PRIVACY POLICY – ACCORDING TO THE EU REGULATION NO 2016/679 (THE “REGULATION”)

1. SAHIN UMIT BENAN with offices in Milan, Via Morimondo n. 23, is the Data Controller in charge of the processing of your personal data through its website www.umitbenan.com (“Website”). Please note that SAHIN UMIT BENAN will process your data in compliance with the Regulations in force and pursuant to what is reported hereinafter.

This privacy policy describes how the personal data of users who access the Site and use the related services offered by the Site are processed, whether registered or not, including the registration of their account, the purchase of products online and other services made available by SAHIN UMIT BENAN. This policy applies exclusively to the processing of personal data carried out through the Site; any third party websites that can be consulted through links remain subject to the privacy policy provided by the operator of the relevant third party website. We therefore invite you to read these documents before surfing the third party sites. The services on this Site are intended for people aged 18 years or older. SAHIN UMIT BENAN does not freely request, collect, use or disclose personal information provided by persons under the age of 18. If SAHIN UMIT BENAN learns that it has collected data from a minor, it will delete it. If you are under the required age, please do not register or purchase a product online and ask an adult (your parents or guardian) to carry out the necessary procedures.

The personal data is collected and processed with automated means, and with the aid of electronic and information media, according to the principles of necessity, lawfulness, correctness, proportionality and transparency, for the purposes and according to the conditions of lawfulness (so-called legal basis) indicated hereinafter.

The personal information requested to the Customer during the processing of the order, useful to the order fulfillment process, are collected and processed by SAHIN UMIT BENAN through electronic means, in order to make operational all obligations arising from the conclusion of the contract. The personal data will not be disclosed to third parties under any circumstances and for any reason. SAHIN UMIT BENAN guarantees the privacy of its Customers while respecting the legislation regarding processing of personal data: Privacy Act governed by Legislative Decree no. 30 June 2003 n. 196 and EU Regulation no 2016/679.

2. Data controller is: SAHIN UMIT BENAN, the person in charge of the data collected: SAHIN UMIT BENAN via Morimondo n. 23 – 20143 Milano (MI) ITALY. The Data Protection Officer or DPO is available at the following email address: DPO@umitbenan.com it or by sending a registered letter to the following address: via Morimondo n. 23 – 20143 Milano.

3. Automatically-collect personal data (Browsing data): in the course of their normal operation, the IT systems and software procedures designated to the website’s operations acquire some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to associate it with identified interested parties, but, due to its nature, could allow users to be identified, through processing and association with data held by third parties. This data category includes IP addresses or the domain names of computers used by users connecting to the site, the URIs (Uniform Resource Identifiers) of the resources requested, the time of the request, the method used to submit the request to the server, the size of the response file obtained, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters related to the operating system and the user’s IT environment.

4. Personal data provided directly by you (for example: name, surname); contact details (such as email address, address, telephone number and mobile phone number); account name and password; payment details; shipping address and billing address; purchase data (date, quantity and type, product code, sales amount, VAT number where applicable, information on complaints, returns, warranty and refunds and other information relating to the sale of products on the Site), provided during registration on the Site or during the use of certain services, such as the purchase of products online. Although the registration on the Site allows you to enjoy an easier browsing and purchasing experience, any online purchases may be made even without registration.

5. Selling goods and services online: The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery. The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of data collected by this Site depends on the payment system used. Payment processing services enable this Site to process payments by credit card, bank transfer or other means. To ensure greater security, this Site shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.

6. Your rights. As interested party, pursuant to articles 15 et seq. of the Regulations you have the right to:

– get confirmation of the existence of your personal data, access their content and get a copy (right of access);

– update, amend and/or correct your personal data (right to rectification);

– request the cancellation or restriction of data processing in the cases provided for by the Regulation, including where data have been processed in violation of the law or storage is not necessary for the purposes for which the data were collected or otherwise processed (right to erasure and right to restriction);

– withdraw consent, where given, at any time, without prejudice to the lawfulness of the processing based on consent given before withdrawal (right to withdraw consent);

– within the limits of what is provided for by the Regulation, get a copy of the data you provided in a structured, commonly used, machine- readable format and request this data to be transmitted to another data controller where technically feasible (right to data portability);

– You also have the right to object to the processing of your data, at any time, for the purpose of direct marketing, including profiling connected to direct marketing and in the event that the processing is founded on legitimate interest (right to object).

