PROTECTING YOUR PRIVACY IS A COMMITMENT FOR LIMONTA. THIS PRIVACY POLICY IS PROVIDED TO YOU IN ORDER TO COMPLY BOTH TO U.S. AND EUROPEAN DATA PROTECTION LAWS.

INFORMATION PROVIDED TO COMPLY WITH U.S. LAWS
This Privacy Policy (the “Policy”) describes how we collect, use, and share your Personal Information (as defined below) in the USA, provided by you through https://us.societylimonta.com/ (“website”) and your rights regarding the Personal Information we collect. This policy is limited to the Personal Information processed on the website.

By visiting our website, submitting information and/or purchasing any products, you agree to let us collect and use your personal information as described in this Policy. Therefore, before you provide us with any Personal Information, you should read through this Policy in its entirety and understand its terms. We may update the Policy from time to time, so please check it occasionally.

This Policy describes:
• Personal Information We Collect;
• How We Collect Your Personal Information;
• How We Use Your Personal Information;
• How We Share Your Personal Information With Third Parties;
• How We Protect Your Personal Information;
• Ability to Access, Update and Correct Personal Information;
• California Privacy Rights;
• Changes to the Policy;
• Questions About This Policy.


Personal information we collect
Limonta collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or a household (“Personal Information”). Limonta also collects non-Personal Information that cannot be linked or associated with any individual person or household. When non-Personal Information is combined with other information so that it does identify an individual person, we treat that combination as Personal Information. We may collect, use, store and transfer different kinds of Personal Information about you, which we have grouped together as follows:

Identifiers such as your first name, last name, alias, username or similar unique personal identifier, account name, online identifier, and/or date of birth.
Contact Information such as your billing address, delivery address, email address, and telephone numbers.
Financial Information such as credit or debit card information, payment details, or other payment information.
Profile Data such as username, password, job title, details about the products you have purchased, payments you have made, and/or other details of products and services you have purchased from us in the past, purchase or product preferences, and personal interests.
Technical Information such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website and other Limonta platforms.
Usage Data includes information about how you use the Website, such as statistics regarding the opening and clicking on emails sent by Limonta, and activity on the Website (pages viewed, products seen, etc.).
Marketing and Communications Information such as marketing campaign data, click-throughs, your preferences and consent in receiving marketing from us and our third parties, email and text communications, and your communication preferences.
Inference Data including inferences drawn from the Personal Information identified above.

If You Do Not Provide Personal Information. Where we need to collect Personal Information by law, or under the terms of a contract we have with you, and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Information You Provide To A Third Party. The website may include links, plug-ins to websites operated by third parties such as Facebook, Twitter, Instagram, and Pinterest as well as embedded videos hosted on third party sites such as YouTube and Vimeo (“Third-Party Sites”). Limonta does not control any Third-Party Sites and is not responsible for any information they may collect. The information collection practices of a Third-Party Site are governed by its privacy policy. It is your choice to enter any Third-Party Site. We recommend that you read its privacy policy if you choose to do so.

Children’s Privacy. The website and other Limonta platforms are intended for adult use only and is not directed towards children, minors, or anyone under the age of 18. If you are under the age of 13, you are not authorized to provide us with any Personal Information. If the parent or guardian of a child under 13 believes that the child has provided us with any Personal Information, the parent or guardian of that child should contact us at the email address below and to have this Personal Information deleted from our files.

HOW WE COLLECT YOUR PERSONAL INFORMATION

Information You Provide To Us:
Limonta may collect Personal Information from you that you voluntarily provide to us in various ways, including, but not limited to:

 To register you as a new customer
 To manage our relationship with you, including your purchase of goods or services both from our stores and the website
 To communicate with individuals in written, electronic, and verbal form
 To provide you with information on products or services
 To improve and optimize our services and website
 To send newsletters, marketing materials, and promotional offers (with your consent)
 To customize the advertising and content you see
 To verify information about you
 For any other purpose disclosed at the point of collection

Information We Collect When You Use Our Services
Automated technologies or interactions. As is true of most websites, we receive and store certain types of Personal Information whenever you interact with us online. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. When you access and use our website and platforms from your mobile devices, we receive data from that mobile device. This may include your device ID, location data, IP address and device type.
You may manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings. If you turn off your cookies, some of the features of the website may not function properly. For more information, read our cookie policy.

