Privacy Policy

For the company Paul Burnett Randal Horse Caller S.r.l. your privacy and the security of your personal data are really important, so we collect and manage your personal data with the utmost care and take appropriate measures to keep them safe.

With this information, made pursuant to Article 13 of EU Regulation 2016/679 (hereinafter GDPR) on the protection of individuals with regard to the processing of personal data and the free movement of such data and Legislative Decree 193/2006 (Privacy Code) as novated by Legislative Decree 108/2018, we intend to explain the manner, timing, nature, purpose of processing of the data we collect when you connect to our site, consult it or interact with it.

This information refers exclusively to the processing of personal data that we collect or that the user sends when visiting the site www.horsecallerpaulrandall.com , owned by the company Paul Burnett Randall Horse Caller S.r.l., and not for other websites that may be consulted by the user and reachable through hyperlinks contained in the site and referring to resources outside the domain of the Owner.

DATA CONTROLLER

The Data Controller is the company Paul Burnett Randall Horse Caller S.r.l., with registered office in 52100 Arezzo (AR), Località Indicatore Zona B n. 102, VAT number: 02405390515, e-mail address: horsestabarrino@gmail.com

WHAT PERSONAL DATA WE COLLECT

The categories of personal data that we collect and process when you browse or purchase our products on the www. site www.horsecallerpaulrandall.com website are as follows:

Navigation data

Navigation data will be collected through the use of log files in which information collected automatically during user visits is stored. The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties but, by its very nature, could – through processing and association with data held by third parties – allow users to be identified. This category of data includes the internet protocol (IP) address, the type of browser and the parameters of the device used to connect to the site; the name of the internet service provider (ISP); the date and time of the visit; the web page the visitor comes from and goes to; the number of clicks, if any; the operations carried out within the site and other parameters relating to the user’s operating system and computer environment. These data are used only to obtain anonymous statistical information on the use of the site and to check its correct functioning and are deleted immediately after processing.

For security purposes (spam filters, firewalls, virus detection), the recorded data may be used, in accordance with the laws in force, to block attempts to damage the site itself or to harm other users, or in any case harmful or criminal activities.

Data provided voluntarily by the user

We may collect and process:

• The data you voluntarily provide us with by filling in the online form to contact our offices and request information (name, surname, email address,);

• the personal data necessary to conclude and execute your purchase on site www.horsecallerpaulrandall.com (first and last name, shipping address, billing address, payment details);

• for the registration of your account site www.horsecallerpaulrandall.com we collect your e-mail address and password. If you are already registered, we collect information about your access to the private area of the Site;

We also remind you that if you are under 18 years of age, you may not provide us with any personal information, and, in any case, we do not accept any responsibility for any false statements provided. If we become aware of the existence of untrue declarations, we will proceed with the immediate cancellation of any personal data acquired. The Data Controller does not process particular or judicial data.

Cookies

We use cookies and similar technologies to collect data. In order to manage, give or revoke your consent to the use of cookies, please read our Cookie Policy, which can be found in the footer of the site and is an integral part of this policy.

HOW WE USE PERSONAL DATA

We collect and process your personal data for the following purposes:

a) to handle requests that are received by our offices. We will use the personal data you voluntarily provide us with to fulfil your requests for information and assistance;

b) to conclude and perform the contract for the purchase of products offered on site www.horsecallerpaulrandall.com. When you conclude your purchase we ask you for the personal data necessary for the activities of executing the contract, (payment data and billing address);

c) registration on the site and use of the services offered to registered users. Registration to the site is possible by entering some personal information, necessary to ensure your identification and the performance of services offered to registered users;

d) comply with legal, administrative and accounting obligations relating to sales activities;

e) preventing and suppressing fraud and abusive behaviour (including by third parties) that is in breach of current regulations, applicable contractual provisions, and the rules of fairness and good faith

f) managing disputes (breach of contract, warnings, settlements, debt collection, legal disputes);

g) perform statistical analysis and surveys. We use some information about your use of the site to carry out statistical analysis and surveys in order to improve our offer and services.

We do not pursue direct marketing, profiling or retargeting.

LEGAL BASIS FOR PROCESSING

We process your personal data only if one of the conditions set out in the applicable legislation is met, and specifically:

• For the conclusion and execution of the contract to which you are a party (Art. 6 para. 1, lett. b GDPR).

When we process your data for the execution of pre-contractual measures and/or for the conclusion of the contract for the purchase of our products, we take care to use only the minimum information necessary for the execution of the same. This legal basis legitimises the processing of personal data that takes place in the activities described under a), b) and c) above. The provision of your personal data for these activities is a contractual obligation. You are free to provide us with your data or not, but without the requested data you will not be able to purchase our products nor will it be possible for us to respond to or handle your requests.

• To fulfil a legal obligation (Art. 6, para. 1, lett. c GDPR).

