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PRIVACY

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INTRODUCTION

Welcome to www.unexpected-custom.com hereinafter (the "Site"). Please read our Privacy Policy carefully. It applies both if you should decide to simply connect with and browse the Website and use its services without purchasing any product, and if you purchase the products or services offered for sale.

Unless specified otherwise this Privacy Policy also applies to data collected by other means than this Site.

By using the Website, you accept the terms given in the Privacy Policy and the disclosure at the foot of the Privacy Policy. Please do not use the Website if you disagree with any of the terms and conditions of the Privacy Policy.

The processing of the Personal Data of users and consumers (hereinafter collectively referred to as "Users") shall be carried out in compliance with applicable European legislation (GDPR – EU Privacy Regulations 679/2016 and EPrivacy Regulations) and the Personal Data Protection Act (hereinafter the "Privacy Act", Legislative Decree No. 196 of 30 June 2003, and after its abrogation, the equivalent Italian legislation), regulating the processing of personal data carried out:

I) as a service by a data holder or a data processing manager in the EU, regardless of the fact that processing is done in the European Union. 4.5.2016 L 119/32 Official Journal of the European Union IT; and

II) processing of personal data of data subjects situated in the EU, carried out by a data holder or data processing manager not established in the EU, when processing tasks regard:

a) the supply of goods or services to the above data subjects in the EU, regardless of whether the data subject is obliged to make a payment; or

b) monitoring their behaviour in the measure in which such behaviour takes place within the European Union.

Processing takes place in respect of fundamental freedoms and rights and of the dignity of the data subject, with specific reference to confidentiality, personal identity and the right to the protection of personal data.

THE POLICY

UC-TRADE di C. Masetti (hereinafter "UC-TRADE/UNEXPECTED-CUSTOM") respects the rights of their Users to be informed about data collection and other processing of their Personal Data. For processing of data that can directly or indirectly identify your person the Website has therefore been configured in such a way as to ensure that use of Personal Data has been minimised and to exclude processing of Personal Data when the purposes pursued in the individual cases can be achieved by using anonymous data (such as, for example, market research aimed at improving services, analysis of the pages and content recording the most visits and clicks, from users from other sites or on-line channels) or carried out in other ways, which enable identification of the data subject only where strictly necessary or required by the authorities and police forces (such as, for example, for data relating to traffic and time spent on the Website or your IP address).

TYPES OF DATA

When filling in the forms available on our sites you are never asked for "sensitive" (personal data susceptible to reveal racial and ethnic origin, religious, philosophical or other sorts of convictions, political opinions, membership of parties, trade unions, associations or organisations of a religious, philosophical, political or trade union nature, as well as personal data susceptible to reveal state of health or sex life) or "judicial" (data concerning criminal record, or relating to being a defendant or under investigation, etc.).

The data we process belong to three general categories: I) browsing data; II) data provided actively by the data subject; III) relevant data collected from third parties.

I) Browsing data

During normal operation computer systems and software procedures responsible for keeping this site working collect some personal information whose transmission is implicit in use of Internet communication protocols. This information is not collected to be associated with identified data subjects, but given their nature could allow for identifying users when processed and associated with data kept by others. Falling in this category of data are IP addresses or domain names of the computers utilised by users who connect to our Site, URI addresses of requested resources, the time of the request, the method used for submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.), the country of origin, and other parameters related to the user's operating system and computer environment (e.g. features of the browser and operating system used by the visitor, the type of device used for connecting to the Internet, the various elements of time related to the visit (e.g. time spent on each page and details related to the path followed on Site pages, particularly as concerns the sequence of the pages viewed. Also falling in this category are so-called system logs, i.e. files that record interactions between the user and the Site. These data are used for managing access to the Site and services offered, by obtaining anonymous statistical information on use of the Site to make Site functionalities technically possible, to check whether they are working properly and to ensure maintenance of the database. In these cases, browsing data do not allow for identifying users or data subjects and are deleted right after being processed in anonymous form. Browsing data can also be used for verifying responsibility in case of felonies or other wrongdoings committed by the data subject at the expense of the Site and/or third parties through the Site.

