PRIVACY POLICY

In accordance with Art. 13 of Regulation (EU) 2016/679 (GDPR)

Welcome to www.slate-collective.com. This Privacy Policy explains how the personal data of users who browse and interact with our website is processed.

Given the nature of the activities carried out on this site, please note that there are two distinct Data Controllers, depending on the purpose for which the data is collected:

Luca Armando Siani is the Data Controller for all other site activities (website management, contact forms, newsletters, analytics, etc.).
Pietro Maria Sbrugnera is the Data Controller for all E-commerce activities (purchases, order management, shipping, and invoicing).

Below are the details of the two Data Controllers:

1. Data Controllers

A) For all other site activities (Contacts, Newsletter, Browsing, Analytics):

Controller: Luca Armando Siani
VAT ID: IT13933450960
Address: Via Legnone 71, 20158, Milan (MI), IT
Privacy contact email: info@slate-collective.com

B) For E-commerce activities (Purchases, Payments, Shipping):

Controller: Pietro Maria Sbrugnera
VAT ID: IT04587040249
Address: Piazetta delle Poste, 36028, Rossano Veneto (VI), IT
Privacy contact email: pietro.sbrugnera@pec.it

2. Types of Personal Data Collected

The site collects different categories of personal data depending on the user's interaction:

Browsing data: IP addresses, browser type, pages visited (collected in aggregate form for statistical and security purposes).
Data provided voluntarily (Contacts/Newsletter): First name, last name, email address.
E-commerce purchase data: First name, last name, shipping address, phone number, email address, data required for invoicing, and payment information (the latter managed directly by secure payment gateways).

3. Purpose and Legal Basis of Processing

Processing is carried out for the following purposes, divided by Controller: For E-commerce activities (Controller: Pietro Maria Sbrugnera):

Performance of a purchase contract: Management of orders, payments, shipping, and after-sales support. Legal basis: Performance of a contract (Art. 6.1.b GDPR).
Legal and accounting requirements: Issuing invoices, accounting management, and tax compliance (e.g., retaining invoices for 10 years). Legal basis: Compliance with a legal obligation (Art. 6.1.c GDPR).

For all other activities (Controller: Luca Armando Siani):

Handling information requests: Managing messages sent via the contact form or email. Legal basis: Pre-contractual measures / Performance of a contract (Art. 6.1.b GDPR).
Newsletter and marketing communications: Sending updates, news, and promotions (subject to subscription). Legal basis: Consent of the data subject (Art. 6.1.a GDPR).
Statistical analysis and site improvement: Monitoring web traffic to optimize user experience. Legal basis: Legitimate interest of the Controller or Consent (if using profiling cookies).

4. Processing Methods

Personal data is processed using electronic and telematic tools, adopting appropriate security measures to prevent data loss, illicit or incorrect use, and unauthorized access. Data is processed exclusively by authorized personnel (Data Controllers) and will never be sold to third parties.

5. Data Retention Period

E-commerce Data (Pietro Maria Sbrugnera): Order and invoice data will be kept for the time strictly necessary to fulfill the order and subsequently for 10 years to comply with tax and accounting legal obligations.
Newsletter Data (Luca): Data will be stored until the user chooses to unsubscribe (revocation of consent) or until the newsletter service is terminated.
Contact Form Data (Luca): Kept for the time necessary to manage and respond to the user's request.
Browsing Data: Deleted or anonymized after a maximum period of [e.g., 14 months], unless extended for IT security investigations.

6. Data Recipients

Data may be communicated to third parties acting on behalf of the Data Controllers as Data Processors (Art. 28 GDPR), including:

Hosting and website maintenance service providers.
Couriers and freight forwarders (strictly for data required for order delivery).
Payment gateways (e.g., Stripe, PayPal) for transaction management.
Tax advisors and accountants (for accounting purposes).
Email marketing service providers (for sending the newsletter).

7. Transfer of Data to Third Countries

Some of the service providers used (e.g., hosting, analytics, payment gateways) may be located in the United States or other non-EU countries. In such cases, data transfer will take place in compliance with Chapter V of the GDPR, based on Adequacy Decisions by the European Commission or Standard Contractual Clauses (SCCs) approved by the European Commission.

8. Data Subject Rights

Pursuant to Articles 15 to 22 of the GDPR, the user has the right to obtain confirmation of the existence of their personal data and to exercise the following rights:

Access to their data and rectification.
Erasure (right to be forgotten) or restriction of processing.
Objection to processing.
Data portability (right to receive data in a structured format).
Revocation of consent (for newsletter and marketing).

How to exercise rights: Users may exercise their rights by sending an email request to the Data Controller responsible for the specific activity:

For data related to purchases and e-commerce, contact Pietro at: floorplan.exe@gmail.com
For data related to newsletters, contacts, and browsing, contact Luca at: slate.milan@gmail.com

9. Right to Lodge a Complaint

Without prejudice to any other administrative or judicial remedy, data subjects who believe that the processing of their personal data violates the GDPR have the right to lodge a complaint with the Data Protection Authority (Garante per la Protezione dei Dati Personali - www.garanteprivacy.it).

10. Cookie Policy

The site uses technical cookies (necessary for site and shopping cart functionality) and, subject to consent, analytical and profiling cookies. For more information on the use of cookies and how to manage or disable them, please consult our Cookie Policy.