Privacy policy

Privacy Policy

Last updated [06/28/2024]

1. Introduction

The website www.zerow.it (the "Site") is published by Zerow - S.R.L., a limited liability company registered with the Registrar of Companies under number IT07138020487, and having its registered office in SCANDICCI (FI) VIA NEWTON 102 ZIP CODE 50018 (hereinafter "Zerow", "We" or "Us").

Zerow gives the highest priority and care to the protection of the privacy and personal data of users of the Site and representatives of its corporate clients and prospects.

The purpose of this Privacy Policy (hereinafter "Privacy Policy" or "Policy") is to inform you, as representatives of corporate buyers and/or visitors to our Site (hereinafter "You"), about how we process your personal data, particularly when you use and place orders through the Site, in connection with our prospecting and promotion activities and after-sales services (hereinafter the "Personal Data" or "Data"). This Policy also provides information about your rights in relation to your Personal Data.

This Policy describes Zerow's processing of your Personal Data (hereinafter "Processing") and your rights regarding the protection of your Personal Data.

For more information about how we handle your orders placed through the Site (the "Orders"), please refer to Zerow's Terms and Conditions of Sale.

We may change this Policy from time to time, particularly if there are changes in how we use your Personal Data. Please check this page regularly to make sure you agree to any changes. You will be informed of such changes, either by a special notice on our Site or by personal notification.

2. What is Personal Data?

Personal Data refers to any information or set of information that could identify you as a natural person either directly (e.g., your first and last name) or indirectly (e.g., your job function, your IP address). This means that Personal Data includes information such as your email address and phone number, but also unique identifiers such as your computer's IP address or your device's MAC address or data about your browsing on our Site.

3. Who is responsible for the protection of your Data?

The 'Data Controller' is the entity that determines the purposes and means of the processing and is responsible to you for compliance with Data Protection regulations (hereinafter "the Data Controller").

With respect to the operation of the Site, Zerow (whose contact information is provided below) acts as the Data Controller. If you have any concerns, questions, or requests regarding our use of your Personal Data, you may contact us at:

  • by email at the following address: support@zerow.it (specifying in the subject line of the email: "personal data"), or
  • by mail at the following address: SCANDICCI (FI) VIA NEWTON 102 ZIP CODE 50018 (for the attention of the Data Protection Officer).

4. Why and how do we use your Data?

How do we collect your Data?

We collect your Personal Data as follows:

  • directly from you when you use our Site and services (filling out various forms on the Site, placing an Order, communicating directly with us, for after-sales services, etc.).
  • indirectly in an automated way when you access or use the Site (cookies, technical details, browsing information, etc.)
  • indirectly by third parties (social media, etc.).

What Data do we collect?

Zerow collects different types of Personal Data about you:

Data we collect directly from you

Categories of Personal Data we may collect directly from you include:

  • Information needed to process your Order: selected items, delivery and billing address, contact information (see above), including credit card number and expiration date,
  • Information for after-sales services: information about returns, exchanges and repairs, including a description of any problems with your purchase, if this information includes personal information,
  • Information about your preferences: preferred products and services, if you choose to provide this information to us, in case this information includes personal data,
  • History and content of your communications with us: we generate the history of our relationship when you contact us about a customer service issue or when you send us a complaint,
  • Recording of our customer service calls: when you contact us or contact one of our consultants, your conversations may be recorded to ensure quality service. You will always be provided with alternative ways to contact us if you do not want your conversation recorded.

When you complete a Data Collection form, all mandatory information will be marked with an asterisk or equivalent method. If you do not complete the mandatory fields, we will not be able to process the relevant request and/or Order.

Data we collect automatically

We automatically collect certain Data about you when you access or use the Site, specifically:

  • Technical Information: we collect information about the device you use to access the Site, as well as about your use of the Site itself (operating system, type of browser used, whether a proxy is used, device location inferred from your IP address identifying your computer, time of access, pages visited and the link that allowed you to access our Site).

Data we collect indirectly from third parties

We may also obtain Personal Data about you from social networks you use through our Site, or from your activity on social media pages. Specifically, when you share your experience with Zerow with other customers using social media, you provide Data about yourself to this social network and to us. These communications are governed by the social network's Personal Data protection policies, which we encourage you to review.

On what legal basis and for what purposes do we use the Data we collect?

In accordance with applicable Personal Data protection legislation, we collect Personal Data only when we have a legal basis to do so.

Personal Data is collected:

  • based on your consent,
  • as part of the performance of a contract,
  • in our legitimate interest, or
  • in accordance with a legal obligation.

