Verarbeitung personenbezogener Daten durch die für das Online-Bewerbungsverfahren verantwortliche Stelle

This Privacy Policy is important for you if you use our Website because it explains how we handle your Personal Data and for what purposes.

We are ShopFully S.p.A. owner of the Website and, Offerista Group GmbH, joint data controllers (from now on, for simplicity, the “Company”, “Companies” or  “we”, “our”, “us”).

The Companies have regulated their respective roles and responsibilities in the performance of the processing activities referred to in this Privacy Policy in an agreement drafted pursuant to Article 26 of Regulation EU 679/2016, of which an excerpt is available by emailing dpo@shopfully.com or dpo-offerista@shopfully.com.

As joint data controllers and in compliance with the applicable data protection law, we are committed to protecting your online privacy as a user of our Website. Later on in this document, you will find Definitions related to this Privacy Policy and an example of the processing of your Personal Data. However, if you need any clarifications or any information regarding your data, please write us to dpo@shopfully.com or offerista@shopfully.com.

1. What information we collect

By using our Website, the processing of collected data and relative purposes depends on how you use our Services and how you manage your Browser and the Device that you are using.

a) Personal Data provided by you:

When you use our Services, you may provide us with Personal Data such as your name, phone/mobile number(s), e-mail address, location, country of residence and address. For example, you transmit your Personal Data when you fill out the forms available on the Website, e.g. in order to request us to share documents with you or in order to subscribe to our Newsletter, when you contact us for questions or requests here, or when you give your consent to profiling Cookies that track your choices and behaviour when using our Website. We do not process Sensitive Data through the Website and we invite you not to give us your Sensitive Data when you are using the Website.

If you provide us with third party data, you must assume all inherent legal obligations and responsibilities, and you must fully indemnify the Company against any complaints, claims or demands for compensation of damages which may arise from the processing of third party Personal Data in violation of any data protection applicable law.

If you decide to apply for a specific position posted on the “Careers” section of the Website and send us information through your application such as your anagraphic details, contact details, resume, cover letter, professional qualifications and/or work information, we inform you that we will share your data with our Companies and Affiliates, including Flipp Operations Inc. with registered office at 350-3250 Bloor St. W, Toronto, ON, M8X 2X9, as joint controllers for the purpose of Intra-Group Sharing for generic candidate applications, as further described below in section 2.g, so that they can evaluate them and contact you if they consider your application to be valid. In the latter case, hence starting from the contact processing and any further processing, please note that there are specific privacy policies for each Company and Affiliate, depending on the relevant Company’s specific position, here, whereby each Company shall act instead as a sole controller.

b) Personal Data collected by the Browser and the Device

When you use our Services, we collect information on the Browser and the Device you are using. This information includes your IP address, location (country), the domain names of your computer, the Unique Identifier, the time of requests made, and other information such as the type of your Browser or Device. In this case this information may consist of your operating system, language, network settings, and plug-in lists.

Some of this information is collected by Cookies or Tracking technologies that are on your Browser or Device and that help us to avoid our Website from malfunctioning when you use it. You can find the complete list of Cookies we use here.

2. Why we collect your Personal Data 

The Information described above is used for the following purposes:

a) Providing our Services and carrying out your requests

We use Personal Data collected from your Browser and Device to allow you to use the Website, fill out forms, or to contact the Company.

This processing is based on the performance of a contractual obligation (our Terms and Conditions) or to carry out your request.

b) Complying with legal obligations

We may use your Personal Data to comply with legal and tax obligations to which impose upon the Company the obligation to collect and/or further process your information.

c) Detecting anomalies and improving our Services

We use Personal Data collected by the Browser or the Device and that which is provided by you in order to avoid anomalies in our Services and to improve them. For example, we can detect anomalies when you open a section of the Website, a link or a bug system.

This processing is based on the necessity to guarantee the Services of the Website as indicated in our Terms and Conditions and is also based on our legitimate interest to avoid any inefficiency of our Services.

d) Protecting our interests and your interests

We may want to use your information within our detecting and preventing activities, or for reacting to fraudulent and illegal behaviour or activity which could cause a prejudice to the safety of our Services. This is the case when you use our Website differently than what it is permitted by our Terms and Conditions.

