Privacy Policy

Privacy Policy

This Privacy Policy is provided pursuant to art. 13 of European Regulation no. 679/2016 and applies exclusively to all data collected through the www.elnagh.com website.
This Privacy Policy is subject to updates which will be published on the website. This Privacy Policy and the Cookie Policy set out the basis on which the Personal Data of the data subject will be processed.

Data Controller

The controller of the data collected from this website is S.E.A. Società Europea Autocaravn S.p.A. with registered office in via Val d’Aosta n. 4, Località Fosci, 53036 Poggibonsi (SI) C.F. e P.IVA n. IT 03345730968, email: privacy@trigano.it

Data Protection Officer (DPO)
The Data Controller has appointed, pursuant to Articles 37-39 of the GDPR, the DPO whose name and reference can be found at the Data Controller. To contact the DPO, e-mail: dpo@trigano.it

Personal data
Personal data shall mean any information concerning an identified or identifiable natural person (data subject). An identifiable person is a natural person who can be identified, directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more characteristic elements of their physical identity.

Category of personal data processed
The personal data processed by this website, either independently or through third parties, include common data, such as: cookies, usage data, first name, last name, email, phone number, address, city, province, postcode and nation.

Personal data processing methods

The personal data supplied or acquired will be processed in accordance with the principles of correctness, lawfulness, transparency and protection of confidentiality pursuant to current law. The Data Controller shall process your personal data taking appropriate security measures to prevent unauthorised access, disclosure, modification or destruction. Your personal data will be processed using electronic and/or computerised instruments, according to organisational procedures and logics that are strictly tied to the indicated purposes.

Purpose of personal data processing and legal basis
Personal data may be collected autonomously by the Data Controller or through third parties. In this case, the IT systems and software procedures used for the functioning of this website acquire certain personal data of the users, of a technical-computer processing nature (e.g. IP address, type of browser used, OS, domain name and addresses of websites from which access or exit was made, etc.), the transmission of which is inherent to the standard operation of the Internet. These data items may be used only to get anonymous statistic information about the use of the site and/or to check its correct operation. All data items are immediately deleted after processing.
The Data that the data subject chooses to voluntarily provide will be processed in compliance with the conditions of lawfulness pursuant to Article 6 GDPR and will be processed to enable the website to provide its services, as well as for the purposes indicated below. All data will be kept for the time necessary for the fulfilment of the aforesaid purposes.
The purposes of processing are as follows:

a) Information and pre-contractual fulfilments
The Data shall be processed in order to be recontacted or to follow up on specific requests made to the Data Controller by the data subject for information communications, for the interest in purchasing products and/or services of the same Controller, to receive the catalogue made available by the Data Controller free of charge and/or to receive assistance from the Data Controller, by e-mail or by filling in the dedicated Forms provided on the website and other communication tools such as telephone.
Legal basis: this processing is optional and based on the consent of the data subject. Nevertheless, the provision of the Data is necessary for the pursuit of the stated purpose.
Period of data retention: until consent is revoked by the data subject.

b) Fulfilment of any obligations provided for by applicable laws
Data shall be processed in order to fulfil any type of obligation envisaged and provided for by applicable laws, regulations, related rules, business practices and tax/fiscal matters, including also for the purposes provided for by the anti-money laundering Decree-Law 231/2007 and subsequent amendments.
Legal basis: the processing is necessary to comply with a legal obligation the Data Controller is subject to.
Period of data retention: 10 (ten) years or other legal obligation.

c) Direct Marketing
The Data will be processed for direct sales of products and/or services, market research, sending of communications and promotional, commercial and advertising material or relating to initiatives and events, through newsletters, e-mails, text messages, WhatsApp, Chat, Direct Messaging from social media, social networks or through phone calls, paper mail and other information material.
Legal basis: this processing is based on the consent freely given by the data subject pursuant to Article 6, par. 1, lett. A of the GDPR.
Period of data retention: until consent is revoked by the data subject.

