PERSONAL DATA PROCESSING INFORMATION (PRIVACY POLICY)
Updated as of
Dear User, below you will find all the information provided for in Article 13 of the European Regulation on the Protection of Personal Data (Reg. EU 2016/679 – hereinafter, GDPR), on the processing of personal data carried out through this App and the Resellify platform. It will be clarified to you which data is collected, how it is used, transferred, communicated and stored by the site, for how long it is retained and what rights you can exercise.
WHO IS THE DATA CONTROLLER?
The GDPR defines the Data Controller as "the natural or legal person, public authority, service or other body that, individually or jointly with others, determines the purposes and means of the processing of personal data".
The Controller is, therefore, the one who decides "why" and "how" the data must be processed, without receiving instructions from others.
The Data Controller of this site is Resellify Srl, with registered office at Via Bagutta, 13 Milan 20121 Italy, VAT: IT12142010961, contactable at the following email address: info@resellify.it.
The Controller may entrust to others (natural persons or companies) some processing of personal data, but such subjects must be specifically designated as Data Processors (Article 28 GDPR) and receive clear and precise instructions on how to process the data, guaranteeing, in turn, adequate standards of security and lawfulness in the processing entrusted to them.
WHAT IS MEANT BY PERSONAL DATA?
To better understand all the information present in this document and that you have the right to know in a clear and transparent manner, we provide you here with a simple, albeit concise, explanation of what is meant by personal data. When using this term, we refer to a natural person and, in particular, to those pieces of information through which such person is or can be identified, such as, for example, their habits, lifestyle, personal relationships, health status, economic situation, etc.
Personal data that identifies a natural person directly are, for example, personal data (first name and surname) and images. Personal data that identifies a natural person indirectly are, for example, phone number, tax code, IP address, email, license plate number, credit card details, etc.
These just listed are defined as "common" personal data.
There are, moreover, the so-called "special" data, or also called "sensitive" data, which are genetic data, biometric data, those relating to health, life or sexual orientation, those that reveal racial or ethnic origin, religious and philosophical beliefs, political opinions, trade union membership. But it doesn't end here. There are also the so-called "judicial" data, that is, those that reveal criminal convictions, security measures or the status of accused or investigated person. Finally, data relating to electronic communications (via Internet or telephone) and those that allow geolocation, providing information on places frequented and movements are considered very significant personal data.
WHAT TYPE OF PERSONAL DATA DO WE COLLECT AND USE ON OUR PLATFORM?
To make our platform/App accessible, functional and performing, in its various services, including selling an item on your behalf, positioning it on the most famous marketplaces, we use the following personal data:
name, surname, email and password, phone, address for the collection of the item you put up for sale, age (although NOT MANDATORY to personalise offers dedicated to you) and bank IBAN.
Some of this data is provided to us directly by Users, while others are derived from navigation, cookies and user navigation tracking systems. All information on how we use such systems and cookies, in particular, is available in another document, called Cookie Policy (which you can find here). In that document you will also find instructions on how to refuse certain types of cookies and, in general, the list with explanation of the types of cookies used by us and third-party companies.
The categories of persons to whom such data belongs and with whom we interact for our services are:
- subjects who sell through our platform (so-called merchants)
- subjects who purchase on our platform (customers)
- subjects who use our apps or our services
- subjects who browse our site or request information through the assistance point of our site.
WITH WHOM DO WE SHARE PERSONAL DATA?
For the processing purposes that we have described to you in this information notice, we may share your personal data with:
- authorised persons (ex Article 29 of the GDPR) by the Controller to process personal data to carry out activities strictly related to the provision of services of this site, who are under his direct supervision, and who have committed to confidentiality or are in any case subject by law to an obligation of confidentiality;
- the so-called Data Processors/sub-Processors (ex Article 28 GDPR), that is, subjects, natural persons and companies, who cooperate with the Controller for the pursuit of the various processing purposes, including the subjects who host this App on their marketplace through the allocation of our widget on their site or on their App, who manage it, those who are delegated to carry out technical maintenance activities of computer networks, to manage sales operations and/or to carry out necessary support activities for services provided through their platform;
- subjects, entities or authorities for whom it is mandatory to communicate personal data by virtue of legal provisions or orders of the Authorities.
The Data Processors/sub-processors of personal data, as well as the Authorised persons, are all appointed by formal act and indicated in a special list. If you wish to have more information about such subjects, do not hesitate to write to the Controller at the following email address: info@resellify.it
FOR WHAT PURPOSES DO WE USE PERSONAL DATA?
In general, we process personal data for:
- providing our services, which includes, for example, the purchase procedure, the digital wardrobe creation procedure, through which to sell items you no longer want, assistance for purchases and information requests, payment of items that we have managed to sell on your behalf, as well as any subscription plans. The legal basis for the processing of personal data for such purposes is established by Article 6, paragraph 1, letter b of the GDPR (execution of a contract or pre-contractual measures).
