Privacy policy

PRIVACY POLICY OF THE MARKETPLACE
AtBeautyQ LLC., having its registered office at 16B Fox Ln, Greenwich, CT, 06830-6884 (“AtBeautyQ”) is the Data Controller of your personal data collected through this Marketplace www.atbeautyq.com (the "Marketplace") and the social media pages in use at AtBeautyQ (hereinafter "Social Pages"). We would like to remind you that AtBeautyQ will process your data in accordance with current regulations and as set forth below.
The Marketplace hosts a technological platform managed by AtBeautyQ through which (a) professional and consumer users can publish their ads of luxury goods and properties offered for sale and (b) potential purchasers can search for the desired luxury goods through the procedure described on the Marketplace.
This privacy policy describes how the personal data of users who access the Marketplace, whether registered or not, and benefits from the related services offered by the Marketplace, including account registration and the purchase of products and services online, sold by the Sellers, made available by AtBeautyQ, are processed.
The personal data of the User is then processed by AtBeautyQ, in compliance with the legislation in force and according to what is stated hereunder.
In its capacity of provider of the registration service and manager of the Marketplace AtBeautyQ carries out, on an exclusive basis, the identification and implementation of the technical and organizational measures that control the processing of the personal data residing on the Marketplace, AtBeautyQ is data controller of your personal data for the purposes explained in sections 3.1. (except for letter d), 3.2., 3.3., 3.4. 3.5., 3.6. and 3.7. of this privacy policy.
This policy applies only to the processing of personal data carried out through the Marketplace; any third-party Marketplaces that can be accessed through links remain subject to the privacy policy provided by the operator of the relevant third-party Marketplace. We therefore encourage you to review these documents before browsing third-party sites.
 1. Categories of personal data collected and processed by AtBeautyQ
AtBeautyQ collects and processes the following data from those who access and visit the Marketplace and/or Social Pages:
 1.1 Automatically collected personal data
 ● Navigation data: the computer systems and software procedures used to operate this Marketplace acquire, during their normal operation - including through the use of technical cookies - some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users connecting to the Marketplace, the URI (Uniform Resource Identifier) notation addresses of the requested resources, 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 (successful, error, etc.) and other parameters relating to the user's operating system and computer environment.
● Aggregate-level information related to user behaviour on the Site (e.g., clicks and/or mouse movements) collected through the use of cookies.
 

1.2 Personal data directly provided by you
 ● Personal information (e.g., first name, last name); contact and contact details (such as email address, address, telephone number, and cell phone number); account name and password; payment details; shipping address and billing address; purchase details (date, quantity and type, product code, sale amount, VAT number where applicable, information on complaints, warranty and refunds, and other information relating to the sale of products on the Marketplace), provided when registering on the Marketplace or when using certain services, such as purchasing products online.
● Personal data, contact data and other data you provide when filling in forms or forms on our Marketplace.  We invite you to read the notices that AtBeautyQ from time to time at the bottom of the forms which contain more detailed information about the processing of personal data carried out in this context.
● Any contact with AtBeautyQ through the customer service by sending messages, via electronic mail, to the AtBeautyQ contact details indicated on the Marketplace entails the subsequent acquisition of the e-mail address of the sender necessary to respond to requests, as well as any other personal data included in the relevant communications.
 ● Data related to your purchasing habits and preferences.
 ● Any data of third parties which, although not using the features and services of the Marketplace, may still be acquired by AtBeautyQ as they are entered by the user as recipients of deliveries. In the case of data provided by third parties, you are obliged to assure AtBeautyQ that you have expressly obtained their prior consent and you undertake to transfer to them the information contained in this policy.
You are responsible for ensuring that the personal information you provide to AtBeautyQ is correct and, if there are any changes, to update this information by writing to the AtBeautyQ contact details indicated on the Marketplace.
 1.3 Personal data collected through social media pages in use at AtBeautyQ
AtBeautyQ may also collect some of your personal information when you interact with the Social Pages. Some information is communicated to AtBeautyQ directly by you, when you decide to share - through your profile - images posted on our Social Pages, comment on our posts and/or express your liking to one of our products, to one of our initiatives or even to one of our events through the selection of the appropriate buttons, as well as when you decide to write us a mail message using the private chat or other channels made available on the different social media.