II) Data provided by the user

Data are voluntarily provided by the user and collected through the Site and are linked by other means to two distinct databases:

This means:

When you spontaneously send an email to an electronic mail address indicated on our sites, we obtain the sender's address and any other personal data included in the message or attachments. Electronic mailboxes of the addresses indicated on our sites and any other UC-TRADE/UNEXPECTED-CUSTOM electronic mailbox are not of a personal nature, not even when they bear the first and/or last name of an individual. These mailboxes belong to our organisation and their main purpose is to allow for work to be carried out efficaciously at companies belonging to the UC-TRADE/UNEXPECTED-CUSTOM group. This means that not only the addressee but others belonging to our organisation know about messages sent to the electronic mailboxes of UC-TRADE/UNEXPECTED-CUSTOM group. By sending an e-mail to other electronic mail addresses indicated on our sites, you declare that you have read and agree to the processing conditions set out in this policy.

WHO PROCESSES YOUR PERSONAL DATA, HOW AND WHY

UC-TRADE/UNEXPECTED-CUSTOM is the only independent data holder of the Users' Personal Data ("Personal Data"), in relation to handling, conclusion and execution of commercial transactions concerning the sale of products and services on the Site or at shops on the street belonging to UC-TRADE/UNEXPECTED-CUSTOM, as well as after-sales services ("Commercial Purposes"), and in relation to direct marketing purposes (including functional profiling to direct marketing activities) carried out through the functionalities of the Site and/or through any other on-line channels (e.g. sending newsletters about the world of UC-TRADE/UNEXPECTED-CUSTOM, its products and services, sending - by text messages, email, telephone with operator, social network, mobile messages - general and/or personalised promotional and advertising messages with respect to consumption habits and/or other preferences and interests shown by the User) hereinafter the ("Marketing Purposes"), depending on the consent given by the data subject as specified below.

For Commercial Purposes, personal data are processed

1) to satisfy pre-contractual requirements (e.g. instruction of offers or your orders, solvency verifications);

2) fulfilment of contractual obligations (connected with the supply or purchase of goods and/or services) and legal obligations (e.g. keeping accounts, tax formalities, administrative , accounting and treasury management);

3) management of customers and suppliers;

4) management of disputes and credit transfers;

Personal Data will only be processed by persons specifically chosen and authorised in writing by UC_TRADE/UNEXPECTED-CUSTOM and checked by UC_TRADE/UNEXPECTED-CUSTOM, to prevent unauthorised access to data or illegal processing by third parties and to prevent security risks for the Personal Data. The categories of persons authorised to carry out processing are subjects belonging to the administrative, marketing, commercial, after-sales, claims, legal and ICT departments.

Personal Data are mainly processed in electronic format and in some cases also as hard copies.

The logics and forms of processing organisations are strictly related to individual purposes specified above. In order to guarantee that the Personal Data is always exact and up-to-date, in any case pertinent and complete, we would ask that you please inform us of any change made to the following e-mail address: info@uc-trade.com

Data are processed in UC-TRADE/UNEXPECTED-CUSTOM's Customer Relationship Management (CRM) computer system dedicated to handling customers, suppliers and other contacts.

The owner also uses Cloud softwares for internal data management.

The content processed

According to law the term processing means different sorts of tasks related to personal data: the collection (through the Site, over the telephone or using telematic or written means or from public registers, lists of acts and documents and/or public and/or private databases (e.g. commercial information companies or third parties responsible for processing delegated by Data Holders), the registration, organisation, storage and processing on hard copy, magnetic, automated or telematic storage devices, the processing of data collected by third parties, the amendment, selection, extraction, comparison, use, inter-connection, also with data of other subjects according to qualitative, quantitative and time-related criteria, recurring or as may be defined each time, the temporary processing aimed at ensuring the rapid aggregation or transformation of said data, the taking of decision in automated and/or discretionary form, the creation of profiles and disclosures, the communication, cancellation and destruction of data, or combinations of two or more of the above-mentioned operations; in addition pseudonimisation of personal data is also considered processing.

