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Confidential

Askato Privacy Policy, Effective May 25, 2018

When you use our services, you’re trusting us with your information. We understand this is a big responsibility and work hard to protect your information and put you in control. This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information.

Your privacy and the security of your personal data are very important to Askato, so we collect and manage your personal data with the utmost care and take specific measures to keep it safe. Below you will find the main information on the processing of your personal data by Askato in relation to your browsing this site and the use of the services offered. For detailed information on how Askato manages your personal data, please read our Privacy Policy.

I. Who is the Data Controller?

Below is the main information on the processing of your personal data carried out by Askato with headquarters at Exchange Place 2, EH3 8BL Edinburgh, Great Britain, as Data Controller. For any clarification, question or requirement related to your privacy and the processing of your personal data, you can contact us at any time by sending a request to our Customer Care, by calling +44 1316 080338 or by writing to the address of Askato.

II.What data do we process and why?

The personal data that Askato processes is that which you provide to us when you conclude an order, and that which we collect as you browse or use the services offered on this site. Askato can then collect data about you, for example, personal details such as name, email, history of orders and payments and cookies at your computer. Your personal data is processed for the following purposes:

  • provide you with the services Askato such as subscription to the newsletter;
  • allow registration to the site and use of services reserved for registered users.

In the aforementioned cases, the processing of your personal data is legitimate as it is necessary to execute an agreement with you or to provide you with the service that you have specifically requested. We also conduct statistical surveys and analyses with data in aggregate form to understand how users interact and use the site, in order to improve our offer and our services. However, only with your express consent will we process your personal data to:

  • carry out commercial and promotional communication activities;
  • customise the site and the commercial offers based on your interests.

III. Who will process your data?

Your personal data is processed by personnel duly authorised by Askato as Data Controller. For organisational and functional needs related to the provision of services on this site, your data could also be processed by our suppliers. The latter have been evaluated and chosen by Askato for their proven reliability and competence. Some of these subjects may also be based in non-EU countries and, in these cases, the transfer of your personal data in these countries is carried out in compliance with the guarantees provided by law.

IV. How long do we keep your data?

We keep your personal data for a limited period of time depending on the purpose for which it was collected, at the end of which your personal data will be deleted or otherwise rendered anonymous in an irreversible way. The retention period is different depending on the processing purpose: for example, the data collected during use this site is processed until the conclusion of all administrative and accounting formalities are therefore stored in accordance with local tax legislation (ten years), that which is used to send you our newsletter until you ask us to stop sending it.

V. What are your rights?

At any time, depending on the specific processing, you may: revoke your consent to the processing, know which of your personal data we have in our possession, its origin and how it is used, request the update, correction or integration and in the cases provided for by the current provisions, the cancellation, the limitation of processing or oppose their processing. If you wish, you can request to receive your personal data in possession of Askato in a format readable by electronic devices and, where technically possible, we can transfer your data directly to a third party indicated by you.

This information may be subject to changes and additions over time, so we invite you to check the contents periodically. Where possible, we will try to immediately inform you of any changes made.

VI. What personal data do we collect?

The categories of personal data that Askato collects and processes when you browse or purchase on this site are as follows:

a) we collect the personal data necessary to conclude and execute your purchase on this site such as name, e-mail address, payment details;

b) we collect your e-mail address when you sign up for our newsletter service;

c) we process the personal data you provide us when you contact our Customer Service to provide the assistance requested;

d) upon your consent, we collect and use your personal data for marketing purposes;

e) we collect information about your browsing on this site such as the pages you visit and how you interact with the single page and we save this information on our servers.

VII. How do we use the personal data we collect?

Askato collects and processes your personal data for the following purposes:

a) to conclude and execute the purchase agreement. When you complete your purchase, we ask you for the personal data necessary for the execution of the agreement, such as payment, anti-fraud checks if you choose to pay by credit or debit card, billing;

b) registration on the site and use of the services offered to registered users. Registration on the site is possible through the inclusion of some personal information which is necessary to ensure your identification and the performance of services offered to registered users.

c) provision of the services offered on this site. For this purpose, in relation to each service and its characteristics, Askato needs to collect the personal data necessary for the performance of the service requested by you.

d) management of requests to our Customer Service, which uses the personal data you provide to meet your requests for information and requests for assistance.

e) statistical analysis and surveys. We use some information about your use of the site to perform statistical analysis and surveys in order to improve our offer and our service

f) subject to your express consent, we may use the contact details you have provided for commercial communications on our products and services, in order to update you on news, new arrivals, our offers and promotions. In addition, always with your consent, we will be able to use your contacts as part of market research and surveys for the detection of satisfaction in order to improve our services and the relationship with our use.

