Retail Hub Privacy Policy
Retail Hub S.r.l., with registered offices established in via Madonnina 19, 20121 Milan - Italy, (hereinafter referred to as “Retail Hub”), is strongly committed to the privacy and the protection of the personal data of the users of its cloud based b2b platform aimed at supporting retailers worldwide in searching and engaging start-up/scaleup companies selected and assessed by Retail Hub (the “Platform”).
Hence, this Privacy Policy is designed:- to inform you, in your capacity as user authorized to access and use the Platform as:
- to outline the choices you have with regard to the processing of your personal data.
(i) individual or corporate subscriber; or user of the Platform authorised by the subscriber (hereinafter referred to, collectively, as the “End Users”); or
(ii) user of the Platform as representative of a Start-Up selected by Retail Hub (the “Startup User”),
about how we process your personal data (hereinafter referred to, collectively, as the “Data”) as they are collected when you access or use our Platform or when you engage with our operators or other users by means of the Chat (available to all users), the Forum (available to End Users only), the Recommendations (available to End Users only) and Reviews (available to End Users only) (hereinafter referred to collectively as the “Services”); as well as
- access the Platform;
- create an account and register to the Platform;
- browse the Platform;
- request or use the Services;
- are connected to the platform through API
This Privacy Policy (along with our Terms of Service applicable to the relevant services, our Cookie Policy and other policies that may be provided in relation to the individual services) sets out the grounds based on which your Data will be processed
1. Which Data do we collect?
1.1 User Data collected through our registration form
In order to enable you to create an account and use the Platform, we need to collect he following Data:- Identification Data (name and surname);
- Contact Details (email address; phone number);
- Company Information (location of the main establishment; Tax / VAT number; sector of business, position etc.);
- Information about your industry and your interests (End Users only);
While providing your Data through the registration form is optional, failure to provide the specific data, marked as mandatory, as needed to complete the registration process, will prevent you from being able to access and use the Platform.
You also have possibility to provide us with additional and optional information about you, your industry and your interests, in the course of registration process. The provision of such further information is optional, but they will be very useful in order to improve your user experience, as more customized on your interests.
Please consider that - without your specific consent - such User Data collected through our registration form will not be used for marketing purposes nor shared with third parties for their own marketing purposes.
1.2 Technical Data
The information systems we use to ensure the smooth running of our Platform will, during normal operations related to your access and use of the Platform, acquire some personal data, the transmission of which is implicit in the use of electronic communication systems (the “Technical Data”)
These Technical Data may include URL information, online identifiers, including cookie data and IP addresses, information about the types of devices you are using such as unique device IDs, network connection type (e.g. Wifi, 3G, LTE, 5G, Bluetooth), provider, network and device performance, browser type, language, and operating system. For more information on the cookies we use, please read our Cookie Policy.
These data are not collected with the purpose to uniquely identify each data subject, but, given their nature, they may allow you to be identified if processed by and associated with data held by third parties.
These Technical Data will only be used to ensure the smooth running of the Platform and will be deleted soon after the processing is completed.
1.3 Usage Data (End Users only)
According to the Terms of Service, Retail Hub provides End Users with a customized subscription service through the Platform employing an artificial intelligence system (the “Artificial Intelligence System”), which allows End Users to access a regularly-updated database of service providers, suppliers, contractors and advisors selected by Retail Hub among the most innovative ready-to-market start-up/scaleup companies operating in the retail industry (collectively, referred to as the “Start-ups”). (To this end, we need to process the following data (the “Usage Data”) collected by the Artificial Intelligence System when you are using the Platform:- Information about your interactions with the Platform, such as your search queries (including the date and time of any requests you make), your browsing history and interactions with the Platform, the Startup company profiles you visit on the Platform.
- Inferences drawn about your areas of interests and preferences based on our usage of the Platforms;
- Content you post on the Platform, such as comments, photos, recordings and interactions with the Platform’s customer service team or with other users of the Platforms by means of the Services.
- Your non-precise location, which may be derived or inferred from certain technical data (e.g., your IP address, language setting of your device.
Your Usage Data - unless you provide a specific consent - will only be processed in order to provide the Service and, in particular, to better target your searches and provide you with a customized user experience. Please consider that, conversely - without your specific consent - such Usage Data will not be used for marketing purposes nor shared with third parties for their own marketing purposes.
