1. Data Controller

Ammodino L.L.C., a limited liability company incorporated in the Sharjah Media City Free Zone (Shams) with a business license number 2010069. 01, whose registered office is at Sharjah Media City, Sharjah, UAE (hereinafter, “Ammodino”) is the autonomous datacontroller with respect to the personal data of users browsing the Website www.ammodoconcept.com (hereinafter, the “Website”), including browsing data, marketing and data connected and correlated with sales made through the Website and the relative pre-sale and after sale activities.

2. Type And Purpose Of Processing Carried Out On The Website

Through the Website different types of personal data are collected and processed for different purposes and with different methods. More specifically:

1. personal data relating to browsing, processed to allow the Website to function properly, as well as for marketing purposes.
2. personal data provided on a voluntary basis by the user (email address, telephone number, biographical details, password provided by completing the registration form) or otherwiseprovided while browsing the Website and processed to respond to user requests and offer the services, support and information requested in relation to the products offered. Please note that signing up to and accessing the Website or the customer account throughsocial networks involve the communication of certain data (Name, Surname, E-mail and any other data relatingto the user and present on the same social network, which will in any case be listed to the user before their confirmation to proceed with authentication via the social network). This communication will in any case take place only after the explicit confirmation of the user’s willingness to proceed before logging in. In some cases, the social networks require some feedback and information about the use of the log in. For further information please refer to the relevant privacy documentation made available by the social network;
3. The personal data provided by the user during the purchase of products on the Website in order to complete transactions and for activities related and accessory to sales, as well as for all necessary pre-sale and after sale assistance;
4. Personal, biographical and contact data, processed by Ammodino – with the user’s express consent – for marketing purposes, i.e. in order to send the user (through traditional and electronic means such as newsletters, emails, SMSs, MMSs and smart messages)
   information and updates on products, sales, promotional campaigns, events and other initiatives promoted by Ammodino or by its commercial partners;
5. Personal data regarding purchases and any preferences expressed, processed by Ammodino – with the user’s express consent – in order to assess consumption habits and choices, so as to bring the products, initiatives and individual commercial offers more in line with the user’s preferences and needs.
   

3. Tudy Of User Consumption Habits And Choices

As specified in point 2 (5) above and with the user’s express consent, Ammodino may process the personal data of the user in order to assess consumption habits and choices, so as to bring Ammodino’s products and initiatives more in line with its customers’ preferences and needs. With the support of automated means, Ammodino will process data relating to the value and frequency of purchases, as well as the type of products purchased. Data concerning consumption and preferences may be collected not only by tracking purchases made on the Website but also through any information that the user may willingly provide. The sole objective of this research is to offer customers and users products, services and initiatives more suited to their preferences and needs. In this regard, please note that research on user and customer behaviour will take place with methods that do not invade the personal sphere.

You may always ask for clarifications concerning the rationale applied to this processing and the modification of the results obtained by contacting Ammodino using the contact information provided.

As specified in point 2 (1) above and with the user’s express consent, Ammodino may also process the user’s personal data, using automated means, to study cookies in order to check browsing on the Website and offer products and services in line with browsing activities.

4. Methods Used By Ammodino To Process Personal Data

The personal data is processed using automated tools for the time strictly necessary to achieve the purpose for which it was gathered. The web services of the Website will be processed on the servers of outsourced companies offering hosting services on behalf of the Company, as well as clouds. The personal data collected through the Website are mainly processed with IT and electronic methods and means, adopting the security measures required to reduce to a minimum the risks of destruction or loss, even accidental, of the data, unauthorised access or processing that is not permitted or not compliant with the purposes of collection specified in this Privacy & Cookies Policy.

However, such measures, due to the nature of online transmission, cannot limit or completely exclude any risk of unauthorised access or data dissemination. To such end, we advise you to periodically check that your computer is equipped with adequate software devices to protect the online transmission of data, both incoming and outgoing (such as updated antivirus systems) and that your internet service provider has adopted suitable measures to ensure the security of online data transmission (such as firewalls and antispamming filters).

5. Mandatory Or Optional Nature Of The Provision Of Data

The provision to Ammodino of personal data collected through the Website to respond to user requests and queries as well as for marketing purposes, to study consumption habits and preferences and for communication to third parties is free, optional and facultative. Not providing data does not limit the use of the Website. The provision of personal data, in particular personal details, email addresses, mailing addresses, telephone numbers and bank details (in case of payments with credit cards) is necessary to conclude the product purchase contract through the Website. Therefore, if the data is not provided, it may be impossible to complete the purchase through the Website.

Some of that data may also be necessary for the provision of other services available on the Website and related to sales (pre-sale and after sale services such as customisation services, etc.) or to fulfil obligations deriving from laws or regulations (tax requirements and anti- money laundering regulations). Failure to indicate the data could therefore constitute, depending on the case, a legitimate and justified reason not to execute the contract to purchase products on the Online Store and/or provide the related services.

When necessary, the mandatory or optional nature of the communication of the data will be indicated on a case by case basis, with the (*) character appearing alongside information that is required for the provision of services and for the purchase of products on the Website. Failure to provide the personal data indicated as optional will entail no limitation or disadvantage for the user.

6. Categories Of Recipients Of Personal Data And Of Browsing Data

Ammodino communicates the personal data of Website users and the browsing data only within the limits permitted by law and in accordance with what is specified below. In addition to what is set forth under point 2 b. (i.e. Social network login), personal data may be known by:

• Ammodino’s employees and advisors, who will operate as authorised data processors for the internal organisation of corporate activities and marketing activities (such as inviting the user to events, sending discounts, promotions, etc.); and
• Companies that carry out for ammodino, as data processors, specific technical and organisational services connected to the website (logistics services, it services, customer care service and marketing services).

