Privacy Policy

Dear user,
Thank you for coming to visit us.
We believe it is extremely important for you to have confidence in us and we would therefore like to share with you on this page the purposes and methods of processing the personal data we collect when you browse on the website (hereinafter “Website”) and when you use the services we offer, as specified in greater detail below.
Processing of your personal data is always based on principles of legality and fairness and complies with all applicable current regulations.
You can find all details on processing of your personal data below.
We will be happy to respond to any questions you may have. Please contact us at the following links: Contact us

Last review 06/06/2018

PRIVACY POLICY
This policy will allow you to discover, before accessing the various sections of the Website, how Storm in a Teacup processes your personal data, including both data you provide directly (such as your first name, surname, postal and e-mail address, age, date of birth, gender, etc.) and the data which Storm in a Teacup collects in the manner described in the section “The personal data we collect and how we collect it” (hereinafter, collectively, the “Personal Data”). Please view the policy before providing your Personal Data.

Identity and contact details of the Controller 
The Controller is Storm in a Teacup s.r.l. (hereinafter “Storm in a Teacup” or “Controller”), with registered office in Via Canton 70, 00144 Rome, Italy.

Storm in a Teacup will process your Personal Data in accordance with Regulation EU no. 2016/679 and national personal data protection regulations (hereinafter the “Privacy Regulation”).

The Personal Data we collect and how we collect it
Storm in a Teacup may collect and then process your Personal Data when you browse the Website and/or access certain sections of it. When you connect to the Website, the IT systems and the software procedures which allow them to function automatically and indirectly provide and/or acquire certain information (such as the so-called “cookies”, as specified in the section “Privacy Policy – Cookies”, at the end of this policy document, “IP” addresses, the domain names of the computers used by users who connect to the Website, the “Url” address of the resources requested, the time of the request to the server).

Any requests for information or services you submit could lead to collection and subsequent processing of your Personal Data (such as first name, surname, postal and e-mail address, age, date of birth, gender, etc.).

In particular, your Personal Data may be collected:

• when you fill out on-line forms; and
• through your publication of Contributions (as defined below), the content of which could include Personal Data which you have provided directly on social networks managed independently by third parties, including, but not limited to, Facebook, Twitter, etc. (hereinafter “Social Networks”). By “Contributions”, we mean images, comments, catchphrases associated with the subject of the Website, contents and any other information you have conceived and published on the pages of Social Networks dedicated to the products of the various Storm in a Teacup group brands, including any image you provide.

If you choose to send a request through the “Contact us” section of the Website, you have to provide certain Personal Data to allow Storm in a Teacup to satisfy your needs, so the relative boxes of the registration form are marked with an asterisk or otherwise indicated as obligatory. Providing Personal Data which is not marked with an asterisk or otherwise indicated as obligatory is entirely optional and there will be no consequences if this Personal Data is not provided, or is incomplete or imprecise. However, if you do not provide the Personal Data marked with an asterisk or otherwise indicated as obligatory, or said data is incomplete or imprecise, the service you request cannot be supplied. If you fail to provide any of the obligatory Personal Data, a Storm in a Teacup error message will appear listing the missing obligatory Personal Data.

The purposes of processing your Personal Data and the legal basis for processing
Based on the needs you indicate each time on accessing the various sections of the Website (and excluding individual initiatives which require specific Personal Data to be provided, for which specific information will be published each time on the Website), the purposes of processing your Personal Data and the legal basis for processing are indicated below.

Your Personal Data will be processed for the following purposes only with your consent to processing, which may be withdrawn at any moment, by sending a request to the Controller via the “Contact us ” section of the Website:

1. Management of your requests and response to them

You may decide to consent to processing of your Personal Data to allow Storm in a Teacup to manage and respond to your requests relating to products and the various initiatives relating to the various If you decide not to consent to processing of your Personal Data for said purposes, you will be unable to send the request.

Furthermore, even without your consent, Storm in a Teacup may process your Personal Data for the following purposes:

1. management of activities linked to your use of the Website, including publication of your Contributions on the pages of Social Networks dedicated to the products of the various Storm in a Teacup (since processing is necessary for execution of a contract or pre-contractual measures);
2. management and fulfilment of legal obligations (accounting, administrative, tax obligations, etc.);
3. management of complaints and any disputes (as this is a legitimate interest of the Controller).

