Welcome to our Privacy Policy. Here we will explain what kind of personal data we collect about you, how we use it and what your rights are as a data subject. This Privacy Policy applies to you if you are:

• Our customer or a potential customer
• Visitor to our website
• A representative or contact person of our corporate customer or business partner

Phonebuddy.it is the data controller of the data described in this Privacy Policy. In the event that Phonebuddy.it acts as a data processor for its clients or partners, you should refer to the privacy policies of those entities for information on the collection and processing of your personal data.

Please also note that the Phonebuddy.it website may contain links to other websites. Our Privacy Policy applies only to our website, so if you click on a link to another website, you should be aware of that website's privacy policy.

To make it easier for you to find the information you need, we have divided the information provided into the following topics, which we hope will help you navigate this information:

• What data is collected and for what purposes?

• Cookies

• Marketing

• Disclosure of data

• How long do we keep your data and how do we keep it safe?

• What are your data protection rights?

• Changes to our privacy policy

• Contact information

What data is collected and for what purposes?

This section explains what personal data Phonebuddy.it collects about you, for what purposes, how it is collected and the legal basis. Please note that more than one of the categories below may apply to you (for example, if you are a customer of ours and use our website, you should read all the relevant paragraphs).

If you are a Phonebuddy.it customer, we collect the following information about you:

• Name and surname
• Contact information
• Your bank account details if you sell us your device
• Other transaction details, such as product type
• Your payment information
• Communicating with us

This information is provided by you when you transact with us, such as by completing our online form, or when you otherwise communicate with us. We use the information to process your transaction, provide customer service, communicate with you about your transaction, and administer your account in relation to your customers. We may also use the information for advertising purposes, subject to legal requirements, and you can always opt out of marketing communications at any time by unsubscribing. We may also conduct customer surveys, using the information above to contact you and collect additional information about your customer experience, preferences, and other feedback.

Please note that when you make a payment or payment subscription on our website, the transaction and payment details will be passed to our payment service partner who provides the payment facility. Similarly, we will share your order details with our logistics partner to make the delivery or, alternatively, to arrange collection of the product from you. If you choose a deferred payment option and therefore apply for credit, our payment service providers may carry out credit checks to ensure your creditworthiness. For more information about their data processing activities, please consult the privacy policy of the relevant partner.

The legal basis for the collection and processing of the above data is the performance of the contract between you and us and, to the extent that they are used for marketing or customer survey purposes, our legitimate interest in advertising our products and services and developing our business. If you subscribe to our newsletter in connection with a transaction with us, the legal basis for the processing of your data is your consent, which you can withdraw by unsubscribing from our newsletter. For more information about our marketing practices, see the section “Marketing”.

If we are subject to a legal obligation to do so, or if it is necessary for fraud prevention activities carried out in our legitimate interests, we may also collect additional identifying information from you, such as a copy of your ID or identification number. In addition, we and our payment service partners may use fraud prevention technologies to ensure that we are conducting a legitimate transaction with you and to block any attempted purchases, for example with stolen identity or payment information. When we do this, we rely on our legitimate interest in preventing fraud and criminal behavior in our business, and the data collected from you may be matched against public information or databases to infer the level of fraud risk in the specific case.

If you consent to our marketing or otherwise submit your data to us: If you consent to our marketing (for example, if you sign up to our newsletter), we collect your contact details and information about the status of your consent. The legal basis for collecting and processing this data is your consent, and it is used to provide you with our marketing communications, which you can opt out of at any time by unsubscribing following the instructions in the marketing messages or by contacting us. We may also run different types of campaigns or competitions from time to time, where you may provide us with your contact details and any other information relevant to the specific campaign in relation to your participation. The legal basis for collecting and processing this data is the entering into and performance of the contract relating to the campaign, and the data is used for the purposes of carrying out the campaign or competition activities and contacting you in relation to your participation.

When you visit our website, your device automatically sends us certain technical and other information (for example, your IP address, browser and device details and the source of your visit). The information is used to provide you with the website and the services included therein; the legal basis is our legitimate interest or the entering into and performance of a contract between you and us, depending on the situation. We may also collect information about your use of the website by using cookies. For information about the data collected through cookies and similar technologies, see the “Cookies” section below.

If you are a representative or contact person of one of our corporate clients or business partners, or an individual entrepreneur working with us, we collect the following information about you:

• Name and contact details, and, if you are an individual entrepreneur, the data necessary to identify you as our contractual counterpart
• Location and other information about your relationship with our customer/business partner
• Any details about our interactions and your preferences

This information is provided directly by you when you communicate with us or, if you are not in direct contact with us, we receive the data from your organization and other representatives with whom we communicate. We use this information to manage our relationship and perform the contract with the corporate customer / our business partners and to communicate in relation to this. The legal basis for the data processing is our legitimate interest in relation to the management of the contractual relationship and cooperation with the customer or business partner, and also, if you are a natural person who is our contractual counterparty, the performance of the agreement between us.

If we are required to report transactions related to our cooperation to the tax authorities, we may also need to collect your personal tax code; the basis for collecting and processing this data is compliance with a legal obligation to which we are subject.

Cookies

Cookies are pieces of data that websites store on your browser or device when you visit them. When cookies are enabled, they collect certain personal data about you through your device and browser. The cookies we use may collect the following information:

• IP address
• Browser type, version and session identifiers
• Device type and operating system
• URL path on website, time spent and actions on website
• Time of visit and location at city level

The amount of information listed above that is collected depends on the type of cookie activated. You can choose not to allow the types of cookies that are not strictly necessary for the operation of our website through the cookie banner that is requested when you land on our website. You can also use your browser settings to delete cookies that have already been set at any time.