In the event of the conclusion of a contract for the purchase of our products, we will process your data in order to comply with legal obligations to which we are bound in accordance with tax, administrative and accounting provisions. This legal basis legitimises the processing of personal data that takes place in the activities described in point d) above. You are free to decide whether or not to conclude a contract and whether or not to disclose your data to us, but if you do conclude a contract your data will be processed to implement the legal obligations described above.

• For our legitimate interest (Art. 6, para. 1, lett f  GDPR)

This legal basis legitimises the processing of personal data that takes place in the activities under e), f) and g) above. You are free to decide whether or not to enter into a contract and whether or not to disclose your data to us, but if you do enter into a contract the data may be processed, after balancing against your rights, to pursue purposes attributable to the legitimate interest of the Data Controller.

• Based on your express consent (art. 6, par. 1, lett. a GDPR)

When you access our site, your browsing data and interaction with social channels will be processed for analytical and statistical purposes, i.e. to understand how users interact with our Platform and allow us to improve it. This legal basis legitimises the processing of personal data that takes place in the activities described in point g) above. Providing us with your personal data for these activities is completely optional, and failure to do so will not affect the possibility of purchasing our products online.

ACCOUNT MANAGEMENT

The controller offers users of the website www.horsecallerpaulrandall.com a secure connection for the transmission of personal data and the connection of the customer account using SSL encryption (security of data transmitted over the Internet). Access to the account at www.horsecallerpaulrandall.com is only possible after entering the personal password. If the customer has lost their password, the online shop allows them to create a new password. The password is stored in the database in encrypted form so that it cannot be read. To create a new password, the customer will be asked to enter their e-mail address in the form available under the “remember password” link provided in the authentication form. The new password will be sent automatically to the email address provided during registration or saved in the last account change. In order to ensure that the information we hold about you is correct so that we can properly carry out the activities described above, please log in to your account periodically and update your details as necessary.

DATA RETENTION PERIOD

We keep your personal data for a limited period of time, which varies according to the purposes for which it was collected. Therefore:

• Personal data collected for purposes related to the conclusion and execution of contracts for the purchase of our products will be retained until administrative-accounting formalities are completed.  Data related to invoicing will be retained for ten years from the date of invoicing.

• Data related to user requests to our offices will be kept until your request for information or assistance has been satisfied;

• Personal data collected for the purposes of our legitimate interest will be retained until we have satisfied that interest. You can find out more about our legitimate interests in the relevant sections of this document or by contacting us at the contact details above;

• Where processing is on the basis of consent, we may retain personal data until such consent is withdrawn and, in any event, within 2 years of the last interaction of any kind with you;

• finally, we may be obliged to retain your personal data in order to comply with a legal obligation or order of an authority, until such time as we have complied with or been complied with.

At the end of the retention period your personal data will be irreversibly deleted or otherwise anonymised. Therefore, at the expiry of the terms described above, the right of access, cancellation, rectification and portability can no longer be exercised.

HOW AND WHERE THE DATA COLLECTED IS PROCESSED

We undertake to process your personal data lawfully, fairly and transparently by manual, computerised and automated means for as long as necessary to achieve the purposes for which it is collected. We take appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of personal data. The data are processed at our operational headquarters by suitably trained and authorised internal staff or on the servers of the Data Controller and/or third party companies appointed, where applicable, as Data Processors. These servers are located in Italy and in any case within the European Union.

Depending on the Owner’s use of tools made available, for example, by Google, the customer’s personal data may be transmitted to a state outside the European Economic Area, in particular to the United States of America (USA) or to another state in which the cooperating party has the necessary means to process the personal data in the context of cooperation with the Owner in which the level of data protection has been deemed adequate by the European Commission pursuant to Article 45 of the GDPR (Privacy Shield). The adequacy decision of the European Commission can be consulted at the following link: https://eur-lex.europa.eu/legal-content/IT/TXT/PDF/?uri=CELEX:32016D1250&from=IT

DISCLOSURE AND DISSEMINATION OF DATA

We may disclose the personal data collected to third parties whose services we use to provide our services and in particular:

• to banks and companies that manage national or international payment circuits through which online payments are made for products purchased through the site;

• to companies, consultants or professionals in charge of the installation, maintenance, updating and, in general, the management of our hardware and software or which we use to provide our services;

• to all those public and/or private subjects (legal, administrative and fiscal consultancy firms, Judicial Offices, Chambers of Commerce, Chambers and Offices of Labour, etc.), if the communication is necessary or functional to the correct fulfilment of the obligations deriving from the law and/or to exercise or defend a right in court.

It is also without prejudice to the communication and/or dissemination of data required, in accordance with the law, by police forces, judicial authorities or other public entities for purposes of defence or state security or the prevention, detection and prosecution of crimes.

The data collected will not be disseminated, except in anonymous and aggregate form, for statistical or research purposes.

SECURITY MEASURES

We protect your personal data with specific technical and organisational security measures to prevent your personal data from being used unlawfully or fraudulently. In particular, we use security measures that ensure: the pseudonymisation or encryption of your data; the confidentiality, integrity, and availability of your data as well as the resilience of the systems and services that process them; and the ability to restore data in the event of a data breach. In addition, we are committed to regularly testing, verifying and evaluating the effectiveness of technical and organisational measures to ensure continuous improvement in the security of processing.

