Privacy Policy

La Tartaruga S.r.l. (“we”, “us”, “our”) takes the issue of safeguarding your privacy seriously.

This privacy notice (“Privacy Notice”) together with our website terms of use and any other documents referred to in these documents, describes what information we collect from our customers, visitors to www.amorvero.com and any other individuals who contact us (collectively each referred to as a “user”, “you”, “your”). We will also identify the way in which La Tartaruga S.r.l. uses this information for legitimate business purposes and to better serve the needs of our current and prospective customers. Please note that this website is not intended for children under the age of 16.

Please read these documents carefully. By visiting our website or otherwise interacting with us in relation to Amorvero products by, for example, ordering such products from us, you acknowledge the processing activities undertaken by us which are described in this Privacy Notice, our terms and any other related documents referenced herein.
Please note that any websites that may be linked to our websites are subject to their own privacy notice.

If you have any questions about this notice, please contact us by email at info@amorvero.com or write to our office at Via Icilio Vanni, 1 - 06062 Città della Pieve (PG).

We may change this Privacy Notice from time to time and will let you know about any changes, including by posting them on our website. Your continued use of our website after any such changes have been made will amount to your acknowledgement of the amended notice.

This version of our privacy notice was published in November 2020.

Contents

1. What is Personal Information?
2. What personal information might we collect about you?
3. Cookie Statement
4. Why do we capture and store your personal information?
5. Legal basis for processing
6. Disclosure of your information
7. How is my Personal Information secured?
8. Is my Personal Information transferred overseas?
9. How long is my Personal Information retained?
10. Your rights

1. What is Personal Information?

“Personal Information” or “Personal data” means any information relating to an identified or identifiable natural person (each a ‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Personal Information may include name; address; email address; phone number; IP address; location data; payment details; information about movements around our websites; information concerning your interests; purchases and product and service preferences; data captured in authentication and tracking logs; and information collected from cookies and similar technologies.

2. What personal information might we collect about you?

We may process the following personal data about you:

Information you give us. You may give us information about you by filling in forms, setting up a user account or profile, ordering a product, uploading information on our website, putting in an enquiry about one of our products or by communicating with us by email, phone or otherwise, e.g. by calling our customer service number. This information may include your name, email address, billing address, phone number, debit or credit card data, the content of any email you send to us and any other similar information. You are under no obligation to provide this information, but without it, we may not be able to provide you with some of our content, goods or information you may request.

Information we collect about you. With regard to each of your visits to our website we may collect:

• information that does not reveal your personal identity, for example, the type of destination you are seeking information on (we use this aggregated, anonymous data mainly for editorial purposes, but we do not connect it to any Personal Information, such as your name or your address);
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, date and time you access our website, and the Internet address of the website from which you linked directly to our website, browser plug-in types and versions, operating system and platform and similar information; and
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website, pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Information about minors. La Tartaruga S.r.l. does not knowingly collect personally identifiable information via our websites from any person we actually know is a person under the age of 18.

Information obtained from someone ordering a product on your behalf. If you are entering data on behalf of another person, you warrant to us that you are authorised by that person to enter their personal data into our system, and that information you enter is accurate and correct. If any non-compliance by you with respect to this provision results in any loss or damage being incurred by us, you may be required to compensate us in respect of such loss.

Information about you obtained from third party sources. These third party sources may include Shopify Inc., which processes payments on our behalf, and other third parties.

4. Why do we capture and store your personal information?

We will only process your personal data, in accordance with applicable law, for the following purposes.