d) Statistics
Data will be processed to perform statistical analysis on aggregated and anonymous data, in order to analyse the behaviour of the data subject to improve the products and services provided by the Data Controller and to meet the data subject's expectations. Legal basis: this processing is based on the consent freely given by the data subject.
Period of data retention: until consent is revoked by the data subject.

e) Profiling
Data will be processed for the analysis and evaluation of interests, habits, consumption choices, including the creation of profiles to be able to send customised information and promotional material on the services/products offered by the Data Controller.
Legal basis: this processing is based on the consent freely given by the data subject pursuant to Article 6, par. 1, lett. A of the GDPR.
Period of data retention: until consent is revoked by the data subject.

Communication of data

In addition to the Data Controller, the following parties may have access to your data:

a) categories of specially trained people involved in the organisation of the website (administrative, commercial, marketing, legal, system administrators);

b) external parties (such as third-party technical service providers, hosting providers, IT companies, communication agencies) appointed as data processors by the Data Controller pursuant to Art. 28 GDPR. The updated list of data processors, if appointed, may be requested from the Data Controller;

c) public or private entities that may access your data in accordance with legal requirements;

d) people who perform ancillary and instrumental tasks with respect to the activities of the Data Controller.

Time of processing

As expressly provided for in Article 5(1)(e) of the GDPR, your data will be retained for the time necessary for processing in relation to the performance of the service required by the you or required by the purposes described in this document. At the end of the retention period, personal data will be deleted, and therefore, the rights of access, deletion, correction and portability of data can no longer be exercised.

Cookies

This website uses cookies. Cookies are small text files that can be used by websites to make your experience more efficient. We use cookies to personalise content and advertisements, provide social media features, and analyse traffic. In addition, information on the way in which you use the website is provided to the Data Controller's partners in charge of web data analysis, advertising and social media, who may combine it with other information that you provided to them or that they collected based on your use of their services. Cookie Policy

Place of processing and transfer of data abroad
The data are processed at the operational headquarters of the Data Controller. For further information, please contact the Data Controller. Your data may be processed by natural persons and/or legal entities operating on behalf of the Data Controller and by virtue of specific contractual obligations and having their registered office in EU or non-EU countries. In the event that the data items are transferred outside the EEA, the Data Controller shall take all appropriate contractual measures to ensure adequate protection of all Data.

How to exercise your rights

You are entitled exercise the rights provided for in Articles 7, 15-22 of European Reg. 679/2016.

In particular, you have the right to revoke your consent at any time and, upon simple request to the Data Controller, you may request access to your personal data, receive the personal data provided to the Data Controller and, where possible, transmit it to another Data Controller without hindrance ("portability"), obtain the updating, limitation of the processing, rectification of data and the erasure of data processed inconsistently with current legislation. You have the right, for legitimate reasons, to object to the processing of your personal data and to the processing for the purpose of sending advertising materials, direct selling and for carrying out market research. You also have the right to lodge a complaint with the Data Protection Authority as the supervisory authority for the protection of personal data. Data subjects may exercise their rights by contacting the DPO appointed by the Data Controller at the following e-mail address: dpo@trigano.it.

Tools used for personal data processing

CONTACT FORM
By filling in the contact form with their data, the data subject consents to their use to reply to requests for information or any other purpose indicated by the header of the form. Personal data collected through the contact form: first name, last name, e-mail, telephone no., address, city, province, postal code, country.
The external Controller of all data collected by these services is:

SellingExperience.com S.r.l. VAT number 06698450480 with registered office in Sesto Fiorentino (FI), Via di Pratignone 11, 50019, Tel: +39.055.8811171 email: administration@sellingexperience.com

Managing addresses and sending emails

These services are used to manage a database of email contacts, telephone contacts or any other type of contacts used to communicate with you.
These services may also allow us to collect data relating to the date and time you viewed messages, as well as your interaction with them, such as information on clicks on links placed in messages.

