Last updated [28/06/2024]

1. Introduction

The website www.zerow.it (the "Site") is published by Zerow - SRL, a limited liability company registered in the Companies Register with number IT07138020487, and with registered office in SCANDICCI (FI) VIA NEWTON 102 CAP 50018 (hereinafter "Zerow", "We" or “Us”).

Zerow gives the highest priority and care to protecting the privacy and personal data of users of the Site and representatives of its customers and business prospects.

The purpose of this Privacy Policy (hereinafter the "Privacy Policy" or "Policy") is to inform you, as representatives of purchasing companies and/or visitors to our Site (hereinafter "You"), about how we process your personal data, in particular when you use and place orders through the Site, in connection with our prospecting and promotional activities and after-sales services (hereinafter the "Personal Data" or "Data"). This Policy also provides information about your rights in relation to your Personal Data.

This Policy describes the processing of your Personal Data by Zerow (hereinafter "Processing") and your rights regarding the protection of your Personal Data.

For more information on how we handle your orders placed through the Site (the "Orders"), please refer to Zerow's Terms and Conditions of Sale.

We may change this Policy from time to time, particularly if there are changes in our use of your Personal Data. Please check this page regularly to ensure that you are happy with any changes. We will notify you of any such changes either through a special notice on our Site or through a personal notification.

2. What is Personal Data?

Personal Data refers to any information or set of information that could identify you as a natural person either directly (for example, your name and surname) or indirectly (for example, your professional function, your IP address). This means that Personal Data includes information such as your email address and phone number, but also unique identifiers such as your computer's IP address or your device's MAC address or data relating to your navigation on our Site.

3. Who is responsible for the protection of your Data?

The 'Data Controller' is the entity that determines the purposes and means of the processing and is responsible to you for compliance with the Data Protection Regulations (hereinafter “the Data Controller”).

In relation to the management of the Site, Zerow (whose contact details are provided below) acts as Data Controller. If you have any concerns, questions or requests regarding our use of your Personal Data, you can contact us at:

• by email to the following address: support@zerow.it (specifying in the subject of the email: "personal data"), or
• by post to the following address: SCANDICCI (FI) VIA NEWTON 102 CAP 50018 (for the attention of the data protection officer).

4. Why and how do we use your Data?

How do we collect your Data?

We collect your Personal Data as follows:

• directly from you when you use our Site and our services (completing various forms on the Site, placing an Order, communicating directly with us, for after-sales services, etc.)
• indirectly and automatically when you access or use the Site (cookies, technical details, navigation information, etc.)
• indirectly from third parties (social media, etc.)

What Data do we collect?

Zerow collects different types of Personal Data about you:

Data we collect directly from you

The categories of Personal Data that we may collect directly from you include:

• Information required to process your Order: selected items, delivery and billing address, contact information (see above), including credit card number and expiration date,
• After-sales service information: information about returns, exchanges and repairs, including a description of any issues with your purchase, where this information includes personal data,
• Information about your preferences: your favorite products and services, if you choose to provide us with this information, where this information includes personal data,
• History and content of your communications with us: We generate a history of our relationship when you contact us with a customer service issue or when you submit a complaint to us,
• Recording of calls to our customer service: When you contact us or one of our consultants, your conversations may be recorded to ensure a quality service. You will always be provided with alternative methods of contacting us if you do not want your conversation to be recorded.

When you fill out a Data collection form, all mandatory information will be marked with an asterisk or equivalent. If you do not complete the mandatory fields, we will not be able to process your request and/or the relevant Order.

Data we collect automatically

We automatically collect some Data about you when you access or use the Site, in particular:

• Technical information: we collect information about the device you use to access the Site, as well as about the use of the Site itself (operating system, type of browser used, whether a proxy is used, location of the device inferred from your IP address which identifies your computer, access time, pages visited and the link that allowed you to access our Site).

Data we collect indirectly from third parties

We may also obtain Personal Data about you from the social networks you use through our Site, or from your activity on social media pages. In particular, when you share your experience with Zerow with other customers using social media, you provide Data about yourself to this social network and to us. These communications are governed by the social network's Personal Data protection policies, which we invite you to consult.

On what legal basis and for what purposes do we use the Data we collect?

In accordance with applicable data protection legislation, we collect Personal Data only when we have a legal basis to do so.

Personal Data is collected:

• based on your consent,
• in the context of the performance of a contract,
• in our legitimate interest, or
• in accordance with a legal obligation.

