PRIVACY POLICY NOTE
The Data Controller is BECOME S.r.l. (hereinafter "BECOME" or "Data Controller"), with registered office in Via Carlo Valvassori Peroni 74/2, 20133 MILAN with the following
contact details.
Become will process your Personal Data in accordance with the EU Regulation no. 2016/679 and the national legislation on the protection of personal data (hereinafter "Privacy Policy").
What Personal Data we process and how we collect it
a) Browsing Data
Your navigation on the Site and/or access to certain sections of the Site or App may entail the collection and further processing of your Personal Data by BECOME. In fact, when you connect to the Site/App, the computer systems and software procedures in charge of their operation automatically and indirectly administer and/or acquire certain information (such as, purely by way of example, the so-called "cookies", as specified in the "Privacy Notice - Cookies", which can be found at the end of this statement, "IP" addresses, domain names of the computers used by users connecting to the Site/App, the "Url" addresses of the resources requested, the time of the request to the server).
b) Data provided voluntarily by the data subject
Your registration on the Site/App and/or any requests for information or services from you may also involve the collection and subsequent further processing of your Personal Data (such as your name, surname, postal and e-mail address, password, age, date of birth, sex, image, profession, marital status, etc.).
In particular, the collection of your Personal Data may take place
through your completion of on-line (digital) and off-line (paper) forms;
through your registration via social log-in; and
through the publication by you of Contributions (as defined below), the content of which may include your Personal Data provided directly by you, on social networks operated autonomously by third parties, such as, but not limited to, Facebook, Twitter, Linkedin, etc. (hereinafter "Social Networks"). By "Contributions" we mean the images, comments, catchphrases associated with the subject matter of the Site/App, content and any other information conceived by you and published on the Social Network pages dedicated to products of the various brands of the BECOME group, including the image that you may confer. The publication of Contributions may also take place by means of a pseudonym ("nickname") chosen by you when registering on the Site/App, and possibly the image that you associate with your nickname. In choosing the nickname and any image associated with it, 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 send an enquiry through the “
CONTACT US” section of the Site/App, the provision of certain Personal Data is necessary for BECOME to be able to meet your needs within the scope of the Site/App's functionalities, and the relevant fields of the registration form are marked with an asterisk or are otherwise marked as mandatory. The provision of Personal Data not marked with an asterisk or otherwise marked as mandatory is purely optional and failure to provide such Personal Data, in whole or in part, or providing such Personal Data incorrectly, will have no consequences. On the other hand, failure to provide Personal Data marked with an asterisk or otherwise marked as obligatory does not make it possible to provide the service requested by you. In the event that you have failed to provide one or more of the mandatory Personal Data, a BECOME error message will appear with a list of the missing mandatory Personal Data.
You can also register to the Site/App via social log-in, i.e. through the automatic compilation, thanks to your request to a Social Network, to which you are subscribed, to communicate to BECOME some of the data that you have already given to the Social Network; in the latter case, BECOME recommends that you pay attention to the following by selecting the link allowing registration via 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 uncheck 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 Controller to provide the services available and are processed lawfully and fairly. Such data are also collected and recorded for the determined, explicit and legitimate purposes indicated below and are used in processing operations that are not incompatible with these purposes.
What are the purposes of the processing of your Personal Data and its legal bases
According to the needs you may from time to time manifest by accessing the various sections of the Site/App (and except for individual initiatives involving the provision of specific Personal Data, for which specific information will be published on the Site/App from time to time), the purposes of the processing of your Personal Data and its legal bases are indicated below.
Your Personal Data shall be processed for the following purposes exclusively with your consent to the processing, which may be revoked at any time by accessing your profile page (where you may uncheck the relevant box), by deleting your profile, by using the link placed at the bottom of each promotional e-mail (as regards marketing activities and the newsletter) or in the manner indicated by the Data Controller from time to time when consent is collected:
(a) Managing and responding to your requests
You may decide to consent to the processing of your Personal Data for the management and response, by BECOME, to your requests in relation to products and initiatives of the various brands of the BECOME group, advertising, or the Site/App (section "
CONTACT" of the Site/App). In relation to this purpose, your consent is required at the time of sending your requests. In the event that you decide not to consent to the processing of your Personal Data for the aforementioned purpose, it will not be possible to continue sending your request.
b) Marketing activities
You may decide to give consent to the processing of your Personal Data for marketing purposes, i.e. for commercial communications, including via e-mail, text message and push notification, concerning the sending of promotional and advertising material relating to any brand of the BECOME group or carrying out 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 will be able to choose which channels you prefer to receive commercial communications through (for example, all or some of the e-mails, text messages, ordinary mail, push notifications) and choose the brands of the BECOME group of your interest.