Processing for Marketing Purposes also involves a limited amount of profiling strictly necessary for satisfying your request to receive our newsletter and promotional and advertising materials of interest to you (and to improve advertising actions, particularly for preventing content the User shows no interest in from being sent and to increase customer satisfaction).

By law it is not necessary to obtain consent before sending advertising emails on products and services similar to those already bought at our Site or in UC-TRADE/UNEXPECTED-CUSTOM stores, although you have the right to tell us to stop sending advertising emails at any time.

Duration of processing

Personal Data will be stored in a way that allows for the identification of the User only for the time strictly necessary to the purpose for which the data was collected and subsequently processed and, in any case, within the legal limits as follows.

Personal data related to browsing are processed for the time necessary to allow browsing and technical interaction between the user and the Site; this time lasts the same as an single browsing session .

a) in the pre-contractual phase, for the time necessary for satisfying the requests of the data subject received by the Company (e.g. opening of technical intervention ticket during the warranty period) and tracking and handling the success of responses sent by the Company to the data subject; this the time is extended beyond to 24 months from the date on which the personal data were collected;

b) in relation to the contract stipulated with the data subject for the whole duration of the contractual relationship established with the data subject (in particular, for 2 years of normal warranty in accordance with the Consumer Protection Act);

c) at the end of the contractual relationship established with the data subject, personal data are processed to fulfil all legal obligations connected with the terminated contractual relationship (in particular for proving fulfilment of fiscal and civil law obligations to controlling authorities (for 10 years from termination of the contract).

Personal data are processed for IT security purposes (e.g. registration, storage, analysis of logs related to electronic and telecommunications events activated by the User during interaction with Site functionalities and/or sending email to UC-TRADE/UNEXPECTED-CUSTOM). The data will be stored for the time it takes to complete the relevant security controls and assess the outcome (1 year from the time of collection), or for abnormal events found, for the time it takes to resolve them.

n case of any out-of-court or judicial disputes with the data subject and/or third parties, the data will be processed for the time strictly necessary for fully exercising the rights of the Data Holder (i.e. until a judicial or out-of-court settlement is reached or a measure with the force of a final judgement has ended the dispute).

For processing for Marketing Purposes, the term is as follows:

a) for profiling purposes, processing will last for the time necessary for using the outcome to plan, conduct and verify the efficacy of direct marketing campaigns based on the same profiling;

b) for direct marketing purposes, processing will last generally 2 years, although the data subject has the right to withdraw his or her consent at any time.

or the time data collected with cookies are kept please see the "Cookie Policy" section below.

UC-TRADE/UNEXPECTED-CUSTOM will take steps to definitively delete the Personal Data from its electronic files after the above time limits. Alternatively, it reserves the right to turn the data into anonymous form at any time and in such case privacy regulations no longer apply.

Place of processing

Personal Data will be processed mainly in Italy and in countries abroad where there are offices of other companies. Some processing can be carried out in other countries, in the EU and in non-EU countries in the measure in which such data are transferred by UC-TRADE/UNEXPECTED-CUSTOM.

Management of technical aspects of this Site and the database are also looked after by companies situated outside the European Union; as a result personnel of such companies can have access to this Site but only rarely for its technical operation.

Particularly, Personal Data shall be transferred abroad to companies partner to UC-TRADE/UNEXPECTED-CUSTOM and, if necessary for the pursuit of Commercial Purposes, only to non-EU countries that guarantee adequate levels of compliance with the decisions of the European Commission on these matters, or when no specific decisions have been taken, only subject to conclusion by UC-TRADE/UNEXPECTED-CUSTOM and such subjects of specific agreements, related to Marketing Purposes, containing suitable clauses for safeguarding Personal Data, in compliance with law and applicable regulations. When the transfer is made to a non-EU country for reasons other than Marketing Purposes, the legal basis for the transfer is founded on the lawful interest of UC-TRADE/UNEXPECTED-CUSTOM to execute the contract with the data subject or a contract stipulated by one of them with third parties in favour of the data subject or fulfilment of relevant legal obligations.

