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CELLULARLINE PRIVACY POLICY

This information notice is provided pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 ("GDPR") to users and visitors of the www.cellularline.com website.

This notice describes how personal data is processed in relation to website navigation, registration, and use of available services, sending promotional communications, managing user requests, and the other purposes indicated below.

1. Who processes personal data?

In relation to the various activities described in this notice, personal data may be processed by the Data Controller:

  • CELLULARLINE S.p.A., with registered office in Reggio Emilia, via G. Lambrakis 1/A, VAT number 09800730963 and registration number in the Register of Companies of Reggio Emilia RE315329, telephone 0522 334002, owner of the website and holder of the domain name and Cellularline trademarks.
    Cellularline has appointed a Data Protection Officer (DPO), who can be contacted at the e-mail address privacy@cellularline.com.

Please also note that T-Data S.r.l., with registered office in via Strasburgo 31, 41011 Campogalliano (MO), tax code and VAT number IT03854490368, registration number in the Register of Companies of Modena 03854490368, telephone 0331 1090043, e-mail supporto@t-data.it, is the entity that manages the sales activities for products marketed through the Site, including orders, payments, shipments, returns, and sales-related activities, according to the responsibilities actually assumed within the customer relationship. For more information on the processing handled by T-Data, please consult the notice at https://www.cellularline.com/en-it/privacy.

2. For what purposes, on what legal basis, and for how long?

2.1 NAVIGATION AND E-COMMERCE USE

2.1.1 Access and website navigation

During navigation, technical data necessary for the operation of the website may be collected, such as IP addresses, device and browser information, access logs, and other data generated by interaction with web services. Information regarding cookies and any tracking tools used on the website is available in the Cookie Policy, which can be consulted at the following address: https://www.iubenda.com/privacy-policy/70839141/cookie-policy.

2.1.2 Registration and management of the Cellularline account

By registering on the website, the user can enjoy all services dedicated to registered members available in their reserved area. Website registration is optional.

Legal basis: the legal basis is the performance of the contract regarding registration and the use of services requested by the user.

Retention periods: the processing of data related to the registered account will take place until the account is deleted by the user, an action always possible by accessing their reserved area on the website or through an explicit request.

2.1.3 Enabling preliminary activities for the purchase contract concluded between the user and T-Data

When the user makes a purchase without registration, the data necessary for order management will be collected and transmitted to T-Data to complete the requested order, shipping, and related fulfillments.

Legal basis: the legal basis for processing such data is the performance of pre-contractual measures adopted at the request of the data subject.

Retention periods: order data is retained for the time necessary to manage the purchase and related fulfillments.

2.2 Marketing

2.2.1 Newsletter and DEM sending

Subject to consent, Cellularline may use the data subject's contact details to send newsletters, DEMs, and other promotional communications concerning its brands and products and related usage contexts, using automated tools and through text content, images, videos, and other multimedia materials. Communications may use tracking pixels to detect opens and interactions, measure campaign performance, and, where applicable, support segmentation and personalization activities.

Legal basis: consent of the data subject expressed at the time of newsletter subscription. It is possible to use the functions in the footer of communications to manage tracking preferences and request unsubscription from the newsletter.

Retention periods: contact data used for sending until unsubscription request or revocation of consent. Tracking data retained for a maximum of 180 days.

2.2.2 Profiling and personalized marketing

For registered users who use e-commerce following authentication, the Controller may analyze preferences and navigation and purchase behaviors to personalize content and promotional communications, including proposals for complementary or alternative products (cross-selling and up-selling).

Legal basis: consent of the data subject expressed at the time of registration. Consent can be revoked at any time through the reserved area of the website.

Retention periods: maximum 12 months from the provision of consent.

2.2.3 Social campaigns and digital marketing

Your personal information, collected while browsing the site or purchasing products, can be shared with digital platforms and social networks for marketing activities and to personalize the ads you see online. The Controller may also process the user's contact details and data communicated by the user during interaction with digital platforms and social networks to display, through the aforementioned platforms, including Meta Platforms Ireland Ltd. ("Meta"), marketing ads and content consistent with their interests, based on preferences and consumption habits analyzed by the platform operators themselves.