How we process your Personal Data
Processing of your Personal Data may include any type of operation, such as collection, recording, organisation, storage, consultation, processing, rectification, selection, extraction, comparison, use, interconnection, blocking, disclosure, erasure and destruction.
Your Personal Data will be processed mainly with automated tools, but also on paper, adopting logic strictly linked to the related purposes, through the use of databases and electronic platforms managed by Storm in a Teacup or by third parties appointed as external processors for this purpose and/or through the integrated IT systems of Storm in a Teacup and of said third parties and/or websites owned or used by Storm in a Teacup.
The Controller has assessed the level of security to be sufficient, taking account of the risks which could derive from loss, destruction, rectification, unauthorised disclosure, accidental or illegal access, abuse or alteration of your Personal Data. In particular:

• it has adopted security measures appropriate to the risks;
• it stores your Personal Data on servers located within Europe, which have an advanced and daily back-up system.

Where we process your Personal Data
Your Personal Data will be processed primarily at the Controller’s offices and in places where the processors are located. For further information, contact the Controller at the addresses indicated in the section “Identity and contact details of the Controller”.

How long we keep your Personal Data
In order to ensure compliance with the principles of necessity and proportionality of processing, the Controller keeps the Personal Data for different periods, depending on the individual purposes being pursued:

1. in order to manage and respond to your requests relating to products and initiatives of the Storm in a Teacup, advertising or the Website (“Contact us” section of the Website), your Personal Data will be kept for the time strictly necessary to fulfil your request;
2. for management of activities linked to your use of the Website, including publication of your Contributions on the pages of Social Networks dedicated to the products of the Storm in a Teacup, your Personal Data will be kept for the time strictly necessary to supply the service you have requested;
3. for management and fulfilment of legal obligations (accounting, administrative, tax obligations, etc.), your Personal Data will be kept for the time strictly necessary for said purpose;
4. for management of any complaints and disputes, the Personal Data will be kept for the period strictly necessary for this purpose and, in any case, not beyond the applicable time limits.

The recipients of your Personal Data  
Your Personal Data may be communicated to and processed by:

(i) legal or natural persons who act as external processors, performing activity in outsourcing, appointed by Storm in a Teacup or by the external processors of Storm in a Teacup (including parties assigned to perform assistance, communication, marketing, advertising, promotion and sale activities relating to products and/or services and also advertisers, advertising agencies, suppliers of IT services, the Website operators, electronic platform operators, partners, credit institutions, professional consultancy firms);
(ii) employees and/or collaborators of the Controller (including system administrators), who operate under its direct authority, who will be authorised to process your Personal Data; and
(iii) employees and/or collaborators of the external processors (including system administrators), who operate under the direct authority of the external processors and will be authorised to process your Personal Data.
Your Personal Data will not be communicated to third parties, except when communicated by Storm in a Teacup to consultants in order to protect its rights, nor disclosed.

Minors
Minors under 16 years of age must not provide information or Personal Data to Storm in a Teacup without parental consent. If this consent is not provided, minors cannot send requests via the Website. Storm in a Teacup invites anyone with parental responsibility on minors to inform them on secure and responsible use of the Internet and the Web.

Identity and contact details of the processors
A complete list of the Personal Data processors may be consulted by contacting the Controller at the address indicated in the section “Identity and contact details of the Controller”.

Contact details of the Data Protection Officer (or “DPO”)
The contact details of the Data Protection Officer appointed by the Controller are: info@stcware.com

Your rights in relation to processing of your Personal Data
As the data subject, you are granted numerous rights by the Privacy Regulation. In detail, you are entitled to:

