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Privacy Policy

Information notice on the processing of personal data
pursuant to Article 13 of Regulation (EU) 679/2016 (“GDPR”)

This privacy notice describes the processing of personal data of users of the website of Grow up network srl, accessible at the address: https://pastrychefmasterclass.com.

DATA CONTROLLER

The data controller is Grow up network srl, with registered office in Milan, 20127, Via dei Valtorta 45, VAT, Tax Code and Milan Companies Register no. 09970930963 (hereinafter also “GUN”).

If you have any doubts about how GUN processes your data, you can always contact the company:

The information you find on this page does not apply to third-party websites, apps or content of any kind, even if accessible from the Website by clicking on links contained on it.

In such cases, the data protection provisions of those third parties may apply, which may differ from this notice and which we recommend you read before providing any data.

DATA COLLECTED

2.1. Browsing data automatically collected by the Website: access and browsing data

Every time Users access the Website, the IT systems and software procedures used to operate the Website acquire, during their normal functioning, access and browsing data (for example: information on the browser used by the User, pages visited, date, time and duration of each visit, as well as other parameters relating to the User’s operating system and IT environment – the “Browsing Data”).

The data collected are exclusively anonymous and aggregated, and therefore cannot lead to the identification of Users. The information collected simply allows the detection and resolution of any technical problems.

2.2. Data provided by Users to contact GUN or request assistance (“Contact us”): identification data, contact details and personal data voluntarily provided

Through the Website, Users can contact GUN by using the e-mail address [email protected] or [email protected] to request information or clarifications relating to GUN’s products. Users can also contact GUN by filling in the dedicated online form on the “Contact us” page of the Website to request assistance in relation to returns, replacements or repair of purchased products.

2.3. Data required to register on the Website and create a personal GUN account

In the “Login/Register” section of the Website, Users are asked to provide specific personal data in order to create their own account on the Website and to purchase products without having to enter their contact and shipping details each time:

IDENTIFICATION DATA

  • First name

  • Surname

  • Date of birth

  • Sex (gender)

CONTACT DETAILS

  • E-mail address

  • Residential address

  • Telephone number

2.4. Data required to register on the Website and purchase products: identification and contact data

Within the Website it is possible to purchase GUN products (“Products”) in two ways:
(i) by accessing the dedicated area and registering a personal account, or
(ii) in “guest” mode, without registering on the Website.

In case (i), after providing the data required for registration as per section 2.3 above, Users are asked to provide additional contact details (i.e. shipping and billing addresses), as detailed in the table below.

In case (ii), Users who do not register but wish to proceed with purchasing a Product are asked to provide specific personal data – as listed below – in order to complete the online purchase of the Products:

IDENTIFICATION DATA

  • First name

  • Surname

CONTACT DETAILS

  • E-mail address

  • Shipping address

  • Telephone number

  • Billing address (if different from the shipping address)

BANKING DATA

  • Credit card number

  • Credit card expiry date

  • CCV

  • PayPal account credentials (in case of payment via PayPal)

2.5. Data provided by Users to receive the newsletter and obtain information and updates from GUN

On the home page of the Website, in the “Login/Register” section or at the end of the Product purchase process, Users can provide specific personal data to subscribe to GUN’s newsletter and receive information and updates about the Products.

The data required for newsletter subscription are: e-mail address and sex (gender).

Providing personal data is voluntary: if Users do not provide these data, they can still browse the Website but will not be able to receive updates on GUN’s activities and Products via the newsletter service.

2.6. Cookies

The Website uses IT techniques for the direct acquisition of users’ personal data consisting of “strings of code”: the so-called “cookies”.

For full information on the cookies used on the Website and the related processing of personal data, click “here”.

PURPOSES OF THE PROCESSING

The personal data of Users of the Website (“Data”) may be processed for the following purposes.

3.1. Browsing data

Browsing data will be used:
(i) to monitor the correct functioning of the Website;
(ii) in anonymous and aggregated form, for statistical purposes related to understanding how the Website is used by Users, in order to improve ease of access and increase its attractiveness; and
(iii) to detect any technical problems as soon as possible.

This information is collected automatically by the Website and does not require any action on the part of the User.

The legal basis for this processing is GUN’s legitimate interest in improving its digital services, especially in relation to the use of the Website, and is compatible with the data subjects’ position because:
(a) monitoring the functioning of the Website and the related statistical data does not involve direct identification; and
(b) the Company’s interest is reasonably also that of the Users, who can thus enjoy an increasingly efficient and optimised Website.

3.2. Responding to Users’ requests

The data provided by Users when filling in the “Contact us” form or via e-mail and phone numbers will be processed in order to respond to the requests sent by Users to GUN.

The legal basis for this processing is the need to perform pre-contractual or contractual measures adopted at the User’s request and to comply with related legal obligations.

Providing data is necessary to allow GUN to receive and respond to Users’ requests: therefore, if data are not provided, GUN will not be able to process the User’s request.

3.3. Website account registration

The data provided by Users by filling in the form in the “Login/Register” section of the Website will be processed to:
(i) allow Users to access their reserved area;
(ii) purchase Products without having to re-enter their contact and shipping data each time; and
(iii) where the User has given express consent, receive the newsletter and stay updated on GUN’s news.

The legal basis for this processing is the need to perform pre-contractual or contractual measures adopted at the User’s request and to comply with related legal obligations and, as regards the sending and receipt of GUN’s newsletter, the express consent given by the User directly through the Website.

