Privacy Policy for SENEER 22

Last Updated: April 2025

1. Our Commitment to Your Privacy

Welcome to SENEER 22 SOCIETA' A RESPONSABILITA' LIMITATA SEMPLIFICATA ("we," "us," or "our"). We are committed to protecting the privacy of your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and Italian Legislative Decree 196/2003 (as amended by Legislative Decree 101/2018). This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you visit our website, make a purchase, or interact with our services. By using our website and services, you consent to the practices described in this policy.

2. Data Controller

SENEER 22 SOCIETA' A RESPONSABILITA' LIMITATA SEMPLIFICATA is the data controller responsible for your personal data.

Registered Address: Via dei Gobbi 34, 59100 Prato (PO), Italy
VAT Number: 02618170977
Contact Email: aushi0218@aushi.shop

3. The Information We Collect

We collect various types of information to provide and improve our services, and we do so in a fair and lawful manner. The data we collect is limited to what is necessary for the purposes for which it is collected.

3.1. Personal Information You Provide

When you register an account, place an order, subscribe to our newsletter, or contact us, we may collect:

• Contact Information: Name, email address, phone number.
• Shipping and Billing Information: Shipping address, billing address.
• Account Information: Username, password (encrypted), and account preferences.
• Communication Data: Messages, feedback, and correspondence with our customer service team.

Legal Basis: Performance of a contract, consent, and legitimate interests.

3.2. Transaction and Payment Information

• Order Details: Purchase history, items ordered, order value, and delivery status.
• Payment Information: We do not directly store your full credit card numbers. All payment transactions are processed through secure, PCI-DSS compliant third-party payment processors. We may retain limited payment information, such as the last four digits of your card and transaction IDs, for record-keeping and customer service.

Legal Basis: Performance of a contract and legal obligations.

3.3. Automatically Collected Information

When you visit our website, we may automatically collect certain technical information:

• Device and Browser Information: IP address, browser type and version, operating system.
• Usage Data: Pages viewed, time spent on pages, links clicked, and referring/exit pages.
• Location Data: General geographic location based on your IP address.

Legal Basis: Legitimate interests (to improve our services and ensure website security).

4. How We Use Your Information

We will use your personal data only for the purposes for which it was collected, or for a compatible purpose, unless you have given your express consent for a new purpose.

• Order Fulfillment: To process and deliver your orders, manage returns and exchanges, and handle customer service inquiries.
• Communication: To send order confirmations, shipping notifications, and respond to your requests.
• Service Improvement: To analyze website usage and improve our products, services, and user experience.
• Direct Marketing: To send promotional emails and special offers. We will only do so with your explicit consent (opt-in), and you may withdraw consent and opt-out at any time.
• Security and Legal Compliance: To detect and prevent fraud, address security issues, comply with applicable EU and Italian laws and regulations, and enforce our terms and policies.

5. Information Sharing and Disclosure

We do not sell or rent your personal data. We may share your information in the following circumstances:

5.1. Service Providers

We may share data with trusted third-party service providers who assist us in our business operations. These include:

• Payment Processors (within the EU)
• Shipping and Logistics Partners (within the EU)
• Cloud Hosting and IT Service Providers
• Marketing and Analytics Tools (only with your consent)

These service providers are contractually obligated to protect your data in accordance with GDPR and are only permitted to use it for the purposes we specify. Data Processing Agreements are in place with all processors.

5.2. Legal and Regulatory Requirements

We may disclose your information if required by EU or Italian law, or if we believe in good faith that disclosure is necessary to protect our rights, property, or safety, or that of our users or the public.

5.3. Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to a successor entity. You will be notified of any such change and your rights will continue to be protected under GDPR.

6. International Data Transfers

We primarily process and store your data within the European Union. If we need to transfer your personal data to a country outside the EU/EEA, we will ensure that appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions by the European Commission
• Your explicit consent

7. Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law:

• Account Information: Retained for the duration of your account plus 2 years after account closure
• Transaction Records: Retained for 10 years to comply with Italian accounting and tax obligations
• Marketing Consent: Retained until you withdraw consent or for 2 years of inactivity

After the retention period, your data will be securely deleted or anonymized.

8. Data Security

We implement appropriate technical and organizational security measures to protect your personal data from unauthorized or accidental access, processing, erasure, loss or use. These measures include:

• SSL/TLS encryption for data transmission
• Encrypted storage of sensitive data
• Restricted access to personal data on a need-to-know basis
• Regular security audits and updates
• Use of secure, PCI-DSS compliant payment processors

However, no method of transmission over the internet is 100% secure. While we strive to protect your data, we cannot guarantee its absolute security.

9. Your Rights Under GDPR

Under the GDPR, you have the following rights:

• Right of Access: Request access to the personal data we hold about you.
• Right to Rectification: Request the correction of your personal data if it is inaccurate or incomplete.
• Right to Erasure ("Right to be Forgotten"): Request the deletion of your personal data under certain circumstances.
• Right to Restriction of Processing: Request that we limit the processing of your personal data under certain circumstances.
• Right to Data Portability: Request a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: Object to the processing of your personal data based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Withdraw your consent at any time where processing is based on consent.
• Right to Lodge a Complaint: Lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) if you believe your rights have been violated.

To exercise these rights, please contact us at aushi0218@aushi.shop. We will respond to your request within one month in accordance with GDPR requirements.

9.1. Direct Marketing Opt-Out

You may opt-out of receiving direct marketing communications from us at any time by:

• Clicking the "unsubscribe" link in any marketing email
• Contacting us directly at aushi0218@aushi.shop
• Adjusting your account preferences (for registered users)

10. Cookies and Tracking Technologies

Our website uses cookies to enhance user experience, analyze website traffic, and deliver personalized content. We use the following types of cookies:

• Strictly Necessary Cookies: Essential for website functionality
• Performance Cookies: Help us understand how visitors use our website
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Track your browsing to deliver relevant advertisements (only with your consent)

When you first visit our website, you will be presented with a cookie consent banner. You can manage your cookie preferences at any time through our cookie settings or your browser settings. Please note that disabling certain cookies may affect website functionality.

For more information, please see our Cookie Policy.

11. Children's Privacy

Our services are not intended for individuals under the age of 16 without the consent of a parent or legal guardian. We do not knowingly collect personal data from children under 16 without such consent. If we become aware that we have collected personal data from a child under 16 without parental consent, we will take steps to delete that information promptly.

12. Automated Decision-Making and Profiling

We do not engage in automated decision-making or profiling that produces legal effects or similarly significantly affects you.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by:

• Posting the updated policy on our website with a new "Last Updated" date
• Sending an email notification to registered users (for significant changes)
• Displaying a prominent notice on our website

Your continued use of our services after the changes are posted will constitute your acceptance of the revised policy. We encourage you to review this policy periodically.

14. Contact Us

If you have any questions or concerns about this Privacy Policy or our data protection practices, please contact us:

Email: aushi0218@aushi.shop
Address: Via dei Gobbi 34, 59100 Prato (PO), Italy

Data Protection Officer: Available upon request at aushi0218@aushi.shop

15. Supervisory Authority

If you have concerns about how we handle your personal data, you have the right to lodge a complaint with the Italian Data Protection Authority:

Garante per la protezione dei dati personali
Piazza Venezia 11
00187 Roma, Italy
Website: www.garanteprivacy.it