We may also learn about some information indirectly collected as a result of your interaction with our Social Pages; for example, we may learn about the time and day you express your liking to one of our posts or send a request through a mail message.
Knowledge of much of your personal information may depend on the social media settings you choose and the content you choose to make public. This information may include your first name, last name, some contact information, and the image associated with your social profile. Therefore, we remind you that some of your information is visible to AtBeautyQ once you decide to follow our Social Pages. For this reason, we encourage you to view the privacy policy of the different social media and check your privacy settings.
1.4 Child data
AtBeautyQ does not request, collect, use, or circulate personal data provided by persons under the age of 18. If AtBeautyQ discovers that it has collected data from a minor, it will delete it. In case you are not of the required age, please do not register or proceed with the purchase of a product online and ask an adult (your parents or guardian) to perform the necessary procedures.
 2. Categories of personal data collected and processed by the Seller
2.1 Personal data you have personally provided
Personal details (e.g. first name, last name); contact information and addresses (such as email address, street address, landline and mobile phone numbers); shipping address and invoicing address; data concerning purchases (date, quantity and product category, product code, amount of the sale, Sales Tax license number, certified email address and SDI number, if applicable, information on complaints, warranty and refunds and other information on the sale of products on the Marketplace) provided during the online purchase of products.
 3. Purpose and legal basis of personal data processing
Personal data are collected and processed by AtBeautyQ and, if expressly envisaged, also by the Seller by electronic and informational means, in accordance with the principles of necessity, lawfulness, fairness, proportionality, and transparency for the purposes and under the conditions of lawfulness (so-called legal bases) set forth below:
3.1 To enable you to navigate our Marketplace and allow you to take advantage of the services offered therein
a) To provide you with the services you have requested (e.g., managing the registration and access processes to the Marketplace, account management, user support, handling any complaints, viewing your order history, managing your shipping and billing addresses, checking the status of your orders, processing data for the provision of individual services you have requested.
b) For online order processing (e.g., performing online operations necessary for order processing; verifying that the information provided for the transaction is complete, valid, correct, and not fraudulent; processing the order and delivering the products; providing pre- and post-sale support services, including handling legal warranties; and contacting you for any problems related to order processing or subsequent inquiries related to the order. In the case of a purchase on the Marketplace from a Seller, the autonomous control of AtBeautyQ for all the purposes explained herein remains in place, the Seller will process the personal data of the user to execute the finalized contract of sale through the Marketplace (including any after-sales assistance in managing legal warranties).
c) To provide you with assistance when requested by you through our Customer Service Department and to respond to your inquiry via e-mail.
In all the above cases, the legal basis for processing is the performance of a contract and the execution of pre-contractual measures.
3.2 Interaction with Social Pages
To allow you to interact with our Social Pages, send comments, express your appreciation for the initiatives promoted by AtBeautyQ, share our posts. We will process your data to allow you such activity and follow up on your requests transmitted through these channels.
3.3. Profiling
Personal data, data relating to household composition, contact data, purchase data, browsing data and behaviour of Users on the Marketplace, relating to the volume of spending and are processed in order to analyze your purchase habits and carry out analysis and market research to improve AtBeautyQ commercial offer. The legal basis for the processing is the User's consent given. This consent can always be revoked through the user's personal page, via the cookie settings or by contacting AtBeautyQ customer service.
If the user has given consent to the use of profiling cookies on the Marketplace, AtBeautyQ may also, process the user's contact information (particularly email address) and data disclosed by the user during interaction with the Social Pages - such as the information provided by the user to the social media according to the privacy settings selected on such social media - to show you marketing ads and content consistent with your interests, based on your preferences and consumption habits identified through cookies and/or other tracking systems of social media companies and/or as a result of the analysis that the social media companies themselves perform on their users.
More information about processing by tracking tools is available in the Cookie Policy.