The personal data and the browsing may also be known by:

• Third parties, only to execute the product purchase contract on the website (such as the credit institution for the execution of remote electronic payment services using a credit/debit card);
• Police forces or judicial authorities, in compliance with the law and upon such subjects’ formal request, or if there are justified reasons to believe that the communication of such data is reasonably necessary (1) to investigate, prevent or take initiatives relating to suspected unlawful activities or to support national control and supervisory authorities; (2) for the defence against any complaint or accusation from third parties, or to protect the website and the company’s security; or (3) to exercise or protect the rights, property or security of ammodino, the companies of the same group, its affiliates, customers, employees or any other party.
  

7. Period Of Retention Of Data

The personal data collected for sale purposes are stored for a period not exceeding 10 years from the purchase, in compliance with tax and civil regulations and without prejudice to particular judicial defence needs that may require storage for a longer period of time. The data provided by the user to request support, information and responses are stored for the period of time required to provide the response requested and to provide any subsequent additional communication with the customer necessary to fully manage the request and/or issue.

8. The Cookies Used And The Purpose Of Such Use

A cookie is a small data file which, in the form of a unique anonymous code, is sent to users’ browser from a web server and then stored on the hard disk of your computer, smart- phone and/or tablet. Cookies may allow the correct use of an internet website (so-called technical cookies), or they may serve to verify the User’s preferences in their online surfing in order to propose advertising in line with such preferences (so-called profiling cookies).

Cookies may be stored permanently on the device for a period of variable duration (so- called permanent cookies) or they may be deleted upon closure of the browser or be of limited duration (so-called session cookies).Upon access to any page on the Website, a banner will display brief notice concerning cookies. Closing the banner or continuing to navigate by visiting other areas on the Website or selecting an element on the same (such as an image or link), indicates your consent to the use of profiling, non-anonymous analytical and third-party cookies. Consent to the use of cookies can be recorded by a “technical cookie”.

Consent is not required for the use of technical and functional cookies (as well as for anonymous analytical cookies). They are thus processed on the basis of the owner’s legitimate interest to provide improved navigation and use of the Website. This Website uses the following cookies:

(a) Navigation Cookies

These cookies allow the Website to function correctly making it possible to view its contents in the relevant language and market from the User’s first visit. They allow the creation of an account, to log in and manage orders. If you are a registered User, thanks to these cookies the Website will recognise you when accessing the services offered to registered users.

(b) Functional Cookies

These cookies allow the Website to recognise you every time you visit, so that you do not have to enter your credentials every time. If items have been added to the Shopping Bag and the session closes before the purchase is completed, these cookies allow you to continue with your purchases on your next visit to the Website (within a limited period of time) with the Shopping Bag in the same state as when you left it. These cookies are not indispensable for the functioning of the Website, but they improve the navigation quality and experience.

(c) Analytical Cookies

These cookies (for example Google Analytics) are used to create statistical analyses on the manner in which users navigate the Website (the device used, the number of pages visited or the number of clicks on a particular page during navigation). Google Analytics is a web analytics service provided by Google, Inc., which uses cookies to help analyze how users use this website. The information generated by the cookie about your use of this Site (such as your IP address, the URL visited, the date and time the page was viewed) will be transmitted and stored by Google on servers in the United States. Google will use this information to monitor your use of this Site, compiling reports on website activity for website operators and providing other services related to website activity and internet usage. Google may transfer this information to third parties where required by law, or where such third parties process information on Google’s behalf. For more information about Google’s privacy policy in respect of Google Analytics, please refer here.

(d) Profiling Cookies

By means of profiling cookies it is possible to identify visitors’ preferences and create profiles which allow the sending of messages more tailored to users’ preferences and interests, for example making it quicker to view the products you are looking for or showing you the closest match to such products.

(e) Marketing/retargeting third party cookies

These cookies are used by third party companies, making it possible to view advertising banners on other affiliated websites, showing the last products that have been viewed. While users are navigating the Website, these cookies are also used to show products which might be of interest or which are similar to those the user has looked at previously, based on their navigation history.

9. Rights Granted To The User

Users always have the right to obtain the following from Ammodino:

1. Confirmation as to whether or not personal data concerning them exists even if it is not yet recorded, and its communication in an intelligible form;
2. Information concerning the origin of their personal data, the purposes and methods of processing, the rationale applied in the case of processing performed with the support of electronic means, the details of the data controller and data processors, an indication of the subjects and categories of subjects to whom the personal data may be communicated or who may be informed thereof in their capacity as, for instance, data processors or as subjects authorised to process the data;
3. The updating, rectification or, where interested, the integration of the personal data;
4. The cancellation, the transformation into anonymous form or the blocking of personal data processed against the law, including those for which storage is not necessary in relation to the purposes for which the data were collected or subsequently processed, as well as certification that the operations mentioned above were brought to the attention of those to whom the data were communicated, except for the case in which such action is impossible or implies use of means that are clearly disproportionate with respect to the protected right;
5. The portability of their own data;
6. The Restriction Of The Processing Of Their Personal Data.

The rights listed above may be exercised by contacting Ammodino, by writing to hello@ammodoconcept.com.

Ammodino, in its sole and absolute discretion, change this Privacy and Cookies Policy from time to time. All changes to the Privacy and Cookies Policy will be effective when posted. We encourage you to check back often to review the latest version. In order to continue using the Website following any changes to the Privacy and Cookies Policy, you must agree to be bound by such changes. If you object to any such changes, your sole recourse shall be to cease using our Website.