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Privacy Policy


INFORMATION NOTE ON PRIVACY

The data controller is BECOME S.r.l. (hereinafter "BECOME" or "Controller"), with its registered office at Via Carlo Valvassori Peroni 74/2, 20133 Milan, Italy.

BECOME will process your Personal Data in accordance with EU Regulation No. 2016/679 and national legislation on the protection of personal data (hereinafter referred to as "Privacy Regulation").


What Personal Data do we process and how do we collect it

a) Navigation data

Your navigation on the Site (www.discoverbecome.com) and/or access to certain sections of the Site or the App (app.become-hub.com or platform.become-hub.com) may involve the collection and subsequent further processing of your Personal Data by BECOME. In fact, during the connection to the Site/App, the computer systems and software procedures responsible for their operation automatically and indirectly provide and/or acquire certain information (such as, by way of example, the so-called "cookies," as specified in the "Privacy Notice – Cookies," which can be found at the end of this notice, "IP" addresses, domain names of the computers used by users connecting to the Site/App, the "Url" addresses of the requested resources, and the time of the request to the server).

b) Data voluntarily provided by the interested party

Your registration on the Site/App and/or any requests for information or services from you may involve the collection and subsequent further processing of your Personal Data (such as name, surname, postal and email address, password, age, date of birth, gender, image, profession, marital status, etc.).

In particular, the collection of your Personal Data may take place:

  • by completing online (digital) and offline (paper) forms on your part;
  • through your registration via social log-in; and
  • through your publication of Contributions (as defined below), the content of which may include your Personal Data provided directly by you, on social networks independently managed by third parties, such as, by way of example and not limited to, Facebook, Twitter, LinkedIn, etc. (hereinafter referred to as "Social Networks"). By "Contributions," we mean the images, comments, catchy phrases associated with the subject of the Site/App, the content, and any other information created and published by you on the Social Network pages dedicated to products of the various brands of the BECOME group, including any image you may provide. The publication of Contributions may also occur through a pseudonym ("nickname") chosen by you during the registration phase on the Site/App, and possibly the image you have associated with your nickname. In choosing the nickname and any associated image, you remain solely responsible for any harm that the use of the nickname or image may cause to third parties.

If you choose to register on the Site/App or to submit a request through the section "CONTATTI” of the Site/App, the provision of certain Personal Data is necessary for BECOME to meet your needs within the functionalities of the Site/App, for which the relevant fields of the registration form are marked with an asterisk or otherwise designated as mandatory. The provision of Personal Data not marked with an asterisk or otherwise designated as mandatory is purely optional, and the failure to provide, partial provision, or inaccurate provision of such Personal Data has no consequences. Instead, the failure to provide, partial provision, or inaccurate provision of the Personal Data marked with an asterisk or otherwise designated as mandatory makes it impossible to fulfill the service you requested. In the event that you have omitted to provide one or more mandatory Personal Data, an error message from BECOME will appear with the list of missing mandatory Personal Data.

You can register on the Site/App also through social log-in, that is, through automatic filling, thanks to your request to a Social Network, to which you are subscribed, to communicate to BECOME some of the data you have already provided to the Social Network; in this latter case, BECOME recommends paying attention to the following: by selecting the link that allows registration through a Social Network, present on the Site/App or on one of BECOME's pages on the Social Network, a window will appear containing a box to accept the communication of your Personal Data from the Social Network to BECOME and a link to deselect the Personal Data that you do not wish to communicate to BECOME.

The data voluntarily provided by the Data Subject are those necessary for the Data Controller to provide the available services and are processed lawfully and fairly. Furthermore, such data are collected and recorded for the specific, explicit, and legitimate purposes indicated later and are used in processing operations that are not incompatible with those purposes.


What are the purposes of processing your Personal Data and its legal bases

According to the needs you express from time to time by accessing the various sections of the Site/App (and except for individual initiatives that involve the provision of specific Personal Data, for which specific information will be published from time to time on the Site/App), the purposes of processing your Personal Data and the related legal bases are indicated below.

