Privacy policy (version 2.0)

Index

A. Type of Personal Data Processed
B. Personal Data Processing of Children below the Age of 18 Years
C. Purposes of the Personal Data Processing
D. Lawful Basis for Processing Personal Data, Mandatory/Discretionary Provision of Personal Data and Consequences in case of not providing
E. Personal Data Sharing
F. Personal Data Transfer
G. Personal Data Retention
H. Data Subject Rights
I. Privacy Policy Amendments

The following Privacy Policy is written by Panini UK Limited., registered office at Brockbourne House, 77 Mount Ephraim, Tunbridge Wells, Kent, TN4 8BS, U.K. Business Registered in England No. 1275893 - VAT Number GB244971344 (hereinafter "Panini") as Data Controller of the personal data collected in our websites and applications for smartphones and tablets (hereinafter websites and applications are collectively referred to as "Application" and/or "Applications"), provided directly by you or however received or generated by us in connection with the, services, subscriptions or Applications we may provide (“Services”).

Panini considers your privacy essential. We therefore ask you to read this information carefully in order to make a freely given, specific, informed and unambiguous choice when you are requested to give your personal data to log in to the Applications or part of them and when your personal data are necessary to use services provided by the Applications for example to purchase of products or services.

In general, all the personal data (hereinafter "Personal Data" and/or "Data") collected by Panini through the Applications or received by Panini in relation to the Services as fully described in the following section "C. Purposes of Personal Data Processing" of this Privacy Policy, will be processed lawfully and in a transparent manner in accordance with the principles stated in the current legislation on the protection of personal data, such as transparency, fairness, lawfulness, data minimisation, purpose limitation, accuracy, storage limitation, integrity and confidentiality.

This Privacy Policy is written on the basis of the transparency principle using simple and not too legal language to increase the level of understanding of the statements given.

This Privacy Policy is divided into sections (hereinafter collectively "Sections" and/or individually "Section"), each of them dealing a specific topic, so that you can immediately find what you are looking for and concentrate your attention on the topic of interest.

The Panini Applications may contain links to other websites and/or smartphone applications. Panini is not responsible for privacy practices or the content of such websites and/or smartphone applications.

A. Type of Personal Data Processed

Personal Data collected through the Application or otherwise in relation to the Services are listed below.

Name, Last name, Contact Details and other Personal Data

When you create an account to log into the Application, Panini may ask your personal information such as: name, last name, gender, contact details, month and year of birth of the purchaser and of the reader, county or state and country of residence.

In the same way, you may be asked to indicate other Data such as: shipping address, the choice of payment method and the age of the reader on the occasion of each purchase of goods and/or services; Data coming from your submission of texts or registration information, on the occasion of participation in competitions, promotions, interactive games and initiatives of any kind. Further Personal Data may be collected during the management of each relationship through the Application itself or may consist of those that you decide to provide to Panini through the use of the Application / Customer Service area of ​​the Application.

Some sections of the Application can include free text fields in which it is possible to provide Panini with information that may contain Personal Data. Being free fields, you may choose to communicate (even inadvertently) particular categories of Personal Data, such as those revealing political opinions, religious or philosophical beliefs, or union membership, as well as genetic data, biomedical data which can permit to uniquely identify a specific person, data related to health or sex life or sexual orientation.

Panini asks you not to disclose any of these types of data, unless you consider it strictly necessary to pursue the request you forward to us. Since the indication of such information is, as said, totally optional, if you choose to do so, Panini will consider this to have been made public by you to us for these purposes (but Panini will not further publicise or use such data). You may request the removal or deletion of this data at any time by contacting us.

Personal Data of Third Parties

As mentioned in the previous paragraph, by providing in the Applications free text fields in which it is possible to forward any type of message, these could in fact contain Personal Data relating also to other people. We ask that you do not submit any Personal Data relating to third parties without first obtaining their express consent. In any cases in which you decide to share such Data, you will be deemed to have confirmed to us that you have obtained such express consent from the applicable third party. Therefore, in this regard, you agree to be responsible for and to hold Panini harmless from and against any dispute, claim, request for compensation for damage from data treatment etc. that could reach Panini from people whose Personal Data have been forwarded by you without their consent or otherwise in violation of the applicable rules on the protection of Personal Data.