You can decide to subscribe, giving your consent, to one of the BECOME group's newsletter services. In relation to this purpose, your consent is required when registering for the same newsletter service.
c) Profiling activities
You may decide to give consent to be subjected to profiling, i.e. the analysis of your 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 purposes of sending of personalized promotional communications, personalization of the contents displayed on the Site/App, publication of banners and statistical surveys. There are various activities that can contribute to the creation of your profile, for example participation or otherwise in prize events, interaction with the Site/App, the purchase of products from the various brands of the BECOME group or the publication of Contributions on Social Network pages dedicated to products of 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) Publication activities
You may decide to give consent for the purpose of publication or dissemination of audio, photo and video recordings bearing your image and/or your voice for dissemination, information, research or scientific purposes, even after editing clips or individual frames, for the institutional purposes of the BECOME group and in particular for publication on websites, as well as for publications, without commercial purposes, on the social channels of the BECOME group (Facebook, Instagram, Linkedin, Twitter, Twitch, TikTok, Youtube, Vimeo, Whatsapp, Telegram) on printed paper and/or on any other means of dissemination.
The legal basis that legitimizes the processing of the data referred to in point a) is the execution of a service supply contract of which the interested party is a party, or the carrying out of pre-contractual activities. In the cases indicated in points b), c) and d) the legal basis is the freely given consent of the interested party.
Furthermore, even in the absence of your consent, BECOME may process your Personal Data for the following purposes:
management of your registration on the Site/App and activities connected to the activation and use by you of the services offered therein, to 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 publication by you of Contributions on the Social Network pages dedicated to products of the various brands of the BECOME group), including the sending of so-called e-mails. "transactional", connected to the registration procedure on the Site/App and the maintenance of your active account (as processing necessary for the execution of a contract or pre-contractual measures);
management of your possible participation in prize events, including the evaluation, assignment and communication of both the offer of free points and bonus points and the opportunities for accumulating them (by sending e-mails so-called “transactional”, connected to your possible participation in the promotion) as well as the assignment of prizes (as processing necessary for the execution of a contract or pre-contractual measures);
management and execution of the obligations required by law (accounting, administrative, fiscal nature, etc.);
management of disputes and possible disputes (as the Data Controller's legitimate interest).
Who are the recipients of your Personal Data
Your Personal Data may be communicated to and processed by:
legal or natural persons who act as external data controllers, carrying out outsourced activities, appointed by BECOME or by BECOME's external data controllers (including subjects who are entrusted with assistance, communication, marketing, advertising, promotions and sales activities products and/or services as well as advertisers, advertising agencies, IT service providers, Site/App managers, electronic platform managers, partners, credit institutions, professional firms), such as, for example, Amazon AWS (Ireland), Squarespace, Vercel, Swell, Sentry, Fitbit, Paddle, Mailchimp, Meta, Google, Linkedin, Slack, Hubspot, CGN Billing;
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
employees and/or collaborators of external data processors (including system administrators) who, operating under the direct authority of the external data processors, will be authorized to process your Personal Data.
Your Personal Data will not be communicated to third parties except in the case in which your Personal Data must be communicated by BECOME to consultants in order to protect its rights, nor disseminated. In the event that you have entered Personal Data in your nickname and/or have also associated an image of yourself with it, such Personal Data may, however, be disseminated via the Site or Social Networks.
How we process your Personal Data
The processing of your Personal Data may include any type of operation, including collection, recording, organisation, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction.
Your Personal Data will be processed in a predominantly automated but also paper form, with logic strictly related to the relevant purposes, through databases, electronic platforms managed by BECOME or by third parties appointed for this purpose as external data controllers and/or integrated IT systems 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, modification, unauthorized disclosure, accidental or illegal access, abuse or alteration of your Personal Data. In particular:
has adopted safety measures appropriate to the risks;
stores your Personal Data on servers mainly located in European territory (to find out how to transfer Personal Data outside the European Economic Area, see the following section "Transfer of your Personal Data outside the European Economic Area"). In any case, the servers are subject to an advanced and daily back up system.
Where we process your Personal Data
Your Personal Data is mainly processed at the Data Controller's offices and in the places where the data controllers are located. For further information, contact the Data Controller at the contact details indicated in the "Identity and contact details of the Data Controller" section.