• Responding to your queries, comments, complaints and requests.
• Managing and administering your user account.
• Processing your orders.
• Delivering any products or information requested by you. We may then send electronic messages at appropriate intervals to the email address you gave us, which may also contain topic-specific advertisements along with editorial information on our products and services. La Tartaruga S.r.l. follows a double-opt-in process and customers will have to validate their consent before we start sending communication. In deciding whether or not to join such lists, please note that they are only used for internal purposes and we do not sell or rent our subscription lists to anyone. You can unsubscribe at any time by email to info@amorvero.com or clicking on any of our unsubscribe links.
• Providing you with a customised and premium service. Our goal is to provide you with a personalised customer service, whether you are a new or a returning customer. For these purposes we may create a profile including your user account as well as online session data. We store transaction information. This information may also include details of the number of products you have ordered.
• Verifying your identity, when required.
• Communicating with you about, and administering your participation, special events, programmes, surveys, contests, sweepstakes, and other offers or promotion
• Displaying content on our websites, such as stories, product reviews, comments and photos, where these are provided by you.
• Allowing you to participate in interactive features of our apps and websites, when you choose to do so.
• Processing claims we receive in connection with our website and products.
• Implement and enforcing our general terms and conditions of business or any other agreements concluded with you.
• Enabling our suppliers and service providers to carry out certain functions on our behalf, including the hosting of our websites, verification, technical, logistical or other functions, as may be required, in order to make available our website and products. For example, when you make an order your credit card number will be verified using by the card provider, but we do not authorise any payments at this point.
• Administering financial operations, including debt recoveries.
• Sending you personalised marketing communications and alerts requested by you.
• Serving personalised advertising to your devices, including delivering ads based on your interests ascertained from your past searches, visits of subpages on our websites, and other data obtained through the use of “cookies” placed on your devices. Please see our Cookie Statement above.
• Ensuring the security of your user account and our business.
• Preventing or detecting fraud or abuses of our websites, products and services, for example, by requesting verification information in order to reset your account password.
• Administering technical aspects of our website, including troubleshooting, diagnosis of technical and service problems, testing, encryption and similar operation.
• For internal business operations, including data analysis, research, trend analysis, statistical and survey purposes, for example to gather demographic information about our users, determine how much time users spend on webpages of our website and to gather information on how our users navigate through our website. We may wish to contact customers to conduct surveys or focus groups to receive your views on our products and delivery. Occasionally we will combine information from a number of customers to better understand trends and customer expectations. When this occurs, all identifiers are removed and the aggregate information cannot be linked to any specific
• Developing and improving our website and products and determining the effectiveness of our business efforts, for example, by reviewing demand for websites and products and user comments or other contributions.
• To comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law. We also record information to comply with financial reporting requirements, including those imposed by auditors and government regulators. We may also collect certain information as required by local laws.

8. Is my Personal Information transferred overseas?

We may transfer your information outside of the country in which it was collected for various reasons. These reasons include: the purpose of entering into or fulfilling a contract with you, processing on-line purchase transactions, replying to or taking actions in response to your enquiries or requests, enhancing personalization of services provided to you, communicating news and promotions to you relating to La Tartaruga S.r.l. products and services and other products and services we think may be of interest to you, and statistical and analysis purposes.

Such transfer of data may be to a country which may not provide the same level of privacy protection as that provided by the country in which the information was collected. However, we will take reasonable steps (including entering into data transfer agreements based on the European Commission model clauses, where required) to ensure that your data is adequately protected by using appropriate technical, organisation, contractual or other lawful means. If you are located in the European Economic Area or the UK, you may contact us for a copy of the safeguards which we have put in place to protect your personal data and privacy rights in these circumstances.

9. How long is my Personal Information retained?

Your personal data will be retained for as long is reasonably necessary for the purposes listed above or as required by applicable local law. We will automatically delete your Personal Information if you have not ordered from us for a certain period of time. Please contact us for further details of applicable retention periods.

We may keep an anonymized form of your personal data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

10. Your rights

If you wish to exercise any of your rights in relation to your Personal Information, please send your request via email to info@amorvero.com.

Right to make subject access request (SAR)

We understand that you may like to know what Personal Information we hold about you. We are happy to assist you with your request. However, to protect your Personal Information we require that you prove your identity to us at the time your request is made. You may also make a request by email.

When you make a request, we will require you to produce some form of photo identification such as a passport or a driver's license and you may be asked to sign a request form. If the request is made in writing via email or letter we require other information so we can check them with our files and satisfy ourselves as to your identity.

The above information is required to create an audit trail of how the request has been handled. Where a request is made, any correspondence or application may be kept and added to your Personal Information.

La Tartaruga S.r.l. will respond to any enquiries as soon as possible but no later than within the timeframes prescribed by law.

La Tartaruga S.r.l. reserves the right to decline access to your Personal Information under certain circumstances, as permitted by law. If your Personal Information is not disclosed to you, you will be provided with the reasons for this non-disclosure.

Right to object to processing, including automated processing and profiling

If at any time you wish for your Personal Information to be deleted from our customer database and systems, or wish to not be part of our profiling module, please contact us.

La Tartaruga S.r.l. will aim to respond to your enquiry within 72 hours. However it might take up to 7 days to have your profile deleted from all our systems.

Right to rectification

You may request that we rectify any inaccurate and/or complete any incomplete personal data.

Right to withdraw consent

You may, as permitted by applicable law, withdraw your consent to the processing of your Personal Data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit certain service features for which the processing of your personal data is essential.

Right to erasure

You may request that we erase your Personal Data and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your Personal Data, such as, a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations.

Right to data portability

In certain circumstances, you may request that we provide your personal data to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services. Although we do not consider that this is relevant to our services, we will comply with such transfer request as required by law. Please note that a transfer to another provider does not imply erasure of your Personal Data which may still be required for legitimate and lawful purposes.

Your right to lodge a complaint with the supervisory authority

We suggest that you contact us about any questions or if you have a complaint in relation to how we process your Personal Data. However, you do have the right to contact the relevant supervisory authority directly. A list of EU national data protection authorities can be found here.