Information We Collect From Third Parties
We collect Personal Information from various third parties. The collection, use, and disclosure of Personal Information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user. Third parties may send their own cookies and pixel tags to you, and may collect information and use it in a way inconsistent with this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used and disclosed by these third parties.

Third Party Service Providers. We collect Personal Information from service providers including payment processors, website hosting providers, electronic commerce providers, fulfillment centers, shipping providers, email service providers, and social media platforms.

Third Party Advertising Partners. We collect Personal Information received from third party advertising partners, including partners who host and manage various online advertisements and ad platforms. This may be combined with the website analytics data described below.

Google Analytics. We use third party cookies provided by Google Analytics to assist us in better understanding our website visitors. These cookies collect IP address and usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our website. Based on this information, Google Analytics compiles data about website traffic and interactions, which we use to offer better user experiences and tools in the future. For information on how to opt-out from Google Analytics, visit https://tools.google.com/dlpage/gaoptout.

Your ‘Do Not Track’ Browser Setting. Some web browsers incorporate a Do Not Track (“DNT”) feature that signals to the websites that you visit that you do not want to have your online activity tracked. At this time, our website does not respond to DNT signals. Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.

HOW WE USE YOUR PERSONAL INFORMATION

Purposes For Which We Will Use Your Personal Information
Our primary purpose in collecting Personal Information is to provide you the products and services that you have ordered or requested with a safe, smooth, efficient, and customized experience. We may also use your Personal Information for the following business purposes:
• Collect and process payments and complete transactions.
• Provide the products, services, and customer support you request.
• Verify your identity and account information in connection with products or services you request.
• Provide you with recommendations for products and services that we believe would be of interest to you.
• Contact you through automated methods of contact (such as sms, mms and e-mail) and traditional (such as phone calls with operator and traditional mail).
• Provide you with our newsletter if you have subscribed to it.
• Assist you with setting up and managing your customer account with us.
• Resolve disputes.
• Troubleshoot problems and support.
• Enforce our Terms of Use and Online Sales and the terms of this Policy.
• Customize, measure and improve our services and content.
• Inform you about our products, services, updates and promotional offers.
• To customize the advertising and content you see.
• To protect our interests, including establishing, exercising and defending legal rights and claims.
• As necessary to comply with legal requirements, to prevent fraud, to co-operate with law enforcement and regulatory authorities, and to stop other prohibited, illegal, or harmful activities.
• For purposes disclosed at the time you provide/we request your Personal Information or as otherwise set forth in this Policy.

HOW WE SHARE YOUR PERSONAL INFORMATION
We share your Personal Information with third parties only in the ways that are described in this Policy and with our business partners, suppliers and sub-contractors in order to provide you with our goods and services and perform any contract we enter into with them or you.

Information You Instruct Us to Share. You may be presented with an option on our website to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.

User Disclosures. Some Personal Information is disclosed as a matter of course as a result of your use of the website. For example, if you choose to review a product. Any Personal Information shared via any public forum on our website will become public information.

Service Providers. We may use third-party service providers to perform certain business services and may disclose Personal Information to such service providers as needed for them to perform these business services. Service providers are only allowed to use, disclose or retain the Personal Information to provide these services and are prohibited from selling Personal Information. Business services provided include, but are not limited to, hosting services, communications services, website development services, payment processing services, fulfillment and shipping services, compliance services, analytics services, and marketing services.

Internal Third Parties. We may share Personal Information with our parent company, subsidiaries, successors, assigns, licensees, affiliates, or business partners and others, including where disclosure of your Personal Information is needed to protect the employees, independent contractors, officers, directors, members, users, or shareholders of Limonta who may use the Personal Information for the purposes described above.

Business Transactions. We may do business with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Policy.