As, in such cases, Panini does not collect this information directly from the data subjects (but indirectly from you), you guarantee that this specific treatment can be based on the consent of these data subjects or on another suitable lawful basis that legitimises the processing of the information in question.

Browsing Data and Cookies

As you interact with our Application, and in particular our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. This information is not collected by Panini to be associated with identified you, but by its very nature could, through processing and association with data held by third parties, allow you to be identified. This category of data includes the IP addresses or domain names of the devices used by you in connecting to the Applications, the addresses in URI (Uniform Resource Identifier), notation of the requested services, 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 result, error, etc.) and other parameters related to the browser, operating system and your device.

The information on the use of cookies is available in our Cookie Policy, which we kindly ask you to read by clicking on Manage Cookies in the website footer.

B. Personal Data Processing of Children of Age below 18 Years

Our Applications and Services are intended for use by those aged 18 and over.

People under the age of 18 are not permitted to purchase goods, subscribe to products or access any of the Services through the Application.

Children are not eligible to use the Services we offer and we ask that children (persons under the age of 18) do not submit any personal information to us.

C. Purposes of the Data Processing

We will process your Personal Data for the following purposes:

• allowing the execution of operations strictly connected and instrumental to the management of relationships with you, such as managing the response to queries received from you; executing contracts for the sale of goods and/or services, managing and fulfilling orders via E-Commerce platforms; allowing you to participate in games, initiatives, competitions and prize events (Services Provision);
• allowing the correct execution of the contractual obligations we have assumed towards you and vice-versa (Contractual Obligations);
• complying with the laws and regulations of England and Wales legislation or EU Legislation as applicable and with any provisions issued by authorities empowered by law and provisions issued by Supervisory and Control Bodies, as well as allowing tax and accounting compliance (Legal Compliance);
• to get the information required to identify anomalies, illegal activity and/or abuse of the use of the Applications towards Panini UK or third parties (Security).
• carrying out information activities about our products and/or services as well as promotional, commercial, marketing campaigns and market research through the use of automated systems without operator intervention (for example, e-mail), but also through traditional methods of contact, such as the postal service; performing customer satisfaction surveys (by sending questionnaires, conducting surveys or conducting surveys) (Marketing);
• sending you, if you are using or have used a service on our Applications or if you are buying or you have bought a product or a service through the Application, direct marketing and promotional communication via e-mail about similar products or services (Soft Opt-In);
• setting-up groups of users by processing the data provided by our users so that we don’t send generalised commercial and promotional communications to all users in an indistinct way. This enables us to segment users, creating groups based upon common features for example, on the country of origin, language, gender, previous purchases, etc. This allows us to send commercial communications - through the use of automated systems without the intervention of the operator (for example, e-mail), but also through traditional methods of contact, such as the postal service - that are the most relevant and least invasive possible, limiting as far as possible the circumstance that you receive messages not of your interest (Profiling).

D. Lawful Basis for Processing Personal Data, Mandatory/Discretionary Provision of the Personal Data and Consequences of not Replying

The lawful basis for processing the Personal Data, in accordance with the purposes set in the earlier Section of this Privacy Policy ("Purposes of the Data Processing"), is as follows.

The provision of Personal Data and the related processing for the purposes related to Services Provision and Contractual Obligations, is strictly functional to the performance of the requested service and the correct execution of the contractual relationship with you and therefore they constitute a necessary condition for the establishment of the contractual relationship itself and the lawful basis of the processing. Consequently, failure to provide the Personal Data requested for this purpose, or the inaccuracy of the data provided, will make it impossible for Panini to carry out the service and the contractual relationship and would legitimise Panini to refuse to carry it out.

The provision of personal Data, and the related processing for purposes related to Legal Compliance, is necessary for Panini in order to comply with the related legal obligations. When you provide your Personal Data to Panini, we must process them in accordance with applicable laws which may include the storage and communication to the competent authorities for compliance with tax, customs or other obligations.

The provision of Personal Data and its processing for purposes related to Security are based on the legitimate interests of Panini to identify and prevent any illegal behaviour and to determine the responsibilities in the event of illegal activity or any abuse to the detriment of the website such as to compromise the Services, as well as the availability, authenticity, integrity and confidentiality of the Personal Data stored or transmitted.

