Dear Visitor,
after consulting this website, data relating to identified or identifiable natural persons may be processed.
With reference to this data processing, we hereby provide, also pursuant to Art. 13 of the European General Data Protection Regulation (Regulation (EU) no 2016/679), the following information, which does not apply to other external websites consulted by the user through links present on this website.

If the user proceeds with browsing and accepts the service proposals contained in the various parts of the website of this company (hereinafter, “Pulkra”) (reserved area login, filling in of forms to request information), it is assumed that this general information on processing has been acquired, together with any specific information on processing for different and specific purposes and that the user gives their consent to processing. The user’s consent is only valid if provided by an adult or by a minor who is at least 14 years old (Art. 8, Pars. 1 and 2, of the GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016).

This Privacy Policy does not apply to the processing of personal data performed by companies who operate independently as franchisees or licensees and who have not been appointed as data processors by Pulkra, or when you share information relating to you through social network platforms (such as Facebook, Instagram, WhatsApp, LinkedIn, etc.) or on other platforms of other companies that are managed by those same companies.

DATA CONTROLLER
PULKRA SRL
61 Via Treviso
31057 Silea (TV)
Italy
VAT number and tax code 05410680267

In order to provide you with products and services, it could be necessary to share some of your personal data with authorised partners who act as data processors. Pursuant to Art. 28 of the Regulation, Pulkra has placed on these parties the obligation of adopting suitable measures to guarantee the security of your information and also the obligation of complying with the instructions of Pulkra on the methods and the purposes for which they are authorised to process your personal data.

USEFUL INFORMATION PROVIDED BY THE USER
Use of the website does not require a personal account to be created. However, in order to access certain pages or services reserved to registered users, you must create a personal account and become a registered user. When the account is created, you will be asked to enter the following registration information:
– first name and surname;
– category (such as private individual, professional);
– e-mail address;
– password;
– telephone number;
– address.
If you disclose information relating to third parties, please do so in compliance with the requirements of personal data protection regulations. You must therefore inform the people to whom the information relates beforehand of the processing and be authorised by them to disclose such data.

DATA ON PREFERENCES
During browsing of the website, the request for and use of services or in the purchase of Pulkra products, information will be collected on your browsing habits, your interactions with the Pulkra content and functions, your preferences and the purchases you make.

COOKIES
Cookies are small files sent by websites you visit and stored on the device used to access those websites. When users visit the same website again, the browser reads the cookies stored on the device and retransmits the information to the website that originally created the cookies. The Website uses various types of cookies and other information reading and storage technologies on the user’s device, in order to perform statistical analysis, for example. We do not use cookies capable of starting up programs on your devices or sending viruses to them, or that allow any form of control to be installed on your devices.
You will find social buttons/widgets on the website, meaning the specific “buttons” depicting the icons of social networks such as Facebook, Instagram and Twitter. These buttons allow users who are browsing the Website to reach and interact directly with social networks with a simple “click”.

Our services use:
Technical cookies, which are necessary to functioning of the website, including the supply of services. This category of cookies includes analytics, session and function cookies, which are used by Pulkra to, for example, collect information, in aggregate form, on the number of users and how they use the Website, to process statistical analysis on the browsing methods of users on the Website in anonymous form or to save your browsing preferences, such as language.
Our own or third-party Profiling cookies, which serve to create profiles relating to the user and are used in order to send and show advertising messages in line with the preferences shown by them during browsing.
The above cookies may be:
• temporary, when they are automatically deleted upon disconnection;
• permanent, when they are stored on the user’s hard disk, unless the user themselves deletes them;
• first-party, when they are set and managed directly by the Website;
• third-party, when they are managed by a different domain to the one visited by the user.

Although use of technical cookies does not require the user’s consent, use of profiling cookies always requires consent. This consent is optional. If the user does not give their consent, browsing will continue with only technical cookies being applied.
Even when the user has given consent to the application of profiling cookies, they can choose to withdraw this consent at any time, or select the cookies for which they intend to give their consent. It is, in fact, possible to manage and disable preferences on the various types of cookies, through the browser settings (i.e. Internet Explorer, Google Chrome, Safari, Firefox) or the cookie bar when accessing the Website.

PURPOSES OF PROCESSING
Pulkra collects, stores, uses and communicates your personal data solely and exclusively for the purposes described in this section.
If you refuse to provide your personal information or do not consent to its processing for certain specific purposes, it might not be possible to provide you with certain services. You will nonetheless be permitted to use the website and to receive the information you request within the limits in which you have communicated the data necessary to manage your request or to use our assistance to the extent that this is possible with the data you have provided. In contrast, for purchases, the data strictly necessary for entry into and performance of the contract (such as the invoicing and shipment data) are essential in order to supply you with the Products.

The purposes for which the data is processed are:
• administrative and accounting purposes, with reference to the entry into and performance of the contract in general and for management of the purchase and maintenance services and after-sales customer care (delivery services, customisation, installation, management of returns and warranties, maintenance and repair of the products purchased);
• those relating to creation of your account and to management of your purchases, to provide you with a service that is as complete and personalised as possible (respond to and manage requests for information and/or feedback);
• analysis and statistics;
• connected to compliance with legal obligations, national and European regulations (including anti money laundering laws), prevention of fraud and for the exercising of legal claims;
• marketing and market research, in order to propose offers and promotions or products that reflect your preferences or to invite you to our events, through the sending of sales or advertising communications (mainly newsletters) or by contacting you directly, providing you with sales support throughout the world, at the store or by e-mail, telephone, text message, instant messaging and traditional mail
• profiling, in the presence of the legal basis for processing described in the paragraph that follows (Legal basis for processing), for the creation of the group and individual profiles that are used to provide you with content, communications, assistance and personalised and custom experiences. You can provide the data when you register at our stores, using the paper and/or electronic forms, acquired during visits to showrooms or through interaction with the Pulkra website and Internet and mobile applications.
For profiling and marketing activities performed using cookies and other tracking technologies, please consult the previous paragraph (Information collected through cookies and other technologies) and the brief information notice present on the cookie bar, where the tracking purposes and methods are specifically indicated, and select the settings that you prefer.

