Privacy Policy

Last update: 31/07/2020

With the present policy, Cynthia Abila Studios, with registered office in Nigeria, no. 2 Seiviri Street, Abuja, Federal Capital Territory, 900271, TIN: 18949006-0001, in its quality as data controller, provides to the Users of the Website www.cynthiaabila.com (hereinafter referred to as “Website”), informs the data subject (User) that his personal data relating to navigation within the Website, with direct access from the homepage or through sub-pages, as well as related to the services, goods or products offered, will be treated with utmost care and with appropriate means to guarantee security. We specify that this policy – subject to provisions of Nigeria Data Protection Regulation (NDPR) and of EU Regulation 2016/679 on the protection of personal data (also “General Data Protection Regulation” – GDPR) – is not to be considered valid for other and external websites that can be eventually consulted through the links present on this Website.

1. DATA CONTROLLER.

The data controller is Cynthia Abila Studios, with registered office in Nigeria, no. 2 Seiviri Street, Abuja, Federal Capital Territory, 900271, TIN: 18949006-0001. The Data controller can also be contacted via e-mail at info@cynthiaabila.com.

2. PURPOSES OF DATA PROCESSING.

The processing of User data is aimed at:

- allowing correct navigation on the present Website;

- concluding and executing the sale of goods offered on the present Website;

- allowing registration on the Website and the use of services reserved for registered Users;

- performing aggregate and anonymous statistical analysis of navigation and users;

- receiving, managing and answering to requests made via e-mail, phone, or live chat provided by tawk.to Inc. (appointed as external data processor, who processes personal data in accordance with the conditions available at https://www.tawk.to/data-protection/dpa-data-processing-addendum/);

- allowing newsletter subscription for the provision of commercial and promotional information about the products offered by Cynthia Abila Studios;

- complying with all the legal obligations to which the data controller is subject;

- establishing, exercising or defending legal claims.

3. LEGAL BASIS OF DATA PROCESSING.

The processing of the User’s personal data is lawful, as:

- necessary for the execution of the contract of which you are a part, or for the execution of pre-contractual measures adopted upon your request, to: allow the correct browsing on the Website; conclude and execute the sale of goods offered on the Website; allow registration on the Website and the use of services reserved for registered users; check the requests made via e-mail , telephone or LiveHelp® live chat;

- based on express consent provided for the newsletter subscription;

- necessary to comply with legal obligations to which the data controller is subject;

- necessary for the pursuit of the legitimate interest of the data controller, for the completion of aggregate and anonymous statistical analysis of navigation and users, aimed at a possible improvement of the Website and the understanding of how the data controller is searched on the Internet, and for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.

4. CATEGORIES AND SOURCES OF DATA CONCERNED.

Cynthia Abila Studiosdoes not process personal data relating to minors who are under the age of 18. With the access to the Website, the eventual registration of a user account, the use of the services offered or the purchase of goods, the User expressly declares to be over 18 years old.

4.1 Data deriving from User’s navigation.

These data, through the normal functioning of the Site, are acquired and transmitted implicitly in the use of Internet communication protocols. This is information that is not collected to be associated with identified data subjects, but, by its very nature, through processing with data held by third parties, could allow Users to be identified.

This category of data includes the IP addresses or domain names of the computers used by the Users who connect to the Website, the addresses in the Uniform Resource Identifier (URI) of the requested resources, the time of the request, the method used to submit 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 and other parameters relating to the operating system and to the user’s IT environment.

These data are used for the sole purpose of obtaining anonymous and aggregate statistical information on the use of the Website and to check its correct functioning, and permanently reside on third party servers (or hosting providers). The data could also be used to ascertain responsibility in the event of any illicit or harmful actions committed on or through the Website.

In any case, these e data processing and association activities are not carried out by the data controller, and are only used to check the correct functioning, to be then automatically deleted after processing.

4.2 Cookies.

For information on the use of cookies on the present Website, visit the appropriate Cookie Policy.

4.3 Data voluntarily provided by the User.

These data are provided by the User, during his/her voluntary interaction with the Website, in order to use the services offered on the Website, purchase the products sold on the Website, request information, receive assistance or for any personal purpose. In particular:

- data necessary for the registration of a user account on the Website, such as: username, e-mail address, password

- personal data necessary to conclude and execute the sale of goods on the Website: name and surname, shipping and billing address, telephone and payment information, e-mail address, company name (optional);

- personal data of third parties, if provided voluntarily by the User who decides, for example, to purchase a good to be delivered to a friend, or to make a gift; in such cases, Cynthia Abila Studios will deliver to this third party the privacy policy at the time of the first communication;

- personal data provided voluntarily in the event of contact by e-mail telephone and/or live chat to request information, receive assistance or for any personal purpose;

- personal data necessary for the newsletter subscription: e-mail address.

5. DATA PROCESSING MODE.

The processing of your personal data is carried out, using methods strictly necessary to meet the aforementioned purposes, by means of some or the set of operations indicated in Nigeria Data Protection Regulation (NDPR) and in art. 4, n. 2) of the EU Regulation 2016/679 2016/679: collection, registration, organization, structuring, storage, consultation, processing, adaptation, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. The operations may be carried out with or without the aid of electronic, telematic or automated means, however in compliance with the provisions of Nigeria Data Protection Regulation (NDPR) and of art. 32 of the EU Regulation 2016/679.