Providing data is necessary to allow Users to register on GUN’s Website. If data are not provided, Users will still be able to browse the Website but will not be able to create a personal account.

3.4. Purchase of Products

The data collected during the purchase of Products will be processed to manage the sale and shipment of Products purchased by the User.

In this context, the data collected may be communicated:

  • to public and private entities involved in the organisational activities and in the management of the purchase and shipment of Products and/or providers of ancillary and necessary services (e.g. couriers, logistics companies, etc.). These entities will process the data, as the case may be, as independent data controllers or as data processors pursuant to a specific written appointment made by GUN.

The legal basis for this processing is the need to perform pre-contractual or contractual measures adopted at the User’s request and to comply with related legal obligations.

Providing data is necessary to complete the purchase of Products: therefore, if the User refuses or fails to provide the requested data – including data required to register an account on the Website – GUN will not be able to process the User’s purchase request.

3.5. Subscription to the newsletter and receipt of communications with commercial content

The data collected (i) when the User requests subscription to the newsletter service, or (ii) when purchasing Products, with the User’s prior consent, will be processed for sending informational and commercial communications about GUN’s activities and Products.

In this context, the data collected may be communicated:

  • to IT service providers managing the platform used to send the newsletter.

The legal basis for this processing is the express consent given by the User directly through the Website.

Providing Data is necessary to complete subscription to, and use of, the newsletter service: therefore, if the User refuses or fails to provide the requested data, GUN will not be able to send newsletters.

The User may unsubscribe from the newsletter service at any time by following the procedure indicated at the bottom of each newsletter or by sending a specific request to GUN at the contact details indicated in section 8 below.

METHODS OF PROCESSING

Data will be processed both on paper and by electronic, IT or automated means, using systems that ensure their protection, security and confidentiality. Data will be stored by GUN on the servers of the company appointed for this purpose (Shopify International Ltd, based in Ireland) and will be processed by individuals to whom GUN has given suitable operational instructions, with particular reference to the security measures adopted.

GUN has also adopted specific and adequate logical, legal, organisational and technical security measures in order to prevent data loss, unlawful or improper use and unauthorised access.

DISCLOSURE OF DATA AND DATA RECIPIENTS

Data may be accessed by employees and/or collaborators of GUN, specifically appointed as persons authorised to process data (for example, staff in charge of administration, accounting and IT systems).

The User’s Data may also be disclosed to third parties providing ancillary or related services for the management of the Website and its functionalities or which are necessary for the e-commerce service. In such cases, the third-party recipients of the Data – acting as independent data controllers or duly appointed data processors – fall into the following categories:

  • entities that carry out, on behalf of or in favour of GUN, technical and organisational tasks or professional assistance/consultancy services, in particular accountants, legal advisors and notaries, shipping and logistics companies for the management of Product purchases (e.g. shipping company PVS), companies appointed by GUN;

  • software and IT service providers, managers of GUN’s Website (Shopify International Ltd, PVS Services Italia S.r.l.).

DISSEMINATION OF DATA

Data will not be disseminated.

DATA RETENTION PERIOD

The Data collected and processed by GUN for the purposes identified in section 3 above may be stored in a form that allows the identification of the User for the period necessary to achieve the purposes of the processing and, in particular:

  • Browsing data do not persist for more than 24 hours and are deleted immediately after aggregation (without prejudice to any need for investigation of crimes by the competent Judicial Authority);

  • For the processing under point 3.2 aimed at dealing with Users’ requests, the data provided by the User are stored for up to 12 months after receipt of the request;

  • For the processing under point 3.3 aimed at managing the User’s request to register on the Website, data are stored for up to 24 months after the last access to the personal account; with 2 months’ prior notice, we will inform the User that, in case of no further access, the Data will be deleted and the User will no longer be able to access the GUN reserved area;

  • For the processing under point 3.4 aimed at managing the User’s purchase of Products offered by GUN, data are stored for the entire duration of the contractual relationship and for the subsequent period necessary to comply with related tax and accounting obligations, as well as to ensure the judicial protection of GUN’s rights;

  • For the processing under point 3.5, i.e. for sending newsletters with informational or commercial content, Data are stored for a period of 24 (twenty-four) months from the last contact.

Data may be stored for longer periods where necessary to comply with legal obligations or for the protection of GUN’s rights, up to the expiry of the relevant limitation period.

USER RIGHTS AND CONTACT DETAILS

The User may, at any time and to the extent that such rights apply:
(I) obtain confirmation as to whether or not personal data concerning them are being processed;
(II) request access to their personal data;
(III) request rectification, erasure or restriction of the processing of personal data;
(IV) object to the processing, or withdraw consent to processing, without affecting the lawfulness of processing based on consent before its withdrawal;
(V) receive, in a structured, commonly used and machine-readable format, the personal data concerning them provided to GUN, and request that those data be transmitted to another data controller (right to data portability);
(VI) lodge a complaint with the competent Data Protection Authority, or file a claim before the competent Judicial Authority.

Requests to exercise the above rights should be sent to one of the following contacts:

  • by e-mail: [email protected]

  • by registered letter with return receipt to: Grow up network srl, Via dei Valtorta 45 – 20127, Milan, Italy

Requests regarding the recipients of the Data, as well as any requests for clarification on this privacy notice, may also be sent to the same addresses.