In other cases, however, we cannot process your personal data without your consent. In the event that, where requested by us, you decide not to give consent, such choice will not condition and compromise your enjoyment of the services that we have described above. What are these cases? The request to subscribe to the newsletter to receive commercial and promotional information from us, the request to transfer your information to third parties, the sending of new items put up for sale on the platform, which, if consent had been given, may meet your preferences.
To contact the User: the User who intends to contact the Controller for any request or information on the services/products offered.
Finally, there are some purposes for which the processing of your personal data has a legal basis different from both the contract and consent. Among these purposes is the fulfilment of legal obligations that are imposed on us by current laws, regulations or community legislation, or satisfying requests from the Authorities or again defence in court, that is, that your personal data may be used by us in court or in the previous phases, in the event that there are abuses on your part in the use of our platform or our services (e.g. fraud, spam, identity theft, etc.).
LINKS TO THIRD-PARTY SITES AND SOCIAL PLUGINS
These services allow interactions with social networks, or with other external platforms, directly from the pages of this Site.
The Controller does not control and has no way to supervise either the content or the policies on the processing of personal data of the websites and third-party services accessible through the links contained within the Site, including any social plugins. The Controller will not, therefore, in any case be held responsible for the processing carried out through or in relation to such third-party sites. Users are, therefore, invited to take note of the privacy and cookie policy, as well as the terms of service published on such sites.
Interaction with Social Networks
In the event that a social network interaction service is installed, it is possible that, even in the case where Users do not use the service, the same collects traffic data relating to the pages where it is installed.
Instagram Widget (Meta Platforms, Inc.)
The Instagram widget and "follow" button are social network interaction services with Instagram, provided by Meta Platforms, Inc.
Personal data collected: Cookies and Usage Data.
Place of processing: USA – Privacy Policy
LinkedIn Widget (LinkedIn Ireland.)
The LinkedIn widget and "follow" button is a social network interaction service with LinkedIn, provided by LinkedIn Ireland.
Personal data collected: Cookies and Usage Data.
Place of processing: USA – Privacy Policy
Third-party Services
The Resellify Platform/App may contain links to websites, applications, services or resources of third parties ("Third-party Services") that are subject to different terms and privacy practices. Resellify Srl is not responsible for any aspect of such Third-party Services and links to them do not constitute sponsorship.
- Google Terms
Some sections of the Resellify Platform/App implement Google Maps/Earth mapping services, including Google Maps application programming interfaces (APIs). The use of Google Maps/Earth is subject to Google Maps/Google Earth Additional Terms of Service. If the user accesses or downloads our application from Google Play Store, they accept the End User License Agreement for the Application licensed by Google - Apple Terms
If the user accesses or downloads our application from Apple App Store, they accept the End User License Agreement for the Application licensed by Apple.
WHAT ARE YOUR RIGHTS, HOW CAN YOU EXERCISE THEM AND WHO SHOULD YOU CONTACT
Your Rights
The rights that you can exercise to protect your personal data are contained in Articles 15 et seq. of the GDPR.
In particular, you have the right to:
- access your personal data, request their rectification, updating and deletion or limitation, if incomplete, erroneous or collected in violation of the law;
- object to the processing for legitimate reasons or obtain their portability;
- obtain confirmation of the existence or not of personal data concerning you, even if not yet recorded, and their communication in intelligible form.
You also have the right to obtain:
a) the indication:
- of the origin of the personal data;
- of the purposes and methods of the processing;
- of the logic applied in case of processing carried out with the aid of electronic instruments;
- of the identifying details of the Controller, of the Processor(s) (internal/external) and of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them as Authorised persons;
b) the updating, rectification or integration of your data within the limits of relevance to the activity carried out by the Controller;
c) the deletion, transformation into anonymous form or blocking of data processed in violation of the law, including those for which conservation is not necessary in relation to the purposes of the processing;
d) the attestation that the operations referred to in letters b) and c) have been brought to the attention of those to whom the data have been communicated, except in the case where such fulfilment proves impossible or involves the use of means manifestly disproportionate to the protected right.
You also have the right to object, in whole or in part:
e) for legitimate reasons to the processing of personal data concerning you, even if pertinent to the purpose of the collection;
f) to the processing of personal data concerning you for the purpose of sending the newsletter for promotional purposes.
How you can exercise your rights
You can send your request to the Controller, at the following email address: info@resellify.it. You do not need to comply with any particular formality for such request, which you can also send through a person appointed by you and which you can renew for justified reasons. The Controller will provide its response as soon as possible, and in any case, not later than one month from receipt of the request itself (extendable by two months, for complexity and number of requests).