Legal Process. Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.

COMMUNICATIONS AND OPT OUT
By establishing an account, making a purchase, or subscribing to our newsletter, you may consent to receive periodic commercial/promotional email communications from us. You may opt-out of receiving such promotional communications at any time by following the unsubscribe instructions in a promotional email or by emailing ecommerce@societylimonta.com. This opt out will not apply to operational or informational emails related to your account and purchases. You may continue to receive promotional email messages for a short period while we process your request.

HOW WE PROTECT YOUR PERSONAL INFORMATION
Limonta transmits information via industry standard secure server (SSL). This SSL creates the secure and encrypted https:// website address for our important pages like My Cart and the Checkout area. When you see the https:// website address, you know the information you are in-putting is protected and secure. We also comply with payment card industry data security standards that require merchants to implement security measures for credit card information. We never have access to your credit card information, as it is tokenized following PCI-compliant standards.

While we endeavour to incorporate reasonable safeguards to help protect and secure your Personal Information, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Therefore, we cannot guarantee its absolute security. It may be possible for third parties to intercept or access transmissions or private communications unlawfully. Any such transmission is done at your own risk.

ABILITY TO ACCESS, UPDATE AND CORRECT PERSONAL INFORMATION
Limonta wants your Personal Information to be complete and accurate. You represent and warrant that all information you provide in connection with your use of the website will be complete and accurate, and that you will update that information as necessary to maintain its completeness and accuracy. To confirm the completeness and accuracy of, or make changes to, your Personal Information, please contact us at ecommerce@societylimonta.com

CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits California residents who have provided personally identifiable information to us or our third-party advertisers and marketing partners, if any, to request certain information regarding our disclosure of personally identifiable information to third parties for direct marketing purposes.

Requests should be submitted via email to ecommerce@societylimonta.com and should include CALIFORNIA PRIVACY RIGHTS in the subject line. We will need your first and last name, mailing address, and email address in order to process your request. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for direct marketing purposes during the immediately preceding calendar year, if any, along with the names and addresses of these third parties, if any. Please be aware that not all information sharing is covered by the requirements of Section 1798.83 and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.

CHANGES TO THIS PRIVACY NOTICE
Limonta may modify or update this Policy from time to time. We encourage you to revisit this page often to remain fully informed of our Policy or you can contact us at any time to obtain the latest copy of this Policy.

QUESTIONS ABOUT THIS POLICY
For questions or comments regarding our Policy, you should contact us by using the Contact Us form. You can also email us at ecommerce@societylimonta.com or write to us at: LIMONTA USA INC. with registered office in 50 Broad Street, Suite 1904 10022 New York (NY).

INFORMATION PROVIDED TO COMPLY WITH EUROPEAN LAWS

DATA CONTROLLERS
Limonta S.p.A. (hereinafter “Limonta”), with registered office in Italy, Via Cesare Battisti 15 - 23845 Costamasnaga (LC), P.IVA 00201760139 and LIMONTA USA INC. with registered office in 50 Broad Street, Suite 1904 10022 New York (NY) (hereinafter “Limonta USA”) (both “we, us, our” as appropriate). Limonta and Limonta USA are autonomous “Data Controller”.

1 – DATA PROCESSING PURPOSES
1.1 – We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you or to form other legal obligations;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us by post or email at the address set out in this Privacy Policy.

1.2 – Contractual purposes: to register you as a new customer, process and fulfil the delivery of any goods/services ordered by you and to manage our relationship with you including your purchase of goods/services both from our stores in US and from our website us.societylimonta.com.

1.3 – Marketing purposes: subject to receiving your express consent or where we are otherwise permitted by law to do so, sending, with automated methods of contact (such as sms, mms and e-mail) and traditional (such as phone calls with operator and traditional mail), promotional and commercial communications relating to services / products offered or reporting of corporate events, as well as carrying out market studies and statistical analysis.

1.4 – Profiling purposes: analysis of your preferences, habits, behaviors or interests in order to send you personalized commercial communications.