3.4. Marketing
Your personal data, contact data and household composition data are used by AtBeautyQ to send you through the channels authorized by you - such as, for example, telephone, mail or electronic communications, e-mail, Text Messages, digital platforms - marketing communications. Marketing activities may also be carried out by sharing your personal data with digital platforms. In this way, AtBeautyQ advertisements may be addressed to you in the spaces on the pages of the digital platforms. The legal basis for the processing is the user's consent given. This consent can always be revoked through the User's personal page, via the cookie settings or by contacting AtBeautyQ customer service.
 3.5 Exercise of the right of defence
AtBeautyQ and, in the case of a purchase from a Seller, said Seller shall process your personal data for the ascertainment, exercise or defence of a right in all courts of jurisdiction. The legal basis for such processing is the legitimate interest of AtBeautyQ and of the Seller. Said legitimate interest does not affect the rights and freedoms of users, since the processing is necessary for the exercise of the constitutionally guaranteed right of defence.
 3.6 Use and control operation of the Marketplace and fulfilment of legal obligations
AtBeautyQ and, in the case of a purchase from a Seller, said Seller shall process your personal data to fulfil the obligations imposed on them by laws, regulations or orders from competent authorities. The legal basis for the processing is the fulfilment of a legal obligation.
3.7. Improvement of Services
In addition, concurrently with the communication of concluded purchase, AtBeautyQ may ask you to express your opinion on the service received. If you decide to provide your opinion on the service rendered, the answers you provide will be processed in aggregate form and on the basis of AtBeautyQ's legitimate interest in improving its services. However, completion of the questionnaire is entirely optional, so failure to provide the data does not have any kind of consequence on the user.
4. Nature of provision of personal data
With respect to the purposes set out in points 3.1, 3.5 and 3.6, the provision of data marked with an asterisk within forms or forms available on the Marketplace is mandatory for the purposes of providing the requested services and failure to provide, incomplete or untruthful communication will result in the impossibility of the provision of the requested service. The provision of personal data other than those indicated above is optional and any refusal will in no way affect the user's ability to use the Marketplace but will result in the impossibility, even partial, of pursuing the purposes indicated above.
5. Recipients of personal data and transfer to third countries
For the purposes of pursuing the above purposes, your personal data will be processed by authorized personnel of AtBeautyQ. In addition, the data may be communicated to the following categories of recipients, who always act as data processors: companies of the group to which AtBeautyQ belongs for the performance of IT and logistical support, administration and accounting activities; companies appointed by AtBeautyQ to send promotional communications; digital platforms that as part of marketing campaigns merely process data on our behalf; to the payment service provider to enable the payment of purchases made on the Marketplace, or their reimbursement if appropriate.
With respect to payments made for purchases on the Marketplace Data pertaining to economic transactions are processed exclusively by online payment providers as autonomous controllers.
In the event that you interact with the Social Pages, your data may be known to the companies that as data processors provide assistance and support to AtBeautyQ in the management of its profiles present on the main social media.
Personal data will not be disclosed or transferred to third parties for use for their own purposes; it is understood that in the event of any extraordinary corporate transactions (e.g., sale or lease of a business, merger, etc.), the data may be transferred or given to third-party purchasers/tenants or assignees.
The list of data recipients is available by writing to the AtBeautyQ addresses listed in the "Contact Information" section below.
6. Retention of personal data
AtBeautyQ retains users' Personal Data for as long as is strictly necessary to pursue the purposes set forth in Paragraph 2, in compliance with civil and tax retention obligations and the limits provided by the law in general.
To this end, AtBeautyQ specifies that the retention period of Personal Data for the above purposes is as follows:
a. Browsing the Marketplace and using the services offered therein (e.g., registration on the Marketplace): personal data processed for said purpose will be kept for a period of 10 years from the termination of the contract under which the above-mentioned processing is carried out, in accordance with the provisions of the statute of limitations.
b. Interaction with Social Pages: the Personal Data processed for said purpose will be processed for a period of time equivalent to that determined by each Social Page with reference to the retention of posts and comments and, in general, User interactions on it.
c. Profiling: the Personal Data processed for said activities will be kept for a period of 7 years from the date of acquisition of consent. The User may in any case revoke his or her consent as specified in paragraph 2 in the section dedicated to the respective purposes.
d. Marketing: the Personal Data processed for said activities will be kept for a period of 7 years from the date of acquisition of consent. The User may in any case revoke his/her consent as specified in paragraph 2 in the section dedicated to the respective purposes.
e. Exercise of the right of defence: the Personal Data will be retained in accordance with the statutes of limitations with reference to torts of a contractual/tort nature.
f. Operation and Control Functioning of the Marketplace and Fulfilment of Legal Obligations: the Personal Data processed for said purposes will be processed for as long as it is necessary to resolve any bugs and malfunctions of the Marketplace, as well as for as long as required by the legal regulations with which AtBeautyQ must comply.