LEGAL BASIS FOR PROCESSING

The legal basis for processing consists of:

a) the lawful interest of UC-TRADE/UNEXPECTED-CUSTOM to guarantee that the Site and services provided through it work properly and to organise the relevant internal organisational and management processes for supply of these services even by interacting with third party sub-suppliers;

b) the necessity to take pre-contractual steps when requested by the same, for example requests for receiving information or commercial offers);

c) when data are aimed at stipulation of a contract with the data subject, the necessity to execute the contract the data subject is a party to or (it is necessary for fulfilment of a legal obligation the data holder is subjected to);

d) the necessity to prove due fulfilment of legal obligation towards the data subject or third parties (for example verification of fulfilment of tax obligations by public authorities; verification of fulfilment of legal obligations by the board of statutory auditors or independent auditors, etc.);

e) or profiling and direct marketing purposes, the fact that the data subject has freely given his or her informed consent to processing for a given purpose and it has not been withdrawn, as well as the lawful interest of promoting one's products and services to certain customers using off-line and on-line methods. .

Does the data subject's consent to processing for profiling and direct marketing purposes apply to disclosure of the data to third parties?

In both cases above, since the third party recipients of the data are designated as "external data processing managers" by UC-TRADE/UNEXPECTED-CUSTOM, they can process data on behalf of UC-TRADE/UNEXPECTED-CUSTOM on the basis of the consent for marketing purposes (including disclosure to third parties for such purposes) given before to UC-TRADE/UNEXPECTED-CUSTOM.

On the other hand, the consent given by the data subject to UC-TRADE/UNEXPECTED-CUSTOM for processing for marketing purposes does not automatically justify disclosure or transfer of the data by UC-TRADE/UNEXPECTED-CUSTOM to third parties which process them as joint data holders or independent data holders (i.e. other than the external data processing manager) (normally this occurs only with partners intending to use data independently for profiling and/or direct marketing purposes): to proceed with such disclosure to third parties, UC-TRADE/UNEXPECTED-CUSTOM must obtain a separate consent from the data subject, which is also optional.

WHAT HAPPENS IF YOU REFUSE TO GIVE UC-TRADE/UNEXPECTED-CUSTOM YOUR PERSONAL DATA

Conferral to UC-TRADE/UNEXPECTED-CUSTOM of Personal Data for the Commercial Purposes (more specifically, personal data, your e-mail address, your postal address, your credit/debit card details and bank details and telephone number) is required for the pursuit of the Commercial Purposes.

An refusal to provide UC-TRADE/UNEXPECTED-CUSTOM with the Personal Data required to this end may make it impossible to stipulate and fulfil the contract for the purchase of the products and services on the Website or to correctly fulfil legal and regulatory requirements. The supply of additional Personal Data, apart from compulsory data, is optional and shall have no consequences as concerns the purchase of products on the Website and in general will not result in any obligation or disadvantage for the User.

On the other hand, in relation to Commercial Purposes, it is unnecessary to obtain prior consent for processing as such processing by UC-TRADE/UNEXPECTED-CUSTOM is lawful based on other reasons (mainly for its lawful interest, prevailing over the interest or fundamental rights and freedoms of the data subject, to complete the contract of sale of the products and services and ensure that this takes place after stipulation). Such lawful interest also includes sending information, when requested by the User, back and forth aimed at the above stipulation (for instance concerning the type and/or features of the products). Similarly the Data Holder is required to fulfil legal obligations arising from the contract.

Conferral to UC-TRADE/UNEXPECTED-CUSTOM of Personal Data/consent for Marketing Purposes is always optional and is connected with registration of the User with the Website. Failure to provide such and failure to give consent to processing for Marketing Purposes shall have no consequence in terms of the buying process, except that it will be impossible to complete registration and therefore to benefit from services such as newsletters, generalised or personalised offers and access to reserved promotional areas, the direct marketing actions consists of. From time to time, we will duly inform you of the compulsory or optional nature of the disclosure of Personal Data to UC-TRADE/UNEXPECTED-CUSTOM and any consequences of non-conferral.

TO WHOM TO WE DISCLOSE THE PERSONAL DATA

Personal Data may be made available to third party companies providing specific services on behalf of UC-TRADE/UNEXPECTED-CUSTOM, as data processing managers, or disclosed to further third parties who process the data independently, purely in order to implement the contract for the purchase of products on the Website and only when this purpose is not incompatible with the purposes for which the Personal Data was collected and subsequently processed and, in any case, in compliance with the law.