We collect Personal Data based on your consent, for the following purposes:

• To handle your requests and questions (other than those relating to an Order): we use your Data to send you the information requested,
• To send you commercial and marketing solicitations: We may use your Data to propose new products and special offers, invite you to future events that may interest you and send you our newsletters.

We collect Personal Data based on the performance of a contract, for the following purposes:

• To process your Order: We use your Data to manage the purchase, delivery and billing of the products you order, including any information provided to create your customer account,
• After-sales services: We use your Data to handle any requests you may have regarding our after-sales services, including returns, exchanges and repairs.

We collect Personal Data based on our legitimate interest, for the following purposes:

• To measure and improve the performance of our Site: We use performance cookies to allow us to count visits and traffic sources. This helps us to know which pages are the most and least popular and see how visitors move around the Site,
• To communicate with you about your account or our relationship (for example, to ask you for feedback, conduct surveys, notify you about changes to the Site or this Privacy Policy, along with any updates to the services),
• To prevent payment fraud and ensure the validity of payments we receive,
• To defend our interests in the event of disputes or legal actions.

We collect Personal Data based on legal obligations, in order to comply with applicable laws:

In the event that some commercial documents include personal data, we inform you that we keep the history of transactions and any other commercial documents for legal and administrative reasons (liability, tax, legal or commercial guarantees, insurance, audit, etc.).

5. Who has access to your Data?

Your Data is processed by Zerow for the purposes described above and is accessible only to Zerow personnel who need to know it.

Some third parties may have access to your Data, in particular:

• our subcontractors and service providers: for after-sales services, as well as for technical and logistical reasons (logistics specialists, couriers, Site hosting and maintenance providers, payment and fraud management service providers, technical service providers responsible for sending emails and newsletters, customer service, etc.),
• social media: When you use social media buttons, your Identifiable Information is automatically sent to these social media. You may also share certain information or content from our Site on social media. We encourage you to review the social media terms of use that govern this matter,
• any third party company that, in the event of a restructuring of Zerow, acquires all or part of Zerow or merges with our company,
• any authority, court or other third party when disclosure is required by law, regulation or judicial decision, or if such disclosure is necessary to protect and defend our rights.

6. Are Personal Data transferred outside the European Union?

Your Data is processed by Zerow in Italy. However, we may rely on certain service providers, located abroad or who in turn rely on data processors located abroad, including outside the European Economic Area (EEA) in countries where the laws on the protection of personal data differ from those applicable in the EEA.

Any transfer of your Data outside the European Union will be carried out with (i) strict measures to ensure the confidentiality and security of such transfers and (ii) appropriate guarantees that will comply with applicable regulations on the protection of Personal Data, such as the signature of standard contractual clauses based on the European Commission model, including any additional measures necessary, available upon request.

7. How long do we keep your Data?

The Data is stored for the time necessary for the purpose for which it was collected and, in any case, will be destroyed at the end of this period.

In most cases, your Data is retained for the duration of our relationship, then for a period of 3 years following the termination of our relationship (which generally corresponds to the date of your last Order via the Site, the date of closure of your customer account or the date of our last contact with you). The Data is then (i) archived when necessary for accounting or documentary reasons for the applicable limitation period (generally up to 10 years) and then destroyed or anonymized once the limitation periods have expired or (ii) if there is no archive, immediately deleted or anonymized.

In exceptional circumstances, we may retain your Data for shorter or longer periods.

See the table below for more details on these periods.

Scope	Applicable Data Categories	Retention period before deletion
Customer Order Management	Identification data	Identification and Order Data: duration of Order processing until delivery + warranty period + then the Purchase Data is archived for up to 10 years for accounting or documentary reasons.
Customer Relationship Management	Purchase history, communications between you and us, customer account	Duration of the relationship + 3 years + then the data relating to the purchase history are archived for up to 10 years for accounting or documentary reasons; others
Sending our newsletter/commercial solicitations	Information about your email address and your choices regarding electronic solicitations	3 years from the last Order or the last contact with you, or earlier if you wish to unsubscribe before the end of this period. Then, the Data will be destroyed or anonymized, unless you reiterate your wish to receive our offers and newsletters.
Disputes/Complaints	Dispute/Complaint Data	If no legal action is filed, according to the applicable limitation period: up to 5 years from the event. In case of legal action: duration of the proceedings until the legal decision or conciliation agreement is fully executed.