The provision of Personal Data, and the related processing of such data for the purposes related to the Marketing activity, is based on your consent collected through a specific checkbox. You are not forced to provide such consent to Panini and, if you do so, you are free to withdraw it at any time without suffering any consequence (other than not receiving marketing communications from Panini). You can withdraw your consent for this purpose by following the instructions contained in the “Data Subjects Rights” section of this Privacy Policy.

The provision of Personal Data, and the related processing, for the purposes related to the activity of Soft Opt-In is based on the legitimate interest of Panini to send marketing communications via e-mail regarding products and services similar to those you have already used or purchased through the application. You can stop the receipt of these communications without suffering any consequence (other than that of not being able to receive further communications of this kind by Panini) using the link at the bottom of each of the e-mails received for that purpose.

The provision of Personal Data, and the related processing, for the purposes related to the Profiling activity is based on your consent collected through a specific checkbox. You are not obliged to provide such consent to Panini and, if you do so, you are free to revoke it at any time without suffering any consequence (other than not being able to benefit from the personalisation of Panini's commercial offers). You can withdraw your consent for this purpose by following the instructions provided in the "Data Subjects Rights " section of this Privacy Policy.

E. Personal Data Sharing

The Personal Data will be made known to the Panini staff in charge of the development and management of the Applications that is authorised to process them for the purpose of achieving the aforementioned purposes and who are committed to confidentiality or otherwise have received an appropriate legal obligation to confidentiality.

Personal Data will be disclosed to subjects who hold the role of system administrators: these are our employees or our data processors who are entrusted with the management of our IT systems and who therefore have the power to access, modify, suspend and limit the processing of your Personal Data. These subjects have been previously selected and appropriately trained.

Personal Data may be shared, used and transferred within the companies belonging to the same group as Panini for accounting and administrative purposes.

Personal Data will be made known to third parties, appointed as Data Processors, as they process Data on behalf of Panini (for example, companies responsible for managing and processing sales orders, suppliers with whom it is necessary to interact for the Service Provision such as hosting providers, platform providers for sending e-mails or, again, suppliers who perform technical maintenance activities including the maintenance of network equipment and electronic communications networks, suppliers who develop interactive games and competitions, software developers for the payment systems, suppliers providing the technological platform and payment gateway for orders for products in the e-payments area, payment service providers for e-payments activities).

Personal Data may be shared with third parties with whom Panini has ongoing contractual relationships concerning services functional to the performance of the activity (such as couriers for the delivery of products, audit firms, persons, companies or professional firms that provide assistance and advice on the subject, administrative, legal, tax, financial and credit recovery firms relating to the provision of the Services).

Finally, Personal Data will be communicated when requested to the competent taxation offices, or to other public bodies, according to the provisions of the laws in force.

Personal Data is not intended for publication or dissemination.

More information is available by writing to Panini at the following address: webprivacy@panini.co.uk

F. Intenational Transfers

Given the international presence of Panini group, some of your Personal Data may be shared with recipients, referred to in the previous paragraph, which could be found in countries outside the UK and European Economic Area. Panini ensures that the processing of your Personal Data by these parties will be in compliance with applicable law.

Where Panini transfer your personal data outside the UK or outside the EEA, Panini does so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event Panini cannot or chooses not to continue to rely on either of those mechanisms at any time Panini will not transfer your personal data outside the UK unless Panini can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this privacy policy.

More information is available by writing to Panini at the following address: webprivacy@panini.co.uk

G. Personal Data Retention

The Personal Data processed for the purpose of Service Provision and Contractual Obligations will be retained by Panini for such time as is necessary for the execution of the requested service and for the correct execution of the contractual relationship with you. As this Personal Data is processed to provide you with the Services and allow the execution of the contractual relationship, Panini may keep them for a longer period, in particular for what may be necessary in order to protect the interests of Panini against possible claims arising from the provision of the Services.

Data related to contacts who have had financial transactions are kept for 10 years from the last transaction date owing to regulatory and tax requirements and s by competent authorities and to assess, defend or bring legal claims.

Data related to contacts without financial transactions but with despatch history are kept for three years from the last despatch date.

Data related to contacts without financial transactions or despatch history are kept for two years from the last contact interaction date.

Your requests, and the data contained in them, collected through the Contacts/Customer Service area of ​​the Applications will be maintained for one year from the closure of the request in order to allow Panini to handle any additional requests received after closure. At the end of this period the Data that permit the identification, even indirect, of a physical person (such as name, surname, e-mail) will be made anonymous and maintained, only in the form of aggregated data, for statistical purposes.

