PRIVACY POLICY

This privacy policy (hereinafter referred to as the “Privacy Policy”) pertains to the processing of your personal data by Euthalia Fragrances S.r.l., with its registered office at Via T. Reggio 10/a, 16123 Genova (GE), Italy, VAT no. 02518710997, email info@euthaliafragrances.com (hereinafter referred to as the “Data Controller” or “Euthalia Fragrances”), also in accordance with EU Regulation 2016/679 (hereinafter “GDPR”). Euthalia Fragrances may process your personal data, as a data subject and/or contractor, in accordance with current personal data protection legislation.

1. Identity and Contact Details of the Data Controller and the DPOThe Data Controller is Euthalia Fragrances. As the Data Controller is established within Italian territory, no representative has been appointed. The Data Controller has appointed a Data Protection Officer (“DPO”), pursuant to Article 37 of the GDPR. The DPO can be contacted at the following address: info@euthaliafragrances.com.
2. Purposes and Legal Basis of the ProcessingYour personal data will be processed for the following purposes:
   • For contractual purposes, specifically to allow you to purchase services and products via Euthalia Fragrances’ E-commerce. The legal basis for processing is the necessity of processing your personal data for the performance of a contract. The communication of your personal data is mandatory. Failure to provide your personal data will make it impossible to conclude any contract;
   • To send you direct marketing communications, newsletters, advertising material, using traditional contact systems and automated computer systems, including commercial or promotional communications via email or SMS, or for market research and analysis. The legal basis for processing is consent, given in accordance with the Privacy Policy;
   • For activities to determine your habits and preferences with profiling processing, to provide you with a personalized service. The legal basis is your consent, given in accordance with the Privacy Policy. Regarding the Personal Data processed, the communication of Personal Data is not a contractual obligation. You have the option to provide the Personal Data. Failure to provide such data will prevent the Company from providing a personalized service;
   • For purposes related to relevant legal obligations. The legal basis for processing is the legal obligation of Euthalia Fragrances to process personal data according to applicable regulations.
3. Consent Expression MethodsYou may express your consent by signing a computerized document, also through specific checkboxes.
4. Processing Methods and Logic
   • For personal data processed for the purposes referred to in section a) number 2 of the Privacy Policy (contractual and pre-contractual purposes), processing will occur using automated logic and CRM-type management software that will allow better contract management;
   • For personal data processed for the purposes referred to in section b) number 2 of the Privacy Policy (marketing purposes), processing will be carried out using commercial information sending software;
   • For Personal Data processed for the purposes referred to in section c) number 2 (profiling), Processing will occur using CRM-type software that allows defining tastes and preferences to offer you personalized services and communications. For further details, see the next section of the Privacy Policy;
   • For personal data processed and stored for the purposes referred to in section d), number 2 (legal purposes), processing will occur using paper tools, automated logic, and CRM-type management software that will allow better management of legal obligations.
5. Automated Decision-Making and ProfilingIf you consent to the Processing of Personal Data to enjoy personalized services through profiling, the Personal Data may be subject to an automated decision-making process, with a specific algorithm that will decide which communications are most suitable for your profile or may be of most interest to you. The Processing carried out has, as its intended consequences, for example, the sending of highly profiled commercial communications, the sending of discounts, the sending of invitations to events considered of interest, etc. Under Article 22 of the GDPR, you have the right to:
   • Obtain human intervention in the decision-making process by the Company;
   • Express your opinion;
   • Obtain an explanation of the decision achieved by the Company;
   • Contest the decision.
6. Source from Which the Personal Data OriginateOnly the personal data provided in accordance with the Privacy Policy will be processed. Euthalia Fragrances will not process personal data from publicly accessible sources.
7. Recipients and Categories of Recipients of Personal DataThe following may be recipients of personal data:
   • Communication companies that carry out commercial communication and profiling activities on behalf of the Data Controller, if the relevant consent has been expressed, which qualify as processors;
   • Companies offering information society services, including, in particular, those offering hosting services;
   • Companies conducting statistical and market research, if the relevant consent has been expressed;
   • Auditing firms;
   • Partner companies of the Data Controller.
8. Categories of DataPersonal data will be processed. In no case will special categories of personal data defined in Article 9 of the GDPR be processed.
9. Data TransferEuthalia Fragrances intends to transfer personal data to entities established in a third country outside the European Union or to an international organization. These entities may include, for example:
   • Communication companies that perform communication activities on behalf of the Data Controller;
   • Providers of information society services;
   • Controlled and/or controlling organizations. The transfer of personal data to such entities, if established in a third country or an international organization, is carried out in the presence of an adequacy decision by the European Commission, which has verified that the third country, territory, or one or more specific sectors within the third country, or the international organization in question, guarantee an adequate level of protection of rights. In any case, Euthalia Fragrances, if deemed appropriate, reserves the right to conclude specific separate agreements that obligate such entities to adopt adequate security measures, including organizational measures, aimed at providing appropriate guarantees for your rights. Personal data may thus be transferred to the following countries: United States of America. To obtain a copy of such personal data or the place where they have been made available, simply send the relevant request to Euthalia Fragrances, at the addresses Via T. Reggio 10/a, 16123 Genova (GE), Italy or info@euthaliafragrances.com.
10. Data Retention Period

