Privacy policy
Introduction
The AQUARELLO Club respects your privacy and is committed to protecting your personal data.
This privacy policy explains what types of information we collect about you when you visit our websites, or that we otherwise obtain directly from you or from third parties, how we use this information, and in what circumstances we may share your information. This privacy policy may change from time to time, so you should review this policy regularly.
For the purposes of this privacy policy, the term "personal data" means all information that identifies you or that can be used to identify you in conjunction with other information. Introduction
For the purposes of this privacy policy, the term "personal data" means all information that identifies you or that can be used to identify you in conjunction with other information.
Important information and who we are
Responsible person
The AQUARELLO Club is made up of different legal entities, the details of which you can find here. This privacy policy is published on behalf of the AQUARELLO Club. Therefore, when we refer to "AQUARELLO", "AQUARELLO Club", "we", "us" or "our" in this privacy policy, we are referring to the relevant AQUARELLO entity responsible for processing your data. The AQUARELLO Club is the owner and operator of this website.
Changes to the privacy policy and your obligation to notify us of changes
It is important that the personal data we hold about you is accurate and up to date. Please notify us if your personal data changes during your relationship with us.
Links to third-party providers
This website may contain links to third-party websites, plug-ins and applications. If you click on these links or activate these connections, third parties may collect or share information about you. We have no control over these third-party websites and are not responsible for their privacy policies. When you leave our website, we recommend that you read the privacy policy of every website you visit.
The data we collect about you
In the course of conducting our business, we may collect, use, store and share different types of personal data about you, which we have summarized as follows:
Identity data includes first name, last name, username or similar identifier, title and date of birth.
Contact information includes work address, email address and telephone numbers.
Financial data includes information about bank accounts and payment cards.
Transaction data includes details of payments made to and from you and other details of products and services you have purchased from us, including the type of card used for a particular transaction (but no other card details).
Technical data and usage data includes information about how you access and use our websites, such as your IP address, your login credentials, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technologies on the devices you use to access our websites, the pages you visit on our websites and the links you follow.
Profile data includes your username and password, your purchases or orders, your job title, your employer, your interests, your preferences, your feedback and your responses to surveys.
Employment data includes your current and previous work experience, qualifications, skills, interests and any other information you have provided in connection with an application for a job at AQUARELLO.
Marketing and communication data includes your preferences regarding receiving marketing communications from us and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data under the law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate your technical data to calculate the percentage of users who access a particular website feature. However, if we combine or link aggregated data with your personal data so that it can identify you directly or indirectly, we treat the combined data as personal data used in accordance with this privacy policy.
We do not collect special categories of personal data about you (including details of your ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information and genetic and biometric data) nor do we collect information about criminal convictions and offences.
How do we collect your personal data?
We use various methods to collect data from and about you, including:
Direct interactions. You may provide us with your identity and contact details in person by completing forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide to us when you:
- request our products or services,
- meet with one of our staff members,
- attend an event organized by us,
- complete a form on our website and ask us to contact you,
- subscribe to our publications,
- request the sending of marketing material,
- participate in a competition, promotion or survey,
- submit an application for a job at AQUARELLO, make a complaint or provide us with feedback.
Automated technologies or interactions. When you interact with our website and our call centers, we may automatically collect technical data about your device, your browsing activity and your behavioral patterns. We collect this personal data using cookies and other similar technologies. We may also collect technical data about you when you visit other websites that use our cookies. For more details, please see our Cookie Policy.
Third parties or publicly available sources. We may collect personal data about you from various third parties as described below:
Technical data from the following parties:
(a) analytics providers;
(b) advertising networks; and
(c) search information providers.
Identity and contact details from data brokers or aggregators. Identity and contact
details from publicly available sources such as the commercial register.
Employment, identity and contact details from third-party recruitment agencies.
How we use your personal data
We only use your personal data where the law permits us to do so. In most cases, we will use your personal data in the following circumstances:
Where it is necessary for our legitimate interests (or those of a third party) and we have determined that your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
In general, we do not rely on consent as a legal basis for processing your personal data. You have the right to opt out of receiving advertising at any time by contacting us.
Purposes for which we will use your personal data
Below is a description of all the ways in which we intend to use your personal data.
Please note that we may process your personal data on more than one legal basis depending on the specific purpose for which we use your data. Please contact us if you would like more information about the specific legal basis on which we rely to process your personal data.
To manage our relationship with you and your business, including:
Processing and delivering orders;
Managing payments, fees and charges;
Collecting and recovering amounts you owe us;
Processing your requests and complaints;
Notifying you of changes to our terms and conditions or our privacy policy;
Asking you to leave a review or complete a survey.
To manage and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and data hosting)
To provide you with relevant website content and advertising, and to measure or understand the effectiveness of the advertising we provide to you
To analyze data to improve our website, products/services, marketing, customer relationships and experiences
To make suggestions and recommendations to you about goods or services that may be of interest to you
To process your job application at AQUARELLO
Marketing
We strive to provide you with choices regarding marketing and advertising.
We may use your technical data to understand what we think you may want or need, or what may be of interest to you. This helps us decide which products, services and offers may be relevant to you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us, or if you have provided us with your details when you participated in a competition or registered for a promotion, and you have not opted out of receiving these marketing communications in any case.
