PRIVACY POLICY FOR WEB SERVICES
Preamble
The company “Kloster Group” attaches great importance to the protection of the privacy of all individuals whose personal data we process in relation to our activity.
In this document ("Privacy Policy") we wish to present the most important information related to the processing of personal data of:

• people who contact us and visit our website or our social media;
• people who enter into contracts with our commercial partners or who are interested in our products;
• representatives and employees of our commercial partners or contractors.

We commit ourselves that the information provided is in compliance with the transparency requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, “GDPR”). If you have any reservation regarding the form or comprehensibility of this Privacy Policy, we invite you to contact us and share your opinion.
Data Controller
The data controller is Kloster Group [S.r.l.] with registered office in Mestre (VE), Viale Giuseppe Garibaldi 87A, Italy (hereinafter: “we”, “Controller”, or “Kloster Group”).
Contact Details
You can contact us:

• by email: Klostergroupco@gmail.com
• by conventional mail to our address: Mestre (VE), Viale Giuseppe Garibaldi 87A, Italy.

For any matters regarding personal data processing, please contact us by email: Klostergroupco@gmail.com
What personal data do we process?
Website and social media profiles
While you use our website we collect data necessary for providing various services we offer and information about your activity on the site. For example:

• If you use the contact form, we collect information such as: first name, last name, contact details, and content of the message.
• When browsing the site, we collect information stored in cookies or system logs, regarding the time spent on the site and interactions with content present on the site.
• On our social media profiles we collect information about your activity related to that webpage/profile (e.g. clicks on “Like”, posts published, comments, messages sent via internal messaging).

Distribution network operations
In relation to the operations of our distribution network, we collect and process data of persons who have concluded a contract with our commercial partners regarding Kloster Group products, or who are interested in our products and have contacted the chosen commercial partner. We collect information such as: contact details; information about the subject of the contract and execution deadlines; information about delivery or installation details; information relative to performance of the contract or management of a prospective customer following a request for an offer. Also, for monitoring the quality of support to our customers, we collect and process data transmitted through satisfaction surveys related to performance of contract by a commercial partner.
Commercial cooperation
In the context of commercial cooperation, we collect and process personal data of entrepreneurs who are our commercial partners, representatives or employees of our commercial partners acting in a corporate form (including partners in our distribution network), or subjects interested in such cooperation. The scope of data collected depends on the type of cooperation. Usually we collect basic information like: contact details; information about the managed business; information about place of employment / entity represented; information about ongoing correspondence; and information relating to contract drafting and execution.
Cookies and similar technologies
Our websites use cookies. More details about cookies and their use are available in the Cookies Policy.
Source of personal data
If personal data is not collected directly from you, it may be obtained from:

• our commercial partners with whom contracts regarding Kloster Group products are agreed;
• in B2B collaboration, from commonly accessible sources, such as websites or official registries;
• your representatives or agents, if they contact us on your behalf.

Purposes and legal basis of data processing
For website usage

• Provision of online services: your data is processed to provide electronic services through the various functionalities and content published on the site. The legal basis is performance of a contract or provision of electronic services (Art. 6(1)(b) GDPR).
• Marketing: on the basis of cookies, if you have consented, we may tailor content to your preferences and expectations. We profile users and display relevant advertisements. If you have given separate consent, we will send commercial content about Kloster Group’s products and services (e.g. newsletter, new products, promotional offers), including personalized content. The legal basis is Kloster Group’s legitimate interest (Art. 6(1)(f) GDPR).
• Analysis, statistics and service quality: your data are used for analytics/statistics, analyzing visitor behavior on the site and preferences regarding functionalities and content offered. To improve service quality, we may use your contact info to ask satisfaction surveys regarding contract execution. The legal basis is our legitimate interest (Art. 6(1)(f)).
• Defending legal claims: where justified, we process your data to establish, exercise or defend a legal claim. Legal basis: legitimate interest (Art. 6(1)(f)).
• Security and effective site operation: user activity is logged for system logs in order to guarantee security of the website and IT systems. Legal basis: legitimate interest (Art. 6(1)(f)).

Social media networks
We also process personal data of users who visit our company profiles on social media (e.g. Facebook, YouTube, Instagram, Twitter). Your personal data (e.g. name or nickname in social media) are collected and used exclusively in connection with management of the company’s website / profile. Data are used to inform users about our activities, respond to comments or messages, employ communication functions offered by social media platforms, as well as promote events, services or products on that platform. The legal basis is our legitimate interest in promoting our brand and managing communication via social media (Art. 6(1)(f)).
In relation to distribution network

1. Warranty: your data are processed in regard to the warranty we provide for our products. Legal basis: necessity to perform the contract (Art. 6(1)(b)).
2. Service quality analysis: data related to contract performance with our commercial partners and data you share in satisfaction surveys. Legal basis: legitimate interest (Art.6(1)(f)).
3. Analytical and statistical purposes: for developing our distribution network and improving our products. Legal basis: legitimate interest (Art.6(1)(f)).
4. Marketing: if you have expressed separate consent to marketing communication, we will use your data for commercial communication or newsletter. Legal basis: legitimate interest (Art.6(1)(f)).
5. Legal compliance obligations: when necessary to comply with legal obligations (e.g. consumer protection, tax law). Legal basis: necessity to comply with a legal obligation (Art.6(1)(c)).
6. Defending legal rights: as above. Legal basis: legitimate interest (Art.6(1)(f)).