8. What are your data protection rights?

Access, rectification and portability

In accordance with applicable laws, you have the right to access your Data. You can also request the correction of your Personal Data if it is inaccurate. Depending on the type of processing, you may also have the right to request that the Personal Data we hold be updated or corrected.

To respond to your request, we are required by law to verify your identity. If necessary, we may ask you to provide us with proof of your identity. We may also need to ask you for additional information or supporting documents to respond to your request. We will do our best to respond to your request as soon as possible.

To the extent provided by law, you can exercise your right to data portability, which allows you to retrieve, in an interoperable format, the Personal Data that you have provided us automatically when you created your account and/or signed up to our loyalty program, as well as when you selected products (favorite products, etc.).

Right to erasure of your Data and restriction of processing of your Data

You can request the deletion of your Personal Data if:

• You believe that our processing of your Personal Data is no longer necessary for the purposes of the services subscribed to or for the use of the Site, or is no longer necessary for the purposes described in this Privacy Policy, or that their retention is unlawful,
• You have withdrawn your consent to the processing of your Data and Zerow relies on consent for such processing (see above),
• You object to the processing of your Personal Data for reasons relating to your personal situation,
• You object to the use of your Data for commercial solicitation or profiling purposes,
• Your Data was collected online when you were a minor.

Alternatively, to the extent permitted by law, you may request the restriction of the processing of your Data.

Please note that, notwithstanding the exercise of your right to erasure or restriction of processing, we will retain some of your Personal Data when the law requires or authorizes it, when we have a legitimate reason to do so (for example, to demonstrate the performance of a contract) or to exercise or defend our rights in court. For example, if we believe that you have violated our General Terms and Conditions of Use or our General Terms and Conditions of Sale.

Right to establish instructions for the management of your Personal Data after your death

Under Italian law, you can determine how you want us to handle your Personal Data after your death.

9. Procedure for exercising your data protection rights

To exercise your rights, you can contact us directly at: support@zerow.it (specifying in the subject of the email: "personal data").

Additionally, if you have a customer account, you can exercise your right to access, rectify and/or delete your Data by accessing your account.

When the processing of your Data is based on your consent (for example, subscription to the newsletter, sending of electronic commercial solicitations, use of cookies and similar technologies on the Site), you can withdraw your consent at any time without justification. This right can be exercised by changing your options regarding commercial solicitation and subscriptions to our newsletters, and by withdrawing your consent to the use of cookies in accordance with the procedure indicated in the cookies section below.

For any questions regarding your rights and the processing of your Data, please contact us at: support@zerow.it (specifying in the subject of the email: "personal data").

10. How is your Personal Data protected?

Zerow uses technical and organizational measures that comply with applicable legal and regulatory requirements to keep your Data safe and confidential.

Under written agreements, Zerow requires its service providers and processors to provide guarantees and implement sufficient security measures to protect the Personal Data they have agreed to process, in accordance with the applicable requirements of Personal Data Protection Laws.

However, Zerow does not control all risks related to the functioning of the Internet and draws your attention to the risks inherent in the use of any website.

11. Protection of minors

Our Site is not intended for children. We do not knowingly collect Data about children unless permitted by law.

You must be at least eighteen (18) years of age to share your Data with us. If we are informed that a child under eighteen (18) has submitted Data to us, we reserve the right to immediately delete such Data and any associated accounts.

12. Cookie

When you visit our Site, it can store or retrieve information on your browser, mainly in the form of cookies.

This information may be about you, your preferences or your device and is mainly used to make the Site work as you expect it to and to personalize your user experience.

You can learn more about the types of cookies on our Site and manage your cookie preferences on this page. Please note that blocking some types of cookies may impact your experience of the Site and the services we are able to offer.

13. Third Party Websites

Our Site may include links to third-party websites or services that we do not control and that are governed by their own privacy and Personal Data protection policies. This Privacy Policy does not apply to third-party websites. We encourage you to consult the privacy and Personal Data protection policies of third-party websites that you visit to understand how they treat your Data. Zerow will not be responsible for the use of your Data by third parties.

14. How to contact us for questions or complaints?

For any questions regarding this Policy or for any questions or complaints regarding your Personal Data, you can contact us at any time at the following address: support@zerow.it (specifying in the subject of the email: "personal data").

If you have a complaint about how we collect and process your Data, you also have the right to lodge a complaint with the Italian data protection supervisory authority (the Garante per la protezione dei dati personali, located in Piazza Venezia, 11 - 00187 Rome, Tel: +39 06 696771) or, if you reside elsewhere in the European Economic Area, with your local data protection supervisory authority.