Transfer outside the European Economic Area of your Personal Data
Your Personal Data may be transferred outside the European Economic Area, i.e. outside the European Union and Iceland, Norway and Liechtenstein (and specifically to the United States of America) to be stored by third parties appointed for this purpose. external data controllers. The transfer is carried out by BECOME, subject to the stipulation of Standard Contractual Clauses compliant with the models prepared by the European Commission with the suppliers of the servers and/or services, or verification of the registration of the external data controller within the system called "Privacy Shield”, when implemented for the purposes of compliance with the ruling of the Court of Justice of the European Union in the judgment rendered on 16 July 2020 in case C-311/18.
How long 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 times for Personal Data in relation to the individual purposes pursued:
for the purposes of managing your registration on the Site/App as well as activities connected to the activation and use by you of the services offered therein, your interaction with the Site/App and the sections present in it, your Personal Data will be kept for the time strictly necessary for this and in any case at most until your profile is active. For security reasons, we will use log data to verify account usage and, if you are inactive for more than 24 months, you will be contacted to verify your interest in keeping your account active, and you will be notified indicate the ways to express this interest. If there is no activity within the next 30 days, your account will be cancelled;
for the purposes of managing and responding to your requests in relation to products and initiatives of the various brands of the BECOME group, to advertising, or to the Site/App (section “
CONTACT US” of the Site/App), your Personal Data will be kept for the time strictly necessary to process your request;
for the purposes of marketing activities, i.e. for commercial communications, including via e-mail, text message and push notification, concerning the sending of promotional and advertising material relating to any brand of the BECOME group or the carrying out of market research, your Personal data, excluding contact data, will be retained for a maximum period of 36 months;
for profiling purposes, i.e. 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 purposes of sending personalized promotional communications, personalization of contents displayed on the Site/App, publication of banners and statistical surveys, the Personal Data that contributes to the creation of your profile will be retained for a maximum period of 36 months;
for the purposes of sending newsletters, your Personal Data, excluding contact data, will be kept for a maximum period of 10 years.
for the purposes of managing your possible participation in prize events as well as for the related regulatory, administrative and accounting obligations, your Personal Data will be kept for the duration of each prize event and for the time strictly necessary to exhaust the relevant activity;
for the purposes of managing and executing the obligations required by law (of an accounting, administrative, fiscal nature, etc.), your Personal Data will be kept for the time strictly necessary for this purpose;
for the purposes of managing disputes and possible disputes, your Personal Data will be kept for the time strictly necessary for this purpose and, in any case, no longer than the applicable limitation periods.
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, the minor's registration on the Site/App will not be possible. BECOME invites 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 registration on the Site/App concerning registration on the Site/App of subjects under the age of 16.
Identity and contact details of the data controllers
The complete list of those responsible for processing Personal Data can be consulted by contacting the Data Controller at the contact details indicated in the "Identity and contact details of the Data Controller" section.
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 in relation to the processing of your Personal Data
The Privacy Law recognizes you, as an interested party, numerous rights. In particular, you have the right to:
right of access – art. 15 GDPR: obtain from the Data Controller confirmation of the existence or otherwise of your Personal Data, even if not yet registered and their communication in an intelligible form as well as access to your Personal Data (obtaining a copy) and related information (including purposes of the processing, the categories and origin of the Personal Data, the categories of recipients to whom they have been or may be communicated, the retention period (when possible), the rights that can be exercised);
right of rectification – art. 16 GDPR: obtain from the Data Controller the rectification of your Personal Data and the integration of your incomplete Personal Data;
right of cancellation (right to be forgotten) – art. 17 GDPR: by accessing the “
CONTACT US” section 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 with respect to the purposes for which it was processed or the legal basis for it no longer exists their treatment;
right to limit processing – art. 18 GDPR: obtain from the Data Controller the transformation into anonymous form or blocking of your Personal Data processed in violation of the law, including those whose retention is not necessary, in relation to the purposes for which the Personal Data itself was collected or subsequently treated; obtain from the Data Controller the limitation of the 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 checks;
right to data portability – art. 20 GDPR: receive, in a structured, commonly used and machine-readable format, your Personal Data as well as transmit or, if technically feasible, obtain direct transmission of your Personal Data to another data controller without impediments, in cases where where the processing is carried out by automated means and is based on your consent or is necessary for the execution of a contract to which you are a party;
right of opposition – article 21 GDPR: by accessing the “
CONTACT US” section of the Site/App or by sending an email to the following email address: staff@become-hub.com, you can object at any moment, for reasons connected to your particular situation, to the processing of personal data concerning you based on the condition of lawfulness of legitimate interest or the execution of a task of public interest or the exercise of public authority, including profiling, unless there are legitimate reasons for the Data Controller to continue processing which prevail over the interests, rights and freedoms of the interested party or for the establishment, exercise or defense of a right in court; object at any time to the processing if personal data are processed for direct marketing purposes, including profiling, to the extent that it is connected to such direct marketing;
right of revocation – art. 7 GDPR: withdraw consent to the processing of your Personal Data for any of the purposes for which it was provided;
right to complain – art. 77 GDPR: lodge a complaint with the Guarantor Authority for the protection of personal data, Piazza Montecitorio 121, 00186, Rome (RM).
