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Privacy Policy

Betterly S.r.l. ("Betterly") acting as Data Controller with respect to the
processing of personal data would like to inform the Users ("Users") of the
website www.betterly.com/uk ("Site") about the ways and the manners in which
we process the data that we obtain from our Users, according to the new
European Regulation n. 679/2016 on the processing of personal data
("European Privacy Regulation") and to the Dlgs 196/2003 (“Italian
Privacy Code
”).


1. Data Controller and Data Processors


Betterly S.r.l. with registered office in Via Giovanni da Verrazano, 15 - 28100
Novara (Italy), is the Data controller, which can be contacted at the following
email address: privacy@betterly.com. A complete list of the Data
Processors can be requested through the above mentioned email address.


2. Personal Data Collected


According to this Policy, Betterly will process personal data obtained from its
Users; these data may include:



a) Personal data and contact details provided by the User upon the creation
of the Account online;
b) Data related to purchases through the Site;
c) Browsing data related to services offered through the Site and collected
through cookies, according to the Cookie Policy available at this link
d) Data provided when requesting information or assistance;
e) Data provided through surveys, competitions or contests organized by
Betterly, provided that in this case, this Policy will be integrated by the
specific Policies that deal with the processing of personal data during
each contest;


Betterly will not process health data or in general other special categories of
data defined in article 9 of the European Privacy Regulation. Personal Data
of minors will be processed in the ways and manners explained in paragraph
8 of this Policy.



The above mentioned categories of data will be processed only to the extent
that is necessary to the purposes described in paragraph 4 of this Policy


3. Processing of Personal Data


Personal data of the Users will be processed using automated or other
means and will be protected with the implementation of adequate security
measures to ensure safety and confidentiality of the personal data.
Specifically, Betterly implements technical and organizational measures
necessary to ensure that personal data are protected against loss, alteration,
unauthorised disclosure of, or access to, Personal Data transmitted, stored
or otherwise processed.



When it is no longer necessary to process the personal data for the purpose
for which they were collected, or at the end of the retention period (further
explained in paragraph 10), Betterly will anonymize personal data and will
remove identifiers.


4. Purposes of the Processing


Betterly will require its Users to provide their personal data for the following
purposes:



a) To allow Users to register to the Site by creating a Personal Account; to
perform all the activities regulated by the Terms of Use and the Terms
and Conditions of the Site, including purchases on the Site; to enjoy all
the services offered through the Site, including participation to online
contests and games and customer services and to establish, exercise or
defend a claim toward the User or others (jointly defined as: "Contractual
Purposes
")
b) To comply with legal and regulatory obligations (defined as: "Legal
Purposes
")
c) When the User gives his consent, to send newsletters, marketing
communications trough traditional and other means, including email,
SMS, MMS, social network, instant messages, mobile applications,
banner, fax, mail and phone, to promote and/or sell products and/or
services offered by Betterly and to conduct other surveys to evaluate the
Users' satisfaction with the Services (defined as "Marketing Purposes");
d) When the User gives his consent, to send marketing communication from
other companies of the De Agostini Group and/or other commercial
partners of the following categories: publishers, mass market retailers,
toys sellers and consumer goods distributors in relation to their
products/services in ways and manners already explained in the previous
paragraph; a list of this subjects can be requested by the Users (defined
as: "Marketing Purposes of Third Parties");
e) When the User gives his consent, to send commercial communications in
the ways and manners defined at points c) and d) based on preferences,
characteristics and habits of the User or to conduct analysis on these
basis (defined as: "Profiling Purposes");
f) When the User gives his consent to the processing of his personal data
for Marketing Purposes of Betterly, to send no more than 3 monthly
newsletters and communications related to Betterly product/services to
Users identified solely on the basis of general categories such as age
range, the fact that they opened a newsletter previously sent, or how they
make their purchases, (defines as: "Legitimate Interest for Marketing
purposes
"); and
g) To carry out activities which are functional to transfer of branches,
acquisitions, mergers, divisions or other changes and to perform such
operations (defined as: "Legitimate Interest for Business Purposes").


5. Legal Basis for the Processing


Processing of personal data for Contractual Purposes is mandatory since it is
necessary for the registration on the Site, for the performance of all activities
related to the Terms and Conditions of the Site, for the purchase of products
online, and to enjoy specific services offered through the Site.
Processing of personal data for Purposes of Law is mandatory since it is
required by the applicable laws. If the User does not wish his personal data
to be processed for these purposes, he will not be able to register to the Site,
nor to enjoy the services offered through the Site by Betterly.



Processing of personal data for Purposes of Marketing of Betterly, for
Purposes of Marketing of Third Parties and for Profiling Purposes is not
mandatory, and subject to prior consent of the User. If the User does not give
his consent however, Betterly, other companies of the group and/or other
selected commercial partners will not be able to inform the User about new
product/services, promotions, personalized offers, or to carry out market
surveys, or to send other communications and materials in line with their
interests.



Processing of Purposes of Legitimate Interest of Marketing is functional to
the pursuit of a legitimate interest of Betterly, properly balanced with the
interests of the Users and, considering the limitation to this form of
processing explained in paragraph 4. f), will be carried out starting from May
25th 2018, when the European Privacy Regulation becomes applicable.
Processing for Purposes of Legitimate Interests of Business is carried out
according to art. 24 par. 1. d) of the Privacy Code and in order to pursue the
legitimate interest of Betterly and his counterparts to carry out economic
operations indicated therein, according to art. 6. f) of the European Privacy
Regulation, and properly balanced with the interests of the Users, since the
Processing will only be limited to the extent necessary to perform such
operations.