Your Personal Data will be processed for the following purposes solely with your consent to the processing, which can be revoked at any time by accessing your profile page (where you can uncheck the relevant box), deleting your profile, using the link at the bottom of each promotional email (regarding marketing activities and the newsletter), or according to the methods indicated from time to time by the Data Controller at the time of consent collection:

a) Management of and response to your requests

You may choose to give consent for the processing of your Personal Data for the management and response by BECOME to your requests regarding products and initiatives of the various brands of the BECOME group, advertising, or the Site/App (section “CONTATTI” of the Site/App). In relation to this purpose, your consent is required at the time of submitting requests. If you decide not to give consent for the processing of your Personal Data for the aforementioned purpose, it will not be possible to proceed with the submission of your request.

b) Marketing activities

You can choose to give consent for the processing of your Personal Data for marketing purposes, that is, for commercial communications, including via e-mail, SMS, and push notifications, regarding the sending of promotional and advertising material related to any brand of the BECOME group or conducting market research. In relation to this purpose, your consent is required at the time of registration on the Site/App. In the section of your personal profile on the Site/App, you can choose through which channels you prefer to receive commercial communications (for example, all or some of e-mail, SMS, regular mail, push notifications) and select the brands of the BECOME group that interest you.

You can choose to subscribe, by giving your consent, to one of the newsletter services of the BECOME group. In relation to this purpose, your consent is required at the time of subscribing to the same newsletter service.

c) Profiling activities

You may choose to give your consent to be subjected to profiling, that is, to the analysis of your habits and/or consumption choices as well as the comparison of your Personal Data present in the various databases of or in use by BECOME, for example, for the purpose of sending personalized promotional communications, personalizing the content displayed on the Site/App, publishing banners, and conducting statistical surveys. There are various activities that can contribute to the creation of your profile, such as participating or not in prize events, interacting with the Site/App, purchasing products from the various brands of the BECOME group, or posting Contributions on the Social Network pages dedicated to products from the various brands of the BECOME group. In relation to this purpose, your consent is required at the time of registration on the Site/App.

d) Publishing activities

You may decide to give consent for the publication or dissemination of audio recordings, photos, and videos featuring your image and/or voice for educational, informational, research, or scientific purposes, including the editing of clips or individual frames, for the institutional purposes of the BECOME group, specifically for publication on websites, as well as for non-commercial publications on the BECOME group's social media channels (Facebook, Instagram, LinkedIn, Twitter, Twitch, TikTok, YouTube, Vimeo, WhatsApp, Telegram), in print media and/or any other means of dissemination.

The legal basis that legitimizes the processing of data referred to in point a) is the execution of a service supply contract to which the Data Subject is a party, or the performance of pre-contractual activities. In the cases indicated in points b), c), and d), the legal basis is the freely given consent of the Data Subject.

Furthermore, even in the absence of your consent, BECOME may process your Personal Data for the following purposes:

  1. management of your registration on the Site/App and activities related to the activation and use of the services offered therein, your interaction with the Site/App and with the sections present in it (for example, access to the reserved areas of the Site/App as well as your publication of Contributions on the Social Network pages dedicated to products of the various brands of the BECOME group), including the sending of so-called "transactional" emails related to the registration procedure on the Site/App and the maintenance of your active account (as this processing is necessary for the execution of a contract or for pre-contractual measures);
  2. management of your potential participation in prize events, including the evaluation, assignment, and communication of both the offer of complimentary points and bonus points as well as the opportunities for accumulating them (through the sending of so-called "transactional" emails related to your potential participation in the promotion) as well as the awarding of prizes (as processing necessary for the execution of a contract or pre-contractual measures);
  3. management and execution of the obligations required by law (accounting, administrative, tax nature, etc.);
  4. management of disputes and any potential litigation (as it is a legitimate interest of the Data Controller).


Who are the recipients of your Personal Data

Your Personal Data may be communicated to and processed by:

  1. legal or natural persons acting as external data processors, performing outsourcing activities, appointed by BECOME or by the external data processors of BECOME (including entities entrusted with activities related to assistance, communication, marketing, advertising, promotions, and the sale of products and/or services as well as advertisers, advertising agencies, IT service providers, managers of the Site/App, managers of electronic platforms, partners, credit institutions, professional firms), such as, for example, Amazon AWS (Ireland), Odoo, Slack, Vercel, Swell, Sentry, Fitbit, Samsung, Canva, Mailchimp, Meta, Google, LinkedIn, Stripe, Fatturazione CGN;
  2. employees and/or collaborators of the Data Controller (including system administrators) who, operating under the direct authority of the latter, will be authorized to process your Personal Data; and
  3. employees and/or collaborators of external data controllers (including system administrators) who, operating under the direct authority of the external data controllers, will be authorized to process your Personal Data.