6. DATA PROVISION.

The provision of personal data by the User, although not a legal obligation, is a necessary requirement for:

- the correct navigation on this Website;

- the purchase goods offered on the Website;

- registering on the Website and using the services reserved for registered users;

- receiving, managing and checking requests made by e-mail, phone and/or live chat;

- subscribing to the newsletter.

therefore, the failure of the provision of personal data involves the impossibility to fulfil the aforementioned purposes. In any case, by providing one’s personal data to the data controller, or to his authorized persons, for any of the purposes listed above, the data controller may process such data to fulfil legal obligations and pursue its legitimate interests in carrying out aggregated and anonymous statistical analyses related to browsing and users, and in establishing, exercising or defending of legal claims.

7. DATA CONSERVATION.

The User’s personal data will be processed and stored for the entire period necessary for the fulfilment of the aforementioned purposes and, in particular:

- the data collected to conclude and execute contracts for the purchase of goods on the Website are kept until the conclusion of the contract and of the related administrative and accounting formalities, while the billing data are kept for ten years from the invoice date;

- the data relating to the payment of commercial transactions relating to the purchase of goods on the Website are kept until the payment is certified and the relative administrative and accounting formalities are concluded following the expiry of the right of withdrawal and the terms applied for the contestation of the payment;

- the data collected for the registration of the user account are kept until the cancellation of such account;

- the data collected for the use of any services offered on the Website are stored until the termination or conclusion of the use of the service;

- the data collected to receive, manage and check requests made via e-mail, phone and/or live chat, are kept until the request is finished;

- the data collected to allow correct browsing on the Website are kept for the duration indicated in the specific Cookie Policy , while the data collected for the accomplishment of aggregate statistical analyses are completely anonymous;

- the data collected for newsletter subscription are kept until the User remains subscribed to the newsletter and/or decides to object to the processing of his/her data;

- the data collected for the fulfilment of legal obligations are kept for the necessary time required by law or regulation;

- the data collected for the establishment, exercise and defence of legal claims are kept until the limitation period of the right to be enforced or, where a legal claim has been initiated, until its final conclusion.

8. DATA COMMUNICATION.

For the purposes listed above and to provide, improve, protect and promote our services, the User’s personal data may be disclosed to, or become known by:

- subjects authorized to treatment, that is collaborators and/or employees of the data controller;

- data processors and other related processors and authorized subjects, such as, by way of non-exhaustive example: accountants, consultants, service providers, IT and assistance service providers and related technical staff, eventual collaborators, in charge of occasional maintenance operations, all adequately trained in the protection of confidentiality;

- courier, carriers and freight forwarders;

- judicial or administrative authorities, for the fulfilment of legal obligations;

- subjects who process data in execution of specific legal obligations.

9. PROFILING.

The User’s personal data are not subject to any fully automated decision-making process, including profiling.

10. TRANSFER OF DATA TO THIRD COUNTRIES.

TRANSFER OF DATA TO THIRD COUNTRIES

If the User is Nigerian, her/his personal data may be transferred to third countries outside Nigeria, due to Website’s Italian server, which ensure in any case adequate levels of personal data protection and that can take place only on the basis of the User’s express consent.

If the User is a citizen of a State Member of the European Union, her/his personal data may be transferred to Nigeria, where Cynthia Abila Studios has its registered office. This transfer will be carried out only on the basis of the User’s express consent.

11. RIGHTS OF THE DATA SUBJECT.

Pursuant to Nigeria Data Protection Regulation (NDPR) and to articles 15-18 and 20-21 of the EU Regulation 2016/679, the User has the right to obtain:

a) confirmation of the existence or non-existence of personal data concerning him/her, even if not yet registered, and their communication in an intelligible form;

b) indication about:

- the origin of personal data;

- the purposes and methods of processing;

- the logic applied in case of treatment carried out with by using electronic instruments;

- the subjects or the categories of subjects to whom the personal data may be communicated or who can become aware of them as processor or parties’ appointees;

c) updating, rectification or, when interested, the integration of data;

d) cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;

e) attestation that the operations referred to in letters c) and d) have been brought to the knowledge, also as regards their content, of those to whom the data have been communicated or distributed, except in the case where this proves impossible o involves a manifestly disproportionate use of resources with respect to the protected right.

e) attestation that the operations referred to in letters c) and d) have been brought to the knowledge, also as regards their content, of those to whom the data have been communicated or distributed, except in the case where this proves impossible o involves a manifestly disproportionate use of resources with respect to the protected right.

The User has the right to object, in whole or in part:

a) for legitimate reasons, to the processing of personal data concerning him/her, even if pertinent to the purpose of the collection;

b) to the processing of him/her personal data for the purpose of sending advertising or direct sales material, as well as for carrying out market researches or commercial communications.

The User has the right to withdraw, at any time, the consent given in relation to the processing activities of which it represents the legal basis, without affecting the lawfulness of the processing based on consent given before the revocation.

The User has the right to data portability, that is to receive personal data concerning him/her in a structured format, of common use and readable by automatic devices, and he/she has the right to transmit these data to another data controller without hindrance. The User also has the right to lodge a complaint with her/his local supervisory authority.

The User can exercise his rights through written request sent to the data controller, using the contact details indicated above.

12. CHANGES TO THE PRIVACY POLICY.

Cynthia Abila Studios reserves the right to modify, update, add or remove parts of this Privacy Policy at its discretion and at any time. The User concerned (data subject) must periodically check any changes published on the Website.