• Personal data processed and stored for the purposes referred to in point a) and d), number 2 (contractual and pre-contractual purposes and fulfillment of legal obligations) are processed and stored by Euthalia Fragrances as provided by current legislation, however for a period not exceeding 10 years from the termination of the effects of the contract in case of conclusion of the same, except for a different legal obligation;
• Personal data processed for the purposes referred to in point b) number 2 of this information (marketing purposes) are processed and stored by Euthalia Fragrances until you request their deletion and/or revocation, as an Interested party;
• Personal Data processed for the purposes referred to in point c) number 2 (preference determination purposes) are processed and stored by the Company for a period not exceeding 12 months from collection.

11. Optional Consent and Consequences of Failure to Consent

• In relation to personal data processed for the purposes referred to in point a) number 2 of this information (contractual and pre-contractual purposes), the communication of personal data is mandatory. If you do not provide such personal data, it will not be possible to conclude any contract.
• In relation to personal data processed for the purposes referred to in point b) number 2 of this information (marketing purposes), the communication of personal data is not a contractual obligation. You have the option to provide personal data. If you do not provide such personal data, Euthalia Fragrances will not be able to carry out any marketing activities.
• In relation to the Personal Data processed for the purposes referred to in point c) number 2 of this information (preference determination purposes), the communication of Personal Data is not a contractual obligation. You have the option to provide Personal Data. If you do not provide such Personal Data, the Company will not be able to carry out any profiling activities.
• In relation to personal data processed for the purposes referred to in point d) number 2 of this information (legal obligations), the communication of personal data is a legal obligation.

12. Your Rights

• Right of OppositionAs a Data Subject, you have the right of opposition as follows:
• The right to object at any time, for reasons related to your particular situation, to the processing of personal data concerning you under Article 6, paragraph 1, letters e) or f) of the GDPR. Euthalia Fragrances will refrain from further processing your personal data unless Euthalia Fragrances demonstrates the existence of compelling legitimate reasons for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of a right in a judicial proceeding;
• If personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you carried out for such purposes, including profiling to the extent that it is connected to such direct marketing;
• In the event of opposition to processing for direct marketing purposes, personal data will no longer be processed for such purposes. You may object to the processing of your personal data for direct marketing purposes also only in part, for example by objecting only to the sending of promotional communications carried out through automated and/or digital tools, or to the sending of paper communications and/or the receipt of telephone communications;
• If your personal data are processed for scientific or historical research purposes or for statistical purposes pursuant to Article 89, paragraph 1 of the GDPR, for reasons related to your particular situation you have the right to object to the processing of personal data, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
• Other RightsEuthalia Fragrances also wants to inform you of the existence of the following rights:
• Right of Access: You have the right to obtain from Euthalia Fragrances confirmation as to whether or not personal data concerning you are being processed, and, if so, to access your personal data and specific information, in accordance with Article 15 of the GDPR;
• Right to Rectification: You have the right to obtain from Euthalia Fragrances the rectification of inaccurate personal data concerning you without undue delay. Considering the purposes of the processing, you have the right to have incomplete personal data completed, also by providing a supplementary statement, in accordance with Article 16 of the GDPR;
• Right to Data Erasure, including the Right to Withdraw Consent: You have the right to obtain from Euthalia Fragrances the erasure of personal data concerning you without undue delay or to withdraw consent to processing, if there are reasons defined by Article 17 of the GDPR. You have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent given before its withdrawal;
• Right to Restriction of Processing: You have the right to obtain from Euthalia Fragrances restriction of processing when the conditions defined by Article 18 of the GDPR are met;
• Right to Data Portability: You have the right to receive in a structured, commonly used and machine-readable format your personal data provided to the Data Controller, and you have the right to transmit those data to another Data Controller without hindrance from Euthalia Fragrances, as provided by Article 20 of the GDPR;
• Right of the Contractor to Oppose Commercial Communications: As a contractor, you have the right to object at any time, free of charge, to receiving commercial communications from Euthalia Fragrances;
• Right to Lodge a Complaint with the Supervisory Authority: You have the right to lodge a complaint with the Supervisory Authority for Personal Data Protection, to complain about a violation of personal data protection regulations, in accordance with Article 77 of the GDPR.