You can exercise your rights towards BECOME by accessing the “
CONTACT US” section of the Site/App or by writing to the following email address staff@become-hub.com or by sending BECOME a letter by ordinary mail to the address indicated in the "Identity and contact details of the Data Controller" section.
INFORMATION NOTE ON PRIVACY – COOKIES
Cookies are small strings of text that act as computer markers sent by a server (in this case, that of the Site/App) to a user's device (generally to the Internet browser) when the user accesses a given page. a website; cookies, which can also be set by websites other than those the user is visiting ("third-party cookies"), are automatically stored by the user's browser and re-transmitted to the server that generated them every time the user accesses the same Internet page. In this way, for example, cookies allow and/or facilitate access to some Internet pages to improve user navigation (i.e. they allow the memorization of pages visited and other specific information, such as pages consulted most frequently, connection errors, etc.), or allow profiling activities. Therefore, for easier and complete use of a website, it would be advisable for the user to configure their browser to accept the receipt of such cookies.
Browsers are often set to automatically accept cookies. However, users can change the default configuration, in order to disable or delete cookies (from time to time or once and for all), with the consequence, however, that the optimal use of some areas of the website may be precluded. It is also possible to check the methods and types of cookies stored on your browser by changing the cookie settings of your browser.
Characteristics and purposes of cookies
Our Site/App uses the following categories of cookies, which may be from BECOME or third parties.
a) Technical cookies or "technical cookies":
Technical cookies are used to navigate or provide a service requested by you; they are not used for further purposes and are installed directly by the Data Controller. Without the use of these cookies some operations could not be carried out or would be more complex and/or less secure. In particular, we use navigation or session cookies, which guarantee normal navigation and use of the website.
You can authorize, limit or block cookies at any time through your browser settings. However, if you set your device to reject these cookies, some site services may not be displayed correctly or function less than optimally.
The use of technical cookies allows safe and efficient use of the site.
From the point of view of duration, temporary session cookies can be distinguished which are automatically deleted at the end of the browsing session and are used to identify the User and, therefore, avoid logging in to each page visited and permanent ones which remain active on the PC until upon expiration or cancellation by the User.
The cookies that are inserted into the browser and retransmitted via Google Analytics are technical only if used for the purpose of optimizing the site directly by the owner of the site itself, who may collect information in aggregate form on the number of users and how they visit the site. Under these conditions, the same rules regarding information and consent as those provided for technical cookies apply to Analytics cookies.
b) Analytical or performance cookies
Analytical cookies allow the Site or App to collect information on responses to anonymous requests from users, with the sole purpose of improving the functions of the Site or App themselves; for example, which pages are most visited by users, errors or delays on the pages, counting the number of visitors.
c) Function cookies or “functionality cookies”
Functional cookies allow the Site or App to remember the choices you have made (for example the language or geographical area you are in) and propose them again on subsequent accesses in order to provide better and personalized services (for example, can be used to propose content similar to those you have already requested previously).
d) Profiling cookies
Profiling cookies are used to send advertising messages and services in line with the preferences expressed by you when browsing the internet. In particular, they are used to offer you advertising and services potentially close to your interests, as well as for the creation of individual profiles on your tastes, preferences and consumption choices, as detected while browsing the Site or the App or by comparing the activities you carry out through your browser. For example, they are used to limit the administration of a given advertisement, or to deduce the effectiveness of a campaign from the frequency of viewing of the relevant advertisement.
Description of the methods of consent to the installation of cookies
When you first access the Site/App, you will find a banner with a short information which contains the link to this extended information where you will find more information on the cookies installed by the Owner and third parties.