In the context of commercial cooperation

1. Contract formation or performance: to enter into or fulfill a cooperation contract with Kloster Group. For entrepreneurs: necessity to perform a contract (Art.6(1)(b)). For representatives or employees: our legitimate interest (Art.6(1)(f)).
2. Analytical and statistical purposes: concerning profitability, extension of cooperation, optimizing business processes. Legal basis: legitimate interest (Art.6(1)(f)).
3. Creation of a contact database: contact data collected in events, business cards. Legal basis: legitimate interest (Art.6(1)(f)).
4. Loyalty programs or incentive plans: for employees or collaborators of our business partners. Data used for such programs, based on either legitimate interest or necessity to perform a contract/regulation (Art.6(1)(f) or Art.6(1)(b)).
5. Marketing: contacting commercial partners to present new cooperation opportunities or send commercial materials. Legal basis: legitimate interest (Art.6(1)(f)).
6. Organization of training courses and events: if under cooperation, your organization may enroll or send employees. Legal basis: either necessity for performance of contract/cooperation or your separate consent (Art.6(1)(b) or Art.6(1)(a)).
7. Compliance with legal obligations: legal/tax/accounting obligations. Legal basis: legal necessity (Art.6(1)(c)).
8. Defend rights: legitimate interest (Art.6(1)(f)).

Correspondence and calls
Personal data provided via contact forms, email or conventional mail, or via telephone are processed to handle your queries, orders, contracts, responses or requested information. Legal basis: our legitimate interest to enable effective communication (Art.6(1)(f)) or necessity to perform a contract (Art.6(1)(b)).
Obligation to provide data

• Website forms: if fields in contact forms are identified as mandatory, providing those personal data is required for us to proceed with your request. We also make clear which data are mandatory and which are voluntary (e.g. via asterisks).
• Correspondence, contracts, events: provision of data is voluntary, but necessary to manage correspondence, conclude the contract, or participate in a training / event.
• Consequence of failure to provide: If required data are not provided, we may be unable to provide the service, conclude or perform the contract, manage your correspondence, or allow participation in the training/event.

Data retention periods
The period for which we keep your personal data depends on type of service and purpose. In general, we process your data for the duration of the service, contract, or order fulfillment, until consent is revoked or objection is made, when processing is based on legitimate interest. Correspondence is retained for 3 months to 2 years after end of communication, depending on subject, unless there is a contract, in which case relevant correspondence is archived for the contract’s duration. Retention may be extended to cover statute of limitations for rights, if data are necessary for asserting or defending rights. Cookies storage times are in the Cookies Policy. We have policies to ensure retention periods consider tax/accounting law, limitation periods, or our legitimate business interests.
Disclosure to third parties — section removed
Your rights
You have the right to access your personal data, rectification, erasure, limitation of processing, and data portability. If your data are processed for our legitimate interests and marketing, you also have a right to object to such processing. If you have given separate consent for specific purposes, you can withdraw that consent at any time. Withdrawal does not undermine the lawfulness of processing carried out before the revocation. If you suspect irregularities in the processing of your data, you have the right to lodge a complaint with the competent data protection authority.
Transfers outside the European Economic Area (EEA)
The level of data protection abroad may differ from that guaranteed by EU law. As a rule, Kloster Group does not send data outside the EEA. However, for assistance to clients or partners in Italy or those contacting via the site https://www.klostergroup.it/, we ensure any necessary transfers use EU standard contractual clauses or other legally allowed mechanisms under GDPR. You may at any time receive information and a copy of the security measures implemented for such transfers. To request this, please contact us via the addresses given in the “Contact” section.
Security
Kloster Group highly values the security of your personal data. We continually conduct risk analyses to ensure data are processed so that only authorized persons have access, and only as much as necessary. All operations on personal data are logged and carried out only by authorized employees and collaborators. IT systems used ensure availability, integrity, confidentiality. We also ensure any subcontractors or collaborating entities implement adequate security measures whenever processing personal data on our behalf.
Changes to the Privacy Policy
This Privacy Policy is continuously reviewed and updated as necessary. We will inform you of all changes to its content on the Kloster Group website.