Newsletter

By signing up for the mailing list or newsletter, your email address is automatically included in a list of contacts to which email messages containing information, including commercial and promotional information, relating to this website may be transmitted. Your email address may also be added to this list as a result of registering on this website or after making a purchase. The data subject may choose at any time to unsubscribe from the newsletter by clicking on a dedicated button to be found within the e-mails. After clicking on the delete button, the data subject's data will be deleted immediately from the "marketing e-mail" software.
Personal data collected: first name, last name, e-mail, telephone no., address, city, province, postal code, country. This website uses the newsletter service provided by:

Amazon Simple Email Service
Amazon Simple Email Service (Amazon SES) is a cloud-based email service provided by Amazon Web Service Inc. designed to allow this website to send newsletters to users who subscribes to the service. Amazon Simple Email Service is a service certified by the EU-US Privacy Shield. Collected personal data: email. Place of processing: Lussemburgo – Privacy Policy

Adopted security measures

This website has an SSL certificate and uses the HTTPS protocol to secure the moment personal data is entered. By using this protocol, transactions and data transmission on the websites take place with the utmost security and the content of the communication cannot be read or manipulated in any way by third parties.

Statistics

The services contained in this section allow the Data Controller to monitor and analyse traffic data and are used to keep track of the User's behaviour. This website uses the following services:

1. Google Analytics (Google Ireland Limited)

Google Analytics is an analysis service provided by Google Ireland Limited. Google utilises the data collected to track and examine the use of this website, to prepare reports on its activities and share them with other Google services. Google may use your Personal Information to contextualise and customise the ads on its advertising network. Google may also send this information to third parties where required by law or in cases where the said third parties process the aforementioned information on behalf of Google. An IP address anonymisation function is active on this website. The IP address transmitted by your browser for the purposes of Google Analytics will not be incorporated into any other data already retained by Google.

You will find the tool made available by Google to deactivate the Google Analytics add-on on your browser at the following link https://tools.google.com/dlpage/gaoptout?hl=en. Collected personal data: Cookies and usage data. Place of processing: Ireland – Privacy Policy

2. Facebook Pixel conversion monitoring (Meta Platforms, Inc.)
The Facebook conversion monitoring (Facebook Pixel) is a statistics service provided by Facebook. Facebook Pixel monitors the conversions that can be attributed to Facebook advertisements. Personal data collected: Cookies and Usage data. Place of processing: Ireland - Privacy Policy.

3. Google Search Console (Google Ireland Limited)
is an analysis service provided by Google Ireland Limited. Google utilises the data collected to track and examine the use of this website, to prepare reports on its activities and share them with other Google services. Google may use your Personal Information to contextualize and customize the ads on its advertising network. Google may also send this information to third parties where required by law or in cases where the said third parties process the aforementioned information on behalf of Google. Personal data collected: Cookies and Usage data. Place of processing: Ireland - Privacy Policy.

TAG MANAGEMENT

Google Tag manager (Google Ireland Limited)
Google Tag manager is a service that allows you to manage and monitor all the third-party tags on the website in order to obtain information on the interest shown by users towards the same website and consequently on the quality of its contents. Personal data collected: Cookies and Usage data. Place of processing: Ireland - Privacy Policy.

Interaction with Social Networks

These services allow you to interact with social networks or with other external platforms, directly from the pages of this website. The interactions and information acquired by this website are anyway subject to the privacy settings of the user for each social network. If a service of interaction with the social networks is installed, even if the you do not use the service it is possible that the latter collects traffic data on the pages in which it is installed.

1. Facebook (Meta Platforms, Inc.)
Facebook buttons are services allowing interaction with the Facebook social network, provided by Meta Platforms, Inc. Personal data collected: Cookies and Usage data. Place of processing: Ireland - Privacy Policy

2. Instagram (Meta Platforms, Inc.)
Instagram buttons are services allowing interaction with the Instagram social network, provided by Meta Platforms, Inc. Personal data collected: Cookies and Usage data. Place of processing: Ireland - Privacy Policy

3. YouTube (Google Ireland Limited)
YouTube buttons are services allowing interaction with the video content display service operated by Google. Personal data collected: Cookies and Usage data. Place of processing: Ireland - Privacy Policy

Remarketing and Retargeting

These services allow this website and its partners to inform, optimise and serve advertising based on your past use of this website. This activity is carried out by tracking usage data and using cookies. This website uses the following services:

1) Google ADS (Google Ireland Limited)

Google ADS is a service provided by Google Ireland Limited that links this website to the Google advertising network. Our site makes use of the Remarketing features of Google Analytics combined with the ability to adapt to different devices of Google ADS.