LEGAL BASIS
Your personal data is processed in accordance with personal data protection regulations, in the presence of one of the legal requirements laid down by those regulations, and specifically:
• for our marketing and market research activities, to propose offers and promotions or products that reflect your preferences, based on the consent you have given;
• for entry into and performance of a purchase contract of the services or products offered by Pulkra, to support you in the phase prior to choice of the products and services and to provide the services available online;
• for compliance with a legal obligation to which controllers are subject in the purposes that they pursue;
• for the legitimate interest of the controller in guaranteeing browsing functions and registration on the Website, to prevent and prosecute fraud, to propose personalised content to you, to protect legal claims and, where necessary, when the data is communicated to companies in the controller’s business group for administrative purposes;

DATA PROCESSING AND STORAGE
Your personal data will be processed on both paper and using electronic mediums and always in compliance with the security requirements set forth by applicable regulations, with particular reference to Art. 32 of the Regulation. We adopt specific technical and organisational security measures to protect your personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorised disclosure or access.

In appointing our product and service providers as data processors, we ensure that they are able to guarantee the security of the personal data according to internationally recognised standards. The employees and collaborators of Pulkra and also the third-party service providers who have access to your personal data are subject to legal and contractual confidentiality obligations.

In the event of occurrence of a security incident that results in a personal data breach as defined by the Regulation, Pulkra has introduced a management procedure serving to guarantee an efficient response to the incident and to mitigate and limit the severity of the consequences. In the cases envisaged by personal data protection regulations, we will inform you and the Personal Data Protection Supervisory Authority of the breach. Pulkra will process your personal data up until the moment when the purposes for which it has been collected have been achieved, in accordance with our internal policies. In particular, we specify that we have a general storage period of 10 years from the moment of collection of your personal data, which is processed for invoicing and accounting purposes, other than in circumstances in which applicable national regulations require different storage periods.

USER DATA AND ACCOUNT
This data will be stored for as long as the account is active, to the extent strictly necessary to supply the services to the user. We will store your data even after closure of the account, only if and to the extent that this is necessary to comply with legal or regulatory obligations, to protect our rights, to prevent fraud or to apply this Privacy Policy.

ACCESS – RECTIFICATION – ERASURE – COMPLAINTS
Pulkra guarantees the rights referred to in Arts. 15 et seq. of Regulation (EU) no 2016/679, including the right to request access to the personal data, to its rectification or erasure, to restriction of processing or to object to processing, and also the right to lodge a complaint with the supervisory authority (Personal Data Protection Supervisory Authority).

PAYMENT DATA
In your purchases of products and services, the payment data will be stored up until certification of the payment and conclusion of the relative administrative and accounting formalities consequent upon the end of the right of withdrawal period and the terms applied to dispute the payment. Sensitive data, such as credit card numbers or bank data on payments, is not managed by Pulkra and reference should be made to the terms and conditions of service of the accredited external providers in this phase, such as Paypal or circuits such as Visa and Mastercard.
In any case, for technical reasons, cessation of processing and the consequent irreversible erasure or anonymisation of the relative personal data will be final within thirty days of the deadlines indicated here above.

PERSONAL DATA RECIPIENTS
Our duly authorised employees have access to the personal data (such as the staff of the Digital, CRM, Retail and IT functions), according to need. The personal data is disclosed to third parties in the following cases: (i) when disclosure is required by applicable laws and regulations with respect to legitimate third-party recipients, such as public authorities and entities, for their respective institutional purposes, e.g. anti money laundering regulations, judicial authorities; (ii) when disclosure is to third-party providers of fraud prevention services.
The personal data is also shared with our service providers, e.g. for technical and organisational services that are functional to the purposes indicated here above, such as freelance collaborators, also in the form of partnership, shipping, marketing, payment management companies, etc., the list of which can be sent on request. We only provide these parties with the data necessary to provide the agreed services and they act as processors in accordance with Art. 28 GDPR, based on the instructions received from Pulkra. It remains expressly understood that Pulkra does not transfer the personal data to third parties for marketing or profiling purposes.

TRANSFER OF THE PERSONAL DATA TO THIRD COUNTRIES
For specific processing activities of your personal data, Pulkra might transfer such data to external parties located in countries outside the European Union (EU) or the European Economic Area (EEA) (hereinafter, “Third Countries”).
In particular, Pulkra informs you that your personal data could be transferred to Third Countries, the list of which will be revised from time to time and/or available on request; the lawfulness of this transfer is, in any case, guaranteed through the mechanisms set forth by Regulation (EU) 2016/679.

CHANGES TO THE PRIVACY POLICY
Pulkra could occasionally make changes to this Privacy Policy, for technical reasons, for example, or to comply with legal requirements imposed by applicable laws or following measures issued by the Personal Data Protection Supervisory Authority. The revised information will be published on the Website, so we invite you to consult it regularly. It could be necessary to notify you of changes in the Privacy Policy. If Pulkra processes your personal data for purposes not indicated in this Privacy Policy, we will inform you and will request your consent, where necessary.