1. obtain from the Controller confirmation of whether or not your Personal Data exists, even if not registered, and its disclosure in intelligible form, and also access to your Personal Data (by obtaining a copy) and the related information (including the purposes of processing, the categories and origin of the Personal Data, the categories of recipients to whom it has been or could be disclosed, the retention period (when possible), the rights which may be exercised);
2. obtain from the Controller the rectification of your Personal Data and supplementing of any incomplete Personal Data;
3. obtain from the Controller the erasure of your Personal Data without undue delay, including when the Personal Data is no longer necessary for the purposes for which it has been processed or the legal basis for processing no longer exists;
4. obtain from the Controller the conversion into anonymous form or blocking of your Personal Data if it is processed illegally, including data which it is not necessary to store, in relation to the purposes for which the Personal Data was collected or subsequently processed;
5. obtain from the Controller the limitation of processing of your Personal Data, also when you dispute its accuracy or object to processing, for the period necessary for the respective checks to be performed;
6. receive your Personal Data in a structured, commonly used, machine-readable format, and also transmit or, if technically feasible, obtain transmission of your Personal Data to another controller without impediments, in cases in which processing is carried out by automated means and is based on your consent or when necessary for execution of a contract to which you are a party;
7. withdraw consent to processing of your Personal Data for any of the purposes for which it has been provided.

You may exercise your rights with Storm in a Teacup by accessing the “Contact us” section of the Website or by sending a letter by ordinary mail info@stcware.com, to the address indicated in the section “Identity and contact details of the Controller”.
Furthermore, if you believe that processing of your Personal Data breaches the Privacy Regulation, you may lodge a complaint with the Data Protection Supervisory Authority in the State in which you reside, where your workplace is located or in which the presumed breach has occurred, or contact said Authority to request information on exercising of your rights under the Privacy Regulation.

The right to object to processing of your Personal Data
At any moment and for reasons linked to your own specific situation, you are entitled to object to processing of your Personal Data which is based on a legitimate interest pursued by the Controller or by third parties. In this case, the Controller abstains from further processing of your Personal Data unless it demonstrates the existence of legitimate and binding reasons which prevail over your interests, rights or freedoms or processing is necessary to ascertain, exercise or protect a legal right.
You are entitled to object to processing of your Personal Data, by accessing the Contact us” section of the Website or sending an e-mail toinfo@stcware.com
If you object to processing of your Personal Data for this purpose, the Controller will be unable to carry out the related processing.

PRIVACY POLICY – COOKIES
Cookies are texts strings which act as computer markers sent by a server (the Website service in this case) to the user’s device (normally an Internet browser) when the user accesses a given page of a website. Cookies, which may also be set by different websites to the one the user is visiting (“third party cookies”), are automatically stored by the browser and retransmitted to the server which generated them each time the user accesses the same web page. In this manner, for example, cookies facilitate access to several web pages in order to improve the user’s browsing (or allow storage of pages visited or other specific information, such as the most frequently consulted pages, connection errors, etc.), or allow profiling. For easy and complete use of a website, the user should therefore configure their browser to accept these cookies.
Browsers are often set to accept cookies automatically. However, users can change the pre-set configuration, to disable or delete cookies (each time or once and for all), although this could prevent optimal use of certain areas of the website. It is also possible to check the cookies modes and types stored on your browser by changing its cookie settings.

Characteristics and purposes of cookies 
Our Website uses the following categories of cookies, which may belong to Storm in a Teacup or to third parties.

These cookies assist you in browsing the Website and using its functions. Technical cookies include what are called “strictly necessary” cookies, which enable functions without which the Website cannot be used in full, or “performance cookies”, which improve the Website functions.

These cookies allow the Website to remember your choices (such as the language or your geographic location) and propose them again on subsequent accesses, in order to provide better and customised services (they can be used to propose similar contents to those you have requested in the past, for instance).

These cookies are used to send advertising messages and services in line with the preferences you have shown.
In particular, they are used to offer you advertising and services potentially reflecting your interests, and also to create individual profiles based on your tastes, preferences and consumption choices, as detected during browsing of the Website or by comparison of your activities via the browser. They are used, for example, to limit the number of times a given advert is shown, or to understand how effective an advertising campaign is from the frequency of views of the relative advert.