We use cookies for the following purposes:

• ensure the functioning of our website (“strictly necessary cookies”)
• provide greater functionality and personalisation of our website (“functional cookies”)
• To provide personalized advertising to the user (“advertising cookies”)
• Measuring, analyzing and improving the performance of our website (“performance cookies”)

The legal basis for collecting personal data through cookies is, for strictly necessary cookies, our legitimate interest or the entering into and performance of a contract between you and us, depending on the situation, and for other cookies, the consent you have given us (if you have chosen) by clicking accept for the chosen cookies on our cookie banner.

For more detailed information on the cookies currently in use on our website, please see the list of cookies at the bottom of this page.

Marketing

As previously stated, we may use some of your personal data to provide you with advertising. In this section, we explain more about our marketing activities and practices.

If you have given us your consent for marketing, for example by signing up to our newsletter, or if we are legally entitled to contact you based on our legitimate interest, we may send you communications and advertising about our products and services, offers and campaigns, or other relevant news about Phonebuddy or its partners’ activities. We may send you these communications by email or SMS, depending on the contact details you have provided. As stated above, you always have the right to unsubscribe from these communications by following the unsubscribe instructions provided in each marketing communication or message. To unsubscribe, you can also contact us using the contact details listed below.

Disclosure of data

We share personal data within the Phonebuddy group of companies for the purposes set out above. Additionally, to fulfill some of the purposes described in this notice, we may share some of your personal data with our service providers or business partners, such as parties who provide services for us or perform actions on our behalf to provide the services or enable the transaction with you, such as our logistics and payment service partners, our IT service providers, consultants, or our partners who participate in your customer journey through our collaboration (such as our trade-in or drop-off partners). If you have consented to third-party cookies, or signed up for our newsletters or marketing activities, we may share your personal data with these third-party cookie providers and our marketing partners who perform the processing purpose for us.

We may also disclose personal data to parties outside of Phonebuddy if:

• It is required by law, for example where we need to disclose personal data to respond to a request made by a public authority or law enforcement agency.
• Disclosure of your personal data is necessary to ensure the safety and protect the rights of Phonebuddy, our partners, our customers or you, or for purposes of public interest in accordance with the law.
• If we are involved in a merger, acquisition, or any form of sale of all or some of our assets, we may share and/or transfer your personal data in connection with the evaluation of and participation in such transactions.
• In any other situation where we have obtained your consent to such transfer.

Because some of our service providers and partners are located outside the European Economic Area, we may need to transfer personal data outside the European Economic Area to carry out our operations. Such transfers are made in accordance with the requirements of applicable laws and following applicable transfer safeguards, such as on the basis of adequacy decisions on the level of data protection adopted by the European Commission, or by using standard contractual clauses approved by the European Commission.

How long do we keep your data and how do we keep it safe?

As a rule, personal data is retained until it is no longer necessary for the purposes described above. Retention periods may be longer if we are legally obliged to retain, for example under accounting laws, certain types of data in accordance with statutory retention periods. In addition, if we need to retain information longer for our legitimate interest in protecting our legal rights, we will retain the information necessary for this purpose according to the statute of limitations or, if applicable, until the complaint or complaints in question have been finally resolved.

We apply technical and organizational measures to ensure the security of your personal data. We have implemented physical, administrative and technical security measures to ensure the security of the processing of your personal data and their confidentiality. Your data can only be accessed by people who need it in relation to their work.

What are your data protection rights?

In accordance with and within the limits of applicable legislation, you have the following rights:

Right to access your personal data – You have the right to know if we are processing your personal data and to access that data.

Right to rectification of personal data – If you believe that your personal data is inaccurate or incomplete, you can request its rectification.

Right to be forgotten – You have the right to request the deletion of your personal data, to the extent permitted by law.

Right to restrict processing – In certain situations, you have the right to request that we restrict the processing of your personal data.

Right to object to processing – In certain situations, you have the right to object to the processing of your personal data.

Right to withdraw consent – ​​Where you have given your consent to the processing of your personal data, you have the right to withdraw it at any time.

Right to portability of personal data – Where applicable by law, you have the right to have the personal data you have provided to us returned to you in a commonly used and machine-readable format or, where technically feasible, to transfer it to a third party.

If you wish to exercise any of these rights, please contact us using the contact information provided at the end of this Privacy Policy. Please note that some of these rights are not absolute and certain limitations may apply to their exercise.

Changes to Phonebuddy's Privacy Policy

We may update this Privacy Policy due to changes in our processing operations or applicable law. If we do so, we will make the updated Privacy Policy available on our website.

Contact information

If you have any questions about this Privacy Policy, the personal data we hold about you, or if you wish to exercise any of your data protection rights, please contact us.

Contact information of the data controller:

Name: ITP TRADING SRL

Company ID: 09927411216

Registered office: Via Fedro 4 - 80122 Naples

Headquarters: via Antiniana 155 - 80078 Pozzuoli

Phone number: +39 081 2785809

Email address: info@phonebuddy.it

Website: www.phonebuddy.it

If you wish to make a complaint or if you feel that Phonebuddy has not addressed your concern satisfactorily, you can contact the competent local supervisory authority in the country where you are located or the supervisory authority where we are based, the Finnish Data Protection Authority.