Legal basis: profiling cookie consents expressed by the user through the Site's cookie preferences, or via the privacy settings of their profile on the social network.

Retention periods: user data is processed for this purpose with reference to the last 2 years of activity, and in any case until the user expresses the desire to no longer participate in the service.

2.3 Customer assistance and after-sales activities

2.3.1 Customer Satisfaction and service improvement

The Controller may process personal data to collect evaluations and feedback on purchased products and analyze customer satisfaction, in order to improve products and services.

Legal basis: legitimate interest of the Controller to evaluate and improve the quality of its products and services, pursuant to art. 6, par. 1, lett. f), of the GDPR.

Retention periods: maximum 24 months from collection, after which data is deleted or anonymized.

2.3.2 Customer Care and Customer Service

Personal data may be processed to handle assistance and information requests, complaints, reports of defects or malfunctions, returns, replacements, repairs, refunds, and other after-sales activities, including any product recall procedures from the market. Identification and contact data, order and product information, purchase documentation, and communications relevant to the request are processed. Data may be communicated to parties involved in case management, such as sellers, assistance centers, and logistics suppliers.

Legal basis: for each request related to a purchase or other services requested by the data subject, the legal basis is the performance of the contract, as well as compliance with legal obligations, where applicable.

Retention periods: the time necessary to manage the case and, subsequently, for an additional 10 years, where necessary to comply with legal obligations or protect the rights of the Controller.

2.3.3 Virtual assistance and AI chatbot

To optimize the management of support requests, the Site uses an AI-based live chat and virtual assistant service. When the data subject starts a conversation, the system automatically processes the data entered in the chat (identification data, contact data, and text messages containing details about the request or order) in order to provide immediate real-time responses. Although the system is configured to provide accurate and useful answers, responses may sometimes be incomplete, inaccurate, or outdated. In case of doubt, it is recommended to consult official sources (e.g., manuals, terms of use, product sheets), interpret answers with caution, or contact customer service.

Legal basis: execution of pre-contractual or contractual measures adopted at the request of the data subject (art. 6, par. 1, lett. b of the GDPR).

Retention periods: maximum of 180 days from the end of the chat session, to ensure support continuity and, where necessary, to verify the correct functioning of the service.

2.3.4 Management and publication of purchase reviews

Following a purchase, contact and purchase-related data may be used to invite the user to leave a review. The collection, moderation, and online publication of reviews and related content (rating, comment, photos and videos, general consumer references) are managed through services of external parties acting as Data Processors.

Legal basis: sending the product review request is based on the legitimate interest of the Controller. The buyer is in no way obliged to provide a review.

Retention period: the processing of data relating to the reviews provided will continue until a request to exercise the right to erasure is made by the data subject.

2.4 Legal protection and compliance

2.4.1 Managing requests to exercise rights regarding personal data protection

In the event of a request to exercise the rights provided by the GDPR, the applicant's identification and contact data, information necessary to verify their identity (where appropriate), and data necessary to manage and document the request may be processed.

Legal basis: compliance with obligations established by personal data protection regulations.

Retention periods: the time necessary to manage the request and, subsequently, for an additional 10 years to prove compliance with obligations and manage any disputes.

2.4.2 Pursuing justice purposes

Personal data may be processed to establish, exercise, or defend a legal claim of the controller, including in judicial or out-of-court proceedings.

Legal basis: the legitimate interest of the controller to protect its rights, pursuant to Article 6, paragraph 1, letter f), of the GDPR, or compliance with legal obligations in anticipated cases.

Retention periods: up to a maximum of 10 years from collection or achievement of the purpose for which they were originally collected, taking into account applicable statute of limitations and forfeiture periods and any duration of disputes.