Description of the methods of consenting to installation of cookies
On your first access to the Website, you will see a banner with brief information containing the link to this extended policy, where you will find further information on the cookies installed by the Controller and by third parties.
This extended policy contains more detailed information on the description and characteristics of the various types of cookies and also allows you to decide independently which cookies you want to authorise.
Your consent is not required for the use of technical and analytical cookies. However, you can disable them using the procedure described in the paragraph “How to enable and disable cookies in your browser”.
Your consent is required for the use of profiling cookies, which are used to send you adverts and services in line with your tastes, preferences and consumption choices.
By browsing the Website, you consent to use of cookies, including profiling cookies. However, you can alter your cookies preferences at any time, also denying consent to use of any cookie (including cookies installed by third parties) in the table below.
The table below describes the cookies sent to your browser when you access the Website. The table is revised up to 22th May 2018; any subsequent reviews will always be published on this page.
Technical cookies

• Session Cookies

Third-party cookies

• Facebook Cookies
• Twitter Cookies
• Youtube Cookies

Links are provided below to the documents and consent forms of third parties who are independent controllers, through which you can obtain more information and manage and disable said cookies.

Profiling Cookies

• Google Cookies

Google Analytics

NAME COOKIE	SUPPLIER	TYPE	EXPIRATION
_ga	stcware.com	HTTP	2 year
_gat	stcware.com	HTTP	Session
_gid	stcware.com	HTTP	Session
fr	facebook.com	HTTP	3 month
personalization_id	twitter.com	HTTP	2 year
r/collect	doubleclick.net	Pixel	Session
tr	facebook.com	Pixel	Session
cookie_notice_accepted	stcware.com	HTTP	29 giorni

This Website uses Google Analytics, a web analysis service supplied by Google, Inc. (“Google”). Google Analytics uses cookies, i.e. text files which are stored on your computer to allow analysis of how you use the Website. The information generated by cookies on your use of the Website will be transmitted to a Google server, where it will be stored. Google will then use this information to analyse your use of the Website, to prepare reports on the Website and to provide further information to the Website operator on use of the Website and use of the Internet. Google will not associate the IP address transmitted by your browser in Google Analytics with any other data possessed by Google. You can prevent storage of the cookies by altering your browser’s software settings, but this could result in the Website functions being less customised in terms of your preferences. You can obtain more information on the data created by Google Analytics at: https://support.google.com/analytics/answer/6004245; you can also prevent Google from recording the data produced by the cookies and relating to your use of the Website (including your IP address) and also from processing said data, by downloading and installing the plug-in of the browser available at the following link: http://tools.google.com/dlpage/gaoptout?hl=it.
By using the Website, you consent to Google processing your data, as the independent controller, with the methods and for the purposes indicated in the Google privacy policy relating to Google Analytics, which is accessible at the following link:
https://www.google.com/intl/it/policies/privacy/partners/ .

Social buttons
The Controller uses social buttons on the Website.
Social buttons are digital buttons or direct links with the platforms of Social Networks configured in each individual “button”.
You can click on those links to interact directly with the accounts (social pages) of the Controller.
The operators of the Social Networks to which the buttons redirect you are independent controllers. You can find more information on the individual privacy policies of the Social Network platforms and on the methods of managing and disabling the relative cookies on the Social Network platforms.

How to enable and disable cookies in your browser:
You can stop your browser from accepting cookies. However, this could make access to certain functions of pages of the Website more difficult or impossible.
The methods provided by the main browsers to block acceptance of cookies are show below:
Internet Explorer: http://windows.microsoft.com/it-it/internet-explorer/delete-manage-cookies#ie=ie-11
Firefox: https://support.mozilla.org/it/kb/Gestione%20dei%20cookie
Chrome: https://support.google.com/chrome/answer/95647?hl=it
Safari:http://support.apple.com/kb/HT1677?viewlocale=it_IT

Further methods for disabling analytical and profiling cookies:
In addition to disabling and/or deleting cookies through your browser settings, you can also disable and/or delete individual analytical and profiling cookies by accessing the following websites:

• https://tools.google.com/dlpage/gaoptout?hl=it to disable Google Analytics
• www.youronlinechoices.eu, a website managed by the European Interactive Digital Advertising Alliance (EDAA), for deletion of other cookies for users located in the European Union,
• http://www.aboutads.info/choises/, for deletion of other cookies for users located in the United States of America. These websites are not managed by the Controller, who therefore accepts no liability in relation to the respective contents.