This feature makes it possible to link the target groups for promotional campaigns created by the Marketing function of Google Analytics with the adaptability to different devices of Google ADS. This allows you to display advertisements based on your personal interests, identified by an analysis of your behaviour on the web, whether on a mobile device or on other devices. You can permanently disable targeting and remarketing functions by disabling the "custom advertising" function in your Google account. To do so, simply follow this link: https://www.google.com/settings/ads/onweb/

Collected personal data: Cookies and usage data. Place of processing: Ireland – Privacy Policy

2) Facebook Remarketing (Meta Platforms, Inc.)

Facebook Remarketing is a Remarketing and Behavioural Targeting service provided by Facebook, Inc. that connects the activity of this website with the Facebook advertising network. This website uses the Facebook Pixel tool provided by Facebook Inc. to measure conversions. Facebook Pixel is used to understand the actions that people perform on the website. The collected data may be used to:

- make sure the ads are shown to the right people;

- create groups of people to whom the advertisements can be directed;

- take advantage of the additional advertising tools of the platform on which advertisements are published.

The information collected is anonymous to the operators of this website and cannot be used to identify an individual user. However, the information is saved and analysed by Facebook, which may link the action to a single profile and use this information for internal Facebook advertising purposes, as outlined in Facebook's Privacy Policy. This will allow Facebook to display advertisements on both Facebook and third-party sites. The website Data Controller has no control over how this data is used. For more information on how you can protect your privacy, please refer to the Facebook Privacy Policy: https://www.facebook.com/about/privacy/

3. Instagram Remarketing (Meta Platforms, Inc.)
Instagram Remarketing is a Remarketing and Behavioural Targeting service provided by Meta Platforms, Inc. that connects the activity of this website with the Instagram advertising network. This website makes use of the Pixel tool to measure conversions and understand the actions people perform on the website. The information collected is anonymous to the operators of this website and cannot be used to identify an individual data subject. However, the information is saved and analysed by Facebook, which may link the action to a single profile and use this information for internal Facebook advertising purposes, as outlined in Facebook's Privacy Policy. For more information on how users can protect their own privacy, please refer to Instagram Data Policy about privacy.

Contents on external platforms

These services enable to display contents hosted on external platforms directly from the pages of this web site and to interact with them. If a service of this kind is installed, even if the users do not use the service it is possible that the latter collects traffic data on the pages in which it is installed.

1. Google Maps (Google Ireland Limited)

Google Maps is a web mapping service provided by Google Ireland Limited which enables this web site to integrate such contents inside its own pages. Personal data collected: Cookies and Use data. Place of processing: Ireland – Privacy Policy

2. Youtube (Google Ireland Limited)

Youtube is a video sharing service provided by Google Ireland Limited which enables this web site to integrate such contents inside its own pages. Personal data collected: Cookies and Use data. Place of processing: Ireland – Privacy Policy

Changes to this Privacy Policy

The Data Controller reserves the right to make changes to this Privacy Policy at any time informing users on this page. Please consult this page often, taking as reference the date of last modification indicated at the bottom. In the event of non-acceptance of the changes made to this Privacy Policy, you are required to cease using this website and may request the Data Controller to remove your personal data. Unless otherwise specified, the Privacy Policy will continue to apply to personal data collected up to that time. The Data Controller is not responsible for updating all the links displayed in this Privacy Policy, therefore whenever a link is not working and/or updated, users acknowledge and accept that they must always refer to the document and/or section of the websites referred to by that link.

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