Privacy policy

KP Srl
Strada Tagliata, 18
12051 Alba (CN)
P.IVA 03651730040
Stock capital fully paid in € 20.000,00.

Economic Administrative Index (REA) registration number in the Trade Register CN-306680

PRIVACY POLICY

In accordance with the provisions of EU Regulation no. 679/2016 (hereinafter the “Regulation”), article 13 – Information to be provided if personal data are collected from the data subject -, Kp S.r.l. (Thok E Bikes), having its registered office in Strada Tagliata, 18, 12051 Alba CN (hereinafter the “Company”), provides the following information on the processing of personal data of its customers, suppliers, employees and outside staff (hereinafter the “Data”) performed by the Company, as Data Controller.

1 Identity of the Data Controller and contact details

In accordance with article 4 of the Regulation, the Company is the Data Controller of its customers, suppliers, employees and outside staff personal data.
For communications or requests, the Company can be reached by e-mail at the address: privacy@thokebikes.com

2. Categories and types of Data collected and processed

The Data processed by the Company may include personal data, not belonging to particular categories (Article 9 of the Regulation) collected for the purpose of the conclusion of the contract and in the context of its execution and/or stipulation.
Furthermore, it is possible to process personal data belonging to third parties communicated to the Company by customers, suppliers, employees and outside staff. With respect to this hypothesis, the Customer stands as an independent Data Controller and assumes the consequent legal obligations and responsibilities, relieving the Company from any objection, claim and/or request for compensation for the damage caused by treatment that should reach the Company from third parties concerned.

3. Purpose and legal basis of the processing and nature of the provision of Data

In compliance with current regulations regarding the protection of personal data and without the need for a specific consent by the data subject, the Data will be stored, collected and processed by the Company for the following purposes:

a) fulfilment of contractual obligations, execution and/or conclusion of the contract and/or management of any pre-contractual measures;

b) compliance with legal requirements, with tax and fiscal provisions deriving from the performance of the business activity and from obligations related to the administrative and accounting activities;

c) sending, directly or through third-party providers of marketing and communication services, newsletters and communications for the purpose of direct marketing through email, sms, mms, push notifications, fax, paper mail, telephone with operator, in relation to the products supplied;

d) communication of Data to third-party companies for the sending of newsletters and communications for marketing purposes through e-mail, sms, mms, push notifications, fax, paper mail, telephone with operator.

The legal bases of processing for the purposes a) and b) above mentioned are the articles. 6.1.b) and 6.1.c) of the Regulation. The provision of Data for the aforementioned purposes is optional, but any failure in providing them and the refusal to supply them would make it impossible for the Company to execute and/or stipulate the contract and grant the services requested by the same.
The legal basis for processing personal data for purposes c) and d) is art. 6.1.a) of the Regulation, since the treatments are based on consent; it is specified that the Data Controller can collect a single consent for the marketing purposes described herein, in accordance with the General Measures issued by the Italian Data Protection Authority for the protection of personal data “Guidelines on promotional activities and the fight against spam” dated July 4th 2013. The provision of consent to use ones’ Data for marketing purposes is optional and if the Data subject wishes to object to the processing of his Data for marketing purposes performed with the means indicated herein, as well as revoke the consent given, he may at any time do so without any consequences (except for the fact that he will no longer receive marketing communications) by following the instructions in the “Data Subject’s Rights” section of this Notice.

4. Methods of data processing

In relation to the aforementioned purposes, the Data are processed using manual, information technology and telematic tools with logics strictly related to the purposes themselves and, in any case, in such a way as to guarantee the security and confidentiality of the Data, in addition to the compliance with the specific obligations established by the legislation. The Data will be processed in compliance with the principle of lawfulness, correctness, relevance and non-excess, in accordance with the provisions on the protection of personal data. The treatment will be carried out by staff who are formally appointed and adequately trained.