3 How is personal data processed?

Personal data is processed using paper, IT, and electronic tools, according to procedures and organizational methods consistent with the purposes for which they are collected. Processing is carried out by authorized personnel and duly identified external parties, within the limits of their respective competencies and instructions received. Adequate technical and organizational measures are adopted to protect personal data from unauthorized access, loss, destruction, disclosure, or unlawful use.

Any automated processes are used, where applicable, for the purposes described in this notice. The existence of automated processes producing decisions based solely on automated processing, pursuant to Article 22 GDPR, will be communicated to data subjects when applicable.

4 Is it mandatory to provide personal data?

The provision of navigation data necessary for the technical operation of the website occurs during the use of web services. For other purposes, the provision of data is generally optional, but may be necessary to use specific services or obtain certain performances. In particular:

  • failure to provide data necessary for registration prevents account creation;
  • failure to provide data necessary for managing an order may prevent the conclusion or execution of the purchase;
  • failure to provide data necessary for managing an assistance request may prevent, wholly or partially, the management of the case;
  • failure to consent to marketing makes it impossible to receive promotional communications based on such consent, without prejudice to access to other services;
  • objecting to the use of tracking systems (pixel tracking) in marketing communications does not prevent receiving DEMs and newsletters, if the data subject has provided and maintained consent to marketing.

The data subject may revoke consents given at any time, without prejudice to the lawfulness of processing carried out before revocation.

5 To whom may personal data be communicated?

Personal data is not disseminated to the public, unless such activity is expressly provided for by applicable legislation or has been legitimately authorized by the data subject. Data may be communicated, within the limits necessary for the indicated purposes, to the following categories of recipients:

  • companies belonging to the Cellularline group;
  • T-Data S.r.l. and other entities involved in the management of orders, shipments, returns, warranties, and assistance;
  • assistance centers, couriers, logistics operators, other parties involved in consumer service;
  • suppliers of IT, hosting, cloud, maintenance, and security services;
  • suppliers of mailing and marketing automation platforms;
  • consultants, professionals, and companies providing administrative, legal, or organizational services;
  • public authorities and other entities authorized to access data under legal provisions or orders of the competent authority.

External parties may operate, depending on the activities performed, as data processors pursuant to Article 28 GDPR, autonomous controllers, or recipients of data. Their qualification depends on the functions actually performed and responsibilities assumed.

The updated list of data processors can be requested from Cellularline using the contact details indicated in this notice.

6 Where is personal data stored?

Personal data is stored at the premises of the controller and suppliers involved in the activities described in this notice, in compliance with applicable security measures.

For processing operations that involve the transfer of data to countries located outside the European Economic Area, the transfer takes place in compliance with Chapter V GDPR. In particular, adherence to the Data Privacy Framework for suppliers/transfers to the USA is verified. Any extra-EU data transfer is based on an adequacy decision by the European Commission, or on appropriate safeguards, such as the use of Standard Contractual Clauses defined by European authorities. Information on actual transfers and related safeguards can be requested from the Controller using the contact details indicated in this notice.

7 What are the rights of the data subject?

As a data subject, you have a series of rights pursuant to Articles 15-22 of Regulation (EU) 2016/679, such as:

  • Right to access your personal data (once confirmation is obtained that data is being processed by the Controller);
  • Right to obtain rectification and integration of your data;
  • Right to obtain erasure of your data;
  • Right to obtain restriction of processing of your personal data under certain conditions;
  • Right to receive personal data provided to the Controller in a structured and commonly used format, and to transmit them to a different Controller;
  • Right to object to the processing of personal data if reasons connected to your personal situation apply;
  • Right not to be subject to automated decision-making;
  • Right to obtain communication in the event that your data suffers a serious breach;
  • Right to revoke consent to processing at any time;
  • Right to lodge a complaint before a supervisory authority.

The Controller undertakes to make the exercise of rights by data subjects as easy as possible.
To request the exercise of rights, or for any doubt or need related to the processing of personal data, you can contact CELLULARLINE SPA via e-mail at privacy@cellularline.com.

8 Update of the notice

This notice may be updated to incorporate regulatory, organizational, or technological changes and to correctly describe processing activities. Date of last update: October 2026.