We collect Personal Data based on your consent, for the following purposes:

  • To handle your requests and inquiries (other than those related to an Order): we use your Data to send you requested information,
  • To send you commercial and marketing solicitations: we may use your Data to propose new products and special offers, invite you to future events that may be of interest to you, and send you our newsletters.

We collect Personal Data based on the performance of a contract, for the following purposes:

  • To process your Order: we use your Data to manage the purchase, delivery and billing of the products you order, including any information you provide to create your customer account,
  • After-sales services: we use your Data to handle any requests you may have as part of our after-sales services, including returns, exchanges and repairs.

We collect Personal Data based on our legitimate interest, for the following purposes:

  • To measure and improve the performance of our Site: we use performance cookies to allow us to count visits and traffic sources. This helps us know which pages are the most and least popular and see how visitors move around the Site,
  • To communicate with you about your account or our relationship (for example, to ask you for feedback, run surveys, inform you about changes to the Site or this Privacy Policy, along with any updates to services),
  • To prevent payment fraud and ensure the validity of payments we receive,
  • To defend our interests in the event of litigation or legal action.

We collect Personal Data based on legal obligations for the purpose of complying with applicable laws:

In case some commercial documents include Personal Data, we inform you that we keep transaction history and any other commercial documents for legal and administrative reasons (liability, tax, legal or commercial guarantees, insurance, audits, etc.).

5. Who has access to your Data?

Your Data is processed by Zerow for the purposes described above and is accessible only to Zerow staff who have a need to know it.

Certain third parties may have access to your Data, namely:

  • our subcontractors and service providers: for after-sales services, as well as for technical and logistical reasons (logistics specialists, couriers, Site hosting and maintenance providers, payment and fraud management service providers, technical service providers responsible for sending emails and newsletters, customer service, etc.),
  • social media: when you use social media buttons, Data about your identification is automatically sent to these social media outlets. You may also share some information or content from our Site on social media. Please see the social media terms of use that govern this matter,
  • any third-party company that, in the event of a restructuring of Zerow, acquires all or part of Zerow or merges with our company,
  • any authority, court or other third party when disclosure is required by law, regulation or court decision, or if such disclosure is necessary to protect and defend our rights.

6. Is Personal Data transferred outside the European Union?

Your Data is processed by Zerow in Italy. However, we may rely on certain service providers, located abroad or who in turn rely on data processors located abroad, including outside the European Economic Area (EEA) in countries where data protection laws differ from those applicable in the EEA.

Any transfers of your Data outside the European Union will be made with (i) strict measures to ensure the confidentiality and security of such transfers and (ii) appropriate safeguards that will comply with applicable Personal Data protection laws, such as the signing of standard contractual clauses based on the European Commission model, including any necessary additional measures, available upon request.

7. How long do we keep your Data?

We keep Data for as long as necessary for the purpose for which it was collected and, in any case, it will be destroyed at the end of that period.

In most cases, your Data is retained for the duration of our relationship, then for a period of 3 years following the termination of our relationship (which generally corresponds to the date of your last Order through the Site, the date your customer account is closed, or the date of our last contact with you). The Data is then (i) archived when necessary for accounting or documentation purposes for the applicable statute of limitations period (generally up to 10 years) and then destroyed or anonymized once the statute of limitations periods have expired or (ii) if there is no archive, immediately deleted or anonymized.

Exceptionally, we may retain your Data for shorter or longer periods.

See the table below for more details on these periods.

Purpose Applicable Data Categories Retention period before deletion
Management of Customer Orders Identification Data Identification and Order Data: duration of Order processing until delivery + warranty period + then Purchase Data is archived up to 10 years for accounting or documentary reasons.
Customer Relationship Management. Purchase history, communications between you and us, customer account Relationship duration + 3 years + then Purchase History Data is archived up to 10 years for accounting or documentary reasons; other
Sending our newsletter/commercial solicitations Information regarding your email address and options regarding electronic solicitations 3 years from the last Order or last contact with you, or sooner if you wish to unsubscribe before the end of this period. Then, the Data will be destroyed or anonymized unless you reaffirm your desire to receive our offers and newsletters.
Disputes/Complaints Dispute/Complaint Data If no legal action is filed, according to the applicable statute of limitations: up to 5 years from the event. If legal action is filed: duration of proceedings until full execution of the legal decision or settlement agreement.

