement contractual and/or pre-contractual measures at your request;
- to allow you to create an account and authorise you to access the different features and restricted sections of the Site, by reason of your express consent given for this purpose;
- to carry out marketing activities by means of automated tools (such as messaging platforms, SMS and email), which may include the delivery of newsletters, promotions, commercial information on Our Products and Services, notification of special initiatives dedicated to BeGood customers and other dedicated Services on the basis of your explicit consent, which may be revoked at any time. In addition to your email address, which is essential for your subscription to the Newsletter, depending on the type of marketing activities that we will carry out, we may use complementary channels/tools (telephone, messaging platforms and SMS), based on the contact details that you have already provided or that you will provide to us in the future.
- to carry out profiling activities within the use of your account, consisting in the analysis of information concerning your personal data, as well as information relating to details on purchases made on our Site, your preferences concerning our products through your personal account on the basis of your explicit consent, which may be revoked at any time;
- to ensure that HW is safeguarded in and out of court, due to the necessary nature of such processing;
- to implement anti-fraud activities in relation to online purchases, in light of HW’s legitimate interest in preventing and combating fraud.
4. Data Processing Methods
Your data may be processed with the aid of IT, electronic and paper supports; processing shall ensure data security, confidentiality and pertinence with respect to the declared purposes, through the adoption of suitable measures to prevent, inter alia, the disclosure, unauthorised access, alteration and loss of the processed information.
Your data will be processed by HW’s internal resources, which are adequately trained and authorised to process them exclusively for the purposes set forth in this policy and in compliance with the provisions of the Regulation.
5. Data Retention Period
Your personal data will only be stored for the time necessary to fulfil the purposes for which they were collected and processed, without prejudice to the need for additional storage for specific legal provisions, after which they will be destroyed or made anonymous.
- Data collected while browsing the Website: period of time not exceeding 365 days, except in the case of investigations of liability for cyber crimes for which a legal obligation or a request from the Authority may require storage for a longer period.
- Data collected for the creation of an account: will be kept until you request the deletion of your profile.
- Data collected through subscription to the Newsletter: will be stored until the consent given is revoked.
- Data collected and processed for marketing purposes: will be retained until we receive your consent revocation, or for marketing processing based on our legitimate interest, until you object to processing.
- Data collected and processed for profiling purposes: will be retained until consent is revoked.
- Data collected and processed to follow up on your request: your data will be stored and processed for the time strictly necessary to fulfil your request and any activities that may be carried out by us as a result.
- Data collected at the time of purchase of products: your personal data will be stored for the time necessary to fulfil contractual obligations and statutory requirements (e.g., taxes) in relation to the sales activities.
- Data collected and processed to protect our legitimate interests or those of third parties: your data will be stored and processed for the time strictly necessary to achieve any legitimate interest that may be pursued from time to time.
- Data collected and processed to comply with legal provisions: your data will be stored and processed for the time required by the legislation applicable from time to time.
6. Scope of Data Notification and Dissemination
Your personal data will not be disseminated.
Your personal data may also be provided to other companies controlled by the Data Controller or to companies, bodies and consortia upon which the Data Controller relies to provide its Services.
The third parties in question belong to the following categories: bank operators, Internet service providers, companies specialising in IT and digital services and couriers, who act as independent data controllers or on behalf of the Data Controller as “External Data Processors”, depending on the Service offered.
The Site also contains links to a variety of websites of third parties (Facebook, Instagram, Pinterest). If you choose to interact with such linked websites, your browsing information will be shared with those social networks and subject to the privacy and security policies of those linked websites.
Your data may also be provided to Public Authorities that lawfully and formally request them for the purpose of establishing the commission of and prosecuting crimes, as well as of preventing and safeguarding against threats to public safety, and allowing HW to ascertain, exercise or defend a right in court.
8. Transfer of Personal Data to non-EU Countries
Some of the third parties listed in paragraph “Scope of Data Notification and Dissemination” above may be located in countries outside the European Union, which, nevertheless, offer an adequate level of data protection, as established by specific decisions of the European Commission.
9. Rights of Data Subjects
At any time you have the right to know which personal data HW has on file about you and the processing operations being carried out, as well as to request your data to be updated or amended, and, in the cases provided for by the regulations in force, to be deleted and accessible with limitations, and even to object to processing. You may also, upon request, receive your personal data in electronic format for the purpose of transfer to a third party specified by you. If processing is based on explicit consent, you may revoke such consent at any time.
You may exercise your rights by sending an email to firstname.lastname@example.org
We will provide you with all the information you requested as soon as possible and, in any case, within 30 days from receipt of your request, and/or we will inform you about the actions we have taken in order to meet your request.
In order to process your request, HW may ask you for some information that is necessary to confirm your identity.
- Right to access data
You have the right to access your personal data as well as to receive information about purposes of processing, categories of data processed, recipients or categories of recipients to whom your personal data may be disclosed, expected storage period, and whether or not profiling mechanisms and automated decision-making processes are applied.
- Right to amend data
You have the right to amend or complete any data that are incomplete after verifying that any new data you have provided are accurate.
- Right to delete data
You have the right to ask for your personal data to be deleted if they are no longer necessary for the purpose for which they were collected, or if HW is no longer authorised to process them.
We would like to point out that it may not be possible to fulfil, or that we may only fulfil part of your request for deletion, due, for example, to legal or fiscal constraints that prevent the total or partial deletion of your personal data. HW shall promptly inform you of the reasons that make the complete or partial deletion of your data by HW impossible.
- Right to restrict processing
You have the right to have a restricted processing in the following cases:
- if you request to determine data accuracy;
- if the use of your data by HW is in violation of a law and you prefer to restrict the use of your data rather than requesting their deletion;
- if the data we hold about you - even though they may no longer be necessary for us to process for the purposes for which they were collected in the first place - are necessary for you to establish, exercise or defend a legal claim;
- if you have objected to the use of your data, but such data are necessary for us to establish the existence of legal grounds for their use.
- Right to withdraw consent
You may revoke your consent in relation to all processing resting upon it.
Please note that revoking your consent may make it impossible for HW to continue providing certain Services or products provided by the Site. In this case, we will inform you thereof when you withdraw your consent so that you can fully assess the effects of your revocation.
- Right to transfer your personal data to a third party
We will provide you or a third party designated by you with your personal data in a structured, commonly used and machine-readable format, provided this is technically possible.
- Right to object
You have the right to obtain at any time the cessation of the processing of your personal data in relation to the purpose(s) indicated by you. Please note that we may or may not grant your request to object on the basis of the lawfulness of processing itself.
Please note that if you withdraw your consent, we may not be able to continue to provide you with certain Services or products supplied by the Site. In this case, we will notify you in this regard when you revoke your consent, so that you can fully assess the effects of your revocation.
If the processing is performed on the basis of a legitimate interest of HW or of third parties, we reserve the right to assess the reasons for your request. If the reasons for the processing of your data legitimately outweigh your interests, rights and freedoms, or if it is necessary for us to process such data in order to initiate and execute legal proceedings, or to defend ourselves in court, we must object to your request, stating the reasons for such refusal.
The exercise of your rights is completely free of charge.
If your request is manifestly unfounded or excessive, in particular due to its repetitive nature, we reserve the right:
a) to charge you a reasonable fee based on the administrative costs incurred in providing you with the information or communication, or in taking the action requested;
b) to refuse compliance with your request.
We are also informing you that if you believe that we have breached data protection regulations, you have the right to lodge a complaint with the competent Data Protection Supervisory Authority (www.garanteprivacy.it).
10. Amendments to this Policy
We therefore invite you to periodically consult this page.