個人資料（隱私）條例

PRIVACY POLICY
Last update: June 14, 2023
1.    FOREWORD
1.1.    F.S.A. S.R.L. (VAT n. 03554300966), with registered office in 20123 – Milan (MI), Via Francesco Petrarca, no. 4, Italy (hereinafter, the “Company”), as the owner of the site linked to the internet domain name “www.fullspeedahead” (hereinafter, the “Site”), with this privacy policy (hereinafter, the “Privacy Policy”) in compliance with EU Regulation n. 679/2016 (hereinafter, “GDPR”) and the applicable national data protection legislation, informs the users browsing the Site (hereinafter, the “Users”) on how their personal data (hereinafter, “Data”) is managed and allows them to give their express and informed consent to the processing of the Data, where necessary.
1.2.    This Privacy Policy applies only to the Site and not for any third-party sites that the User may access through links on the Site.
1.3.    By accessing and using the Site, the User acknowledges that he/she has carefully read this Privacy Policy and that he/she accepts its purposes and methods of processing. If the User does not accept the contents of this Privacy Policy, he/she is invited to leave the Site and, in any case, not to use its contents and/or services.
1.4.    All Data provided by the User (name, surname, email address, telephone number, etc.) will be collected, stored and processed exclusively in accordance with the GDPR.
1.5.    Processing of Data shall mean any operation or set of operations, carried out with or without the help of electronic means, concerning the collection, recording, organisation, storage, elaboration, modification, selection, comparison, interconnection, blocking, communication, dissemination and destruction of data, whether or not are contained or not in a data bank (hereinafter, “Processing”).

2.    DATA CONTROLLER
2.1.    The Company is the Data Controller of the Data provided or collected through the Site. The Company’s contact details are set out below:
Company name:        F.S.A. S.R.L.
Registered office address:    20123 – Milan (MI), Via Francesco Petrarca, no. 4, Italy
Email address:        maurizio@fullspeedahead.com
VAT:                03554300966

3.    PROCESSED DATA
3.1.    The following Data are processed:
3.1.1.    navigation Data: the Site’s hardware and software acquire certain Data whose transmission is implicit in the use of Internet communication protocols. This Data, through processing and association with data held by third parties, could allow Users to be identified. This category of Data includes the IP addresses of the User’s computers connecting to the Site, the time of the request, the method used to submit 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 (successful, error, etc.) and other parameters relating to the User's operating system and computer. We may also receive information about the User's geographical location and his electronic device. This Data is used solely to obtain anonymous statistical information on the use of the Site and to check its correct functioning and is deleted immediately after processing. The Data could be used to establish responsibility in the event of hypothetical computer crimes against the Site. Apart from this eventuality, Data on web contacts are currently not kept for more than seven days. Data relating to the User's geographical location may be used to provide information, suggestions and other personalised content based on location. If the User does not wish to share information about his/her geographical location, he/she should disable the location services on his/her device
3.1.2.    Data provided voluntarily by the User: the Data entered on the Site (during the registration of the User profile on the Site and/or the purchase of products on the e-commerce platform), as well as the Data sent by the User by email to the email addresses indicated on the Site (including the sender's email address and any other Data contained in the message)
3.1.3.    purchase Data: when purchasing products via the e-commerce platform on the Site, the Data provided by the User as part of the purchase process, and, in the case of Users registered on the Site, the Data provided for the purposes of registering with the Site.
3.1.4.    Cookies: the Site uses cookies to make the navigation easier, faster and more intuitive for the User and to improve the function of the Site. For more information about the cookies on the Site, please refer to the cookie policy [insert hyperlink] (hereinafter, the “Cookie Policy”).

4.    PURPOSE OF PROCESSING
4.1.    The Company processes User Data for the following purposes (hereinafter, the “Purpose”): 
4.1.1.    to enable the creation of User profiles and the sending of emails confirming the registration of the User profile on the Site;
4.1.2.    to enable the purchase of products through the e-commerce platform on the Site and to complete the transaction, deliver the products purchased, process any exchange and/or return requests or issue refunds;
4.1.3.    to create of a database of Users interested in the Site and its services;
4.1.4.    to process technical and commercial request form Users;
4.1.5.    to comply with legal obligations (including tax obligations) and to protect its prerogatives;
4.1.6.    to carry out direct marketing by email for products and services similar to those requested by the User (so-called “soft spam”);
4.1.7.    for marketing purposes, including sending newsletters and/or other promotional messages by email;
4.1.8.    for profiling purposes, e.g. analysing preferences in order to create content and offers.

5.    LEGAL BASIS FOR DATA PROCESSING
5.1.    The Company shall Process Data:
5.1.1.    for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, pursuant to Article 6(1)(b) of the GDPR;
5.1.2.    for compliance with a legal obligation to which the controller is subject, pursuant to Article 6(1)(c) of the GDPR;
5.1.3.    on the basis of the Company’s legitimate interest, pursuant to Article 6(1)(f) of the GDPR;
5.1.4.    with the User’s consent, pursuant to Article 6(1)(a) of the GDPR, form marketing and profiling purposes.

6.    METHOD AND PLACE OF DATA PROCESSING
6.1.    Data will be processed by automated means for the time strictly necessary to achieve the Purposes for which they were collected.
6.2.    The Company has adopted technical solutions and security measures that guarantee the security of Data and prevent their alteration, loss, incorrect processing or unauthorised access.
6.3.    Processing related to the services of the Site may take place on servers of third party companies that provide hosting services on behalf of the Company.
6.4.    Where Data is transferred outside the European Union, such transfers will be made pursuant to Articles 45 and 46 of the GDPR, ensuring an adequate level of data protection.