8. What are your Data protection rights?

Access, rectification and portability

In accordance with applicable regulations, you have the right to access your Data. You can also request correction of your Personal Data if it is inaccurate. Depending on the type of processing, you may also have the right to request that the Personal Data we hold be updated or corrected.

To respond to your request, we are required by law to verify your identity. If necessary, we may ask you to provide us with proof of your identity. We may also need to ask you for additional information or supporting documents to respond to your request. We will do our best to respond to your request as soon as possible.

To the extent permitted by law, you may exercise your right to Data portability, which allows you to retrieve, in an interoperable format, the Personal Data you provided to us in an automated manner when you created your account and/or enrolled in our loyalty program, as well as when you selected products (favorite products, etc.).

Right to erasure of your Data and limitation of the processing of your Data

You can request the deletion of your Personal Data if:

  • You believe that our processing of your Personal Data is no longer necessary for the purposes of the services you have subscribed to or for your use of the Site, or is no longer necessary for the purposes described in this Privacy Policy, or that its retention is unlawful,
  • You have withdrawn your consent to the processing of your Data and Zerow relies on your consent for such processing (see above),
  • You object to the processing of your Personal Data for reasons related to your personal situation,
  • You object to the use of your Data for purposes of commercial solicitation or profiling,
  • Your Data was collected online when you were a minor.

Alternatively, to the extent permitted by law, you may request the restriction of the processing of your Data.

Please note that, notwithstanding the exercise of your right to erasure or restriction of processing, we will retain some of your Personal Data when the law requires or authorizes it, when we have a legitimate reason to do so (e.g., to demonstrate performance of a contract) or to exercise or defend our rights in court. For example, if we believe that you have violated our Terms and Conditions of Use or our Terms and Conditions of Sale.

Right to establish instructions for the management of your Personal Data after your death

Under the provisions of Italian law, you can determine how you want us to handle your Personal Data after your death.

9. Procedure for exercising your data protection rights

To exercise your rights, you can contact us directly at: support@zerow.it (specifying in the subject line of the email: "personal data").

In addition, if you have a customer account, you may exercise your right to access, rectify and/or delete your Data by logging into your account.

When the processing of your Data is based on your consent (e.g., newsletter subscription, sending electronic commercial solicitations, use of cookies and similar technologies on the Site), you may withdraw your consent at any time without justification. This right can be exercised by changing your options regarding commercial solicitation and subscriptions to our newsletters, and by withdrawing your consent to the use of cookies in accordance with the procedure outlined in the cookies section below.

If you have any questions regarding your rights and the processing of your Data, please contact us at: support@zerow.it (specifying in the subject line of the email: "personal data").

10. How is your Personal Data protected?

Zerow uses technical and organizational measures that comply with applicable legal and regulatory requirements to keep your Data secure and confidential.

Under written agreements, Zerow requires its service providers and processors to provide safeguards and implement sufficient security measures to protect the Personal Data they have agreed to process, in accordance with applicable requirements of Personal Data protection laws.

However, Zerow does not control all risks related to the operation of the Internet and draws your attention to the risks inherent in the use of any website.

11. Protection of Children

Our Site is not intended for children. We do not knowingly collect Data about children unless permitted by law.

You must be at least eighteen (18) years old to share your Data with us. If we are informed that a child under eighteen (18) has submitted Data to us, we reserve the right to immediately delete that Data and any associated account.

12. Cookies

When you visit our Site, it may store or retrieve information on your browser, primarily in the form of cookies.

This information may relate to you, your preferences, or your device and is primarily used to make the Site work as you expect and to personalize your user experience.

You can get more information about the types of cookies on our Site and manage your cookie preferences on this page. Please note that blocking certain types of cookies may affect your experience of the Site and the services we are able to offer.

13. Third-party websites

Our Site may include links to third-party websites or services that we do not control and that are governed by their privacy and Personal Data protection policies. This Privacy Policy does not apply to third-party websites. We encourage you to review the privacy and Personal Data protection policies of the third-party websites you visit to understand how they treat your Data. Zerow will not be responsible for the use of your Data by third parties.

14. How to contact us with questions or complaints?

If you have any questions regarding this Policy or any questions or complaints about your Personal Data, you may contact us at any time at: support@zerow.it (specifying in the subject line of the email: "personal data").

If you have a complaint about how we collect and process your Data, you also have the right to lodge a complaint with the Italian data protection supervisory authority (the Garante per la protezione dei dati personali, based in Piazza Venezia, 11 - 00187 Roma, Tel: +39 06 696771) or, if you reside elsewhere in the European Economic Area, with your local data protection supervisory authority.