Your Personal Data will not be communicated to third parties except in cases where your Personal Data needs to be shared by BECOME with consultants in order to protect its rights, nor will it be disclosed. In the event that you have included Personal Data in your nickname and/or have associated an image with it, there may, however, be a dissemination of such Personal Data through the Site or Social Networks.


How we handle your Personal Data

The processing of your Personal Data may include any type of operation, including collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion, and destruction.

Your Personal Data will be processed primarily in an automated manner but also in paper form, with logic strictly related to the respective purposes, through databases, electronic platforms managed by BECOME or by third parties appointed for this purpose responsible for external processing and/or integrated IT systems of BECOME and the aforementioned third parties and/or websites and/or apps owned or used by BECOME.

The Data Controller has assessed the level of security as adequate, taking into account the risks that could arise from loss, destruction, alteration, unauthorized disclosure, accidental or illegal access, abuse, or alteration of your Personal Data. In particular:

  • has adopted security measures appropriate to the risks;
  • stores your Personal Data on servers primarily located within the European territory (to learn about the methods of transferring Personal Data outside the European Economic Area, please see the following section “Transfer Outside the European Economic Area of your Personal Data”). In any case, the servers are subject to an advanced and daily backup system.


Where we process your Personal Data

Your Personal Data is primarily processed at the locations of the Data Controller and in places where the data processing managers are located. For more information, contact the Data Controller at the contact details provided in the section "Identity and contact details of the Data Controller."


Transfer of your Personal Data outside the European Economic Area

Your Personal Data may be transferred outside the European Economic Area, namely outside the European Union and Iceland, Norway, and Liechtenstein (specifically to the United States of America) to be stored by third parties appointed as external data processors. The transfer is carried out by BECOME, subject to the signing of Standard Contractual Clauses in accordance with the models prepared by the European Commission with the server and/or service providers, or verification of the registration of the external data processor within the system known as "Privacy Shield," when implemented for compliance with the ruling of the Court of Justice of the European Union in the judgment delivered on July 16, 2020, in case C-311/18.


How long do we keep your Personal Data

In order to ensure compliance with the principles of necessity and proportionality of processing, the Data Controller has identified different retention periods for Personal Data in relation to the specific purposes pursued:

  1. for the purpose of managing your registration on the Site/App as well as the activities related to the activation and use of the services offered therein, your Personal Data will be retained for the time strictly necessary and, in any case, for a maximum period until your profile is active. For security reasons, we will use log data to verify account usage and, in the event of your inactivity for a period exceeding 24 months, you will be contacted to verify your interest in keeping your account active, and you will be informed of the ways to express that interest. In the event of no activity in the following 30 days, your account will be deleted;
  2. for the purpose of managing and responding to your requests regarding products and initiatives of the various brands of the BECOME group, advertising, or the Site/App (section "CONTATTI” of the Site/App), your Personal Data will be kept for the time strictly necessary to fulfill your request;
  3. for marketing purposes, that is, for commercial communications, including via e-mail, SMS, and push notifications, regarding the sending of promotional and advertising material related to any brand of the BECOME group or the conduct of market research, your Personal Data, excluding contact information, will be retained for a maximum period of 36 months;
  4. for profiling purposes, that is, the analysis of consumption habits and/or choices as well as the comparison of your Personal Data present in the various databases of or in use by BECOME, for example, for the purpose of sending personalized promotional communications, personalizing the content displayed on the Site/App, publishing banners, and conducting statistical surveys, the Personal Data that contribute to the creation of your profile will be retained for a maximum period of 36 months;
  5. for the purpose of sending newsletters, your Personal Data, excluding contact information, will be retained for a maximum period of 10 years.
  6. for the purpose of managing your potential participation in prize events as well as for the related regulatory, administrative, and accounting obligations, your Personal Data will be retained for the duration of each prize event and for the time strictly necessary to complete the related activities;
  7. for the purpose of managing and executing the obligations required by law (of an accounting, administrative, tax nature, etc.), your Personal Data will be retained for the time strictly necessary for this purpose;
  8. For the purpose of managing disputes and any potential litigation, your Personal Data will be retained for the time strictly necessary for this purpose and, in any case, no longer than the applicable statute of limitations.