UC-TRADE/UNEXPECTED-CUSTOM relies on suppliers which provide after-sales service, better described in the Terms of Sale on the Site, which can be viewed at the following link. In the dispatch stage, UC-TRADE/UNEXPECTED-CUSTOM also relies on carriers and couriers (UPS, DHL, etc .) which process the personal data of Users solely for completing the delivery assignment given.

In addition, the data can be disclosed to:

1) banks, digital currency institutes and other subjects authorised for providing remote electronic payment services by credit and debit cards or through functionalities made available on mobile devices;

2) insurance companies for transport insurance coverage;

3) credit collection, insurance and credit assignment companies (in case the User defaults of his or her contractual obligations towards UC-TRADE/UNEXPECTED-CUSTOM);

4) commercial information companies (in case of a dispute with the User);

5) other companies, entities and/or natural persons providing instrumental services or services in support of or functional to the fulfilment of the contracts of services requested (e.g. companies responsible for looking after the website, companies providing maintenance and assistance to the Data Holder's database).

Personal Data are disclosed to some other external data processing managers such as chartered accountants, attorneys and law firms, auditing companies and/or auditors, supervisory bodies connected with the organisational model adopted by UC-TRADE/UNEXPECTED-CUSTOM in accordance with Italian Legislative Decree 231 of 2001 for prevention of the risk that certain felonies are committed; this is to allow them to carry out tasks necessary for ensuring respect for legal obligations related to the sale of goods and services on the Site.

For Marketing Purposes UC-TRADE/UNEXPECTED-CUSTOM also discloses Personal Data to third-party external data processing managers: marketing and advertising agencies, hosting service companies, website development and management companies, web marketing companies, suppliers of electronic communication and ICT services; business partners - even those operating in production sectors not included in the e-shop, for example, operating in the automotive industry - with which UC-TRADE/UNEXPECTED-CUSTOM carries out co-marketing and events management actions. UC-TRADE/UNEXPECTED-CUSTOM can also share some data (first name, last name, email) with social media platforms (e.g. Facebook, Google) which use them solely for identifying other people similar to the user who may be interested in the services and/or products of UC-TRADE/UNEXPECTED-CUSTOM, so as to advertise them on social media platforms.

These external data processing managers have been appointed by UC-TRADE/UNEXPECTED-CUSTOM because they have proven to have the experience, capacity and reliability to provide a suitable guarantee of complete compliance with current provisions, including as concerns data security. Data processing managers process data according to the instructions of the Data Holder which appointed them, and periodically verifies that they promptly carry out the tasks assigned and continue to provide adequate guarantees demanded by the provisions of contracts and personal data protection laws.

You can obtain an updated list of external data processing managers and independent data holders at any time by writing to: info@uc-trade.com

User data related to registration on the Site

The Personal Data will not be disclosed, sold or in any other way transferred to third parties unless the Users have been informed of this in advance and given their consent, where required by the law.

In the event of sale of the company or business unit the Site belongs to, the personal data of the user will be automatically transferred to the buyer. In the event the majority stake of the share capital of UC-TRADE/UNEXPECTED-CUSTOM is sold to third parties, your personal data could be disclosed to the buyer(s).

Personal data will not be diffused, i.e. will not be made available to an uncontrollable number of third parties.

HOW PERSONAL DATA ARE COLLECTED ON THE WEBSITE

UC-TRADE/UNEXPECTED-CUSTOM collects Personal Data and other information directly from Users as part of the processes managed on the site (purchase of products on the Website for the stipulation of electronic trade transactions/completion of User registration forms with the Website for the Marketing Purposes of UC-TRADE/UNEXPECTED-CUSTOM), or by other means (e.g. on hard copy, or by using computers in shops and at events and trade fairs).

More specifically, in the pursuit of the Commercial Purposes, under the scope of the buying process of products and services on the Website, UC-TRADE/UNEXPECTED-CUSTOM collects Personal Data (such as personal data, e-mail address, postal address, credit card and bank details, details on payment instruments and codes when using mobile devices) by means of the order form for the sale of products on the Website.

