We Are Creative with registered office in Via Maurizio Bufalini 5 – Florence (Italy) recognises the importance of maintaining the confidentiality, integrity and security of your personal data (“Personal Data”), and hereby informs you that any Personal Data which you provide to We Are Creative through our Website, as well as any Personal Data will be processed in compliance with current European privacy laws (Regulation (EU) 2016/679 – “GPDR”) and with any specific local regulations applicable from time to time for the processing of data outside the European Union, together with the principles and general rules of conduct contained in the Code of Ethics adopted by us.

1. Type and source of Data
Browsing data
During their normal operation, the computer systems and software procedures used to operate our Website collect certain personal data (log files). The transmission of such data is inherent to the use of internet communication protocols. This information is not collected in order to be associated to specific data subjects. However, due to its nature, this information can allow users to be identified by means of their processing and integration with data held by third parties. Such information includes the IP addresses or domain names of the computers you use to visit our Website, URIs (Uniform Resource Identifiers) of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical status code of the server reply (successful, error, etc.) and other parameters concerning the user’s operating system and computer environment. This data is used with the sole purpose of obtaining anonymous statistical information on the use of our Website and to guarantee its correct operation.

Cookies
Our Website uses cookies to ensure its efficient functioning and to improve our services. Cookies are small text files that are sent to your computer (usually to your browser) by the websites you visit. Cookies are stored in your computer to be recognised by those websites on your subsequent visits. For more information on cookies, on the types of cookies used on our Website, on how to disable them and on how you can revoke your consent, see our cookie policy.

Personal Data voluntarily provided by the data subject
We Are Creative collects and processes the Personal Data that you directly and voluntarily provide through our Website when register to our Website and/or subscribe to our newsletter and/or contact us. These data may include, for example, your first and last name, postal and e-mail address, phone number and date of birth. Furthermore, when you voluntarily send an e-mail through our Website and/or to the addresses indicated in our Website, we collect your e-mail address so that we can reply to any request, as well as any additional Personal Data contained in your message.

2. Purpose of the processing
Your Personal Data may be processed for the following purposes:

(a) to respond to all your requests and to manage your relationship with us;

(b) profiling: to perform individual or group studies, surveys, statistical and/or market researches on your preferences with regards to our products, so that we can offer you a personalised service and promote cultural and recreational activities that may interest you;
(c) marketing: to contact you and/or send you (by post, telephone, e-mail and any other form of electronic communication) information and promotions, including commercial information, newsletters, advertising material, catalogues and invitations to events related with us.

3. Processing Methods
Your Personal Data will be processed by suitable electronic or automated means and computerized tools, or manually and on hard copy, exclusively for the purposes for which they have been collected and guaranteeing the security and confidentiality of any processed information. Your Personal Data will be processed only by We Are Creative, your Personal Data may also be processed by third parties to the extent necessary and/or instrumental for the above purposes. These third parties will act on behalf of We Are Creative as data processors (e.g. service providers, carriers, IT technicians or any other suppliers appointed to carry out and/or manage any promotional campaigns for We Are Creative’s products and services, etc.).

4. Nature of the provision of personal data
The processing of your Personal Data for the purposes indicated on the paragraph 2 above is subject to your prior express consent. If you withhold your consent, we may not be able to offer you a personalised service and inform you of any initiatives that may interest you and/or send you any other commercial information on products, initiatives and events of us.
You may withdraw your consent to the processing of your Personal Data by us at any time, by writing to We Are Creative, Via Maurizio Bufalini 5 – Florence (Italy), by sending an e-mail at info @ wac-agency.com, or by using the “unsubscribe” link included in all of our commercial electronic communications, and/or by using any other appropriate procedures which may be made available to you.

5. Transfer and disclosure of data
Whenever necessary and/or instrumental to the above purposes, your Personal Data may be processed on behalf of We Are Creative by other entities acting as data processor. Your Personal Data may be transferred abroad in accordance with applicable legislation, including to countries outside the European Union where We Are Creative pursues its interests, by adopting all appropriate security measures and safeguards to ensure an appropriate level of data security.
Your Personal Data will not be used for third-party advertising purposes or for the promotion of products, services or initiatives by entities other than We Are Creative, nor shall they be disclosed to unknown persons under any circumstances.

6. Retention period
Your personal data will be processed and stored for as long as required for the purposes for which they were collected, and in accordance with the storage periods provided for by the applicable laws, or until you revoke your consent to the processing, if applicable. After such period, your Personal Data will be automatically and permanently erased or made anonymous.

7. Data controller
The Data Controller is We Are Creative, with offices in Florence, Via Maurizio Bufalini 5, Florence – Italy. We Are Creative will process your Personal Data in accordance with the GDPR.
If you want to exercise your rights or receive any information on your rights and/or this Privacy Policy, please contact the Data Controller or Data Protection Officer (“DPO”) by writing to We Are Creative – Via Maurizio Bufalini 5, Florence – Italy, or by sending an e-mail to info @ wac-agency.com 

8. Rights of the data subject
Please note that you may exercise the rights under Articles 15 to 21 GDPR, and specifically the right to request information as to whether your Personal Data is being processed and as to the characteristics of the processing, the right to rectification and erasure of your Personal Data, the right to object to the processing and/or the right to have those Personal Data transmitted to another controller.
You also have the right to withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of processing based on your consent before its withdrawal. You may lodge a complaint with the Italian supervisory authority (Autorità garante per la protezione dei dati personali) at Piazza di Montecitorio no. 121, 00186, Rome (RM).

9. Contacts
If you have any request on your Personal Data, on this Privacy Policy or on how you might exercise your rights, you may contact the Data Controller or the DPO free of charge at the contact details indicated at paragraph 7.

We Are Creative reserves the right to amend this Privacy Policy at any time. The Privacy Policy currently in force is the one published on our Website.