Minors

Minors under the age of 16 must not provide information or Personal Data to BECOME without the consent of those exercising parental responsibility over them. In the absence of such consent, registration of the minor on the Site/App will not be possible. BECOME encourages all those who exercise parental responsibility over minors to inform them about the safe and responsible use of the Internet and the Web, and to implement the procedures indicated during the registration phase on the Site/App concerning the registration of individuals under the age of 16.


Identity and contact details of the data controllers

The complete list of data controllers can be consulted by contacting the Data Controller at the contact details provided in the section "Identity and contact details of the Data Controller."


Contact details of the Data Protection Officer (DPO)

The Data Protection Officer appointed by the Data Controller has the following contact details: staff@become-hub.com


Your rights regarding the processing of your Personal Data

The Privacy Regulation recognizes you, as the interested party, numerous rights. In particular, you have the right to:

  1. right of access – art. 15 GDPR: to obtain from the Data Controller confirmation of the existence or non-existence of your Personal Data, even if not yet recorded, and their communication in an intelligible form as well as access to your Personal Data (obtaining a copy) and the related information (including the purposes of processing, the categories and origin of the Personal Data, the categories of recipients to whom they have been or may be disclosed, the retention period (when possible), the rights that can be exercised);
  2. right to rectification – art. 16 GDPR: to obtain from the Controller the rectification of your Personal Data and the completion of your incomplete Personal Data;
  3. right to erasure (right to be forgotten) – art. 17 GDPR: accessing the section “CONTATTI” of the Site/App or by sending an email to the following email address: staff@become-hub.com, you can request the deletion of your profile on the Site/App and, in any case, obtain from the Data Controller the deletion of your Personal Data without unjustified delay, among other things, when the Personal Data is no longer necessary for the purposes for which it was processed or when there is no longer a legal basis for its processing;
  4. right to restriction of processing – art. 18 GDPR: to obtain from the Data Controller the transformation into anonymous form or the blocking of your Personal Data processed in violation of the law, including those for which retention is not necessary, in relation to the purposes for which the Personal Data was collected or subsequently processed; to obtain from the Data Controller the restriction of processing of your Personal Data, among other things, when you contest its accuracy or object to the processing, for the period necessary for the respective verifications;
  5. right to data portability – art. 20 GDPR: to receive, in a structured, commonly used, and machine-readable format, your Personal Data as well as to transmit or, where technically feasible, obtain the direct transmission of your Personal Data to another data controller without hindrance, in cases where the processing is carried out by automated means and is based on your consent or is necessary for the performance of a contract to which you are a party;
  6. right to object – Article 21 GDPR: accessing the section “CONTATTI” of the Site/App or by sending an email to the following email address: staff@become-hub.com, you can object at any time, for reasons related to your particular situation, to the processing of personal data concerning you based on the lawful basis of legitimate interest or the performance of a task carried out in the public interest or the exercise of public authority, including profiling, unless there are legitimate grounds for the Data Controller to continue the processing that override the interests, rights, and freedoms of the Data Subject or for the establishment, exercise, or defense of a right in legal proceedings; object at any time to the processing if personal data is processed for direct marketing purposes, including profiling, to the extent that it is related to such direct marketing;
  7. right of withdrawal – art. 7 GDPR: withdraw consent to the processing of your Personal Data for any of the purposes for which it was given;
  8. right to complain – art. 77 GDPR: to file a complaint with the Data Protection Authority, Piazza Montecitorio 121, 00186, Rome (RM).

You will be able to exercise your rights against BECOME by accessing the section “CONTATTI” of the Site/App or by writing to the following email address staff@become-hub.com or by sending a letter to BECOME via regular mail to the address indicated in the section “Identity and contact details of the Data Controller.”