13. How to Exercise Your RightsYou can exercise the rights indicated in the Cookie Policy by addressing requests directly to Euthalia Fragrances at the email address info@euthaliafragrances.com, or by sending the relevant communication by registered mail with return receipt to Via T. Reggio 10/a, 16123 Genova (GE), Italy. You can file a complaint with the Supervisory Authority for Personal Data Protection according to the procedures provided by the official website, addressing it to the contact details available at https://www.garanteprivacy.it/home/footer/contatti.
14. Accessibility of the InformationThe Privacy Policy is available at the URL https://euthaliafragrances.com/privacy-policy or at Euthalia Fragrances. If expressly requested by the data subject, Euthalia Fragrances may also provide the information orally, provided that the data subject’s identity is proven, with a telephone request addressed to +39 010 2344774.
15. ChangesEuthalia Fragrances may change the Privacy Policy, also to adapt to changes in national and/or European Union legislation, or to technological innovations. Any new versions of the Privacy Policy will be reported on the Site. We invite you to periodically check the Privacy Policy. Any changes will nevertheless be communicated to you through a pop-up on the Site or different methods and/or computer tools. If Euthalia Fragrances substantially changes the Privacy Policy, envisaging new purposes of processing and/or categories of personal data processed, Euthalia Fragrances itself will inform you, requesting the necessary consents, through a pop-up on the Site or different methods and/or computer tools.

DATA PROCESSING BY EUTHALIA FRAGRANCES S.R.L. FOR MARKETING AND PROFILING PURPOSES

This information governs the processing of personal data through the use of the website available at https://euthaliafragrances.com/privacy-policy, Euthalia Fragrances S.r.l., with its registered office at Via T. Reggio 10/a, 16123 Genova (GE), Italy, VAT no. 02518710997, email address info@euthaliafragrances.com, (hereinafter the “Data Controller”), in compliance with current data protection regulations, including, in particular, the EU Regulation 2016/679 (hereinafter “GDPR”).

1. Identity and Contact Details of the Data ControllerThe Data Controller is Euthalia Fragrances S.r.l. As the Data Controller is established within Italian territory, no representative has been appointed.
2. Contact Details of the Data Protection Officerinfo@euthaliafragrances.com
3. Processing Methods

3.1 Cookies and Environmental Data TECHNICAL COOKIES

• Navigation, functional, session cookies: allow the site to function correctly. The use of so-called session cookies (which are not persistently stored on the data subject’s device and are automatically deleted when the browser is closed) is strictly limited to the transmission of session identifiers and are used to enable safe and efficient use of the site. They are differentiated into:
  • Activities strictly necessary for operation: cookies used to save the User’s session and to perform other activities strictly necessary for the operation of the application, for example in relation to traffic distribution;
  • Activities for saving preferences, optimization, and statistics: cookies used to save browsing preferences and optimize the User’s browsing experience. Among these cookies are, for example, those to set the language and currency or for the management of statistics by the site owner.
• Statistical cookies: the site uses statistical cookies made directly by the data controller, as the first party, or provided by third parties. In the latter case, suitable tools have been adopted to reduce their identifying power, also by masking significant portions of the IP addresses thus processed. The use of such third-party statistical cookies, moreover, has been subject to contractual constraints that bind the third party to use them exclusively for the provision of the service, to store them separately and not to “enrich” or “cross” them with other information they have. Concerning specifically Google Analytics cookies, information obtainable from cookies about users’ use of the site will be transmitted by the interested party’s browser to Google Inc., based at 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States, and stored at the company’s servers.

Google’s privacy rules, which we invite you to read, are available at the following address: http://www.google.com/intl/en/privacy/privacy-policy.html The privacy policy for Google Analytics services is available at the following address: http://www.google.com/intl/en/analytics/privacyoverview.html

• Browsing Data and Environmental Variables: The computer systems and procedures responsible for the operation of the site automatically acquire, in the course of their normal exercise, some personal data related to the browsing of the data subject, including environmental variables. In this category of data include, by way of example:
  • IP addresses of computers used by users who use the service;
  • the number of accesses;
  • the pages viewed;
  • the date and time of access;
  • the URL in which the browser was before viewing our page;
  • the type of browsing browser;
  • the operating system used.

