ZEROTRACCE EMAIL MARKETING NEWSLETTER POLICY
Last update: [date of publication]
1. OBJECT
This Newsletter & Email Marketing Policy governs the manner in which ZEROTRACCE may send commercial, promotional, and informative communications via email.
This policy supplements the Privacy Policy available on the website.
2. DATA CONTROLLER
The Data Controller is:
Amerion Group LLC
30 N Gould St #36862
Sheridan, WY 82801
USA
Email:
sirius.amerion@gmail.com
3. NEWSLETTER SUBSCRIPTION
Subscription to the newsletter is optional.
The user may subscribe through the specific forms available on the website or through other methods made available by ZEROTRACCE.
Subscription is not required to purchase products.
Providing an email address for the purpose of receiving commercial communications is optional.
4. PURPOSE OF COMMUNICATIONS
Subscribed users may receive communications related, depending on the active campaigns, to:
- ZEROTRACCE products;
- new products;
- product availability;
- offers and promotions;
- discount codes;
- commercial campaigns;
- special initiatives;
- informative content related to the catalog;
- communications regarding brand activities.
Commercial communications are sent in compliance with the preferences expressed by the user and applicable regulations.
5. MARKETING CONSENT
When consent is required by applicable law, commercial communications are sent exclusively after obtaining the user's consent.
Marketing consent is separate from the acceptance of the Terms and Conditions of sale and does not constitute a condition for making a purchase.
Failure to consent to commercial communications does not prevent the use of the website or the purchase of products.
6. WELCOME PROMOTION
ZEROTRACCE may offer newsletter subscribers a promotional incentive, such as a discount code on their first order.
When present, the promotion is subject to the conditions specifically indicated at the time of subscription or receipt of the code.
The code may be subject to conditions such as:
- temporal validity;
- minimum order amount;
- excluded products;
- inability to combine with other promotions;
- single use per customer;
- other expressly communicated conditions.
The conditions actually applicable are those communicated in the specific promotion.
7. COMMUNICATIONS REGARDING ORDERS AND SERVICES
Communications necessary for the execution of an order or for the management of the contractual relationship do not constitute a promotional newsletter.
They may include, by way of example:
- order confirmation;
- payment confirmation;
- shipping information;
- delivery updates;
- communications regarding returns and refunds;
- requests necessary for order management;
- communications regarding assistance;
- communications regarding product safety;
- communications necessary to comply with legal obligations.
Such communications may also be sent to users who have not subscribed to the newsletter, when necessary for the execution of the contract, to comply with a legal obligation, or for another applicable legal basis.
8. PLATFORMS USED
ZEROTRACCE may use professional tools for managing and sending email communications, including Shopify Email and Klaviyo, depending on the currently active configuration.
These tools may allow for the management of subscriber lists, the sending of communications, and, where provided and permitted, the measurement of interactions with the communications.
Data processing by providers is also governed by their respective terms and privacy policies.
9. DATA PROCESSED
For the management of the newsletter, the following may be processed, depending on the subscription method and tools used:
- email address;
- name, if provided;
- information regarding subscription status;
- communication preferences;
- date and method of subscription;
- record of consent, when applicable;
- technical information necessary to manage delivery;
- information regarding interaction with communications, when such functionality is active and permitted.
ZEROTRACCE does not request personal data that is not necessary for sending the newsletter.
10. RECORD OF CONSENT
When consent constitutes the legal basis for sending commercial communications, ZEROTRACCE may retain information necessary to demonstrate that consent exists.
Such information may include:
- date and time of subscription;
- email address used;
- method by which consent was collected;
- information regarding the version of the policy presented;
- consent status;
- any revocation date.
11. DOUBLE OPT-IN
When technically enabled, the subscription system may use an email address confirmation procedure, through which the user must confirm their subscription via a specific link.
Whether or not this procedure is used depends on the configuration actually adopted by ZEROTRACCE.
12. FREQUENCY OF SENDING
A fixed number of communications is not guaranteed.
The frequency may vary based on commercial campaigns, catalog news, and brand activities.
ZEROTRACCE commits to avoiding sending communications that are manifestly disproportionate to the purpose of the newsletter.
13. PERSONALIZATION OF COMMUNICATIONS
When permitted by applicable law and the configuration of the service used, ZEROTRACCE may personalize certain communications based on available information regarding the user's interaction with the website or previous communications.
Any profiling activity or processing that requires specific consent is carried out only within the limits of validly acquired consent.
14. EMAIL TRACKING
Communications may contain technologies that allow for the detection of certain interactions, such as:
- opening of the communication;
- clicks on links;
- interaction with specific content.
These features are used according to the currently active configuration and in compliance with applicable law.
The user may revoke consent for commercial communications at any time.
