PRIVACY NOTICE

TENOGLIO’S FLORIDA DISTRIBUTION LLC
1620 Drexel Ave
39130 Miami Beach
Florida – USA (Version 1.0, May 2023)

Pursuant to the EU Regulation no. 679/2016 (GDPR) and the state and federal regulations in force in the USA, regarding personal data, sensitive or not, collected by TENOGLIO’S FLORIDA DISTRIBUTION LLC, this notice describes in detail how the data provided during the purchase by phone, in person, or through the website www.sumomihi.us are used. The notice also describes the data provided during the checkout if not otherwise held by the checkout and payment page manager. About the checkout data manager you will have to refer directly to the specific regulation of the service https://stripe.com/en-it/privacy.

This document helps to understand what personal information we collect about you, how we collect it, for what purposes we use it, and what your rights are regarding personal data.

With “Tenoglio Florida Distribution LLC”, “we”, “us”, or “our”, we mean the company TENOGLIO’S FLORIDA DISTRIBUTION LLC, 1620 Drexel Ave, 39130 Miami Beach, Florida – USA.

We also use the term “Notice” to refer to this Privacy Notice, and “Website” refer to www.sumomihi.us and any other websites owned by Tenoglio Florida Distribution.

1 Personal Data: What we collect and why we use it

1.1 Personal Identification Information

When you make a purchase, we automatically collect the following personal information about you (the “Personal Identification Information”) to carry out a shipment. In case of shipment to locations not directly attributable to your property, it will be implicitly declared, through your payment, that you have the consent of the owner to us his address as your. In any case, the company that manages payments will take care of the security of the data relating to your transaction while your data will be held by us for the sale as necessary. It will also be possible that for payments, you will be asked to verify your identity, as required by law; however, such verification data will not be retained.

We mean Personal Identification Information:

• Name;
• Surname;
• Date and place of birth;
• Shipping address;
• Tax code and/or VAT number, identification code valid in the destination country;
• Payment method as managed by the manager of the checkout page;

If these mandatory data are missing, it will not be possible to make purchases.

Additional Contact Data

We may also collect, upon your communication,

• Email address;
• Fax;
• Phone numbers;

Additional Non-Sensitive Data

You may also choose to add additional non-sensitive personal data related to preferences, general and nonspecific information.

NB In case you inadvertently provide sensitive data (religion, political ideology, state of health), these will not be stored.

The additional non-sensitive data and the additional contact data will still be part of the Personal Identification Information.

1.2 Information contained in communications related to advance bookings and/or from merchants

When you make a purchase through the third-party website, we collect the information that will be sent to us by the checkout page manager. This may include:

• Credit card data;
• Bank account data;
• Any reference number or order ID (if you or the company provide one);

If we ask you to provide information or documentation proving payments, and you provide us with such documentation, we will collect and process the documentation for the purposes specified in the request.

NB Do not share personal documents or sensitive information with us, either about yourself or others. However, if this information is provided, it will be immediately deleted and not stored in any archive.

1.3 Information on views and IP connection information

When you connect to On our website, we may collect contact information. However, we do not track people’s identities, but we collect data on the number of consumers who read the website. We do not store IP addresses, except when necessary to protect our interests.

When you make a request from a website, we may use the IP address of your computer to roughly identify your location relative to the nearest city. This information is not stored or made available to others.

1.4 Information requests

If you ask us for information regarding specific needs, we collect the information provided only for the purpose of the request, without storing or disclosing the information, but only the request message.

1.5 Information from other services, including social networks such as Facebook

You can also contact us through your social network profile, e.g. Facebook and Instagram (“Social Network”). When you use these tools, we may automatically collect selected information about you from Social Networks. The information we collect depends on the information you have made available on Social Networks and your privacy settings for sharing such information on Social Networks. Depending on your settings and selection, we will collect the following information:

• Name and/or username;
• Email address;
• Your contacts in social networks;

You can choose to delete interactions from your Social Network profile from social pages related to us through your Account. At this point, upon request, if collected, we will remove the unique ID of your social network from our social pages and delete any collected data.

1.6 Cookies

Our website uses cookies. Cookies identify your computer or device rather than you as an individual user and are used for various purposes. For more information on the types of cookies used by the website and their purposes, see below.

1.7 Newsletters and summary emails

When you request to receive our newsletters, summary emails, or similar, we collect your name, email address, and newsletter preferences. If you no longer wish to receive our newsletters, summary emails, or similar, you can unsubscribe by making a request.

