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CELLULARLINE PRIVACY POLICY

This policy has been prepared in accordance with Articles 13-14 of Regulation EU 2016/679 and is intended for all users and visitors to the website cellularline.com. This document cancels and replaces in full the previously published documents.

Please note that this website conforms to Regulation EU 2016/679 (GDPR), which protects individuals with regard to the processing of their personal data. Your data will be processed in accordance with the principles of fairness, legality and transparency, and your confidentiality and rights will be protected.
1 Who processes my data?
Through the use of this website, your personal data will be processed by the following independent Data Controllers:

  • CELLULARLINE S.P.A. (headquartered in Reggio Emilia, Via G. Lambrakis 1/A, VAT number 09800730963 and number of registration on the Companies Register of Reggio Emilia no. RE315329; Tel. 0522 334002, the proprietor of the website, and the owner of the domain names and brand names “Cellularline” and “Interphone”.
    Cellularline informs that it has designated, pursuant to art. 37 EU Reg. 2016/679, your Data Protection Officer ("DPO") who can be contacted via email at: privacy@cellularline.com
  • T-DATA S.r.l. (headquartered in Campogalliano, Via Strasburgo 31,41011 (MO) tax code and VAT number IT03854490368 and number of registration on the Companies Register of Modena 03854490368; tel. 0331 1090043; e-mail: supporto@t-data.it), which is responsible for the management of orders, sales and deliveries of “Cellularline” and “Interphone” products sold on the website and for managing returns, the legal warranties and other activities necessary for the sale of products on the site. For information about the vendor please see: https://www.cellularline.com/en/privacy.

2 Why is the data used, on what legal basis and for how long?
A) MANAGEMENT OF USER ACCESS AND BROWSING
Information on the processing of browsing data and cookies can be found in the Cookies policy available at: https://www.cellularline.com/en/cookies.

B) REGISTERING ON THE CELLULARLINE WEBSITE
By registering on the website, users can access all the services provided for registered users, which are available in the reserved area. The login credentials for the reserved area of the website www.cellularline.com are also valid for the services available in the reserved area of the website www.interphone.com. Registration is optional.

Legal basis
The legal basis for the processing of this data is the contract between the user and Cellularline for the use of our services, including website purchases and management of the standard warranty.
Conservation period
The data relating to a registered account will be processed until the account is deleted by the user. This can be done at any time by accessing the reserved area of the website, or upon express request by the user.

C) CONSENTING TO ACTIVITIES PRELIMINARY TO THE FORMATION OF A PURCHASE CONTRACT BETWEEN THE USER AND T-DATA
With an e-commerce purchase by an unregistered user, Cellularline will collect and make available to T-Data the data necessary to complete the order.
Legal basis
The legal basis for the processing of this data is the fulfilment of the pre-contractual measures adopted at the request of the data subject.
Conservation period
Details of orders made by an unregistered user will be kept by Cellularline for the time necessary to complete the order.

D) MARKETING
Registration for newsletters is completely optional.
The newsletter and DEM service is conducted through automated systems. This may involve mailing campaigns provided by MagNews (Diennea), the company appointed as the external Data Processor. The content of marketing communications may relate to: products of Cellularline S.p.A., contexts using products available from the online shop, images, videos or other multimedia content relating to the products or brands of Cellularline S.p.A.
Legal basis
This data is collected on the basis of consent. The legal basis for this processing is the consent given through conclusive evidence at the time the newsletter is requested.
Conservation period
The processing of contact details for this purpose will take place until such time as the user declares that they no longer wish to receive the service (using the link in each email or, for registered users, using the section in their personal area), or if the email address is no longer active.

D2) AUTOMATIC BASKET RECOVERY FEATURE
Basket recovery invites are only sent to registered users who have used the e-commerce website, having logged in and not finished their purchase. This service involves sending messages through marketing automation tools managed by Klaviyo, an external company appointed as a Data Processor.
Legal basis
This data is collected on the basis of the Data Controller’s legitimate interests. The data subject still has the right to object to receiving these messages by the option of unsubscribing in the messages received.
Storage period
The details on products added to the basket and the user’s contact details are processed for this purpose for up to 96h after the basket has been abandoned on the e-commerce website.

D3) UP-SELLING AND CROSS-SELLING
Up-selling and cross-selling involve promotional and marketing messages only sent to registered users who have used the e-commerce website, having logged in and finished their purchase.
This service involves sending messages through marketing automation tools managed by Klaviyo, an external company appointed as a Data Processor. The contents of the message may involve products sold on the platform, including ones related or connected to purchases made by the user.
Legal basis
This data is collected on the basis of the user’s consent, which is completely optional. The data subject still has the right to object to receiving these messages by the option of unsubscribing in the messages received or in the preferences section which can be accessed in the members’ area. Any refusal to grant consent may mean it is not possible to receive information on promotions, discounts and offers.
Storage period
The details on purchases made and the user’s contact details are processed for this purpose for up to 6 months after the purchase is made on the e-commerce website, or until the user expresses their desire to no longer be a member of the service, or the email address is no longer active.

