This Privacy Policy is effective upon 14 October 2021.
SHUGA is concerned about protecting your personal data and respecting your privacy.
Here is how we do it:
Our duty and your privacy
This information concerns you if you are already a customer of ours, if you are registered on our site, if you have signed up to our newsletter, or if you are visiting our website.
About us
As regards the management of your data concerned with registering with the site and the sale of products, the data controllers are SHUGA, with registered Piazza Bernardino Luini 4
Lugano, Switzerland, which handle your data on the basis of specific agreements about whose essential contents we will gladly provide you with more information, should you require it.
As regards the management of your data regarding promotional and marketing activities, the data controller is SHUGA SA.
Our responsibility
If you are already a customer, you are registered with or are simply visiting the www.redfoal.com site, or you have signed up to our newsletter, we inform you that your data will be legitimately processed according to our decisions regarding the procedures and aims of that processing.
Your commitment
We would only ask you to read this policy carefully in order to be fully informed about how we process your personal data.
When and how we collect your personal data
As soon as you begin to interact with www.redfoal.com, we start to collect your data. It may be collected through a specific communication from you and also automatically during your use of the website.
This is how it is collected:
Data you provide us with Data we collect automatically
Your identification data X
Browsing the website X
Your telephone number X (only if provided by you spontaneously)
Use of SHUGA X X
Conclusion of purchase orders X X
Customer services X X (only the order number)
Marketing communications X (only following your explicit consent)
The kind of data we collect
Contact details
Your first name and surname, delivery and billing address, telephone number, email address;
Identification data
Your IP address, your login data, browser type and version, time zone setting, plug-in types, geopositioning information regarding your probable position, operating system and related versions, etc.
Data relating to the use of www.redfoal.com
Your browsing path through the website www.redfoal.com (Clickstream analysis), your displaying of products and services, load times and page responsiveness, download errors, browsing time, behavior and other actions, etc.
And what about sensitive data
We do not collect any sensitive data that could concern you (i.e. personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or sex life or sexual orientation).
What we collect your data for
We process your data only for specific purposes and, nevertheless, always when there is a legal basis that will enable us to do so. Here is why we process your data:
Use of the site and management of services
Your data is processed to allow registration on the Website, access to and supply of the services reserved to users registered on the Website and sending via the Website of a purchase order for the products available on the Website, with the consequent conclusion of the related contract of sale with including any administrative and accounting formalities. In this case, the legal basis is the contract and the legitimate interest.
Customer support
Communicating changes to our services, customer support via live chat, phone or email, including the correction of any bugs. In this case, the legal basis is the contract.
Marketing
Your data is processed in order to send advertising material and newsletters, to provide commercial information by telephone, SMS, email, and also using traditional methods (e.g. sending catalogs by post), about promotional and sales initiatives of SHUGA, to conduct market research and surveys on customer satisfaction. In this case, the legal basis is your consent.
Profiling
With the sole aim of offering things, as far as possible, in line with your interests, we will perform certain analyses on aggregate data but without conducting any profiling on your specific habits. In this case, the legal basis is a legitimate interest.
In any case there is absolutely no automatic decision-making process concerning you.
What we mean by legal basis
Consent
This is the authorization to process your personal data for a specific purpose.
You can change your mind whenever you like!
You can withdraw your consent at any time, by sending us an email to the following address: privacy@shuga.com.
If you decide to withdraw your consent and there are no other reasons that authorize us to process your personal data, we will stop processing it. Conversely, if another legal basis were to authorize us, we would continue to process your data, still in compliance with your rights.
Contract
Processing your data is essential for gathering information prior to a purchase and for the performance of the relevant contract.
Legitimate interest
The processing of your data is possible on the basis of our legitimate interests or those of third parties, provided that these do not predominate over your rights and your freedoms. Legitimate interests may concern:
How we process your data:
Data is processed mainly using electronic means, with the exception of product shipping operations which may also be performed using manual procedures.
Your choices and rights:
Your choices
Your rights
You can always exercise your rights by sending us an email to the following address: privacy@shuga.com
You have the right to access the information about you
This includes the right to ask us for further information about:
We will provide you with the information within one month of receiving your request, unless this adversely affects the rights and freedoms of other parties (e.g. the confidentiality of another person or intellectual property) or if there are legal obligations that prevent us from doing so. We will inform you if we are unable to meet your request for these reasons.
We might use your data to identify information that may potentially be relevant for you (for example, sending you customized e-mails based on your preferences that we have detected). Otherwise, we will use your information solely to provide you with our services.
We guarantee your rights even if we process your personal data on behalf of third parties
If we process your personal data on behalf of third parties, we guarantee that any requests made regarding the exercise of your rights will be provided to them without undue delay.
What level of security do we adopt in order to process your data?
We guarantee that your data is processed with the utmost security: we have, in fact, adopted physical, IT and organizational measures to ensure the protection of your data.
Nevertheless, we should remind you that:
You provide us with your data at your own risk. We do everything within our power but, unfortunately, as the way things stand, there is no 100% secure means of data transmission.
You need to keep your username and password safe at all times: you are the only one who knows them.
If you feel that you have suffered a data breach, we would ask you to contact us immediately at privacy@shuga.com person or intellectual property) or if there are legal obligations that prevent us from doing so. We will inform you if we are unable to meet your request for these reasons.
If we needed to transfer and/or store your personal data outside the EU, you will be properly informed of this. Also in this event, we will adopt all the appropriate measures to ensure maximum data protection.
How long will we keep your data for?
We will stop active processing of your data within 12 months from the last use of the service or the closure of your account unless there are legal obligations (e.g. sales invoices) that require us to keep your data for a longer period. As regards promotional activities targeted at you (which you may ask us to stop at any time), we will keep your data for a maximum of 24 months from the date you registered with the service.
Third parties who may process your data:
To run our online business we need to avail ourselves of third parties that host the applications, communicate with our customers, manage emails, etc. Please be assured that this kind of collaboration is provided by the best players in the market providing this kind of service. We share your data with them only when this is necessary to ensure the maximum functionality of our services and in compliance with the security measures and best practices described in this Privacy Policy.
For further information, contact us at this address privacy@shuga.com