Privacy Policy

PRIVACY AND SECURITY – Regulation (EU) 2016/679

This Privacy Policy is based on several legal systems, including Articles 13 and 14 of Regulation (EU) 2016/679, also known as GDPR (General Data Protection Regulation).

Unless otherwise stated, this Privacy Policy applies solely to this Application.

In accordance with Regulation (EU) 2016/679 on measures to protect individuals and legal persons with regard to the processing of personal data, all personal data collected at the time of ordering will be used in accordance with applicable data protection laws and only for the purpose of providing the purchased products, commercial support to the customer and to fulfil regulatory, administrative, operational and accounting obligations.

P. Iva 16806791006
Tel. 06/69797080

The data will not be disclosed to third parties, with the exception of the transport companies in charge of the delivery, nor will they be disclosed in any way to third parties.


Personal data may be provided voluntarily by the user or collected automatically when using this application.
Unless otherwise specified, all data required by this application is mandatory. If the user refuses to provide the data, this application may not be able to provide the service. In cases where this application identifies certain data as optional, the user is free not to provide this data without affecting the availability of the service or its operation.

Users who have doubts about which data is mandatory are encouraged to contact the owner.

Any use of cookies or other tracking tools by this application or by the third party services used by this application, unless otherwise specified, has the purpose of providing the service requested by the customer, apart from the other purposes described in this file in the Cookie Use section.

Users are responsible for all third party personal data obtained, published or disclosed through this Application and guarantee that they have the right to do so, releasing the Administrator from any responsibility towards third parties.

The transmission of the requested, collected and used data is possible only with the consent of the customer and is necessary for the delivery of the goods, otherwise I CIRCLE SRL would not be able to fulfil pre-contractual, contractual, regulatory and tax obligations.

The transmission of these data is absolutely voluntary, any refusal will have no consequences, apart that the conclusion of the commercial contract is impossible.


Personal data collected independently or with the express consent of the user include cookies and usage data that may be voluntarily accepted by the user or automatically collected during the use of this application.

Any use of cookies or other tracking tools by this application or by the third party services used by this application aims to identify the user and record the associated preferences for purposes related solely to the provision of the service requested by the user.

The user can disable cookies in his browser. However, the non-provision of some personal data may impede this application from providing its services.

The processing of data will be carried out ensuring its confidentiality and security, and may also be carried out on paper and/or by automated means suitable for storing, managing and transmitting the data.


The Holder shall take appropriate security measures to prevent the loss of data, illegal or improper use and unauthorized access.

The processing of the data is carried out with the help of computers and/or IT tools, using organizational procedures and work methods that are closely consistent with the stated objectives.


In addition to the Controller, in some cases other parties involved in the organization of this application (administrative, commercial, marketing, legal, system administrators) or external parties (such as technical service providers, carriers, hosting providers, IT companies, communication companies) may have access to the data that may be used by the Controller as data processor. The controller may be requested at any time to provide an up-to-date list of processors.


The data will be used in the business premises of the Holder and in other places where the parties involved in the data processing operate.

The personal data may be transferred to another country where the user is located. To obtain information about the place where the User’s data is processed, the User may refer to the section on processing of personal data.

The user has the right to obtain information on the legal basis for the transfer of data outside the European Union or to an international organization governed by international law or consisting of two or more countries, such as UN, as well as on the security measures taken by the controller to protect the data.

The User may verify whether such transfers have taken place by referring to the section in this document on the details of the processing of personal data, or may request information from the Company by contacting it directly.


The data will be kept for as long as necessary to fulfil the purposes for which they were collected.


Personal data collected for the purpose of fulfilling a contract between the owner and the user will be stored until the complete fulfilment of this contract;

Personal data collected for the legitimate interest of the owner may be kept until this legitimate interest is fulfilled;

The User may read further information in the sections of this Policy that relate to the legitimate interest of the Controller or contact the Controller using the contact details;

If the processing is based on the consent of the user, the controller may keep the personal data longer until the consent is revoked. In addition, the controller may be obliged to store personal data for a longer period of time due to a legal obligation or an official order;

After expiration of the retention period, the personal data will be deleted. Thereafter, it is no longer possible to exercise the right of access, erasure, processing and portability of the personal data.


Regulation (EU) 2016/679 provides citizens with specific rights. In particular, the data subject can obtain from the data controller information about the data concerning him or her; obtain the cancellation or blocking of the data in violation of the law, the updating, the correction or the integration, to oppose the processing for commercial purposes, advertising or market research. The interested party may also request to know the origin of the data as well as the logic on which the treatment is based and oppose the treatment itself for legitimate reasons.

I CIRCLE SRL also informs that further information regarding the processing and communication of personal data may be requested by writing to the data controller.

In particular, the User has the right to:

Withdraw the consent at any time. The User may revoke her/his consent to Personal Data processing as previously expressed.

The right to objection: the User has the right to object to the processing of his Data when it occurs on a legal basis different than consent and may also oppose the processing of Personal Data for profiling or automated processing purposes.

Access your Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.

Verify and request correction. The user can check the accuracy of his data and request its update or correction.

Request the restriction of processing. The user may request the restriction of processing if certain conditions are met. In this case, the controller will not process the data for any purpose other than storage.

Requesting the erasure or removal of your personal data. The user may request the controller to delete his/her data if certain conditions are met.

To receive data or to transfer it to another controller. The data subject has the right to receive the personal data concerning him or her in a structured, commonly used and technically feasible form, and has the right to transfer this data to another controller. This provision applies when the data is processed using automated procedures and the processing is based on the user’s consent, on a contract to which the user is a party, or on related contractual measures.

Filing a Complaint. The User may file a complaint by contacting the authority responsible for the protection of personal data or by initiating legal proceedings.


When personal data are processed in the public interest, users may object to such processing in the exercise of official authority vested in the owner or in view of the legitimate interests pursued by the owner by providing a basis for their particular situation to justify the objection.

Please note that users may object to the processing without giving reasons if their data is processed for purposes that fall under those mentioned in this document and may be considered as direct marketing. To find out if personal data is processed for direct marketing purposes, please refer to the relevant sections in this policy.


To obtain complete information, users may send a request to the contact details of the data controller indicated in this document. Requests will be deposited free of charge and processed by the data controller as soon as possible, and in any case within one month.


This application can send push notifications to the user.


Legal defence
Personal information may be used by the Company in legal matters or during the preliminary stages of defence strategy in the event that misuse of this application or related services by the user is alleged. The user declares to be aware that the owner may be obliged to disclose the data by order of the authorities.


At the user’s request, this application may provide additional information about specific services, data collection and processing in addition to this privacy policy.


For operational and maintenance purposes, this application and any third-party services may collect files that record interaction with this application (system logs), or use other personal data (such as IP address) for this purpose.


For more information about the processing of personal data, please contact the Data Controller at any time using the contact details provided.


“Do Not Track” requests are not supported by this application.

For a detailed explanation of the other tools used, please refer to their Privacy Policy.


The controller reserves the right to amend this Privacy Policy at any time by notifying users on this page and, where possible, on this application. Where technically and legally possible, amendments could be notified to the Users throughout the contact details provided. Therefore, please check this page regularly for its most current version.

If the changes concern treatments for which consent is the legal basis, the holder will, if necessary, obtain the user’s consent again.

Last update: 23 March 2023

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