PRIVACY

INFORMATION NOTICE RECIPIENTS

This information notice is intended for all subjects who interact with the flykly.com platform, and in particular:

  • those who browse the flykly.com platform, without registering; 
  • those who register on the flykly.com platform using the services offered online via the Website, including the e-commerce service.

This information notice does not cover other websites that may be consulted by the user via links contained in the flykly.com platform, for which flykly cannot be held liable in any way for any unlawful data processing by third parties.

This information notice is provided pursuant to art. 13 of the Privacy Code [Italian Data Protection Act] and EU Regulation no. 679/2016 (GDPR).

PERSONAL DATA CONTROLLERS

Any personal data provided or collected by means of operations which will be carried out on this flykly.com platform in order to (allow registration with the website and) access the services contained, including the e-commerce service, will be processed by flykly.com, as data controller, with head office in Milan, Via Soperga 57, 20127, listed in the Milan Business Register under no. MI-2077439, share capital fully paid up, VAT no. 09225000968, flyklysrl@legalmail.it

PURPOSES OF THE DATA PROCESSING

The purpose of the data processing is exclusively to:

  1. allow registration on the flykly.com platform;
  2. manage the access credentials to the flykly.com platform for administrative and legal requirements connected with use of the platform;
  3. allow correct performance of the procedures and compliance with the requirements connected with online purchase of the flykly products, including correct fulfilment of all the obligations arising from the purchase contract together with the relative administrative and legal requirements;
  4. allow, via use of the email address provided during the (registration on the flykly.com platform) or (purchase procedure), the sale of similar products or services, after acquiring specific consent; 
  5. allow the offer of discounts, promotions, concessions and other services, in addition to the sending of commercial information, free gifts, and information on promotions and events, after acquiring specific consent; 
  6. allow market research to be carried out and information to be provided on all the initiatives concerning the products, also by email, text message, post and telephone, after acquiring specific consent; 
  7. allow use of the data provided for analysis by flykly of consumer choices, to be carried out by identification of type and frequency.

SCOPE OF THE DATA COMMUNICATION

The personal data provided by the user can be brought to the knowledge of or communicated to the following subjects:
(i) to employees and/or collaborators of flykly, for carrying out activities of administration, accounting and IT and logistical support, who act as processors and persons in charge of the processing respectively;
(ii) to companies or consultants charged with the installation, maintenance, updating and, in general, management of the hardware and software of flykly (including the Platform);
(iv) to the subjects in charge of repair of the products purchased under the legal warranty;
(v) to all public and/or private subjects, individuals and/or legal entities (legal, administrative and fiscal consulting firms), if the communication is necessary or functional to correct fulfilment of the contract obligations undertaken in relation to the services provided via the Website and the legal obligations;
(vi) to forwarding agents and to subjects charged with delivery and/or collection of the products purchased;
(vii) to all subjects (including the Public Authorities) that have access to the data pursuant to law or administrative provisions.

The personal data provided by the users in relation to registration with the Website and/or purchase via the Website are not subject to disclosure. The updated list of the supervisors and persons in charge of the processing can be consulted at the office of the Data Controller.

DATA PROCESSING METHODS

The data will be processed with the aid of electronic, hardcopy and IT tools; said processing will follow the principles of correctness, lawfulness and transparency and safeguarding of your rights and confidentiality.

The data will be processed so as to minimize the risks of destruction, loss, unauthorized access or processing not permitted or not conforming to the purposes of the data collection.

PERSONAL DATA

The personal data provided voluntarily for the purposes specified in the preceding paragraph “Purpose of the Data Processing”, points 1, 2, 3 are necessary to allow registration on the flykly platform and provision of the reserved services, including the E-Commerce Service.

Furthermore, if, after registration on the flykly platform, you intend to make a purchase online, some further personal data must be provided in addition to those already provided at the time of registration, in particular, data relative to the delivery address.