SOCIAL PLATFORMS

The www.horsecallerpaulrandall.com website provides links to other social media platforms. In particular, Facebook and Instagram widgets and TiK Tok are installed on the site, which lead to servers installed by third parties and over which the Owner has no control. This type of service allows you to view content hosted on external platforms directly from the pages of our site and to interact with them.

However, it is possible that, even if users do not use the service, it collects traffic data relating to the pages where it is installed.  For more information on the purposes, type and methods of collection, processing, use and storage of personal data by social network platforms, as well as on how to exercise your rights, please consult the respective privacy policies on the websites www.instagram.com  and www.facebook.com  and www.tiktok.com .

GOOGLE ANALYTICS

This website uses a statistical system provided free of charge by Google Analytics. The cookies and IP data are recorded solely for the purpose of generating anonymous statistical information about the use of the website, but will not be retained for any other purpose. The information generated by the cookies will be transferred to and stored by Google on servers in the United States. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. Google Analytics is provided by Google Inc.  Further information on the privacy policy of Google Analytics can be found at the following addresses http://www.google.com/analytics/terms/it.html  and http://www.google.com/privacypolicy.html

PAYMENT MANAGEMENT

The payment management services allow us to process payments for the purchase of our products online via PayPal.

The data used for payment are acquired directly by the manager of the payment service requested – who will act as autonomous data controller – without being processed in any way by the Owner. Some of these services may also allow messages to be sent to the User on a scheduled basis, such as emails containing invoices or notifications regarding payment.

Personal data will not pass through our Site’s server, which will therefore not process such data in any way. The processing of your personal data is necessary to allow the conclusion of the online purchase contract. Failure to provide your personal data will not allow you to complete the online purchase process.

In case of payment by PayPal, you will be directed to a page outside the Site, where you must indicate the personal data required by PayPal to complete the purchase process. For further information, please consult PayPal’s privacy policy at www.paypal.com

RIGHTS OF DATA SUBJECTS

Pursuant to Article 7(3) of the GDPR, you may at any time withdraw your consent to the processing of your data, where given, without prejudice to the lawfulness of the processing based on your prior consent.

In addition, in relation to the processing described in this Policy, you may, under the conditions set out in the GDPR, exercise your rights under Articles 15 et seq. of the GDPR and in particular:

– the right to obtain confirmation as to whether or not personal data concerning you are being processed, and if so, to obtain access and a copy (Right of access art. 15 GDPR);

– the right to verify the correctness of your data and request its rectification or integration if it is inaccurate or incomplete (Right of rectification art. 16 GDPR);

– The right to request the deletion of your data when: i) it is no longer necessary in relation to the purposes for which it was collected or processed; ii) you have revoked your consent to the processing; iii) you have objected to the processing and there is no overriding legitimate reason for the controller to proceed with the processing anyway; iv) the data has been processed unlawfully; v) the data must be deleted in order to comply with a legal obligation (Right to erasure “right to be forgotten” art. 17 GDPR);

– The right to request, when certain conditions are met, the restriction of the processing of your data. In this case, the Controller will not process the data for any purpose other than its storage (Right to restriction of processing art 18 GDPR);

– The right to receive in a structured, commonly used and machine-readable format your personal data and, where technically feasible, the unimpeded transfer thereof to another Data Controller. This provision is applicable when the data is processed by automated means and the processing is based on your consent, a contract to which you are a party or contractual measures related thereto (Right to data portability Art. 20 GDPR);

– The right to object to the processing, at any time, when personal data is processed in the public interest, in the exercise of public authority vested in the Controller or in pursuit of a legitimate interest of the Controller if there are reasons related to your particular situation. If the data is processed for direct marketing purposes, you may object to the processing at any time without giving any reasons (Right to object Art. 21 GDPR).

To exercise the aforementioned rights, you may send a written request to the Data Controller at the contact details indicated in this document. Requests will be processed as quickly as possible, in any case within one month of the request. The exercise of the rights described above is free of charge. However, in the case of requests that are manifestly unfounded or excessive, including due to their repetitiveness, the Data Controller may charge a reasonable fee, in light of the administrative costs incurred in handling your request, or deny satisfaction of your request (Information, communications and transparent methods for exercising the rights of the data subject art. 12 GDPR).

RIGHT TO COMPLAIN

If you believe that the processing of your personal data carried out through this website is in breach of the provisions of the GDPR, you have the right to lodge a complaint with the Garante per la Protezione dei Dati Personali (Italian Data Protection Authority), as provided for by Article 77 of the GDPR, or to take legal action in accordance with Article 79 of the GDPR.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to make changes to this privacy policy at any time. If the changes affect processing whose legal basis is consent, we will re-collect your consent as necessary.

Date last updated 21 June 2021

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