6. Communication of Personal Data


For the Purposes explained in paragraph 4, Betterly might communicate
Users' personal data, strictly necessary to each type of processing, to the
following categories of subjects:
a) Employees, collaborators and suppliers of Betterly, within the
performance of their tasks and/or contractual obligation and in relation to
the commercial relations with the Users;
b) Sub suppliers and/or subcontractors within the activities connected to the
performance of services and products offered by Betterly;
c) Other companies of the De Agostini Group in Italy or abroad, nationals
and internationals, as explained in the following paragraph 7;
d) To Postal Offices and couriers to send and deliver products purchased by
the Users and/or other materials related to the services offered by
Betterly;
e) To legal, administrative and fiscal consultants, within the limits of what is
necessary or functional to the activities of Betterly, in the ways and
manners explained above;
f) To financial institutions for the management of revenues and payments
deriving from the performance of the contract with the User.
Personal data of the Users will not be disclosed.


7. Overseas Transfer of Personal Data


Personal Data of the Users can be freely transferred outside the national
territory to other European Countries, but they may also be transferred
outside the European Union, and in particular in Russia, Japan and US.
Whenever Betterly transfers personal data outside the European Union, it will
take reasonable steps and appropriate safeguards to keep the personal data
safe, according to art. 44 of the Privacy Code and articles 45 and 46 of the
European Privacy Regulation.



Users will have the right to obtain a copy of the Data held abroad and to
receive information on the place where the Data are kept, by asking directly
to the Controller, through the contact details provided in paragraph 9 of this
document.


8. Rights of the Us


In relation to his personal data, the User will be able to exercise, with no
additional charge and at any time, the following rights:
a) To obtain confirmation as to whether or not personal data concerning
him are being processed, and, where that is the case, access to the
personal data;
b) To know the origin of the data, the purposes and the way in which
they are processed and the logic applied to processing by automated
means;
c) To ask for the update, rectification or - if he is interested - the
integration of the data;
d) To ask the erasure, the anonymization or the blocking of data
unlawfully processed or to object to the processing for legitimate
reasons;
e) To object, fully or partially, to the processing of data for purposes of
direct marketing carried out either through automated or more
traditional ways;
f) To withdraw his consent at any time, without affecting the lawfulness
of processing based on consent before its withdrawal.



Together with the abovementioned rights, starting from May 25th 2018,
Users will also enjoy the rights enshrined in the following paragraph 10 b).
Users will be able, at any time, to exercise their right, to modify their contact
details, to notify Betterly changes and updates regarding their data, to obtain
further information on the processing of their personal data carried out by
Betterly, by writing an email to the following address:
privacy@betterly.com or by calling the following number: 0800
0148593.


9. Retention period and additional rights for Users


a) Retention periods for personal data: Betterly will retain personal data for
no longer that is necessary to fulfil the purpose for which data have been
collected, according to paragraph 2 of this privacy policy. In any case, the
following retention periods will apply for this specific purposes:
➢ Personal data collected for Contractual Purposes (par. 4.a) will be
retained for the duration of the contract and for 10 years after its
termination to exercise/defend a right of Betterly, both in court and
outside, where a claim should arise relation to the contract ;
➢ Personal data collected for Purposes of Law (par. 4.b) shall be retained
in accordance with the specific limitation periods defined by law;
➢ Personal data collected for Marketing Purposes of Betterly (per 4.c)
shall be retained for the duration of the service provided, the
participation to the contest and/or the collection; and for 2 years after
the collection and/or the termination of the service offered;
➢ Personal data collected for Purposes of Marketing of Others and
Profiling Purposes (par 4.d-e) shall be retained for 12 months after the
collection;
➢ Personal data collected for Purposes of Legitimate Interest of
Marketing (par 4.f) should be retained for all the duration of the
registration of the User on the Site through his Account end/or the
participation to an online contest end/or the collection and for 2 years
after the cancellation/deactivation of the Account;
➢ Personal data collected for Purposes of Legitimate Interest of business
(par. 4.g) will be retained for 10 years from the moment of their
collection.



Once these terms have expired, Users' personal data will be
deleted/anonymized and/or aggregated.
b) Additional rights: the User, at any time and in the ways and manners
explained in the previous paragraph will have the right to:
Ask for a restriction of the processing when: (i) the accuracy of the
personal data is contested by the data subject, for a period
enabling the controller to verify the accuracy of the personal data;
(ii) the processing is unlawful and the data subject opposes the
erasure of the personal data and requests the restriction of their
use instead; (iii) Betterly no longer needs the personal data for the
purposes of the processing, but they are required by the data
subject for the establishment, exercise or defence of legal claims;
(d) the data subject has objected to processing pursuant to Article
21.1 of the European Privacy Regulation, pending the verification
whether the legitimate grounds of the controller override those of
the data subject;
Ask for the erasure of personal data without undue delay;
Ask for the portability of his personal data.
c) Bring a claim before the National Authorities for the processing of
personal data.


10. Update


This document will be effective from the date indicated in the headi
Betterly might change and/or integrate this document, also as a
consequence of further modifications and/or integration of the European
Privacy Regulation. Updates and modifications will be notified in advance
and Users will always be able to view the update Policy at the following link.
If you have doubts, questions or complaints with regard to the collection and
processing of your personal data, you may contact Betterly at
privacy@betterly.com or calling the following number 0800 0148593.