7.    DISCLOSURE OF DATA TO THIRD PARTIES
7.1.    The Data collected and stored in the Company’s databases will be processed by its employees and/or cooperators as persons in charge of processing such data.
7.2.    The User’s Data may also be processed by third parties whom the Company uses to uses to carry out activities on its behalf (e.g. analyse data, store data, send newsletters or other commercial or non-commercial communications, provide marketing assistance, carry out market analysis, deliver purchased goods, manage the credit card payment platform and other customer services).
7.3.    The Company provides these parties only with the Data necessary to carry out the agreed activities and they act as data processors (hereinafter, the “Data Processors”). These subjects have been selected because they are considered to have sufficient experience, capacity and reliability, as well as the ability to guarantee applicable privacy regulations. The User may request the list of Data Processors by writing to maurizio@fullspeedahead.com.
7.4.    With regard to the scope of communication of the Data, the Data provided by the User or otherwise collected may be communicated to the following subjects or categories of subjects:
7.4.1.    Public administrations, in order to fulfil obligations imposed by law, regulation or national or EU legislation;
7.4.2.    parent, subsidiary or associated companies of the Company;
7.4.3.    other companies or natural personal contractually linked to the Company and specifically entrusted with the processing of Data on behalf of the Company.

8.    NATURE OF DATA PROVISION
8.1.    Certain required fields on the Site (which may be marked with a star or other symbol) may be mandatory, for example, to enable valid registration on the Site, to provide the products you wish to purchase and to process any requests.
8.2.    By entering his/her Data on the Site, the User guarantees that the personal information provided is accurate and up-to-date. He/she also acknowledges that he/she is solely responsible for the Data provided, whether personal data, photos, comments or otherwise, and releases the Company from any liability.
8.3.    The provision of Data that may processed by the Company for marketing and profiling purposes is entirely optional. Failure to consent to the processing of Data for such purposes or the subsequent withdrawal of consent, will not prevent the User from browsing the site and making purchases through it.

9.    WITHDRAWAL OF CONSENT
9.1.    You may withdraw your consent to marketing activities (including the sending of newsletters) or profiling by the Company at any time by sending an e-mail to maurizio@fullspeedahead.com.
9.2.    Withdrawal of consent does not affect the lawfulness of processing based on consent prior to withdrawal.

10.    PERIOD OF DATA RETENTION
10.1.    The Data processed in the course of the activity are kept by the Company for the period of time necessary to pursue the specific purposes of each Processing and to ensure compliance with the applicable legal provisions.
10.2.    Data processed for the fulfilment of contractual obligations, including pre-contractual activities, will be kept by the Company for 10 (ten) years from the conclusion of the contract for the sale of goods through the Site or, if the latter is not concluded, for the time necessary to respond to the User's requests.
10.3.    Data processed for the management and keeping of company accounts will be kept for the time necessary to fulfil fiscal and accounting obligations.
10.4.    The Data processed by the Company for "soft spam" activities will be processed until the User objects to the processing, which can be done sending an e-mail to maurizio@fullspeedahead.com.
10.5.    The Data collected by the Company, with the User's consent, for marketing and profiling purposes may be kept for up to 7 (seven) years, following the data protection impact assessment carried out by the Company itself. After this period, the Company will take steps to obtain a new consent and, failing this, the Data will be deleted from its database.
10.6.    The e-mail address collected for subscription to the newsletter will be kept until the User's consent is revoked, to be exercised in accordance with the provisions of the "Withdrawal of Consent" section of this Privacy Policy.
10.7.    With regard to the storage of data collected through cookies installed on the Site, please refer to the section 'Cookies installed on the Site' of the Cookie Policy [insert hyperlink].

11.    MINORS
11.1.    The newsletter service is not directed to minors under the age of 16, or to minors whose age makes it illegal to process their data or who require parental consent for the processing of their Data under local laws (hereinafter, the “Age Limit”).
11.2.    The Company does not knowingly collect Data from minors under the Age Limit. Therefore, if you are under the Age Limit, please do not subscribe to the newsletter and do not provide any Data.
11.3.    If you are the parent of a minor under the Age Limit and you became aware that your child has provided Data to the Company, please contact us by sending an email to maurizio@fullspeedahead.com. We also remind you that you may exercise the rights described in the "User’s Rights" section of this Privacy Policy.
11.4.    If the Company learns that it has collected Data from a minor under the Age Limit, it will take reasonable measures to delete the Data.
11.5.    In any event, by registering on the Site or by any voluntary provision of Data to the Site, the User confirms that he/she is above the Age Limit.

12.    USERS’ RIGHTS
12.1.    Users may at any time exercise their rights under data protection legislation (in accordance with provisions of Articles 15 to 22 of the GDPR), including the right:
12.1.1.    to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and to the specific information of article 15(1)(a)-(h) of the GDPR;
12.1.2.    to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her and to have incomplete personal data completed, including by means of providing a supplementary statement;
12.1.3.    to obtain from the controller the erasure of personal data concerning him or her without undue delay;
12.1.4.    to obtain from the controller restriction of processing where the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; or the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; or the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; or the data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject
12.1.5.    to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided;
12.1.6.    to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1) of the GDPR end for direct marketing purposes, including profiling based on those provisions;
12.1.7.    not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her;
12.1.8.    right to lodge a complaint with a supervisory authority.
12.2.    Request to exercise the rights under article 12.1 of this Privacy Policy must be sent by registered letter with acknowledgement of receipt, addressed the registered office address of the Company.
12.3.    Request relating the exercise of tights will be dealt without undue delay and, in any event, within one month of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. In that case, the Company will inform of any such extension within one month of receipt of the request, together with the reasons for the delay. The Company will inform without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

13.    CHANGES ON THE PRIVACY POLICY
13.1.    The Privacy Policy may be subject to changes and updates. Users are invited to consult it periodically.