In this extended information you will find more information on the description and characteristics of the different categories of cookies and you will have the possibility to decide independently which cookies to authorize.
For the use of technical and analytical cookies, your consent is not required. You can, however, disable them by following the procedure described in the paragraph "How to enable or disable cookies on your browsers"
However, as regards the use of profiling cookies, useful for sending you advertising and services in line with your tastes, preferences and consumption choices, your consent is required.
By browsing the Site or using the App, you consent to the use of cookies, including profiling cookies. In any case, you can change your preferences regarding cookies at any time, including denying consent to the use of any cookies (including cookies installed by third parties) in the table below.
The following table describes the cookies sent to your browser when accessing the Site/App. The table is updated as of 02/02/2022; any updates will always be published on this page.
Analytical cookies
Squarespace cookies (Discoverbecome)
Profiling cookies (marketing)
Below are links to the information and consent forms of third parties, independent data controllers, through which you will have the opportunity to collect more information, manage and deactivate these cookies.
How to enable or disable cookies on your browsers
In general, beyond the type of cookies used by this website, it is noted that, in addition to the protections provided by current legislation, options are available for browsing without cookies, such as for example:
Block third-party cookies: third-party cookies are generally not essential for browsing, so it is possible to refuse them by default, through specific functions of your browser.
Enable the Do Not Track option: The Do Not Track option is present in most latest generation browsers. Websites designed to respect this option should automatically stop collecting some browsing data when enabled. As mentioned, not all websites are, however, set up to respect this (discretionary) option.
Activate the "anonymous browsing" mode: using this function you can navigate without leaving any trace of your browsing data in the browser. The sites will not remember the User, the pages visited will not be stored in the history and new cookies will be deleted. However, the anonymous browsing function does not guarantee anonymity on the Internet, because it only serves to avoid keeping browsing data in the browser, where, instead, your browsing data will continue to remain available to website managers and connectivity providers .
Delete cookies directly: there are specific functions to do this in all browsers. It should be remembered, however, that new cookies are downloaded with each connection to the Internet, so the deletion operation should be performed periodically. If desired, some browsers offer automated systems for periodically deleting cookies.
You can, in any case, authorize, limit or block cookies through the settings of your browser. However, if you set your device to reject technical cookies, some site services may not be displayed correctly or function less than optimally.
Below we report the methods offered by the main browsers to block the acceptance of cookies:
Internet Explorer:
Mozilla Firefox:
Google Chrome:
Safari:
Further ways to disable analytical and profiling cookies
In addition to disabling and/or deleting cookies through the relevant settings of your browser, you can proceed to disable and/or delete individual analytical and profiling cookies by accessing the following sites:
Cookies from Google Analytics, which is a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, i.e. text files that are stored on the user's computer to help analyze how users use the Site/App. The information generated by the cookies on the use of the Site/App by the User will be transmitted to a Google server where they will be stored. Google will use this information to analyze your use of the Site/App, prepare reports on activities on the Site/App and to provide further services to the operator of this Site/App related to the use of the Site/App and the use of the Internet. Google will not associate the IP address transmitted by your browser as part of Google Analytics with other data held by Google. The user can prevent the storage of cookies by changing the settings of their browser software, but this could make the functions of the Site/App less personalized based on the user's preferences. The user can receive information on the processing activities of his personal data carried out by Google Analytics at the following address:
https://support.google.com/analytics/answer/6004245; you can also prevent the recording by Google of the data produced by cookies and relating to your use of the Site/App (including your IP address) as well as the processing of such data by Google, by downloading and installing the browser plugin available at the following link:
http://tools.google.com/dlpage/gaoptout?hl=it. By using the Site/App, the user consents to the processing of their data by Google in the manner and for the purposes indicated in Google's privacy policy in relation to the use of Google Analytics, accessible at the following link:
https ://www.google.com/intl/it/policies/privacy/partners/. To disable these cookies visit:
https://tools.google.com/dlpage/gaoptout?hl=.
Social buttons
The Owner uses social buttons on the Site. Social buttons are "digital buttons" or direct connection links with the Social Network platforms configured in each single "button".
With a click on these links you will have the opportunity to interact directly with the accounts (social pages) of the Owner.
The managers of the Social Networks to which the buttons refer are independent data controllers. You will be able to find more information on the individual privacy policies of the Social Network platforms and on how to manage and deactivate the relevant cookies on the platforms themselves.