Unsubscribe
You may ask us or third parties at any time to stop sending you marketing messages by following the unsubscribe links in any marketing message sent to you or by contacting us at any time.
Cookies
Our website uses cookies and similar technologies to distinguish you from other users of our website. This helps us provide you with a good experience when you browse our website and to improve our website. We may also use these technologies to track you online and to show you targeted advertising on third-party websites and social media platforms based on your preferences and likely interests.
You may set your browser to reject all or some browser cookies or to notify you when websites set or access cookies. If you disable or reject cookies, please note that some parts of this website may become inaccessible or not function properly.
Sharing your personal information
We may need to share your personal data for the purposes mentioned above with the parties listed below:
Our external service providers who perform functions on our behalf in connection with the operation of our business, such as IT service providers and system administrators; third parties that host and manage data, provide our products and services, carry out reference and criminal record checks on applicants on our behalf, etc.
Professional advisors such as lawyers, bankers, auditors and those who provide advisory, banking, legal, insurance and accounting services.
Our external advertising partners to display products tailored to your preferences and likely interests on third-party websites.
Our external analysis partners to analyze website traffic and understand customer needs and trends.
Third parties where we are required to do so by law or where we believe such action is necessary to: (a) comply with a governmental or regulatory request; (b) comply with legal requirements or legal process; (c) protect or defend our rights or our property, our websites or our customers
Third parties to whom we may sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If our business changes, the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third-party providers to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party providers to use your personal data for their own purposes and only permit them to process your personal data for specific purposes and in accordance with our instructions.
International transfers
This section applies if you are resident in the European Union.
We may share your personal data within AQUARELLO. This includes transferring your data outside the European Economic Area (EEA).
Our third-party service providers may be located outside the EEA, so their processing of your personal data involves a transfer of data outside the EEA.
When we transfer your personal data to countries outside the EEA, we ensure an equivalent level of protection by implementing at least one of the following safeguards:
We will only transfer your personal data to countries that the European Commission has determined provide an adequate level of protection for personal data. For more details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
When we use certain service providers, we may use special contracts approved by the European Commission that provide the same level of protection for personal data as exists in Europe. For more details, see European Commission: Model contracts for the transfer of personal data to third countries.
When we use providers based in the United States, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide equivalent protection for personal data exchanged between Europe and the United States. For more details, see European Commission: EU-US Privacy Shield
Please contact us if you would like more information about the specific mechanism we use when transferring your personal data to countries outside the EEA.
Data security
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed, altered or disclosed. In addition, we limit access to your personal data to those employees, representatives, contractors and other third parties who need that data for a business purpose. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
We have procedures in place to deal with any suspected breach of personal data security and will notify you and the relevant supervisory authority of a breach if we are legally required to do so.
Data retention
How long will you use my personal data?
We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including to meet legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, type and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes by other means, as well as the applicable legal requirements.
You may request details of the retention periods for various aspects of your personal data by contacting us.
Under certain circumstances, you may ask us to delete your data: see more information below.
Under certain circumstances, we may anonymize your personal data for research or statistical purposes (so that it can no longer be associated with you); in this case, we may use this information indefinitely without notifying you.
Your legal rights
If you are in the European Union, you have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This allows you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully.
Request correction of the personal data we hold about you. This allows you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This allows you to ask us to delete or remove your personal data if there is no compelling reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data if you have successfully exercised your right to object to processing (see below), if we may have processed your data unlawfully, or if we need to delete your personal data to comply with local laws. Please note, however, that we may not always be able to comply with your request for erasure for certain legal reasons that may be communicated to you at the time of your request.
Object to the processing of your personal data where we rely on legitimate interests (or those of a third party) and you wish to object to processing on the grounds related to your particular situation, as you believe this affects your fundamental rights and freedoms. You also have the right to object where we process your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data that override your rights and freedoms (except in the case of direct marketing).
Request that we restrict the processing of your personal data. We will provide your personal data to you or to a third party you have chosen in a structured, commonly used and machine-readable format. Please note that this right only applies to automated data that you originally consented to the use of, or if we used the data to fulfill a contract with you.
Request that we transmit your personal data to you or to a third party. We will provide your personal data to you or to a third party you have chosen in a structured, commonly used and machine-readable format. Please note that this right only applies to automated data whose use you originally consented to, or if we used the data to fulfill a contract with you.
Withdraw your consent at any time where we rely on consent to process your personal data. However, this does not affect the lawfulness of processing that occurred before you withdrew your consent. If you withdraw your consent, we may no longer be able to provide you with certain products or services. We will notify you if this is the case when you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
Usually no fee is required
You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to respond to your request in such circumstances.
What we may need from you
We may need certain information from you to confirm your identity and to ensure that your right to access your personal data (or to exercise any of your other rights) is maintained. This is a security measure to ensure that personal data is not disclosed to unauthorized persons. We may also contact you to request further information in connection with your request to enable us to respond more quickly.
Timeframes for responses
We strive to respond to all valid requests within one month. Occasionally, it may take longer than one month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.