1.8 For what purposes do we use your personal information?

We use the information provided to us to:

• Offer you our services, including offering you products;
• Verify your identity for legal purposes and therefore to comply with our legal obligations;
• Respond to your questions and provide related customer support services;
• Transmit messages, including promotional messages, and therefore to pursue our legitimate business interests in relation to the management of the website and the provision of our products, provided that your fundamental interests and rights do not override such interests;
• Contact you in case of issues related to your purchase and, if necessary, ask you to provide the necessary documentation to resolve any issues that may arise;
• Send you our newsletters;
• Comply with legal requirements and legal proceedings, requests from public and governmental authorities, relevant industry standards, and our internal policies;
• Enforce our Terms and Conditions;
• Protect our rights, privacy, security, or property and/or those of our affiliated companies, yours, or third parties;
• Allow us to pursue available remedies or limit any damages and therefore to assert, exercise or defend legal actions, where necessary.

Some of these reasons for processing your personal data overlap, so there may be several reasons justifying the processing of your personal information.

In the limited circumstances where you have expressly provided us with consent to process your personal data, such as when you subscribe to our newsletters, you are free to revoke your consent in anytime. However, you should be aware that we may have the right to continue processing your information if it is justified by one of the other legal bases mentioned above. You have the right to object to how we process your personal information, or to ask us to limit its processing.

1.9 On what legal bases do we process your personal data?

Purpose of the processing	Legal basis of the processing
provision and delivery of services	processing is necessary for the performance of a contract to which the data subject is party
billing	processing is necessary for the performance of a contract to which the data subject is party and to comply with a legal obligation
debt recovery and assignment	processing is necessary for the legitimate interest of the data controller which consists in protecting its credit
fraud prevention, including IT fraud	processing is necessary for the legitimate interest of the data controller which consists in protecting the services provided from fraudulent operations carried out by third parties
customer satisfaction survey	The processing is carried out with the consent of the Customer, which can be revoked at any time without prejudice to the lawfulness of the processing carried out before the revocation. Revocation of consent can be exercised by contacting customer service at the email address xxxx@xxxxx.xxx
sending commercial communications via email, whatsapp, messenger or others	Advertising communications via email/messages relating to products and services similar to those purchased are carried out unless the data subject objects to the sending. The opposition to the sending can be exercised by contacting customer service at the email address privacy@

 

If you would like more information on our legal basis for processing your personal information, please contact our Data Protection Officer (DPO) at privacy@.

2 Disclosure of data

2.1 Disclosures to third parties

We do not disclose your personal information to third parties except for the following parties and under the following circumstances:

• To enable third-party providers, consultants, and other service providers to perform services on our behalf
• To companies controlled by the ownership of Tenoglio Florida Distribuition and other companies within the group of companies
• To comply with laws or to respond to claims, legal proceedings (including, but not limited to, subpoenas and court orders), and requests from public and governmental authorities
• To cooperate with supervisory bodies and governmental authorities, in relation to investigations or referral of cases
• To third parties in relation to the enforcement of our Terms and Conditions and Guidelines
• To third parties in order to protect our business or that of our affiliated companies
• To third parties to enable us to investigate, prevent, or take action regarding alleged or actual prohibited activities, including, but not limited to, fraud and misuse of our website
• To a third party in the event of any reorganization, merger, acquisition, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in relation to any bankruptcy or similar proceeding).

3 Data controller

3.1 Information on the data controller

TENOGLIO’S FLORIDA DISTRIBUTION LLC

1620 Drexel Ave

39130 Miami Beach

Florida – USA

represented by its legal representative is the data controller for the personal data provided by you.

4 Links to websites

Our website may contain links to other websites. Our inclusion of such links does not imply our approval of such websites. We do not control the content of such third-party websites and assume no responsibility for third parties or their policies or practices. We encourage you to carefully read the privacy policies of such third-party websites as their procedures for collecting, managing, and processing personal data will differ from ours.

5 Data Controller

We employ a specific data processor to maintain the technical functioning of the website and to study any critical issues related to data integrity. Mr. [name] is the data controller for personal data for which we are the data controller in accordance with our instructions. By accepting this Privacy Policy, you authorize us to provide instructions to the data controller for the processing of data in accordance with this Policy and for the purpose for which they were released. The data controller has adopted reasonable technical and organizational measures to protect the information against accidental or unlawful destruction, loss or deterioration, and to protect the information against disclosure to unauthorized persons, improper use, or other processing in violation of data protection laws.

Upon request, and for a fee based on the applicable hourly rates of the data controllers at any time for such work, the data controllers must provide you with sufficient information to demonstrate that the aforementioned technical and organizational security measures have been adopted.

6 Data Retention

We keep the personal information and other data you provide us for as long as necessary to provide our services to you. If you choose to delete your data, please note that all of your bookings will also be deleted, subject to any applicable penalties due to you for canceling a booking. We will delete this information upon your request and will only keep a record with the following information: your name, a copy of the request, and the date of the deletion of the data. We will keep the record for 3 years. All other information will be deleted.

