Your Privacy and the security of your personal data/information are very important for the whole of Born Primitive Sales, and that is why we use the utmost care in collecting and handling the personal data we will process providing you with the services dedicated to visitors of our Website, adopting specific provisions in order to ensure the security, confidentiality and integrity thereof, in compliance with Regulation (EU) 2016/679 (from here on, the Regulation), and with the applicable privacy regulations in U.S.A., according to the implementation and within the limits of their territorial scope.
The Privacy Policy herein supplements the Privacy Policy of the Website, to which you should refer to for additional information.

1.Data Controller

The Data Controller of your personal data, which will be processed for the purposes described in the following section, is Born Primitive Sales (hereinafter referred to as “Born Primitive Sales”, “we”, “us” or “our”), having its registered office in 2235 Heron Way
Portland OR, United States (US)

2.Lawfulness and Purposes of Processing

Unless specified otherwise within the Privacy Policy herein, we collect and process the personal data you provide; we shall not obtain your personal data from any third party. “Personal data” pertains to any information concerning an identified or identifiable natural person (the ‘data subject’).

We shall process your personal data (i.e. your name, surname, e-mail address, telephone number, and the like) to fulfil our commitments and to allow you the usage of the Services you requested. We would like to point out that the services available on our Website may change based on the individual Country.

The provision of any personal data is voluntary. However, failure to disclose certain personal data could prevent you from partially or fully using Service.

Any and all further processing of your personal data, performed by the point of sale you selected, both preparatory and related to the purchase of Born Primitive Sales products shall be carried out by each retail company of Born Primitive Sales, which, in its role as the Data Controller will provide you with, the necessary information concerning your privacy and the processing of your personal data.

Whenever, a service is provided through the use of communication channels such as messaging APPS (such as WhatsApp, WeChat, Telegram, and the like), we kindly invite you to read the privacy policy of the messaging platform in use as well.

Finally, we reserve the right to process your personal data in order to comply with any legal obligations that we may be subject to, or to pursue any legitimate interest be it ours or belonging to third parties, (i.e. improving the services-providing process, preventing frauds, exercising and defending a right of ours or improving the interactions with our customers), in compliance with the conditions and limits set by the legislation currently in force.

3.Personal data Processing and Security

We shall process your personal data both by means of paper- and IT-based tools, and such processing shall be based on the principles of fairness, lawfulness, and transparency, in order to protect your rights and privacy.

We make use of industry-standard physical, organizational, contractual and technological security measures to protect your personal data from unauthorized access, public disclosure, use, modification, damage or loss.

We take all reasonable and practicable steps to protect your personal information, but unfortunately, no system or network can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Your Rights” section below (note that physical mail notification will delay the time it takes for us to respond to the problem).

4.Personal data Disclosure and Transfer

We shall not disseminate your personal data.

We will not sell your personal information to third parties.

To the extent permitted by law and where required with your consent, your Personal information may be disclosed, for the purposes described in the Privacy Policy herein: our service providers, including other companies of Born Primitive Sales, performing technical and organizational tasks on our behalf (i.e. IT support services , delivery and logistics services, customer support, processing, or hosting services, etcetera);

ii.local retailer companies belonging to Born Primitive Sales, who carry out, on our behalf, one or more steps of the Service you have subscribed to;

iii. to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other shift in all or in any given part of our business, assets or stock (also in connection with bankruptcy or similar outcomes); connection with the essential purposes described above (that is to say in order to comply with legal obligations or to execute a lawful request of public authorities).

Your personal information shall be transferred from your country to our headquarter in Italy. Please, consider that we are subjects to the Regulation (EU) 2016/679, the data protection law applicable in all the EU Member States; which provides a level of personal information protection comparable to that ensured by the U.S. regulatory framework.

i.specific “Standard Contractual Clauses” are to be drafted, issued by the European Commission, in order to ensure that the protection level of the personal data processed by our partners outside the EU shall comply with the EU’s data protection level;

ii.adoption of Company Binding Rules, approved by the competent Public Authorities, in compliance with the data transfer within a group of undertakings or enterprises is done through binding corporate rules, approved by the competent data protection authority in the UE, pursuant to the consistency mechanism referred to in art. 63 and to the conditions detailed under art. 47 of the Regulation.

We also undertake to carry out, in accordance with laws in force, any possible prior risk assessment concerning the data transfer; adopting, if necessary, any additional security measures, complementary to the safeguards guaranteed by the aforementioned transfer mechanisms.

At any rate, we shall transfer your personal information, only if the protection level, guarantee by the privacy laws in force in our countries, is not compromised.

Your personal data shall only be processed by parties being duly instructed and able to provide adequate technical and organizational safeguards, as well as bound to the strictest confidentiality by us.

5.Retention of personal data

The Company shall process your personal data for different lengths of time depending on different purposes of the processing and on the kind of Service you have subscribed to.

We shall process your personal information and data only for the period being strictly necessary to fulfil the commitments we have taken as you have subscribed to the Service.

We would also like to inform you that we are further required to store your personal data in order to comply with specific law provisions, in the manner and within the timeframe established by said regulations.

Should the processing of your personal data be based on any legitimate interest, be it ours or belonging to third parties, the processing of your personal data shall be strictly limited to the time required to achieve the legitimate interest, on a case-by-case basis.

6.Your Rights

You have the right, as detailed within the law in force, to access your personal data, to correct or update it, to delete or to obtain a copy or the transmission in a structured format to any third party thereof. You may also request to limit or object to such processing.

You may exercise these rights at any time, by writing to our Data Protection Officer (DPO) to the following addresses:

·by e-mail: [email protected].

·by post: Data Protection Officer –, 2235 Heron Way
Portland OR, United States (US)

We would like to point out that, should you exercise one or more of the privacy rights acknowledged by the relevant legislation we shall not discriminate against you, and such activities shall have no impact on the services provided, nor on any relationship of yours with Born Primitive Sales.

We will make sure to comply with your request to exercise your rights, always within the terms of the law.

We shall retain the right to ask you, in the ways we deem appropriate, for specific information to help us confirm your identity and be reasonably certain that only you can access your personal data and no unauthorized third party can seize, change or delete them. The processing of your request is free of charge. However, should your requests be manifestly unfounded, excessive, or repetitive in nature, we shall retain the right to refuse to comply with them or to request suitable economic contributions for them.

We would like to stress the fact that we do not sale your personal information, for this reason is not available a feature by means of the which to inhibit the sale of your personal information.

Remember that you can file a complaint with the Supervisory Authority if you believe that we have violated any rules concerning the protection of personal data.