5. Transmission and diffusion of Data, recipients, Data transfer and Data Processors

For the aforesaid purposes, the Data may be disclosed to other Group companies and to third parties appointed as data processors in accordance with Article 28 of the Rules and in particular to banking institutions, insurance companies, to providers of services strictly necessary to the carrying out of the business activity, or to consultants of the company, where this proves to be necessary for fiscal, administrative, contractual reasons or for needs protected by current regulations.
Furthermore, the other Group companies will be able to access the Data for administrative and / or accounting purposes, in accordance to recitals 47 and 48 and to Article 6 of the Regulation.
Finally, the Data may be shared with authorities, entities and / or subjects to whom the Data must be communicated pursuant to legal provisions or orders of authority. These authorities, bodies and / or subjects will act as independent data controllers.
Data will not be disclosed.
A periodically updated and complete list of data processors appointed for data processing may be requested by sending an e-mail to the Data Controller at the addresses indicated above.

6. Transfer of Data to international organizations and / or countries outside the EEA (European Economic Area):

Any transfer of Data to international organizations and / or non-EEA countries will take place according to one of the methods permitted by current legislation, such as the consent of the interested party, the adoption of Standard Clauses approved by the European Commission, the selection of subjects adhering to international programs for free circulation of data (i.e. EU-USA Privacy Shield) or operating in countries considered safe by the European Commission.
On request, it is possible to have more information from the Company to the above-mentioned contacts.

7. Data Retention

The Data will be stored on paper and / or computer only for the time necessary for the purposes for which it was collected, respecting the principles of limitation of conservation and minimization according to Article 5, paragraph 1, letters c) and e) of the Regulation.
The Data will be kept to comply with the Regulation and to pursue the above-mentioned purposes, in compliance with the principles of indispensability, non-excess and relevance.
The Company may retain the Data after the end of the contractual relationship to fulfil regulatory and / or post-contractual obligations; subsequently, when the aforementioned reasons for the processing no longer exist, the Data will be deleted, destroyed or simply stored anonymously.
On request, it is possible to have more information from the Company to the above-mentioned contacts.

8. Data subject’s rights

In relation to the aforementioned processing, each data subject can exercise the rights referred to in articles 15 to 22 of the Regulation.
In particular, the data subject has the right to ask the Company for access to its Data, correction or cancellation of the same, he has the right to oppose the processing or to require the limitation of processing in the cases contemplated by Article 18 of the Regulation and to obtain, in a structured format, in common use and readable by an automatic device, its own Data, in the cases contemplated by Article 20 of the Regulation.
The data subject may also revoke at any time the consent granted in accordance to Article 7 of the Regulation, as well as propose a claim by the Privacy Authority for the protection of personal data according to Article 77 of the Regulation, in case he considers the processing of his own Data to be contrary to the current regulation.
In case of opposition to the processing of Data according to Article 21 of the Regulation, the Company reserves the right to assess the request, which will not be accepted if there are legitimate reasons to proceed to the processing that prevail over the interests, rights and freedom of the Data Subject. Requests should be sent in writing to the Company at the above addresses.

COOKIE POLICY

We describe below the various types of cookie used by the Site as a function of the utilisation goals envisaged. Technical cookies these cookies ensure the proper operation of some sections of the Site. They are subdivided into two categories: persistent and session cookies:

There are different types of cookie, some of which are used to improve the efficiency of Site utilisation, while others are used to enable specific functions. When analysed in detail, our cookies make it possible to:

• Save the preferences entered;
• Prevent the same information, e.g., username and password, from having to be entered repeatedly during a visit;
• Analyse the way the services and contents supplied are used, with a view to optimising the navigation experience and the services offered.

Types of Cookie used by the Site

We describe below the various types of cookie used by the Site as a function of the utilisation goals envisaged. Technical cookies these cookies ensure the proper operation of some sections of the Site. They are subdivided into two categories: persistent and session cookies:

• Persistent cookies: when the browser is closed, these cookies are not deleted and are kept until a pre-determined expiration date
• Session cookies: are cleared when you quit the browser

All these cookies are sent from our domain and are necessary to display the site properly and in relation to the technical services offered; hence they will always be used and sent, unless the users change the settings in their browsers (this might result in an incorrect display of the contents of the Site).

