Privacy policy and information

This Privacy Policy is provided pursuant to Article 13 of the European Regulation No. 679/2016 and applies exclusively to all Data collected through the website www.TheDonkey.it. This Privacy Policy is subject to updates that will be published promptly on the website. This Privacy Policy and the Cookie Policy establish the bases on which the User's Personal Data will be processed.

1. Data Controller The Data Controller of the Data collected from this website is D.A.C. s.r.l., via della Magliana 214, 00146 Rome CF/VAT: 06539501004, Share Capital: €90,000.00, email address: cs@dac-it.com

2. Types of Data Collected The Personal Data provided or acquired will be subject to Processing based on principles of fairness, legality, transparency, and confidentiality in accordance with current regulations. Among the Personal Data collected by TheDonkey.it, either independently or through third parties, are: first name; last name; phone number; address; email; company name; shipping address; Cookies; Usage Data. Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed prior to the collection of the data itself. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of TheDonkey.it. Unless otherwise specified, all Data requested by TheDonkey.it is mandatory. If the User refuses to communicate them, it may be impossible for TheDonkey.it to provide the Service. In cases where TheDonkey.it indicates some Data as optional, Users are free to refrain from communicating such Data without this having any consequence on the availability of the Service or its operation. The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through TheDonkey.it and guarantees that they have the right to communicate or disseminate them, releasing the Owner from any responsibility towards third parties.

3. Methods and place of processing of the collected Data

3.1 Methods of processing The Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data. The processing is carried out using IT and/or telematic tools, with organizational methods and logics strictly related to the purposes indicated. In addition to the Controller, in some cases, other subjects involved in the organization of TheDonkey.it (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communication agencies) may have access to the Data. The updated list of Managers can always be requested from the Data Controller.

3.2 Legal basis of processing The Controller processes Personal Data relating to the User if one of the following conditions exists:

a) the User has given consent for one or more specific purposes;

b) the processing is necessary for the execution of a contract with the User and/or the execution of pre-contractual measures;

c) the processing is necessary to fulfill a legal obligation to which the Controller is subject;

d) the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;

e) the processing is necessary for the pursuit of the legitimate interest of the Controller or third parties;

It is always possible to request the Controller to clarify the concrete legal basis of each processing and, in particular, to specify whether the processing is based on the law, provided for by a contract, or necessary to conclude a contract.

3.3 Place of processing The Data is processed at the Controller's operational offices and in any other place where the parties involved in the processing are located. The User's Personal Data may be transferred to a country different from the one in which the User is located. To obtain further information about the place of processing, the User can refer to the section relating to the details on the processing of Personal Data. Personal Data will not be transferred to non-EU countries. The Data may be communicated to third parties to comply with legal obligations, to comply with orders from public authorities, or to exercise a right of the Controller before judicial authorities. The management of databases and the processing of Data are related to the Purposes of the Processing and are carried out in accordance with the applicable Data protection regulations.

3.4 Retention period The Data is processed and stored for the time required by the purposes for which it was collected. Therefore:

a) Personal Data collected for purposes related to the execution of a contract between the Controller and the User will be retained until the execution of that contract is completed.

b) Personal Data collected for purposes related to the legitimate interest of the Controller will be retained until the satisfaction of that interest.

c) When the processing is based on the User's consent, the Controller can retain the Personal Data longer until such consent is revoked. Additionally, the Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority. At the end of the retention period, Personal Data will be deleted. Therefore, upon the expiration of that term, the right of access, deletion, rectification, and the right to Data portability can no longer be exercised.

4. Purposes of the Data collected The User's Data is collected to allow the Controller to provide its Services, as well as for the following purposes: Registration and authentication, Access to accounts on third-party services, Contacting the User, Managing payments, Statistics, Managing contacts and sending messages, Remarketing and behavioral targeting, Advertising, and Managing support and contact requests. For more detailed information on the purposes of the processing and on the Personal Data concretely relevant for each purpose, the User can refer to the relevant sections of this document.