 

SECURITY MEASURES

UC-TRADE/UNEXPECTED-CUSTOM takes suitable security measures by which to minimise the risk of the deliberate or accidental destruction or loss of Personal Data, unauthorised access or processing that is either not permitted or not compliant with the purposes of collection, as specified in this Privacy Policy.

Such measures include use of authentication credentials (User-ID and password) by whoever accesses the data on behalf of UC-TRADE/UNEXPECTED-CUSTOM, configuration of authorisation profiles for restricting access to just authorised legal persons and natural persons, periodic revision of such authorisation profiles, use of back-up and recovery procedures, antivirus software at the server and customer level, updated daily, firewall and anti-intrusion software. The email file is protected by antivirus and antispam software. Additionally, the Site is based on HTTPS technology, a protocol for secure communication via a computer network used on the Internet. HTTPS consists of communication via the HTTP (HyperText Transfer) protocol in a connection encrypted by the Transport Layer Security (TLS) or by its predecessor, Secure Sockets Layer (SSL). The underlying principle of HTTPS is having: i) authentication of the web Site visited; ii) protection of privacy; iii) integrity of data exchanged by communicating parties. The system that sends out our newsletters is also protected by antispam and antivirus software. Data are kept in files saved daily on supports which are stored in protected rooms.

As regards the best possible protection of your Personal Data, for all aspects that lie outside the control and management of UC-TRADE/UNEXPECTED-CUSTOM, we recommend that you ensure that the computer used has suitable software installed to protect data transmission over the internet, both incoming and outgoing (such as updated anti-virus systems) and that the chosen internet supplier has taken suitable steps to ensure the security of data transmission over the internet (such as firewalls and anti-spamming filters).

COMPULSORY PROCESSING

Please note that UC-TRADE/UNEXPECTED-CUSTOM may process Personal Data even without consent in certain cases established by the law, such as, for example, where such should be necessary in order to execute the contract with the User or fulfil a legal obligation.

For example, Personal Data can be disclosed to police forces or legal authorities, in compliance with the law and upon formal request by such parties, for example under the scope of anti-fraud services or even in the absence of a specific request, for fulfilment of tax obligations (e.g. Inland Revenue Agency).

RIGHTS OF THE DATA SUBJECTS

The data subject should know that he or she has the following rights:

How to exercise your rights

You can exercise the above rights and obtain a list of the independent third parties appointed as data processing managers to whom data have been communicated by UC-TRADE/UNEXPECTED-CUSTOM by sending an email to info@uc-trade.com

DATA HOLDER. CONTACT DETAILS

The Data Holder of the personal data of Users is UC-TRADE di C. Masetti with head office at Via Mazzini,6 – 21100 – Varese - Italia, P.IVA 02592520122.

If you wish to receive more information on how UC-TRADE/UNEXPECTED-CUSTOM processes Personal Data, write to our head office info@uc-trade.com.

To find out your rights and keep up-to-date on legislation governing personal protection in respect of the processing of Personal Data, we suggest that you take a look at the Italian Data Protection Authority's website www.garanteprivacy.it.

 

APPLICABLE LAW

This Privacy Policy is regulated by community law (GDPR) and Italian law, specifically the Privacy Act.

AMENDMENTS AND UPDATES TO THE PRIVACY POLICY

UC-TRADE/UNEXPECTED-CUSTOM may amend or simply update all or part of the Privacy Policy at any time, to incorporate any changes made to provisions or law or regulation protecting your rights. Written at the bottom of this document is the most recent version of this Privacy Policy, which applies to processing of Personal Data from the date specified.

Amendments and updates to the Website Privacy Policy shall take effect as soon as they are published in this section of the Website. Users will receive an email notice whenever changes are made to this Privacy Policy. You are required to look at this section regularly in order to verify the latest, most updated publication of the Website Privacy Policy.

PRIVACY POLICY ver 1 22.05.2018




UC- Trade Di C.MASETTI.
Via Mazzini, 6 - I.21100 Varese (VA) - Italia
P.I. 02592520122
C.F. MSTCNZ61E66E734U



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