The Personal Data processed for the purposes of Legal Compliance will be retained by Panini for the period necessary to comply with specific legal obligations or applicable legislation.

Personal Data processed for the purposes of Security will be kept by Panini the time strictly necessary for the said purposes, and in in general no longer than seven days, except where circumstances require us to take action to protect our systems and data and to detect and prevent criminal activity which may be damaging for you or us, at which times we may need may need to keep any relevant Personal Data to disclose to legal authorities.

The Personal Data processed for the purposes of Marketing and Profiling will be retained by Panini until the revocation of the consent you have given and renewed periodically. Once your consent is withdrawn, Panini will no longer use your Personal Data for such purposes, but may retain them, particularly as may be necessary in order to protect Panini's interests from possible liability based on such processing.

Panini informs you that, in order to respond to the principle of limitation of conservation, the data processed for the purposes of Marketing and Profiling will in any case be maintained for a maximum of 54 months from the date of the last login in accordance with the logic used for the retention of authentication credentials to the Application Services referred to above.

The Personal Data processed for the purpose of Soft Opt-In will be kept by Panini until you object to the process through the link found at the bottom of each of the Soft Opt-In e-mails sent.

H. Data Subjects Rights

At any time you are entitled, as Data subject, to:

• request access to your Personal Data, (and/or a copy of such Personal Data), as well as further information on the current treatment of them;
• request the correction or updating of your Personal Data processed by Panini, where they are incomplete or out of date;
• request the deletion of your Personal Data from the Panini databases, where you deem the processing unnecessary or illegitimate;
• request the limitation of the processing of your Personal Data by Panini, where you believe that your Personal Information is not correct, necessary or is unlawfully processed, or if you had opposed its processing;
• exercise the right to data portability, i.e. to obtain a copy of the Personal Data supplied to Panini that relates to you in a structured format, for common use and readable by an automatic device, or to request transmission to another Data Controller;
• oppose the processing of your Personal Data, using a legal basis relating to your particular situation, which you believe should prevent Panini from processing your Personal Data;
• to revoke your consent to certain cookies when using the website by clicking on the Settings button in the appropriate banner, always accessible by clicking on Manage Cookies located in the footer of the website;
• revoke your consent for the purposes of Marketing and Profiling and to oppose the processing for the purpose of Soft Opt-In.

Please note that the Personal Data you provided to Panini may be changed at any time by writing to: webprivacy@panini.co.uk. You may exercise the above rights by means of the methods indicated above.

We inform you that for the Marketing and Soft Opt-In purposes you can revoke and terminate at any time the sending of this commercial information, by writing to the e-mail address indicated above, in addition to using any unsubscribe options set out in the relevant e-mails.

In general, if the information provided by you is not sufficient to identify you with a sufficient degree of certainty, taking into account the specific type of right exercised (such as, in particular, your right to request access to your Personal Data, data portability and right to request the deletion of your Personal Data), Panini will request further information from you as required by specific regulatory provisions regarding the protection of personal data. In the event that Panini detects the absence or lack of suitable data to identify you and therefore there are reasonable doubts about your identity, Panini may then ask you to provide a copy of an identification document or any additional information deemed useful for your identification. In the event that you provide such a document, personal details such as your first and last name and your address should be clear in order to be able to identify you correctly, while any other information such as your photo or any other personal characteristics not necessary for identification should be removed or obscured before sending. We specify that our use of the information on your identity document is strictly limited to fully accounting for your request: in fact, such Data will be used only to verify your identity and will not be kept for longer than necessary for this purpose.

Panini informs you that you always have the right to lodge a complaint with the competent Supervisory Authority (for example that of the country in which you have your habitual residence: in the UK, this is the Information Commissioner’s Office or “ICO”, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, telephone 0303 123 1113, www.ico.org.uk.) if you believe that the processing of your Personal Data is contrary to the legislation in the field of personal data protection currently applicable.

I. Privacy Policy Amendments

This Privacy Policy was last updated on 12 September 2023. Panini reserves the right to modify or update the content of this policy (in part or completely), for example where there are changes to the applicable legislation. Panini may not inform you of these changes as soon as they are introduced, but they will be applicable as soon as they are published on the website. Panini invites you to visit this section regularly to review the most recent and updated version of the Privacy Policy in order to understand the Personal Data collected and the use that Panini makes of it.