5. Details on the processing of Personal Data Personal Data is collected for the following purposes and using the following services:

5.1. Access to Facebook account This service allows TheDonkey.it to connect with the User's account on the social network Facebook, provided by Facebook Ireland Ltd. Permissions requested: Email Place of processing: Ireland – Privacy Policy

5.2 Contacting the User Contact form (TheDonkey.it) The User, by filling in their Data in the contact form, consents to their use for responding to requests for information, quotes, or any other nature indicated by the form's header. Personal Data collected: last name; email; first name; phone number. Mailing list or newsletter (TheDonkey.it) By registering for the mailing list or newsletter, the User's email address is automatically added to a list of contacts to whom email messages containing information, including commercial and promotional information, related to TheDonkey.it may be sent. The User's email address may also be added to this list as a result of registering with TheDonkey.it or after making a purchase. Personal Data collected: last name; email; first name. Subscription to a mailing list for communication, promotion, offers, and other purposes can only occur after specific free and informed consent given by the user. This consent must be tracked (including digitally via logs) and retained for a maximum retention period of 24 months, after which such consent expires and must be requested again from the customer. Managing contacts and sending messages This type of service allows managing a database of email contacts, phone contacts, or any other type of contact, used to communicate with the User. These services may also allow collecting data regarding the date and time messages are viewed by the User, as well as the User's interaction with them, such as information on clicks on links inserted in messages.

6. Managing payments Payment management services allow TheDonkey.it to process payments via credit card, bank transfer, or other instruments. The data used for payment is acquired directly by the requested payment service provider without being processed in any way by TheDonkey.it. Some of these services may also enable the sending of messages to the User, such as emails containing invoices or notifications regarding payment. PayPal (Paypal) PayPal is a payment service provided by PayPal S.à r.l. et Cie SCA, which allows the User to make online payments. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: Luxembourg – Privacy Policy Stripe Stripe is a payment service provided by Stripe Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: USA – Privacy Policy

7. Managing support and contact requests This type of service allows TheDonkey.it to manage support and contact requests received via email or other tools, such as the contact form. The Personal Data processed depends on the information provided by the User within the messages and the tool used for communication (such as the email address).

8. Advertising This type of service allows using the User's Data for commercial communication purposes in various forms of advertising, such as banners, also in relation to the User's interests. This does not mean that all Personal Data is used for this purpose. Data and conditions of use are indicated below. Some of the services listed below may use Cookies to identify the User or use the behavioral retargeting technique, i.e., display personalized advertisements based on the User's interests and behavior, also detected outside TheDonkey.it. For more information, we suggest you check the privacy policies of the respective services. In addition to the opt-out options offered by the services listed below, the User can opt-out of receiving cookies related to a third-party service by visiting the Network Advertising Initiative opt-out page.

9. Registration and authentication By registering or authenticating, the User allows the Application to identify them and give them access to dedicated services. Depending on what is indicated below, registration and authentication services may be provided with the assistance of third parties. If this happens, this application may access some Data stored by the third-party service used for registration or identification. 9.1 Direct registration (TheDonkey.com) The User registers by filling out the registration form and providing their Personal Data directly to TheDonkey.it. Personal Data collected: last name; email; address; shipping address; first name; phone number; company name. 9.2 Facebook Authentication (Facebook Ireland Ltd) Facebook Authentication is a registration and authentication service provided by Facebook and connected to the social network Facebook. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: Ireland – Privacy Policy 9.3 Google OAuth (Google Ireland Limited) Google OAuth is a registration and authentication service provided by Google and connected to the Google network. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: Ireland – Privacy Policy 9.4 Linkedin OAuth (LinkedIn Ireland Unlimited Company “LinkedIn Ireland”) Linkedin Oauth is a registration and authentication service provided by Linkedin Corporation and connected to the social network Linkedin. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: Ireland – Privacy Policy

10. Remarketing and behavioral targeting This type of service allows TheDonkey.it and its partners to communicate, optimize, and serve advertisements based on the User's past use of TheDonkey.it. This activity is carried out through the tracking of Usage Data and the use of Cookies, information that is transferred to the partners to which the remarketing and behavioral targeting activity is linked. In addition to the opt-out options offered by the services listed below, the User can opt-out of receiving cookies related to a third-party service by visiting the Network Advertising Initiative opt-out page. 10.1 Google Ads Remarketing (Google Ireland Limited) Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited, depending on where TheDonkey.it is used, that connects the activity of TheDonkey.it with the Google Ads advertising network and the DoubleClick Cookie. Users can choose not to use Google's cookies for ad personalization by visiting Google's Ads Settings. Personal Data collected: Cookies; Usage Data. Place of processing: Ireland – Privacy Policy – Opt Out. 10.2 Facebook Remarketing (Facebook Ireland Ltd) Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, which connects the activity of TheDonkey.it with the Facebook advertising network. Personal Data collected: Cookies; Usage Data. Place of processing: Ireland – Privacy Policy