This processing is based on our legitimate interest to safeguard our users.

e) Tracking your preferences when using our Website

We can create a profile of you or show to you ads that may be useful to you through the use of profiling cookies delivered by third parties and regarding the choices you make when using the Website as well as your general activities on the Website. For example, we may show you advertisements that reflect your product preferences and we believe are useful to you. All algorithms involved in this automated or semi-automated processing are regularly tested to ensure the processing’s fairness and to control for bias.

This processing is based on your consent expressed by means of our cookie banner displaying at your first visit of our Website.

f) Sending our Newsletter

We will send you our informative and promotional Newsletter, in case where you have provided the Company with your consent to receive it.

This processing is based on your consent expressed by means of entering your e-mail address in the specific e-mail fields provided within our Website.

g) Intra-Group Sharing for generic candidate applications

We will share, through a common database of applicants and/or potential applicants, generic candidate applications within our Companies and Affiliates, including Flipp Operations Inc., so that they can evaluate them and contact you if they consider your application to be valid. In the latter case, hence starting from the contact processing and any further processing, please note that there are specific privacy policies for each Company and Affiliate, depending on the relevant Company’s specific position, here, whereby each Company shall act instead as a sole controller.

3. How we use your Personal Data

Personal Data collected for the purposes indicated above is processed both manually and automatically, thus through programmes or algorithms that analyse information collected by the Browser and the Device.

Your Personal Data may be subject to Combination and/or Crossing: this allows us to understand, for example, if the same user is utilizing our Services with the same IP address both from the Browser and the Device.

4. Who we share Your Personal Data with

We share your information with the following list of persons/entities (“Recipients”):

persons authorised by us: our employees and collaborators who have undertaken an obligation of confidentiality and abide by specific rules concerning the processing of your Personal Data;

our data processors: external subjects to whom we delegate some processing activities. For example, security systems providers, database providers, accounting, administrative, legal, tax, financial and debt collection consultants, e-mail platform providers to send our Newsletter and hosting providers. We have signed agreements with our data processors to ensure that your Personal Data are processed with appropriate safeguards and security measures under our instruction;

systems administrators: our employees or those of our data processors who provide us with the management of our IT systems and therefore can access, modify, suspend and limit the processing of your Personal Data. These subjects have been previously selected, adequately trained and their activities are tracked by systems that they cannot modify;

our Affiliates: for example, if you are an Australian citizen, we may share your request or questions with the Affiliate form your country to help you in your own language. All our Affiliates have signed Personal Data processing agreements with us;

authorities to whom your Personal Data may be disclosed in accordance with the law or to respond to orders. We may also disclose your Personal Data when any dispute arises with you under our Terms and Conditions.

5. Where your Personal Data are located

Our Website and Services are available all over the world. We ensure that the processing of your Personal Data by our Recipients is compliant with EU and Italian law to which we are subject. Transfers of Personal Data may be based on adequacy decisions (for example, EU-US Data Privacy Framework) or on Standard Contractual Clauses approved by the European Commission. For more information on where your data are located please write us here: dpo@shopfully.com or dpo-offerista@shopfully.com.

6. How long we retain your Personal Data

Personal Data processed for the purposes indicated above will be kept for the period deemed strictly necessary to fulfil such purposes or until you revoke your consent, if this is the legal basis that allow us to process your Personal Data.

Personal Data processed in compliance with the legal obligations to which we are subjects is kept for the period required by the law.

Personal Data processed to protect our interests and our user’s interests is kept until Italian law provides for protecting our interest (Art. 2946 of the Italian Civil Code and related Artts ). You can ask us for more information on our criteria and data retention policy by writing us here: dpo@shopfully.com or dpo-offerista@shopfully.com.

7. How you can control your Personal Data

At any time, you can ask to:

access your Personal Data: according to your use of our Services, we will give Personal Data we have related to you, such as your name, IP address, Unique Identifiers of e-mail together with the Privacy Notice that you received when you provided us with your Personal Data;

exercise your right to portability of your Personal Data: according to your use of our Services, we will provide you and excel file containing your Personal Data you have provided us, or which we have gathered from you, when such Personal Data are used by us to provide you our Services, or when processing is based on your consent;

correct your Personal Data: for example, you can ask us to modify your e-mail address if it is incorrect;

limit the processing of your Personal Data: for example, when you think that the processing of your Personal Data is unlawful or that processing based on our legitimate interest is not appropriate;

delete your Personal Data: for example, when you don’t want to use our Services and may not want us to retain your Personal Data any longer;

update your preferences for processing based on your consent: in the case of Cookies, you may withdraw your consent by using the relevant options provided by design by our Website (i.e., the “lock” icon found at the bottom left corner of your screen); in the case of our Newsletter, you may do so by clicking the link at the bottom of each e-mail received.