CREDIT CARD DATA

To make a payment on the Website by credit card, the User must enter the confidential data of the credit card (card number, card holder name, expiry date, security codes). These data will be acquired by the provider of the payment service who will act as autonomous data controller, without passing through the flykly server which, therefore, will not process the data in any way. The data will be acquired in encrypted form and according to the security requirements of the PCI certification. The payment service uses the SSL Protocol. Via the Website, the user can request saving of these data, but said data will be saved directly by the provider of the payment service and will not be acquired by flykly which will keep a record only of the last four digits making up the credit card number, solely and exclusively to prevent online payment fraud.

SENSITIVE DATA

To register with the Website and make a purchase via the Website, sensitive data will never be requested.

BROWSING DATA

It is possible to access the Website and view the products offered for sale without any personal data being requested. However, during normal operation, the IT systems and software responsible for functioning of the Website acquire some personal data, the transmission of which is implicit in use of the Internet communication protocols.
Said information is not collected to be associated with identified data subjects but, due also to its very nature, it could, via processing operations or associations, allow identification of the user.
This category comprises the IP addresses or the domain names of the computers used by the users who access the Website, the Url addresses of the resources requested, the time of the request, the method used to submit the request to the server, the dimension of the file obtained in reply, etc. These data are used to obtain anonymous statistical information on the use of the Website (such as, in particular, the number of accesses) and to control correct operation thereof. This process does not entail the processing of direct identification information.
The browsing data will be acquired, according to the above procedures, only by flykly.

DATA PROVISION

Provision of the data is necessary to allow purchase via the Website; any refusal to provide the data in question will make it impossible to register with the Website and/or to make a purchase online.
With reference to the purposes of the processing for marketing and profiling, consent to the processing of personal data is optional and can be manifested by selecting an appropriate box, for each distinct purpose, provided at the bottom of the Website registration form. Failure to provide consent will not affect the possibility of registering with the Website and/or making purchases on the same and will entail exclusively the consequences described below:

DATA CONSERVATION

The personal data will be kept only for the time necessary to guarantee correct provision of the services offered.

RIGHT OF ACCESS TO PERSONAL DATA

The user has the right to:
a) obtain confirmation of the existence or otherwise of personal data concerning them and communication thereof in an intelligible form;
b) obtain, from each of the Data Controllers:
- indications of the origin of the personal data, the purposes and modes of processing, and the logic applied in the case of processing with the aid of electronic instruments;
- indication of the identification details of each of the data controllers;
- indication of the subjects or categories of subjects to whom the data can be communicated or who can obtain knowledge thereof in their capacity as designated representative in the territory of the State, as data supervisors or persons in charge of processing;
c) obtain:
- updating, rectification or integration of the data concerning him/her;
- cancellation, transformation into an anonymous form or blocking of data processed in breach of the law, including data which does not have to be kept in relation to the purposes for which the data have been collected or subsequently processed;
- certification that the operations in the preceding points have been brought to the knowledge, also as regards content, of those to whom the data have been communicated or disclosed, unless this is impossible or involves a deployment of means manifestly disproportionate to the right safeguarded;
d) oppose, wholly or partly:
- for legitimate reasons, processing of the personal data concerning him/her, even if pertaining to the purpose of said data collection;
- processing of personal data concerning him/her for the purposes of commercial information or dispatch of advertising or direct sales material or for carrying out market research or commercial communication.
The above rights can be exercised by request to the Data Controller, at the contacts given in the paragraph Personal Data Controllers of this information notice.
The right of opposition of the data subject to the processing of his/her personal data for the purposes specified in point 4, 5 of the paragraph “Purposes of the Data Processing” by electronic means (email) extends also to traditional communication methods (post), without prejudice to the possibility for the data subject to exercise said right partly, pursuant to art. 7, paragraph 4, letter b) of the Privacy Code [Italian Data Protection Act], i.e. by opposing, for example, only the sending of promotional communications by automated means.