E) PROCESSES RELATING TO THE "ONE4EVER” WARRANTY
The processing of personal data relating to the purchase and activation of the “One4ever” warranty.
To use the service, various data will be requested, together with the general details required at the time of registering, in relation to the product for which the warranty is to be activated (the phone for which the product was bought, the EAN code for the purchased product, the date of purchase indicated on the purchase document, a photo of the receipt/invoice, a photo of the open box of the purchased product and a photo of the phone showing the IMEI code). This data is essential in order to activate the warranty contract.
Where a “One4ever” warranty is purchased, CELLULARLINE SPA may conduct market research and customer satisfaction surveys.
Legal basis
The basis for the processing of data for the warranty is the contract, while for market research, the legal basis is the legitimate interest (Article 6 letter f of Regulation EU 2016/679).
Conservation period
The data processed for the warranty contract will be kept for 10 years.

F) MANAGEMENT OF REQUESTS BY USERS TO EXERCISE THEIR RIGHTS
If you request the exercise of your rights as indicated in paragraph 7 of this policy, you may be asked to provide identification details which will be processed in accordance with the legal obligations by which CELLULARLINE is bound, in order to reply to the request, to verify its authenticity and to take the necessary actions.
Any refusal to provide data for this purpose will mean that CELLULARLINE will be unable to fulfil the request of the user, who may not, therefore, exercise their rights.
Legal basis
For the performance of legal obligations.
Conservation period
The data requested from the data subject for this purpose will be processed for the time necessary for the management and closure of the request, and it may be kept for the time necessary to certify that the request has been fulfilled.

G) PURSUIT OF LEGAL PURPOSES
CELLULARLINE SPA may process the personal data collected through browsing the website and through using its functions in order to verify, exercise or defend its rights.
Legal basis
For the above purpose, data that was initially collected for a different purpose will be used; such data will be processed on the basis of the proprietor’s legitimate interests (Art. 6 letter f of Regulation EU 2016/679).
Conservation period
For up to 10 years from the date of collection or fulfilment of the purpose for which the data was originally collected.
3 How will the data be processed?
For the above purposes, the personal data will be processed using manual, analogue, computer-based, electronic and telematic instruments and media, which may be automated, in order to connect the data with the data of other persons based on quali-quantitative and temporal criteria which may be recurring or defined on a case-by-case basis, using logic and forms of data organisation which are closely correlated to the purposes of the processing, always in such a way that the data’s security and confidentiality is guaranteed.
4 Am I obligated to provide my data?
Subject to the indications given with regard to browsing data, users are free to provide their personal data. As CELLULARLINE has organised its activities by limiting the collection of personal data based on the principle of strict necessity, for certain operations such as the completion of online forms, any failure to provide data marked with an asterisk (*) may mean that it is not possible to fulfil the requested operation.
Please also note that any consent you provide for marketing operations may be withdrawn at any time, using the link in each email or, for registered users, using the relevant section in their personal area.
5 Who will my data be disclosed to? Will my data be disseminated?
Dissemination: Your data will NOT be disseminated in any case.
Communication: Your data may be disclosed to any person, including public authorities, who have access to it by virtue of regulatory or administrative orders.
Your personal data may also be communicated to:

  • Employees and/or contractors who are authorised to use the data;
  • T-Data, to fulfil its activities;
  • Companies in the Cellularline Group;
  • Third parties, consultants or professionals appointed as Data Processors, including IT providers for maintenance, mailing, marketing automation or cloud services.

The full list of data recipients is available at the CELLULARLINE head office.
6 Where will my data be stored?
Data shall mainly be stored at the headquarters of the Data Controller and its suppliers based in the European Union. The involvement of suppliers based in the United States is only required for marketing automation (purposes D2 and D3). This data transfer shall be made in accordance with Chapter V of EU Reg. 2016/679 through contractual agreements based on the Standard Contractual Clauses approved by the European Commission.
No data shall be transferred outside the EU for any other activities.

7 What are your rights?
As the data subject you have a series of rights governed by Articles 15-22 of Regulation (EU) 2016/679. These include:

  • Right to access your personal data (once you have confirmation that the data has been processed by the Data Controller);
  • Right of rectification and integration of your data;
  • Right to the erasure of your personal data;
  • Right to limit the processing of your personal data under certain conditions;
  • Right to receive your personal data as supplied to the Data Controller, in a structured, commonly used format, and to send them to a different Data Controller;
  • Right to object to the data processing for legitimate reasons related to your personal situation;
  • Right not to be subjected to an automated decision-making process;
  • Right to be informed if your data is affected by a serious breach;
  • Right to revoke consent to the data processing at any time;
  • Right to make a complaint to a supervisory authority.

The Data Controller will facilitate the exercise of the data subjects’ rights, wherever possible.
To exercise your rights or if you have any doubts or concerns related to the processing of your personal data, please contact CELLULARLINE SPA by e-mail at privacy@cellularline.com.
8 Policy update
Policy last updated on: 15 July 2022