In relation to all the activities mentioned above, we will process your personal data mainly through IT and electronic means; the means we use guarantee high safety standards, in full compliance with current legislation.

VIII. Legal basis of the processing

We process your personal data only in the presence of one of the conditions provided for by the law in force, and specifically:

a) for the conclusion and execution of a contract of which you are a part.

When we process your data for the conclusion of the purchase agreement of which you are a part, we ensure that we only use the minimum information necessary for the execution of this. This basis legitimises the processing of personal data that takes place in the following activities:

  • conclusion and execution of a purchase agreement;
  • registration on the website and use of services reserved for registered users;
  • provision of services offered on this site;
  • management of your requests by our Customer Care.

The contribution of your personal data for these activities is a contractual obligation. You are free to communicate your data or not, but in the absence of the requested data, it will not be possible to conclude or execute the agreement and your requests. This means that you will not be able to purchase the products and you will not be able to use the Askato services and that Askato will not be able to handle your requests;

b) to comply with a legal obligation.

In the event of conclusion of an agreement on this site, the processing of the user's data will take place in order to fulfill the legal obligations to which Askato complies with in accordance with the tax provisions and other regulations to which Askato is subject. You are free to decide whether to conclude an agreement and whether or not to disclose your data, but if you conclude it, your data will be necessary and will be processed to effect the aforementioned legal obligations to which Askato is require;

c) for our legitimate interest.

If you purchase products on this site by credit or debit card, some of your personal data may be processed to carry out anti-fraud activities: we have a legitimate interest in carrying out this activity to prevent and pursue any fraudulent activity

d) based on your consent.

We will carry out the following processing only if you have given us your express consent:

• carrying out marketing activities and opinion polls and market research.

Providing your personal data for these activities is absolutely optional. You are free to provide us with your data for these purposes, but without it, it will not be possible for Askato to carry out marketing activities, opinion polls and market research, and to analyse your habits.

IX. Who will process your data?

Your personal data will be processed by Askato internal staff who are specifically trained and authorised to process.

Your personal data will also be transmitted to third parties that we use to provide our services; these subjects have been adequately selected and offer a guarantee of compliance with the rules on the processing of personal data. These persons have been appointed as data controllers and carry out their activities according to the instructions given by Askato and under its control.

The third parties in question belong to the following categories: banking operators, internet providers, companies specialised in IT and telematic services; companies that carry out marketing activities; companies specialised in market research and data processing.

Your data may be transmitted to police and judicial and administrative authorities, in accordance with the law, for the detection and prosecution of crimes, the prevention and protection from threats to public security, to allow Askato to ascertain, exercise or defend a right in court, as well as for other reasons related to the protection of the rights and freedoms of others.

X. Extra-EU data transfer

Some of the third parties listed in the previous paragraph “Who will process your data?” may be located in countries outside the European Union that nevertheless offer an adequate level of data protection, as established by specific decisions of the European Commission (http://www.garanteprivacy.it/home/provvedimenti-normativa/normativa/normativa-comunitaria-e-intenazionale/trasferimento-dei-dati-verso-paesi-terzi#1).

The transfer of your personal data to countries that do not belong to the European Union and that do not ensure adequate levels of protection will be performed only after conclusion between Askato and said subjects of specific agreements, containing safeguard clauses and appropriate safeguards for the protection of your personal data which are so-called "standard model clauses", also approved by the European Commission, or if the transfer is necessary for the conclusion and execution of an agreement between you and Askato (for registration on the website or the use of services on the website) or for the management of your requests.

XI. How long do we keep the data?

We keep your personal data for a limited period of time, which is different depending on the type of activity that involves the processing of your personal data.

After this period, your data will be permanently erased or otherwise rendered anonymous in an irreversible way.