We will reply to your request within one month according to EU data protection law (and at the longest, additional two months in case of particular complexity). You can exercise your rights as indicated above writing by clicking here.

In any case, you can:

reach our Data Protection Officer (DPO) here: dpo@shopfully.com or dpo-offerista@shopfully.com;

contact the Data Protection Authority in your country;

set up your preferences regarding Personal Data collected by your Browser and Device using the instructions that you find here.

8. What this Privacy Policy does not cover

This Privacy Policy explains and covers processing that we carry out as joint data controllers within this Website and its Services.

This Privacy Policy does not cover processing carried out by different subjects from the Companies.

Regarding these cases, we are not responsible for any processing of your Personal Data carried out by a third party or processing which is not covered by this Privacy Policy.

9. Amendments

This Privacy Policy entered into force on 19th February 2025. We reserve the right to amend this Privacy Policy, or simply to update its content, for example, as a result of changes in applicable law. We will inform you of substantial changes to this Privacy Policy through a message via your Browser.

10. Setting your preferences for Personal Data collected by your Browser or Device

a) Cookie

You can find our Cookie Policy by clicking here.

Definitions

Affiliate/Affiliates: refers to any entity that directly or indirectly controls, is controlled by or is under common control with the Companies and its Affiliates’ subsidiaries, meaning any entity which is directly or indirectly controlled by the Affiliates     .

Browser: refers to programs you use to access the internet (e.g. Safari, Chrome, Firefox, etc.).

Combination and Crossing: refers to both automated processing and manual processing, through which we combine the information you provide, Personal Data collected by the Browser or the Device, or Personal Data collected by the Website to provide you with the Services.

Company: refers jointly to ShopFully S.p.A., with registered office in Italy, in Via Giosuè Borsi 9 – 20143, Milan, VAT Number: IT03156531208, Offerista Group GmbH with registered office at Waldemarstraße 33a, 10999 Berlin, Germany      , VAT Number: DE269181955     , acting as joint data controllers regarding the processing of user’s Personal Data.

Cookie: refers to a small text sent to your Browser from our Website or third parties. It allows the Website to record information including your visit, language preferences, as well as other information. Cookies are used for different purposes, for example, to record your preferences regarding the use of Cookies (technical cookies). Information transmitted by Cookies are subject to Combination and/or Crossing with other Tracking Technologies where applicable.

Device: refers to electronic devices and/or smartphones (e.g. iPhone) through which you visit this Website.

IP address: refers to a unique number used by your Browser or your Device in order to connect to internet. This number is provided by the internet service provider and also allows for identification of the provider and/or the area where you are located. Without this data you cannot connect to the Internet.

Newsletter: refers to the newsletter concerning the Companies and its Affiliates, which is sent to those who enter their e-mail address in the specific e-mail fields provided within our Website. It consists in sending, on a periodical basis, communications, communications relating to company news (such as acquisitions or mergers, press releases, new hires, internal appointments, case-studies), information and data drawn from our marketplace, webinars and events organized by the Companies or by our Affiliates, offers and promotions offered by the Companies, and so on. The content of our Newsletter may be customized in accordance with the preferences and information you have provided us when subscribing; this activity does not imply any automated profiling of your Personal Data.

Personal Data: means any information relating to an identified or identifiable natural person. For example, an e-mail address (if it refers to one or more factors of an individual) or an IP address are considered personal data.

Privacy Policy: refers to this document provided pursuant to Arts. 13 and 14 of Regulation EU 679/2016.

Sensitive Data: means special categories of Personal Data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation for the purpose of uniquely identifying a natural person. We do not use, deduce or transfer this information.

Services: refers to the services as described in our Terms and Conditions (e.g. filling out the form provided on the Website).

Terms and Conditions: the terms and conditions regarding this Website which you can find here.

Tracking Technologies: refers to pixel tags (tracking technologies that are inserted on images of the webpages with the intent to track some of your activities when you visit our Website).

Unique Identifier: refers to information that identifies you uniquely through your Browser and Device. Your Browser considers your IP address and Cookies as Unique Identifiers. We precise that we do not use, complying with EU Supervisory Authorities, other identifiers such as MAC Address and IMEI because they are not settleable by you. You can set your URI here.

Website: refers to our website https://shopfully.com/.