7. Security
 AtBeautyQ recognizes the importance of protecting the personal data (e.g., identification and transaction data) of users of the Marketplace. For this reason, AtBeautyQ adopts policies and security measures of a technical and organizational nature to protect, in compliance with applicable regulations, users' personal data and the information systems used to manage the Marketplace. In particular, AtBeautyQ has implemented technical, legal, and organizational measures to protect personal data against accidental or intentional tampering, loss, destruction, disclosure, or unauthorized access to data collected online.
However, although AtBeautyQ continues to implement and improve security measures in line with the development of technology and industry standards, by the very nature of the Internet such measures cannot totally limit or exclude the risk of unauthorized access or dissemination of data. It is therefore recommended that you periodically update software for the protection of network data transmission (e.g., antivirus) and check that your electronic communication service provider has taken appropriate measures for the security of network data transmission (e.g., firewalls and spam filters). We would also like to remind you that access to your personal account, containing your personal data, is only possible by means of your username and password: to help us better protect this data, we therefore recommend that you do not communicate or make this information available to third parties.
With regard to payments made for online purchases, the Marketplace uses systems designed to ensure maximum security through the use of the most advanced technological and encryption systems (SSL).
8. The rights of users
8.1 As a data subject, pursuant to Articles 15 et seq. of the Regulations You have the right to:
● Receive confirmation of the existence of your personal data, access their content and obtain a copy (right of access);
● Update, amend, and/or correct your personal data (right of rectification);
● to request the deletion or limitation of the processing of data in the cases provided for in the Regulations, including where the data have been processed in violation of the law or where storage is not necessary in relation to the purposes for which the data were collected or otherwise processed (right to deletion and right to limitation);
● revoke consent, where given, at any time and without prejudice to the lawfulness of the processing based on the consent given before revocation (right to withdraw consent);
● within the limits of the Regulation, receive copies of the data you have provided in a structured, commonly used, machine-readable format and request that such data be transmitted to another data controller if technically feasible (right to data portability).
You also have the right to object at any time to the processing of your data for direct marketing purposes including profiling insofar as it is related to such direct marketing and in cases where the processing is based on our legitimate interest (right to object).
You may exercise your rights at any time by writing to the following email address: customers@atbeautyq.com.
Please note that requests for deletion of data are subject to existing legal and regulatory obligations regarding record retention.
We remind you that to manage your consents where given (including revocation) and to change or update your personal data and profile, you can access your restricted area at any time and use the features available in the "My Account" section.
AtBeautyQ may require you to prove your identity and provide you with information regarding the action taken concerning an inquiry within one month of receipt of the request. In accordance with the provisions of the Regulations, this period may be extended by two months if necessary, taking into account the complexity and number of requests: in such case, AtBeautyQ shall inform you of such extension, and the reasons for the delay, within one month of receipt of the request.
At any time, he/she may file a complaint with the Supervisory Authority in case of violation of data protection regulations.
9. Data controller and data protection officer contact info
The Data Controller is: AtBeautyQ, based at 16B Fox Ln, Greenwich, CT, 06830-6884.
The Data Protection Officer or DPO (Data Protection Officer) is available at the following e-mail address: customers@atbeautyq.com
10. Updates
This Privacy Policy may also be updated over time in consideration of changes in data protection laws or regulations, in which case we will notify you. Changes and updates will apply from the time of their publication on the Marketplace (in case of changes for which the applicable legislation requires the collection of consent you will be allowed to express your choice freely). We therefore invite you to periodically consult this page to check for the most up-to-date version of the Marketplace's notice.