15. UNSUBSCRIBING
Every commercial communication must allow the user to easily stop receiving promotional communications.
The user may use the “Unsubscribe” link or equivalent present in the emails received.
Unsubscribing from the newsletter does not automatically result in the deletion of data that ZEROTRACCE is authorized or obliged to retain for other legitimate purposes.
16. REVOCATION OF CONSENT
Marketing consent may be revoked at any time.
Revocation can be performed, depending on the available tools:
- via the unsubscribe link in the emails;
- via the preference management system;
- by contacting ZEROTRACCE at sirius.amerion@gmail.com.
Revocation does not affect the lawfulness of processing carried out before the revocation.
17. COMMUNICATIONS AFTER UNSUBSCRIPTION
After unsubscription, ZEROTRACCE will stop sending the commercial communications subject to the revocation according to the technical times necessary for the systems used.
The user might receive a communication already scheduled or technically initiated before the unsubscription request was received by all systems.
Communications necessary for the management of orders, payments, deliveries, returns, refunds, warranty, product safety, or other legal obligations are not automatically interrupted by unsubscribing from the newsletter.
18. DATA RETENTION
Data related to the newsletter subscription is retained for the period necessary to manage the marketing relationship and, subsequently, within the limits eventually necessary to demonstrate compliance with applicable obligations or to protect the rights of the Data Controller.
Data that is not necessary is not retained beyond the period justified by the relevant purpose.
19. SECURITY
ZEROTRACCE adopts technical and organizational measures appropriate to the nature of the data and the risks of processing.
Access to email marketing tools is limited to authorized personnel or providers who need to access the data to provide the requested services.
20. PROVIDERS AND DATA PROCESSORS
When external providers process personal data on behalf of ZEROTRACCE, the relationship is governed in accordance with applicable personal data protection laws.
Providers may include, depending on the tools actually used:
- Shopify;
- Klaviyo;
- other technical providers necessary for the management of communications.
The updated list of main recipients and providers is governed by the Privacy Policy.
21. INTERNATIONAL TRANSFERS
Some technology providers may process personal data outside the European Economic Area.
When processing involves an international transfer of personal data, ZEROTRACCE applies, as far as it is responsible, the mechanisms provided for by applicable law.
The safeguards actually used depend on the provider and the service activated.
22. RELATIONSHIP WITH PURCHASERS
The purchase of a ZEROTRACCE product does not automatically imply subscription to the newsletter.
The customer may receive operational communications related to their order regardless of their subscription to promotional communications.
Any commercial communications following a purchase are carried out exclusively according to the applicable legal basis and in compliance with the data subject's preferences.
23. MINORS
The ZEROTRACCE newsletter is not specifically intended for minors.
Subscription to commercial communications must be carried out in compliance with the conditions provided by applicable laws regarding personal data protection and consent.
24. DATA SUBJECT RIGHTS
The data subject may exercise, in cases provided for by applicable law, their rights regarding personal data protection, including:
- access to data;
- rectification;
- erasure;
- restriction of processing;
- objection;
- data portability, where applicable;
- revocation of consent;
- right to lodge a complaint with the competent supervisory authority.
To exercise your rights, you may contact:
sirius.amerion@gmail.com
25. OBJECTION TO MARKETING
The data subject may object at any time to the processing of their data for direct marketing purposes.
The objection may be exercised via the unsubscribe link present in communications or by contacting ZEROTRACCE directly.
26. COMPLAINT TO THE SUPERVISORY AUTHORITY
A data subject who believes that the processing of their personal data violates applicable law may lodge a complaint with the competent supervisory authority, in accordance with the procedures provided by law.
For processing subject to European personal data protection regulations, the competent Italian authority is the Garante per la protezione dei dati personali, without prejudice to the rules applicable to territorial jurisdiction.
27. CHANGES TO THIS POLICY
ZEROTRACCE may modify this Newsletter & Email Marketing Policy to reflect:
- regulatory changes;
- technical changes;
- changes of providers;
- introduction or removal of tools;
- changes to subscription methods;
- changes to delivery methods;
- changes to processing purposes.
The updated version is published on the website with an indication of the relevant update date.
28. CONTACTS
For any questions regarding the newsletter or commercial communications:
Amerion Group LLC
30 N Gould St #36862
Sheridan, WY 82801
USA
Email:
sirius.amerion@gmail.com
29. SUMMARY OF PRINCIPLES
Subscription to the newsletter is optional.
Marketing consent is not a condition for purchasing.
The user may refuse commercial communications.
The user may revoke consent at any time.
Revocation does not affect the lawfulness of processing carried out before the revocation.
Communications necessary for the management of an order or to comply with legal obligations are distinct from promotional communications.
ZEROTRACCE does not consider the purchase of a product as an automatic subscription to the newsletter.
Last update: [date of publication]