NON-TECHNICAL COOKIES

• Profiling cookies: the site uses profiling cookies provided by third parties. In detail, they are used:
  • Interaction with social networks and external platforms: this type of services allows interactions with social networks, or with other external platforms, directly from the pages of this application. The interactions and information acquired by this application are in any case subject to the User’s privacy settings related to each social network.

In the event that an interaction service with social networks is installed, it is possible that, even if Users do not use the service, it may collect traffic data relating to the pages in which it is installed. AddThis (Addthis Inc.): is a service provided by Clearspring Technologies Inc. that displays a widget that allows interaction with social networks and external platforms and the sharing of contents of this application. Depending on the configuration, this service may show widgets belonging to third parties, for example, the managers of the social networks on which to share the interactions. In this case, even the third parties that provide the widget will become aware of the interaction performed and the usage data relating to the pages where this service is installed. Personal Data collected: Cookies and Usage Data. Processing location: USA – Privacy Policy.

Facebook Remarketing (Facebook, Inc.): is a Remarketing and Behavioral Targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network. Personal Data collected: Cookies and Usage Data. Processing location: USA – Privacy Policy – Opt Out.

AdWords Remarketing (Google Inc.): is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of this Application with the Adwords advertising network and the Doubleclick Cookie. Personal Data collected: Cookies and Usage Data. Processing location: USA – Privacy Policy – Opt Out.

Google Analytics with anonymized IP (Google Inc.): is a web analytics service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google. Google may use the Personal Data to contextualize and personalize the ads of its advertising network. This integration of Google Analytics anonymizes your IP address. Anonymization works by shortening the IP address of Users within the member states of the European Union or other countries participating in the agreement on the European Economic Area. Only in exceptional cases, the IP address will be sent to Google servers and shortened within the United States. Personal Data collected: Cookies and Usage Data. Processing location: USA – Privacy Policy – Opt Out

Facebook Ads conversion tracking (Facebook, Inc.): is a statistics service provided by Facebook, Inc. that links data from the Facebook ad network with actions taken within this Application. Personal Data collected: Cookies and Usage Data. Processing location: USA – Privacy Policy

Criteo Dynamic Retargeting: is a remarketing service provided by Criteo SA. Personal Data collected: Cookies and Usage Data. Processing location: France Privacy Policy – https://www.criteo.com/it/privacy/ Opt Out – https://privacy.eu.criteo.com

Deleting and disabling cookies Since cookies are normal text files, they can be accessed using text processing programs. In any case, it is possible to configure your browser to prevent it from treating cookies. Delete/disable cookies with Firefox: http://support.mozilla.com/en/kb/Delete%20cookiesDelete/disable cookies with Edge: https://support.microsoft.com/en-us/help/4027947/windows-delete-cookies Delete/disable cookies with Chrome: http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647

3.2 Data Voluntarily Provided by the Data Subject The data optionally and freely provided by the data subject by sending emails to the addresses on the site may be acquired for the purpose indicated in point 4. In particular, in addition to the email address necessary to respond to the sender, any other personal data contained in the respective communication will be processed.

