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Introduction

Pursuant to Article 13 of Regulation (EU) 2016/679 (hereinafter also "GDPR"), Ridewill s.r.l., as the data controller (hereinafter also referred to as the "controller" or "Ridewill"), informs data subjects about the use of their personal data in relation to the requests sent by customers in the "Contact" section of the company website, concerning general/technical information, purchase requests, product/service returns or right of withdrawal requests for products/services offered by Ridewill.

1. Data Controller and Data Protection Officer (DPO)

Pursuant to Article 4(7) of the GDPR, the data controller is Ridewill, headquartered at Via Socrate 6, 22070 Casnate con Bernate (CO), Italy. Tel.: +39.031.5476941, Email: info@ridewill.it PEC: ridewill@pec.it

Ridewill’s Data Protection Officer (DPO) can be contacted via email at dpo@trustds.it or PEC: dpotrustds@legalmail.it

2. Purpose of Processing, Processed Personal Data, Legal Basis, Data Retention Period and Nature of Provision

Purpose A): Management of general information requests received from customers or potential customers (option "Other/General Information" in the contact form)

• Processed personal data: First and last name, email address, phone/mobile number (optional), message content, and any documents attached to the request;
• Legal basis for processing: Personal data are processed based on the freely given and explicit consent of the data subject (Art. 6(1)(a) GDPR);
• Data retention period: The controller may retain the data for the time necessary to send the requested information, without prejudice to any further retention period resulting from subsequent contractual relationships with Ridewill;
• Nature of provision: Providing the requested data is optional, but failure to do so prevents the controller from responding to the data subject’s request.

Purpose B): Management of account deletion requests submitted by registered customers on Ridewill’s website (option "Other/Account Deletion Request" in the contact form)

• Processed personal data: First and last name, email address, phone/mobile number (optional), message content, and any documents attached to the request;
• Legal basis for processing: Personal data are processed to comply with a legal obligation (Art. 6(1)(c) GDPR), given the data subject’s right to request account deletion (Art. 17 GDPR). The phone number is processed based on the data subject’s consent, which can be withdrawn at any time;
• Data retention period: The controller may retain the data for the time necessary to fulfill the data subject’s request, without prejudice to any further retention period required by law;
• Nature of provision: Providing the requested data is mandatory in order to proceed with account deletion.

Purpose C): Management of technical information requests submitted by customers/potential customers regarding Ridewill’s products and services (applicable to the "Technical Info" option in the contact form)

• Processed personal data: First and last name, email address, phone/mobile number (optional), message content, and any documents attached to the request;
• Legal basis for processing: Personal data are processed for the execution of pre-contractual measures (Art. 6(1)(b) GDPR), where the request aims to evaluate the purchase of a product/service offered by Ridewill. The phone/mobile number is processed based on the data subject’s consent, which can be withdrawn at any time;
• Data retention period: The controller may retain the data for the time necessary to fulfill the data subject’s request, without prejudice to any additional retention period resulting from contractual relationships established with Ridewill;
• Nature of provision: Providing the requested data is mandatory in order to send the requested technical information.

Purpose D): Management of requests submitted by customers regarding purchase orders made on Ridewill’s website (applicable to the "Orders" section of the contact form)

• Processed personal data: First and last name, email address, phone/mobile number (optional), message content, and any documents attached to the request;
• Legal basis for processing: Personal data are processed for the performance of a contract (Art. 6(1)(b) GDPR), following a purchase order placed by the customer. The phone/mobile number is processed based on the data subject’s consent, which can be withdrawn at any time;
• Data retention period: The controller may retain the data for the time necessary to fulfill the data subject’s request, without prejudice to any further retention period required by law;
• Nature of provision: Providing the requested data is mandatory in order to manage the data subject’s requests.

Purpose E): Management of product return requests submitted by customers due to defects in purchased products ("Faulty Product?" option)

• Processed personal data: First and last name, email address, phone/mobile number (optional), message content, and any documents attached to the request;
• Legal basis for processing: Personal data are processed for the performance of a contract (Art. 6(1)(b) GDPR), following the purchase order placed by the customer. The phone/mobile number is processed based on the data subject’s consent, which can be withdrawn at any time;
• Data retention period: The controller retains the data for the time necessary to handle the return request, without prejudice to any additional retention period required by law;
• Nature of provision: Providing the requested data is mandatory in order to perform the purchase contract following the order placed by the data subject.

Purpose F): Management of withdrawal requests ("Easy Return/Withdrawal" option) submitted by customers pursuant to the Italian Consumer Code (Legislative Decree No. 206/2005).

• Processed personal data: First and last name, email address, phone/mobile number (optional), message content, and any documents attached to the request;
• Legal basis for processing: Personal data are processed for the performance of a contract (Art. 6(1)(b) GDPR) and to comply with a legal obligation (Art. 6(1)(c) GDPR), pursuant to Articles 52 et seq. of Legislative Decree No. 206/2005 (consumer right of withdrawal). The phone/mobile number is processed based on the data subject’s consent, which can be withdrawn at any time;
• Data retention period: The controller may retain the data for the time necessary to handle the withdrawal request, without prejudice to any additional retention period required by law;
• Nature of provision: Providing the requested data is mandatory in order to execute the withdrawal process.

3. Processing Methods and Data Recipients

Personal data collected are processed in the context of handling the above-mentioned requests and in compliance with the principles set out in Article 5 of the GDPR.

Processing is carried out by individuals authorized by the controller for the purposes indicated. Authorized persons are bound by professional confidentiality. Personal data may also be processed with the collaboration of other parties appointed as data processors, who carry out processing in accordance with the purposes and means determined by the controller pursuant to Article 28 of the GDPR. Further information may be requested from the controller.

Processing is carried out in compliance with fundamental rights and freedoms and in accordance with the principles of Article 5 of the GDPR, primarily the principles of fairness, lawfulness, and transparency. The controller ensures the relevance and proportionality of the information processed in relation to the purposes pursued.

4. Data Transfer Outside the European Economic Area (EEA)

Personal data processed for the above purposes are generally not transferred to third countries outside the European Union or the European Economic Area (EEA), nor to international organizations. Should data be transferred outside the EEA, the controller undertakes to comply with the provisions of Chapter V of the Regulation to ensure adequate data protection.

Further information may be requested from the controller and/or the DPO.

5. Data Subjects’ Rights

Data subjects—meaning natural persons whose data are processed—may exercise the rights set out in Articles 15 et seq. of the GDPR, including the right to access their personal data, request rectification, restriction, or erasure where applicable, as well as the right to object to processing and the right to data portability. Where the legal basis for processing is consent, data subjects also have the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise their rights, data subjects may contact the controller or the data protection officer using the contact details provided in this notice.

If data subjects believe that the processing of their personal data by the controller violates the GDPR, they have the right to lodge a complaint with a supervisory authority in the Member State where they habitually reside or work, or where the alleged violation occurred (Art. 77 GDPR). The Italian supervisory authority is the Garante per la protezione dei dati personali, whose contact details are available on its website (www.garanteprivacy.it).

Pursuant to Article 79 of the GDPR, data subjects have the right to an effective judicial remedy if they believe that their rights have been violated as a result of processing.

6. Changes to This Privacy Notice

The controller may modify, add, or remove any part of this privacy notice. To facilitate verification of possible changes, the notice includes the date of the latest update.