Your personal data is stored in compliance with the following terms and criteria:

a) data collected to conclude and execute agreements for the purchase on this site: until the administrative and accounting formalities have been completed. The billing data will be kept for ten years from the billing date;

b) data of the registered user: the data will be stored until you request cancellation of your profile;

c) data relating to the payment: up to the certification of the payment and the conclusion of the related administrative and accounting formalities resulting from the expiration of the right of withdrawal and the terms applied for the contestation of the payment;

d) data collected in the context of the use of services offered on this site to the user: these data are retained until the termination of service or cancellation of the subscription to the service by the user;

e) data related to user requests to our Customer Care: the data useful to assist you will be kept until your request is met;

f) data used for commercial communication activities towards users who purchase products on this site: this data is kept until the termination of service or the exercise of the opposition by unsubscription by the user;

g) data provided for commercial communications activities, opinion polls and market research: up to the request by the user to interrupt the activity and in any case within 2 years from the last interaction of any kind of user with Askato;

h) data used to personalise the site and to show customised commercial offers: as long as the user does not request the termination of the activity and in any case within two years from the last interaction of any kind of user with Askato;

i) data used for carrying out market research and surveys for the detection of satisfaction: as long as the user does not request the termination of the activity.

In any case, for technical reasons, the termination of the processing and the subsequent cancellation or irreversible anonymisation of the related personal data will be final within thirty days of the terms indicated above.

XII. Your rights

You can exercise your rights at any time with reference to the specific processing of your personal data by Askato. Below is their general description and how to practice them.

a) Access your data and modify it: you have the right to access your personal data and to request that it be correct, modified or integrated with other information. If you wish, we will provide you with a copy of your data in our possession.

b) Revoke your consent: you can revoke a consent you have given for the processing of your personal data in relation to any activity for marketing purposes at any time. In this regard, we remind you that marketing activities are considered the sending of commercial and promotional communications, the conduct of market research and surveys for the detection of satisfaction for the customisation of the website and commercial offers according to your interests. Once we receive your request, it will be our duty to promptly cease to process your personal data based on this consent, while different processing or that which is based on other assumptions will continue to be carried out in full compliance with the provisions in force.

c) Opposition to the processing of your data: you have the right to object at any time to the processing of your personal data made on the basis of our legitimate interest, explaining the reasons that justify your request; before accepting it, Askato will have to evaluate the reasons for your request.

d) Delete your data: you may request the cancellation of your personal data in the cases provided for by current legislation. Once your request has been received and examined and if it is legitimate, it will be our duty to timely cease to process your personal data and to delete it.

e) Request of restriction of the processing: in this case, Askato will continue to keep your personal data but will not process it, unless it is subject to your different request and the exceptions established by law. Processing of your personal data can be limited when you dispute the accuracy of your personal data, when the processing is illegal but you oppose the cancellation of your data, when we no longer need your personal data but you need to exercise your right in court and when you oppose your processing, in the period in which we evaluate the reasons for your request.

f) Request of data transfer to other party than Askato ("right to data portability"). You can ask to receive your data that we process based on your consent or on the basis of an agreement with you in a standard format. If you wish, where technically possible and at your request, we may transfer your data directly to a third party that you indicate.

In order to ensure that our users' data is not infringed or illegitimate by third parties, we will ask you for some information to be sure of your identity before accepting your request to exercise one of the rights indicated.

XIII. Security measures

We protect your personal data with specific technical and organisational security measures, aimed at preventing your personal data from being used illegitimately or fraudulently. In particular, we use security measures that guarantee: the pseudonymisation or the encryption of your data; the confidentiality, integrity, availability of your data as well as the resilience of the systems and services that process them; the ability to restore data in the event of a data breach. Furthermore, Askato agrees to test, verify and regularly evaluate the effectiveness of technical and organisational measures in order to guarantee continuous improvement in the security of processing.

XIV. Complaints

If you believe that the processing of your personal data has been carried out illegally, you can file a complaint with one of the supervisory authorities responsible for compliance with the rules on personal data protection.

XV. Changes to this information

The constant development of our services may lead to changes in the characteristics of the processing of your personal data described up to now. Consequently, this privacy policy may be subject to changes and additions over time, which may also be necessary with regard to new regulatory measures regarding the protection of personal data.

Therefore, we invite you to periodically check the contents: where possible, we will try to inform you promptly on the changes made and their consequences in In any case, the updated version of the privacy statement will be published on this page, with indication of the date of its last update.