3. Purposes of the processing, legal basis and data retention
| Nature of the data processing | Purposes | Legal Basis | Retention Period |
|---|---|---|---|
| Registration Process (mandatory information) | Enabling you to create an account and register to the Platform, as well as request and use the Services. | The contractual necessity to provide the Services to the registered users (Art. 6.1.b. of Reg. UE 2016/679, [the “GDPR”]). | In the event of receipt of a cancellation request or detecting account inactivity over more than 12 months, we will proceed to cancel the account and all the relating Data |
| Processing of Technical Data for browsing the Platform | Enabling you to access and use the Platform. Monitoring the Platform’s functioning and preventing abuses. | The contractual necessity to allow the users to access and use the Platform (Art. 6.1.b. GDPR). The legitimate interest of Retail Hub to ensure network and information security (Art. 6.1.f. GDPR). | Your Data will be processed for the time required in order to enable you to use the Platform, and for the time required to monitor the correct functioning of the Platform. In any case the Technical Data will be retained while it is needed after that, they will be erased. |
| Processing of Usage Data and optional information, collected in the course of the registration process, for the provision of the Service (End Users only) | For the provision of the Service, through the Artificial Intelligence system, aimed at better targeting your searches and, therefore, selecting and providing customized contents among the countless contents on Start-Ups available on the Platform. The Artificial Intelligence System used to customize the user experience is inextricably incorporated in the Platform’s software, as well as instrumental and necessary to its functioning. | The contractual necessity to allow the users to access and use the Platform (Art. 6.1.b. GDPR). | The optional information, collected in the course of the registration process will be retained until your account is closed. |
| Business Intelligence | Your Usage Data can be processed – in a pseudonymized form – for statistical purposes and in order to improve the quality of the Services and the functioning of the Platform. | The legitimate interest of Retail Hub. (Art. 6.1.f. GDPR). | Your Usage Data (in a pseudonymized form) will be retained to ensure the correct operation of the platform. |
| Soft spam | Your contact details will be used to send you email communications relating to services which are similar to the Service you requested. Under art. 130, co 4, d.lgs. 196/2003, Retail Hub will be able to use the email address which you provided in order to promote services similar to the Services you used or requested, unless you object by clicking on the specific link to object to the receipt of commercial communications from Retail Hub. The registered users will also be able to opt out from said processing when they create their account, by selecting the specifically provided checkbox. | The legitimate interest of Retail Hub. (Art. 6.1.f. GDPR and art. 130, co 4, d.lgs. 196/2003). | Your data will be retained until you opt out or object the legitimate interest of the processing. |
| Direct marketing | Sending you commercial and/or promotional information as well as advertising material or engaging in direct selling of products, services or engaging in market research endeavours. For example, we may send you emails or use instant messaging or contact you by phone through an operator to illustrate commercial offers, initiatives and promotions relating to our products and services (including products and services other than those you requested). | Your consent (Art. 6.1.a GDPR). | Your Data will be retained until you withdraw your consent. |
| Profiling for marketing purposes (End users only) | Creating a profile based on your Usage Data and the personal data collected through our registration form in order to send you personalized promotional information, targeted advertising material and tailored commercial offers. | Your consent (Art. 6.1.a GDPR). | Your Data will be retained for 36 months or as needed to ensure the correct operation of the platform. |
| Data sharing with third parties for marketing purposes | Sharing your Data with third parties for their own marketing purposes in order to allow them to send you promotional information, advertising material and illustrate commercial offers and initiatives relating to their products or services. | Your consent (Art. 6.1.a GDPR). | Your Data will be retained until you withdraw your consent. |
| Compliance with a legal obligation | Your Data may be used to comply with legal obligations. | Compliance with a legal obligation (Art. 6.1.c. GDPR). | Your Data will be retained for the time required to comply with the legal obligation at issue. |
| Enforcement of rights | Your Data may be used to enforce a right of Retail Hub before or out of Court (i.e., for illicit uses of the Platform). | Legitimate interest of Retail Hub to enforce its rights (Art. 6.1.f. GDPR). | Your Data will be retained for the time required to enforce our rights. |
4. Who do we share your Data with?
4.1 Service providers and business partners when necessary to perform services on our or your beh
Your Data may be shared, for the purposes of Platform operation and delivery of the Services requested, with companies providing services, including IT services, instrumental to the smooth running of the Platform and to the provision of the Service. These entities will act as data processor.
Your Data may also be shared with other business partners whose support is deemed necessary in order to deliver the requested Services, with particular reference to payment operators (e.g. Stripe), who will operate as independent data controllers and in compliance with their own privacy policies, which they will promptly provide you with if you request their services
4.2 Third parties you authorize
Upon your consent, we may finally share with other business partners, who will operate as independent data controllers, additional personal data you may provide us with, so that they may send you offers and provide you with services that best meet your specific needs.
If you wish to receive a full list of the entities to whom your Data may be shared with, please request it by sending an email to the address: info@retailhub.tech.