1.5 – Legal Obligations: fulfill obligations under applicable national and international regulations and legislation and to protect our legal rights.

1.6 – Newsletter: if requested by registration with this service.

1.7 – Data Controller rights: if necessary, to ascertain, exercise or defend the rights of the controller in court.

1.8 – Website operations: the computer systems and software procedures used to operate the Website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified, but by their very nature could, through processing and association with data held or third parties, allow users to be identified on the Website.

The Data Controller for purposes 1.2, 1.5 and 1.7 is Limonta USA. The Data Controller for purposes 1.3, 1.4, 1.6 and 1.8 is Limonta.

2 – LEGAL BASIS FOR DATA PROCESSING
2.1 – Contractual purposes: execution of a contract to which you are a party, or for the booking and purchase of products and services both from our stores in USA and on the Website.

2.2 – Marketing and profiling purposes: consent (optional and revocable at any time).

2.3 – Legal Obligations: fulfill legal obligations.

2.4 – Newsletter: execution of a contract to which you are a party, subscribing newsletter service.

2.5 – Data Controllers rights and Out-of-court debt recovery: legitimate interest.

3 – DATA RETENTION PERIOD
3.1 – Contractual purposes, Legal Obligations and Newsletter: Contractual duration and, after termination, for the ordinary limitation period of 6 years.

3.2 – Marketing and profiling purposes: until the withdrawal of consent for these purposes. Personal data relating to the details of the purchases will only be kept for 24 months.

3.3 – Data Controllers rights and Out-of-court debt recovery: in the case of litigation, for the entire duration of the same, up to the exhaustion of the terms of practicability of the appeals.

3.4 – Website operations: for the entire duration of the browsing session on the Website.
Once the aforementioned retention period has lapsed data will be destroyed or made anonymous compatibly with technical erasure and backup procedures.

4 – PERSONAL DATA
4.1 – PERSONAL DATA PROCESSED FOR CONTRACTUAL PURPOSES – LEGAL OBLIATIONS – CONTROLLER RIGHTS – OUT OF COURT DEBT RECOVERY
Title, name, surname, mobile and landline number, country, address, city, post code, email, password.

4.2 – PERSONAL DATA PROCESSED FOR MARKETING AND PROFILING PURPOSES

Title, name, surname, tax code, mobile and landline number, country, address, city, postal code, email address, password, purchase data made on the Website, data collected from cookies installed by the Website.

4.3 – PERSONAL DATA PROCESSED FOR NEWSLETTER
Name, surname and email address.

4.4 – PERSONAL DATA PROCESSED FOR WEBSITE OPERATIONS
The IP addresses or domain names of the computers used by users connecting to the Website, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (good order, error, etc.), other parameters related to the operating system and the user’s computer environment, information relating to user behavior on the Website, to the pages that have been visited or searched, in order to select and make specific announcements to the user of the Website and the data relating to the browsing behavior held on the Website using, for example, using cookies.

4.5 – THIRD PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any company outside the Limonta group of companies for marketing purposes.

5 – REQUIREMENT TO PROVIDE PERSONAL DATA
The provision of personal data referred to in point 4.1 for the purposes referred to in paragraph 1.2 is mandatory. The refusal to provide the aforementioned personal data means that you will not be able to use the services of the Website relating to sales of products.

The provision of personal data referred to in point 4.2 for the purposes referred to in points 1.3 and 1.4 is optional and subject to your consent.

Some personal data referred to in point 4.4 are strictly necessary for the operation of the Website, others are used for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check its correct functioning and are deleted immediately after processing. In the processing of personal data that can directly or indirectly identify you, we try to respect a principle of strict necessity. For this reason, we have configured the Website in such a way that the use of personal data is kept to a minimum and in order to limit the processing of personal data that allow identifying it only in case of need or at the request of the authorities and police (as, for example, for data relating to traffic and your stay on the Website or to your IP address) or for ascertaining responsibility in the event of hypothetical computer crimes against the Website.