4. Purposes and Legal Basis of ProcessingTo send direct marketing communications, newsletters, advertising material, through traditional contact systems and automated computer systems, including commercial or promotional communications via email or SMS, or for market research and analysis. In this case, the legal basis is consent, expressed in accordance with this policy; For profiling activities and determination of habits and preferences. In this case, the legal basis is consent, expressed in accordance with this policy.
5. Consent Expression MethodsConsent to the processing of personal data through non-technical cookies can be expressed:
   • By clicking on a specific box presented within a banner.
6. Source of Personal DataOnly the data provided by the data subject in accordance with this policy, collected through the website, will be processed.
7. Recipients and Possible Categories of Recipients of Personal DataThe following may be recipients of the data subject’s personal data:
   • Communication companies that carry out commercial communication and profiling activities on behalf of the Data Controller, which qualify as processors;
   • Companies offering information society services, including, in particular, those offering hosting services.
8. Categories of DataThe data subject’s personal data will be processed.
9. Data TransferThe Data Controller intends to transfer personal data to a third country or an international organization. These entities may include, for example:
   • Communication companies that perform communication activities on behalf of the Data Controller;
   • Companies offering information society services, including, in particular, those offering hosting services;
   • Providers of communication society services. The transfer of personal data to such entities, if established in a third country or an international organization, is carried out in the presence of an adequacy decision by the European Commission, which has verified that the third country, territory, or one or more specific sectors within the third country, or the international organization in question, guarantee an adequate level of protection of its rights. In any case, the Data Controller – if deemed appropriate – reserves the right to conclude specific separate agreements that oblige such entities to adopt adequate security measures, including organizational measures, aimed at providing appropriate guarantees regarding its rights. Google Inc., in particular, has contractually bound itself to ensure adequate protection of the data subject’s rights. The data may thus be transferred to the following countries: UK, United States of America. To obtain a copy of such data or the place where they have been made available, simply send the relevant request to the email address info@euthaliafragrances.com.
10. Data Retention PeriodPersonal data processed for marketing purposes are processed and stored until the data subject requests the revocation of consent or the deletion of the data. Personal data processed for the purposes of preference determination are processed and stored for a period not exceeding 12 months from collection. The Data Controller reserves the right, in any case, to request the data subject to renew their consent to processing and/or to verify the consents already expressed.
11. Optional Consent and Consequences of Failure to ConsentRegarding personal data processed for marketing purposes, the communication of personal data is not a contractual obligation. There is the option to provide personal data; in the event of failure to communicate such data, however, no marketing activity will be possible; Regarding personal data processed for profiling purposes, the communication of personal data is not a contractual obligation. There is the option to provide personal data; in the event of failure to communicate such data, however, no profiling activity will be possible.
12. Rights of the Data Subject1 Right of Opposition Regarding personal data processed by technical cookies to allow correct use of the website, the communication of personal data is not a contractual obligation, but based on the legitimate interest of the owner, as without such processing the website could not be made available perfectly functional. Consent is considered optional regarding non-technical cookies. In this case, failure to communicate such data will only determine the impossibility of providing a personalized service. Regarding data voluntarily provided via email, consent is considered optional. However, failure to communicate such data will determine the impossibility of responding to the interested parties; Regarding data communicated for contractual and pre-contractual purposes, the communication of personal data is a contractual obligation and a necessary requirement for conducting pre-contractual negotiations and for the conclusion of the contract. The data subject has the option to provide personal data; in the event of failure to communicate such data, however, it will not be possible to conclude any contract or carry out any contractual negotiation; Regarding data voluntarily provided by email, failure to communicate them will result in the impossibility of responding to the requests of the data subject. 12.2 Other Rights The Data Controller also intends to inform the data subject of the existence of the following rights:

• Right of Access by the Data Subject: The data subject has the right to obtain from the Data Controller confirmation as to whether or not personal data concerning them are being processed and, if so, to obtain access to the personal data and specific information, in accordance with Art. 15 of the GDPR.
• Right to Rectification: The data subject has the right to obtain from the Data Controller the rectification of inaccurate personal data concerning them without undue delay. Considering the purposes of the processing, the data subject has the right to have incomplete personal data completed, also by providing a supplementary statement, in accordance with Art. 16 of the GDPR.
• Right to Data Erasure, including the Right to Withdraw Consent: The data subject has the right to obtain from the Data Controller the erasure of personal data concerning them without undue delay and the Data Controller has the obligation to delete personal data without undue delay, or to withdraw their consent, if there are reasons defined by Art. 17 of the GDPR. Concerning the right to withdraw, the data subject also has the right to withdraw consent at any time without affecting the lawfulness of processing based on consent given before its withdrawal.
• Right to Restriction of Processing: The data subject has the right to obtain from the Data Controller restriction of processing when the conditions defined by Art. 18 of the GDPR are met.
• Right to Data Portability: The data subject has the right to receive in a structured, commonly used, and machine-readable format the personal data concerning them provided to the Data Controller and has the right to transmit those data to another Data Controller without hindrance from the Data Controller under the cases and conditions specified by Art. 20 of the GDPR.

13. Exercise of RightsRequests to exercise the rights indicated in this information, including, in particular, the right to deletion and the right to withdraw consent granted, must be addressed directly to the Data Controller at the email address info@euthaliafragrances.com. Alternatively, it is possible to exercise one’s rights by sending the relevant communication by registered mail with return receipt to the address Via T. Reggio 10/a, 16123 Genova (GE).
14. Accessibility of the InformationThe information is accessible at the address https://euthaliafragrances.com/privacy-policy, as well as at the Data Controller. If expressly requested by the data subject, the information can also be provided orally, provided that the identity of the data subject is proven, by a telephone request addressed to the addresses of the Data Controller.