You may exercise your right at any time by writing to the following email address: sales@umitbenan.com or by sending a registered letter to the following address: SAHIN UMIT BENAN via Morimondo n. 23 – 20143 Milano (MI) ITALY. When contacting us, you must include your name, email address, postal address and/or telephone number if provided in order to process your request correctly. We remind you that requests for the cancellation of data are subject to current legal and regulatory obligations regarding the retention of documents. SAHIN UMIT BENAN may require you to prove your identity and provide you with information regarding the action taken on a request within one month of receiving the request. In accordance with the Regulation, this deadline may be extended by two months, if necessary, taking into account the complexity and number of requests, in which case SAHIN UMIT BENAN will inform you of this extension, and the reasons for the delay, within one month of receipt of the request.  You also have right to lodge a complaint with a Supervisory Authority for Data Protection at any time in the event of a breach of data protection regulations. For further information:  https://www.garanteprivacy.it/home_en/rights#how

7. The customer’s personal data will not be used nor SAHIN UMIT BENAN nor by third parties for sending promotional material, unless the customer has given consent, through check of the item at the time of registration. Where strictly necessary, your personal data may also be disclosed to independent thirdparty data controllers, such as the competent Authorities (for example, in the event of card theft being reported or dispute management), a notary and the chamber of commerce (in the event of entering prize draws) or legal, fiscal or administrative consultancy firms (if the communication is necessary or functional to the correct fulfilment of the contractual obligations referred to in the services offered by the Site, including the purchase contract, as well as obligations deriving from the law or in the case of assessment, exercise or defence of a right), to the acquirer (in order to allow the payment of purchases), to the provider of fraud prevention services (in order to carry out an analysis of the order to identify any fraudulent transactions), to shippers and companies that deal with logistic support and that manage the collection points for the products purchased on the Site.

8. Personal data storage: SAHIN UMIT BENAN stores your personal data for the time period strictly necessary in compliance with civil and tax obligations on data storage and the limits provided for by the law. The data processed to fulfil any contractual obligations with you may be stored for the whole duration of the contract, plus another 10 years after the end of the fiscal year in question, in order to deal with any tax-related audits and/or disputes. In the event of disputes: if we must defend ourselves or act or make claims against you or third parties, we may store personal data whose processing we consider reasonably necessary to these ends, for the time in which the claim may be pursued.

Rules Applied

9. The sales contract between SAHIN UMIT BENAN and the Customer is concluded in Italy and is therefore subject to the Italian Law regulations. For the solution of civil and criminal litigation arising from the conclusion of this sale contract and if the customer is an individual consumer, the territorial jurisdiction is related to his town of residence; for all other cases, the local jurisdiction is the Court of Milan (Italy).

10. SAHIN UMIT BENAN has the right to change the contract terms without notice and will be valid from the date of publication of Umitbenan.com.

11. This Policy may be updated over time also in consideration of changes in laws or regulations regarding the protection of personal data and, in this case, we will inform you. The changes and updates will apply from the moment they are published on the Website (in case of changes for which the applicable legislation requires the collection of consent, you will be allowed to express your choice freely). We therefore invite you to periodically consult this page to check the most up-to-date version of the Website’s Policy.

Cookie Law

Umitbenan.com uses cookies to deliver services that improve the experience of the user’s navigation.

Cookies are short text files sent from a website to the user’s web browser. Every time the page is visited again, cookies are re-sent to the site that originated them (first-party cookies) or to another website that recognises them (third-party cookies). Cookies are useful, because they allow websites to identify the user’s device, and have several functionalities, such as allowing the visitor to surf efficiently through pages, remembering favourite websites and improving the web browsing experience. They also contribute to guaranteeing that the advertising material is better targeted and more in line with user’s interests (targeting cookies). Cookies can last for just one session and get automatically disabled when the user close the browser; they can also have an expiration date and, until then, they remain active in the user’s device, collecting data session after session.

How we use cookies:

• We use anonymous browser cookie, you need to allow users to navigate correctly on Umitbenan.com, use the full functionality and access to secure areas.

• We use analytical cookies to better understand how our users use the web site, to optimize and improve the site, making it more interesting and relevant for users.

This information is anonymous and used for statistical purposes only.

We use cookies for anonymous trade show our advertisements on other websites, based on the products that you have displayed in previous voyages. These cookies are usually inserted by trusted third parties (such as Google through remarketing to display advertising), however, Umitbenan.com not permit these companies to collect personal information about users. This means you will be guaranteed anonymity and personal data will not be used by other websites or marketing database.

By default, browsers accept cookies from SAHIN UMIT BENAN and third-party websites. On the first visit on UMITBENAN.COM, the user can accept or decline the cookies, as per banner. At any time, the user can manage the preference: if you wish to restrict or block browser cookies from our website or third party cookies, you can do this through your browser settings. You can change the settings and choose to accept all cookies, the pop-up window requires your explicit acceptance, or refuse all cookies indiscriminately. However, by doing so, you might lose some functions of the website. In order to allow the website to function correctly, to enjoy all the features and to enhance the overall user experience, we strongly recommend you accept the use of cookies from our page and third parties.

How to change or disable your cookie preferences:

• Capable browser settings (Internet Explorer, Safari, Firefox, Chrome etc ..) you can determine which cookies you want to receive and which not. To know where you can find these settings, use the “Help” button on your browser.

• Visitors can opt out of Google Analytics to display advertising and customize the ads on the Google Display Network using the Ads Preferences Manager.

Latest update: October 2022