Dear Customer,
pursuant to Articles 12, 13 and 14 of EU Privacy Regulation 2016/679, we inform you that the personal data you provide or that are otherwise collected when you subscribe to the Loyalty Card will be processed in compliance with the applicable legislation and with the principles of fairness, lawfulness, transparency and protection of confidentiality set out therein.
DATA CONTROLLER
The Data Controller is PiùMedical S.p.A.,
with registered office at VIALE LOMBARDIA, 62 – 21040 – CASTRONNO (VA) (Address)
which, for the processing of data for the purposes of the activities listed below, makes use of the cooperation of the External Data Processor FIDELITY SALUS SERVICE & CONSULTING SRL, with registered office at Via Giovanni Battista Pontani, 33 – 06128 – Perugia (PG).
METHODS OF PROCESSING
Data will be processed using electronic and/or paper-based tools, according to logic strictly related to the purposes indicated above and, in any case, by adopting procedures and measures suitable to safeguard their security and confidentiality.
PURPOSES OF PROCESSING
Data processing will be carried out for the purposes of performing the activities listed below:
a) issuance of the Loyalty Card and management of activities that cannot be carried out anonymously and are necessary to enable subscribers to use and receive discounts and promotions, the offering and sending of rewards, participation in points-collection initiatives and access to other ancillary services available through the Card;
b) performance, subject to your express written consent, of direct marketing activities, such as sending—also via email, SMS, MMS and apps—advertising material and communications with informational and/or promotional content relating to products or services provided and/or promoted by the Data Controller or, on behalf of the Data Controller, provided/promoted by the External Data Processor Fidelity Salus Service & Consulting srl, including gifts and free samples;
c) performance, subject to your express written consent, of individual or aggregated profiling activities and market research aimed, for example, at analyzing consumption habits and purchasing choices, preparing related statistics, or assessing the level of satisfaction with the products and services offered. Data processed for profiling or marketing purposes may be retained for a period not exceeding 36 months from the last transaction carried out, unless they are effectively transformed into anonymous form that does not allow the data subjects to be identified, even indirectly. In the event of withdrawal, deactivation due to non-use within a certain period of time, expiry or return of the card, a retention period for personal data must be defined for administrative purposes only (and not for profiling and marketing) not exceeding one quarter.
NATURE OF DATA PROVISION
For the purposes referred to in letter a) of the previous section, providing data is optional, but it is a necessary and essential condition for the issuance of the Loyalty Card: failure to provide the data therefore makes it impossible for the applicant to obtain the Card. For the purposes referred to in letters b) and c) of the previous section, providing data is optional and any refusal to provide such data and to give the related consent will make it impossible for the Data Controller to carry out the direct marketing and profiling activities described therein, but will not affect the applicant’s ability to obtain the Loyalty Card and access the related benefits.
SCOPE OF DATA DISCLOSURE
Data will be processed by personnel directly employed by the Data Controller and/or by natural or legal persons specifically identified by the Data Controller as internal and/or external processors or persons authorized to process the data. Your personal data will not be disseminated, i.e., it will not be made known to an indefinite number of persons; however, such data may be “disclosed” by the Data Controller to specific parties identified by the Data Controller, such as: – Pharmacy Consortia – Cooperatives, where the Data Controller is a member, – companies operating in the pharmaceutical sector, for the performance of instrumental and/or ancillary activities related to the management of the Loyalty Card.
Such data will be “disclosed” by the Data Controller to specific parties appointed as External Data Processors: Fidelity Salus Service & Consulting srl, for the performance of instrumental and/or ancillary activities related to the management of the Loyalty Card and for marketing activities, such as suppliers of services and products on behalf of the Data Controller.
Such data will be “disclosed” by the Data Controller to specific parties appointed as External Data Processors: pharmacies that are part of pharmacy networks, within the scope of the service offered to customers allowing the use of the loyalty card and the related benefits at the points of sale included in the Data Controller’s network.
The updated list of such parties may be consulted at the Pharmacy’s premises. Please note that, pursuant to Article 9 of EU Regulation 679/2016, personal data revealing racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade-union nature, as well as personal data revealing health status and sex life, and health-related data, are special categories of data. Such data, if voluntarily provided by you, will not be processed without your express written consent.
DATA SUBJECTS’ RIGHTS
Data subjects to whom the personal data relate, if they consent to the use of their data, may at any time exercise the rights granted to them vis-à-vis the Data Controller pursuant to Articles 12 to 23 of EU Regulation 2016/679. In particular, at any time they will have the right to object, in whole or in part, to the processing referred to in points b) and c) by sending an email to info@piumedical.it – garante.privacy@piumedical.it or by sending a fax to 0332893662.