In the event that such response should be missing or is not shared by you, you have the right to lodge a complaint with the Data Protection Authority (Article 77 GDPR, Article 141 Privacy Code) or to take appropriate judicial venues (Article 79 GDPR, Article 152 Privacy Code). The complaint form and information on how to compile and submit it are available here.
FOR HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
Data is processed and retained for the time required by the purposes for which it was collected. Personal data provided for the provision of services offered by this App will be retained for the period of time necessary for their provision, within the times provided for and allowed by Italian legislation to protect their interests (and in any case not beyond the terms referred to in Articles 2946 of the Civil Code et seq. - prescription).
Personal Data collected for purposes attributable to the legitimate interest of the Controller will be retained until such interest is satisfied.
If you have decided to subscribe to the newsletter for promotional purposes, personal data will be retained for a period not exceeding two years from their provision, without prejudice to the fact that you can unsubscribe from the service at any time through the "UNSUBSCRIBE" link present at the bottom of each communication.
In general, all data processed on the basis of your consent is retained until such consent is revoked by you. The Controller may, however, be obliged to retain personal data for a longer period in compliance with a legal obligation or by order of an Authority.
At the end of the retention period, Personal Data will be deleted. Therefore, upon expiry of such term, the right of access, deletion, rectification and the right to portability of the Data can no longer be exercised.
More information regarding the data retention period and the criteria used to determine such period can be requested by you from the Controller at the email address: info@resellify.it
WHERE IS THE DATA PROCESSED?
Personal data collected through this App is processed at the operational offices of the Controller and in any other place where the subjects involved in the processing, authorised or responsible/sub-responsible for the processing, are located. The transfer of your personal data and Users outside the EU, where necessary for the provision of services/products of this App, takes place exclusively towards non-EU countries that ensure adequate levels of protection to the current privacy legislation. For further information, we invite you to contact the Controller.
We specify that the App is present on Google and Apple stores, two providers based in the United States, also connected to the providers that make tracking tools available in the following way: when you download the app from your store of interest (Google - for Play Store, or Apple - for Apple Store), you do so through the credentials of your account, which are personal data. In this case, the processing of data is necessary, precisely, to proceed with the download of the App and the relative legal basis is represented by the execution of pre-contractual measures, in accordance with Article 6.1.b. of the GDPR. We remind you that already on Play Store (section "Data Security") and App Store (section "App Privacy") you can find some information on the processing of your Data.
The App also uses, like web cookies, tracking tools for technical purposes, that is, to be able to download the App, analytical purposes, for statistical or profiling investigations, or to target users based on their tastes and preferences. In the first case, the tools are functional to effective use of the App, in the second and third, requiring explicit consent, they are also subject to refusal by the user, without prejudice to the normal usability of the App. Therefore, any transfer of Data that should be necessary to be able to download the App, for such purposes, is permitted by Article 49 letter b) of the GDPR while, with regard to the other processing purposes, any transfer of Data to the United States is guaranteed by the adequacy decision adopted by the European Commission on 10 July 2023.
If, moreover, it should be necessary to transfer your Data to another non-EU country, this will be carried out in compliance with the obligations provided for in Chapter V of the GDPR, adopting all precautions to guarantee the security of the transfer and giving adequate information.
HOW IS DATA PROCESSED AND PROTECTED?
Data is collected in compliance with the principle of minimisation of processed data (only data strictly necessary to provide the requested services or achieve the other purposes specified here is acquired). The processing of personal data by the Company takes place through manual, computer and telematic tools with logics strictly correlated to the cited purposes. Processing operations are carried out in such a way as to guarantee the security of data and systems. Adequate security measures are adopted in order to minimise the risks of destruction or loss, even accidental, of the data itself, of unauthorised access, of unauthorised or non-compliant processing with respect to the purposes indicated in this information notice. The security measures adopted, however, do not allow to exclude, absolutely, the risks of interception or compromise of personal data transmitted with telematic tools. We therefore invite you to verify that your device (PC, smartphone, tablet, etc.) is equipped with software systems adequate for the protection of telematic data transmission, both incoming and outgoing (such as, for example, updated antivirus systems, firewalls and anti-spam filters).
MINORS UNDER 18 YEARS OF AGE
To use the services of our App, you must be at least 18 years old. In the absence of this, any personal data possibly provided by the minor, without parental consent, will be immediately deleted, exempting the Controller from any responsibility, request for refund and/or compensation.
MODIFICATIONS
This App reserves the right to make changes or update the content of this information notice, also as a consequence of possible variations in the applicable legislation. You will be informed of such variations at the time of their introduction and they will have binding effect at the time of their publication on the Site. To take, therefore, cognisance of the most updated version of the Privacy Policy, we invite you to regularly visit this section of the site, so as to be constantly informed about the use and types of data collected by the Controller.