4.3 Other third parties required by law
In the event of express and lawful requests or orders issued by Public and/or Law Enforcement Authorities, your data may be transmitted to such Authorities.
5. Will your Data be transferred to non-EU countries
Your Data may be transferred outside the EU territory. In that case, the Data will only be transferred to countries which provide a level of protection adequate to the one set out by the EU applicable legal framework, or by means of the implementation of adequate safeguards to protect your Data, such as the Standard Contractual Clauses issued by the Eu Commission with the implementing decision (UE) 2021/914 of June 4th 2021. In any case, the data transfer will comply with the recommendations (n.1/2020 and n.2/2020) issued by the European Data Protection Board (“EDPB”).
6. What rights are you entitled to?
You have the right to request access to, rectification or erasure of your Data, restriction of processing and object to the processing of your Data by us, as well as the right to request the delivery of some of such Data.
Right of access
The data subject has the right 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 the following information:- The purpose of processing;
- The categories of personal data concerned;
- The recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients of third-party countries or international organisations, with confirmation as to whether adequate safeguards are in place;
- Where possible, the envisaged period for which the personal data will be stored or, if not possible, the criteria used to determine that period;
- The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing concerning the data subject or to object to such processing;
- The right to lodge a complaint with a Supervisory Authority;
- Where the personal data have not been collected from the data subject, any available information on their source;
- The existence of an automated decision-making process, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her and, at least in those cases, meaningful information about the rationale, the significance and the envisaged consequences of such processing for the data subject.
Right to rectification
The data subject has the right to obtain from the data controller without undue delay the rectification of inaccurate personal data concerning him or her.
Right to erasure
The data subject has the right to obtain from the data controller the erasure of personal data concerning him or her without undue delay and the data controller has the obligation to erase personal data without undue delay where one of the following grounds applies:- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- The data subject withdraws consent on which the processing is based and where there is no other legal ground for the processing;
- The data subject objects to the processing and there are no overriding legitimate grounds for the processing;
- The personal data have been unlawfully processed;
- The personal data have to be erased for compliance with a legal obligation under the European Union or Member State law to which the data controller is subject.
Right to restriction of processing
The data subject has the right to obtain from the data controller restriction of processing where one of the following applies:- The accuracy of the personal data is contested by the data subject. Data processing will be restricted for a period enabling the data controller to verify the accuracy of such personal data;
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use;
- The data 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;
- The data subject has objected to processing pending the verification whether the legitimate grounds of the data controller override those of the data subject.
Right to object
The data subject has the right to object at any time to the processing of personal data concerning him or her which is based on the data controller’s legitimate interest, including profiling. The data subject has the right to object at any time to the processing of personal data concerning him or her for direct marketing purposes, including profiling to the extent that it is related to such direct marketing.
Right to data portability
The data subject has the right to receive some 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 has the right to transmit those data to another data controller without hindrance from the data controller to which the personal data have been provided, where the:- Processing is based on consent or on a contract; and
- Processing is carried out by automated means.
In exercising his or her right to data portability, the data subject has the right to have the personal data transmitted directly from one data controller to another, where technically feasible.
7. How can you change your preferences or withdraw your consents
You may at any time control, change or withdraw your consents in relation to the purposes outlined in the chart above (par. 3), as well as opt out from the Soft Spam activities (par. 3 above). All you need to do is change your account settings, or contact Retail Hub.
8. How to contact Retail Hub in order to exercise your right?
You may exercise your rights by writing to the data controller, Retail Hub to the following addresses:
Retail Hub S.r.l.
Address: via Madonnina 19, 20121 Milan - Italy
Email: info@retailhub.tech
9. How to contact the relevant Supervisory Authority to lodge a complaint?
Any complaint may be lodged with your Supervisory Authority. For Italian users, the Supervisory Authority is:
Garante per la Protezione dei Dati Personali [Authority for the Protection of Personal Data]
Piazza Venezia n. 11, 00187 Rome - Italy
Fax: (+39) 06.69677.3785
Tel: (+39) 06.696771
E-mail: garante@gpdp.it
Certified email address: protocollo@pec.gpdp.it
10. How can you be notified of any changes to this Privacy Policy
This Privacy Policy may be subject to changes and updates in the event that changes are made to the way we process your Data or to other information provided hereunder. Any such changes will ensure that your rights are fully safeguarded. If changes are made to the effect that the safeguards protecting your Data and your rights may be hindered as compared to the current version, before the processing of your data according to the new method begins you will be promptly informed through the contact details you provided and you will be entitled to exercise your right to delete your account on the Platforms, or, at any time, to change your consents and preference
In any event, we encourage you to check from time to time the updated Privacy Policy.
Last updated on: September 2021