Analytical cookies the cookies belonging to this group are used to collect information on site use.

Google Analytics
This website uses Google Analytics, a web analysis service supplied by Google, Inc. (“Google”). Google Analytics uses cookies consisting of text files stored in your computer in order to enable the website to examine site utilisation modalities by the users. The information generated by the cookies on website use (including your anonymous IP address) will be communicated and saved in the servers operated by Google in the U.S. Google uses this information to examine the way you use the website, compile reports on site activities for site administrators, and supply other services to do with the activities of the website and the use of the Internet. Google can also disclose this information to third parties, when this is required by the applicable regulations or when such third parties are responsible for processing the information on Google’s behalf. Google will not associate your IP address with any other data in its possession. You may prevent analytical cookies from being used by changing the settings in your browsers, but this could result in your being unable to use all the functions of the Site. By visiting the pages of the Site you agree to the processing of your data by Google according to the modalities, and for the purposes, described above.

Third party websites and services
The Site may contain links to other websites having a privacy policy of their own, which is not necessarily the same as the one adopted by the Site. For information on the use of these cookies, see the information provided in the various third party sites.

Cookies used by the Site

A list of the cookies used by the Site is given below:

Managing the cookies by configuring your browser

You may configure your browser to accept or reject automatically all cookies or to receive a warning on screen for each cookie being transmitted and decide case by case whether to agree to its installation on your hard disk. For a more detailed account of the steps involved, consult the “Help” section of your browser. Without prejudice to the foregoing, you should know that disabling the cookies could undermine the proper operation of specific sections of the Site. Instructions on how to configure these settings for the browsers used most widely are given below:

Chrome

1. Launch the Chrome browser
2. Click the menu situated in the instrument bar of the browser next to the window where urls are entered for navigation purposes
3. Select Settings
4. Click Show advanced settings
5. In the Privacy section, click the Contents settings button
6. In the Cookies section you can change the following cookie settings:
   • Enable the data to be saved locally
   • Change local data only until the browser is closed
   • Prevent the sites from setting cookies
   • Block third party cookies and website data
   • Manage exceptions for some Internet sites
   • Clear one or all the cookies

For further information, see the website of the software distributor.

Mozilla Firefox

1. Launch the Mozilla Firefox browser
2. Click the menu situated in the instrument bar of the browser next to the window where urls are entered for navigation purposes
3. Select Options
4. Select the Privacy panel
5. Click Show advanced settings
6. In the Privacy section, click the Contents settings button
7. In the Tracking section you can change the following settings:
   • Ask the sites not to perform any type of tracking
   • Tell the sites that you are willing to be tracked
   • Abstain from specifying any preference concerning personal data tracking
8. In the History section you can:
   • By enabling the option Use Personalised Settings, enable third party cookies to be accepted (always, from the sites visited most often, or never) and to be stored for a given period of time (up to their expiration time, until you quit Firefox, or ask every time)
   • Clear the individual cookies stored

For further information, see the website of the software distributor.

Internet Explorer

1. Launch the Internet Explorer browser
2. Click the Tools button and select Internet Options
   • Select the Privacy tab, and under Settings, move the slider to the top to block all cookies
   • Allow all cookies
   • Selection of the sites from which to obtain cookies: move the slider to an intermediate position so as not to block or allow all cookies; click Sites and then type the address of an Internet Site in the appropriate box, then click Block or Allow.

For further information, see the website of the software distributor.

Safari

1. Launch the Safari browser
2. Click Safari, select Preferences and click Privacy
3. In the Block Cookies section, specify how you want Safari to accept the cookies coming from Internet sites.
4. To see which sites have stored cookies, click Details.

For further information, see the website of the software distributor.

This page can be reached through the links that appear at the bottom of all the pages of the website pursuant to art. 122, 2nd clause, of Legislative Decree 196/2003 and according to the simplified modalities for the notice on cookies and the acquisition of consent to the use of cookies published on the Official Gazette of the Italian Republic (no. 126 of 3 June 2014) and the relative register of measures (no.229 of 8 May 2014).