6 – DATA RECIPIENTS
The data can be processed, as well as by Data Controllers, also by

1. companies controlled by or connected to Data Controllers in Italy, USA and/or worldwide for the pursuit by Data Controllers of the purposes indicated in points 1.2, 1.3 and 1.4;

2. designated employees and collaborators in charge of processing who manage the Data Controllers physical stores or e-commerce and who can view, modify and update the data entered in the CRM system and in the event of any third party collaborators, we will enter into a suitable data processing agreement with them in order to safeguard the safety of your personal data;

3. external bodies such as, for example, authorities and supervisory and control bodies and in general subjects, public or private, entitled to request data;

4. external subjects designated as processor who will be subject to a suitable data processing agreement with us ensuring that any processing carried out is in accordance with USA and EU data protection rules and laws, who are given appropriate operating instructions, included in the following categories:

a. companies that offer e-mail sending services;
b. companies that offer site maintenance and development services;
c. companies that offer support in carrying out market studies.
d. third parties established in the European Union and also outside the European Union, data processor, which the Data Controllers relies on in particular for data acquisition and data entry services, shipping, mailing of promotional material, after-sales assistance, research market, management and maintenance of the CRM system and other Data Controllers information systems.

7 – PARTIES AUTHORISED TO PROCESS DATA
Your data may be processed by employees of the Data Controllers corporate functions appointed for the pursuit of the aforementioned purposes, who have been expressly authorized to process and who have received adequate operating instructions.
The data referred to in point 4.4 collected during navigation of the Website will be processed by employees, collaborators of the Data Controllers or external subjects, as persons in charge of data processing, who perform technical and organizational tasks on the Website.

8 – INTERNATIONAL TRANSFERS
We do not share your personal data with any third party unless you have expressly consented to this. Currently, personal data is held on servers located in the European Union. Some personal data may be held on servers in the US. This may involve transferring your data outside the United Kingdom and/or European Economic Area (EEA).
Whenever we transfer and/or process your personal data outside of the USA and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe;

• where we use providers based in the US, we will only transfer your personal data to them where they provide similar protection to that afforded in the USA and EEA

9 – SECURITY OF DATA
Your personal data will be processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected and in compliance with the principle of necessity and proportionality, avoiding the processing of personal data when operations can be performed through the use of anonymised data or by other means.
We have adopted specific security measures to prevent the loss of personal data, illicit or incorrect use and unauthorized access, but please do not forget that it is essential for the security of your data that your device is equipped with tools such as antivirus constantly updated and that the provider providing the connection to the Internet guarantees the secure transmission of data through firewalls, anti-spam filters and similar safeguards.


10 – DATA SUBJECTS’ RIGHTS – COMPLAINT TO THE SUPERVISORY AUTHORITY
By contacting the Data Controllers by e-mail at the e-mail address ecommerce@societylimonta.com, you can ask the Data Controllers for access to data concerning you, their deletion, correction of inaccurate data, the integration of incomplete data, the limitation of treatment in the cases provided for by art. 18 of the GDPR, as well as the opposition to the treatment in the case of legitimate interest of the Data Controllers.

Furthermore, in the case where processing is based on consent or a contract and carried out with automated tools, you have the right to receive the personal data in a structured, commonly used and machine-readable format, and to transmit the data to another data controller without obstruction.

You have the right to revoke the consent given at any time for marketing and / or profiling purposes, as well as to object to the processing of data for marketing purposes, including profiling related to direct marketing. It remains the possibility that he prefers to be contacted for the aforementioned purpose exclusively through traditional methods, to express his opposition only to the receipt of communications through automated methods.

You have the right to lodge a complaint with the competent Supervisory Authority in the Member State where you normally reside or work or of the State in which the alleged violation has occurred.

Cookies: You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Limonta and Limonta USA website may become inaccessible or not function properly.

You have additional legal rights to:

• request access to your personal data (commonly known as the data subject access request);
• request correction of the personal data that we hold about you;
• request erasure of your personal data in certain circumstances;
• request the restriction of processing of your personal data;
• request the transfer of your personal data to you or to a third party;
• withdraw consent at any time where we are relying on consent to process your personal data.