Privacy Policy
Privacy Policy
1. Who is the data controller?
The data controller of your personal data is Ninesquared Srl (hereinafter referred to for brevity as “Ninesquared“, the “Controller”, or “We”). Any requests can be sent by mail to the following address: Ninesquared Srl, Via Somier 7, 38062 – Arco (TN), or using the following email address: info@ninesquared.it
2. What personal data do we process and where do we collect it?
The Controller may process your common personal data for the purposes indicated below. As an example, it may process personal data such as personal details, contact information, financial data necessary for purchasing products and/or services, access credentials to restricted areas, data regarding your preferences and consumption habits, personal data contained in comments published on the website, browsing data (for more information on this type of processing, we invite you to consult our cookie policy), additional categories of personal data, as required from time to time depending on the type of service you intend to use.
Ninesquared Srl may collect your personal data upon registration or during the course of the ongoing relationship in the following scenarios:
- Directly from you (e.g., to enable registration on the website and/or purchase of products and/or services, or to respond to specific requests);
- From our partners to whom you have provided them, for example, for participation in specific initiatives organized or promoted by the same entities.
3. For what purposes do we process your personal data?
a. Accessing the content and services offered through the website.
We will process your personal data in order to fulfill the request to create an account – as indicated in the General Terms and Conditions – for access to the e-commerce website https://www.ninesquared.team/ and allow you to access the services offered that require registration. In relation to the aforementioned activities, the collected data will also be processed for all administrative, financial, and/or legal operations connected thereto.
b. Customer Service
We will process your personal data to handle support requests, as well as to fulfill your request for information and/or clarification.
c. Compliance with legal obligations.
We will process your personal data in order to comply with legal obligations to which we are subject and any other obligation arising from orders of competent authorities.
d. Verification of user satisfaction and service functionality
We will process your personal data in order to verify the correct functioning of our services, measure the level of satisfaction of our users, and improve the quality of our customer care services.
e. Soft Spam
We may send you commercial communications via the email address you provided at the time of accessing and/or purchasing one of the services mentioned in the previous section A. This will be limited to products and/or services similar to those you have accessed or used. In such cases, you always have the right to exercise your right to object to receiving the aforementioned commercial communications at any time.
f. Profiling
Subject to your consent, we will process your personal data, including through tracking technologies such as cookies, to carry out activities of analysis and processing of information aimed at defining a profile of your preferences, habits, consumption choices, and/or browsing experiences. Such profiling activities may also be conducted using tools provided by third parties, such as social networks (e.g., Facebook) or third-party advertising service providers (e.g., Google), adopting appropriate security measures. To this end, we may also associate the personal data acquired through tracking technologies such as cookies (where you have provided your consent) and/or the personal data provided by you within the scope of our specific initiatives and/or initiatives of our partners with those acquired as a result of your registration on the site or as a result of their use.
g. Commercial communications
Subject to your consent, we will process your personal data to inform you about our commercial initiatives, including offers specifically tailored to you, to conduct market research, and to send advertising materials, as well as to send you communications regarding commercial initiatives of our partners through the indicated channels.
h. Sharing your personal data with third parties for commercial purposes
Subject to your consent, we will process your personal data to disclose them to Ninesquared Srl, for them to use for commercial and/or promotional purposes.
i. Statistic Analysis
We will process your personal data for the production of aggregate and anonymous statistics in order to assess and improve our services. In any case, the personal data processed for statistical purposes will not be used to make decisions or take measures directed at individual data subjects, nor for the pursuit of purposes of another nature.
4. What are the legal bases that allow us to process your personal data?
Below are the legal bases for processing for each of the purposes indicated in the previous section.
- Execution of a contract or pre-contractual measures (Article 6, paragraph 1, letter b) GDPR).
The Personal Data collected for the purposes outlined in letters A and B will be processed as necessary to perform a contract of which you are a part and/or pre-contractual measures adopted at your request. This processing is necessary, and therefore, failure to provide personal data, when mandatory, will prevent us from providing the requested service. - Compliance with a legal obligation (Article 6, paragraph 1, letter c) GDPR).
The personal data collected for the purpose outlined in letter C will be processed to fulfill a legal obligation to which Ninesquared Srl is subject. Their provision is therefore necessary, and refusal will prevent us from providing the requested service. - Legitimate interest (Article 6, paragraph 1, letter f) GDPR)
The personal data collected for the purposes outlined in letters D, E, and I will be processed on the basis of the legitimate interest of Ninesquared Srl or third parties. The provision of your data for these purposes is not necessary for the provision of the requested services; however, failure to provide them or opposition to the processing will prevent us from evaluating the performance of our services and improving customer satisfaction for the same. Additionally, in cases outlined in letter E, it will prevent us from sending you commercial communications regarding products and/or services similar to those you have purchased and/or used. - Consent (Article 6, paragraph 1, letter a) GDPR)
The data collected for the purposes outlined in letters F, G, and H will be processed only with your freely given, specific, informed, and unambiguous consent. The provision of your personal data for these purposes is not necessary for the provision of the requested services; however, failure to provide consent – or its revocation, if initially given – will prevent you from receiving communications, including potentially profiled ones, about commercial initiatives from Ninesquared Srl and/or our commercial partners.
5. How and for how long do we process your data?
We process your personal data electronically and in paper form, adopting technical and organizational security measures to ensure an adequate level of security based on the risk.
Your personal data will be processed for the time strictly necessary to achieve the purposes for which they are collected and will be kept for different periods of time, depending on the pursued purpose. At the end of the indicated retention period, your personal data will be deleted or anonymized, unless it is necessary to retain them for longer periods for different purposes for which the data were legitimately collected. Ninesquared Srl has identified a retention period of 10 years for each of the purposes mentioned above.
6. To whom may we disclose your personal data?
For the purposes outlined above, we may disclose your personal data to the following categories of entities:
- third parties and/or companies that provide services related and/or instrumental to the activities carried out by Ninesquared Srl;
- companies that need them for administrative, accounting, or legal reasons;
- with your prior consent, our commercial partners so that they can process them, as independent data controllers, for marketing purposes;
- independent authorities, law enforcement agencies, or the judicial authority for their institutional purposes within the limits provided by law.
the aforementioned entities may act, depending on the cases, as data processors (based on a specific data processing agreement with Ninesquared Srl) or as independent data controllers. A detailed and updated list of such entities and their privacy qualifications can be requested from the Data Controller.
Your personal data may also be accessed by personnel authorized by the Data Controller, who have been specifically instructed on the methods and purposes of processing.
7. Transfer of personal data outside the European Economic Area
If strictly necessary to achieve the purposes outlined above, your personal data may be transferred outside the European Economic Area (hereinafter referred to for brevity as “EEA”). In such cases, the measures prescribed by the GDPR (Articles 44 and onwards) will be observed.
8. What are your rights and how can you exercise them?
In relation to the processing of your personal data carried out by Ninesquared Srl, you may, at any time, request access, rectification, and deletion of your personal data, as well as request restriction of processing. You may also object to processing based on our legitimate interest and at any time, revoke any consent you may have given.
If you believe that the processing of your personal data violates the principles established by the current legislation on the protection of personal data, you may lodge a complaint with the Judicial Authority or the Data Protection Authority.
To exercise these rights, make reports, or request clarification on the processing of your personal data, you can send an email to info@ninesquared.it or write to Ninesquared Srl, at the registered office located at Via Somier n. 7, 38062 – Arco or to the operational headquarters located at Via Venezia n. 61, 38066 – Riva del Garda.