In some cases, even if you request deletion of data, we may decide to retain certain information (e.g. visits to our website) in anonymous or aggregated form.

7 Security Measures

We use reasonable organizational, technical, and administrative measures to protect your personal information within our organization and regularly monitor our system for any vulnerabilities. However, since the internet is not a 100% secure environment, we cannot ensure or warrant the security of the information you transmit. Emails sent through the website may not be encrypted and therefore we advise you not to include any sensitive information in the emails you send to us.

For further information about our current security practices and policies, please refer to our security practices. We are constantly working to improve our security practices and will update this information as our practices evolve over time.

8 Cookies

The website uses cookies and other similar technologies (“Cookies”). By using our website, you accept our use of Cookies as described below.

8.1 What types of cookies do we use?

Cookies are small pieces of information that the website places on the hard drive of your computer, tablet, or smartphone. Note that HTML5 has introduced a Web Storage mode that has a similar nature to cookies, and therefore, we consider it a cookie from now on.

Cookies contain information that the website uses to make communication between you and your web browser more efficient. Cookies identify your computer or device rather than you as an individual user.

We use session cookies, persistent cookies, HTML5 sessionStorage and HTML5 localStorage session cookies, and temporary HTML5 sessionStorage objects that are deleted when you exit your web browser. Persistent cookies are permanent in nature and are stored on your computer until deleted. Persistent cookies expire or are automatically deleted after a certain period, established for each cookie, but they are renewed each time you visit the website. HTML5 localStorage objects are permanent in nature and remain on your computer until deleted.

8.2 How do we use cookies?

We use cookies to:

• Generate statistics

Measure website traffic, including, for example, the number of website visits, the domains from which visitors come, the pages they visit on the website, and in which global geographical areas visitors are located.

• Monitor website performance and your use of our website

Optimize your experience with the website, which includes remembering your username and password when you return to the website and remembering information about your browser and preferences (e.g., the language you prefer).

• Targeted advertising

Display relevant ads on the website, including personalized advertising that we believe is of interest to you. We use third parties to provide these ads when you visit the website and other websites. These third parties may use cookies on their own or in combination with web beacons or other tracking technologies to collect information about your use of our website and other websites.

8.3 Third-party cookies

Third-party cookies are set by third-party websites, not our website. When you visit our website, the following third-party cookies may be set:

• Facebook cookies, set when accessing our website from Facebook
• Google cookies, set when accessing our website from Google
• Google AdSense cookies, set during the display of targeted advertising on our website

8.4 Deleting cookies

You can delete cookies already downloaded on your device. Typically, you can delete cookies from the Privacy or History area, available from the Settings or Options menu in the browser. In most browsers, the same menu can be reached via the keyboard shortcut Ctrl+Shift+Delete or Command+Shift+Delete if you are using a Mac.

If you do not accept cookies from our website, you may experience difficulties using the website and may not have access to all of the website’s features.

9 Access and information about personal data we have on you

You can send an email to xxxx@xxxx.xxx to request information about your personal data. After receiving your request, we will inform you of what personal information we have about you, how we collect information, the purpose for which we process your personal data, and with which entities we share your personal information.

10 Rectification and deletion of your personal data

In case some of your personal data or other personal information is inaccurate or misleading, you can ask us to correct your information.

11 Other rights

In addition to the above-mentioned rights, you also have the following rights:

• You have the right to object to the processing of your personal data and to restrict the processing of your personal data. In particular, you have an unconditional right to object to the processing of your personal data for direct marketing purposes.
• If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. Such withdrawal does not affect the lawfulness of the processing of data carried out before you withdrew your consent. You can revoke your consent by sending us an email to the address:
• In some circumstances, these rights may be limited or conditioned. For example, whether or not you have the right to data portability in a particular case depends on the specific circumstances of the processing activity.

12 Our Data Protection Officer

We have a Data Protection Officer (DPO). If you have any questions about the data processing activities we carry out, you are invited to contact our DPO via email at the address:

Mr. X is the Data Controller

Y is the Data Protection Officer (DPO)

13 Changes to this Policy

We reserve the right to modify this Policy. The date indicated at the beginning of this Policy indicates the date of the last update. If we make substantial changes, we will provide notice through our website or by other means, to give you the opportunity to review the changes before they become effective. If you object to the changes, you can of course ask to terminate any ongoing relationship. Your continued use of our services after the publication or sending of a notice regarding changes to the Policy will constitute your acceptance and consent to the updated Policy.

14 Contact Information and Where to Send Questions or Complaints

If you have any doubts or questions about this Policy or how we process your personal information, please contact us at the email address provided on the website or contact the DPO at info@sumomihi.us