11. Statistics The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior. 11.1 Google Analytics with anonymized IP (Google Ireland Limited) Google Analytics is a web analytics service provided by Google. Google uses the collected Personal Data to track and examine the use of TheDonkey.it, compile reports, and share them with other Google services. Google may use the collected Personal Data to contextualize and personalize the ads of its advertising network. This integration of Google Analytics anonymizes your IP address. Anonymization works by shortening the IP address within the borders of EU Member States or other countries adhering to the Agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to Google's servers and shortened within the USA. Personal Data collected: Cookies; Usage Data. Place of processing: Ireland – Privacy Policy – Opt Out. 11.2 HubSpot Analytics (HubSpot, Inc.) HubSpot Analytics is a statistics service provided by HubSpot, Inc. Personal Data collected: Cookies; Usage Data. Place of processing: USA – Privacy Policy. 11.3 Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.) Hotjar is a statistics service provided by Hotjar Ltd. Hotjar respects the generic "Do Not Track" headers. This means that the browser can indicate to the script not to collect any of the User's data. This is a setting that is available in all major browsers. More information on opting out of Hotjar is available here. Personal Data collected: Cookies; Usage Data. Place of processing: Malta – Privacy Policy. 11.4 Facebook Ads Conversion Tracking (Facebook Pixel) (Facebook Ireland Ltd.) Facebook Ads Conversion Tracking (Facebook Pixel) is a statistics service provided by Facebook, which connects data from the Facebook advertising network with actions performed within TheDonkey.it. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram, and Audience Network. Personal Data collected: Cookies; Usage Data. Place of processing: Ireland – Privacy Policy. 11.5 Google Ads Conversion Tracking (Google Ireland Limited) Google Ads Conversion Tracking is a statistics service provided by Google Ireland Limited, depending on where TheDonkey.it is used, that connects data from the Google Ads advertising network with actions performed within TheDonkey.it. Personal Data collected: Cookies; Usage Data. Place of processing: Ireland – Privacy Policy.

12. Further information on Personal Data 12.1 Sharing of personal data within TheDonkey.it The User is aware that, for the purpose of providing the delivery service, the carrier may have access to some of their Personal Data such as name, surname, company name, starting and destination address. If the User does not agree with the above, they are requested to refrain from using TheDonkey.com. 12.2 Google permissions requested by TheDonkey.it TheDonkey.it may request certain Google permissions that allow it to perform actions with the User's Google account and to collect information, including Personal Data, from it. This service allows TheDonkey.it to connect with the User's Google account. For more information on the following permissions, refer to the Google permissions documentation and Google's Privacy Policy. 12.3 Basic profile information of the User's Google account TheDonkey.it has access to basic data from the User's account, such as name, email address, gender, or country. 12.4 Sale of goods and services online The Personal Data collected is used for the provision of services to the User or for the sale of products, including payment and possible delivery. The Personal Data collected to finalize the payment can be related to the credit card, the current account used for the bank transfer, or other payment instruments provided. The payment data collected by TheDonkey.it depends on the payment system used.

12.5 User Rights Users may exercise certain rights with reference to the Data processed by the Controller. In particular, the User has the right to: a) withdraw consent at any time. b) object to the processing of their Data. c) access their Data. d) verify and request rectification. e) obtain the restriction of processing. f) obtain the deletion or removal of their Personal Data. g) receive their Data or have it transferred to another controller. This provision is applicable when the Data is processed with automated tools and the processing is based on the User's consent, on a contract of which the User is a part, or on contractual measures related to it. h) lodge a complaint with the competent data protection authority or take legal action.

12.6 Details on the right to object When Personal Data is processed in the public interest, in the exercise of official authority vested in the Controller, or for the pursuit of a legitimate interest of the Controller, Users have the right to object to the processing for reasons related to their particular situation. Users are reminded that, where their Data is processed for direct marketing purposes, they can object to the processing without providing any reason. To find out whether the Controller is processing Data for direct marketing purposes, Users can refer to the respective sections of this document.

12.7 How to exercise rights To exercise the User's rights, Users can direct a request to the contact details of the Controller indicated in this document. The Data Controller reserves the right to make changes to this Privacy Policy at any time by giving publicity to Users on this page.

Privacy Policy updated in July 2024