1. Data Controller
The Data Controller responsible for the processing of personal data collected through this website is:
Winterlude Group s.a.s.
Via Senigallia 19
60126 Ancona, Italy
Telephone: +39 071 206612
Email for privacy-related requests: privacy@winterludegroup.it
2. Personal data we collect
We collect only the personal data voluntarily provided through the forms available on the website.
Depending on the service used, this may include:
- email address;
- company name and contact person;
- country;
- telephone or WhatsApp number;
- company website;
- information about the type of business;
- product categories of interest;
- usual purchasing quantities and price ranges;
- specific purchasing requirements entered in the message field;
- any files voluntarily attached.
We may also process technical information necessary for the security and correct operation of the website and forms.
3. Newsletter and stock offers
Users may subscribe to receive stock offers and commercial communications from Winterlude Group.
Subscription is completed only after the email address has been confirmed through the link sent to the address provided.
The email address is used to send information about stock opportunities and merchandise that may be of interest to professional buyers.
The legal basis for this processing is the user’s consent pursuant to Article 6(1)(a) GDPR.
Consent can be withdrawn at any time by using the unsubscribe link included in our emails or by contacting:
Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
4. Purchasing preferences and selected offers
After subscribing, users may voluntarily provide additional information about the merchandise they are interested in.
These preferences may include product categories, quantities, price ranges and other purchasing requirements.
Winterlude Group uses this information to better understand the buyer’s interests and, where possible, avoid sending offers that are clearly unrelated to those interests.
The information may be compared with:
- stocks available through Winterlude Group;
- stock proposals received from Italian companies;
- commercial opportunities identified through our contacts;
- merchandise that may be searched for according to specific buyer requirements.
Providing purchasing preferences is optional.
Completing the buyer profile does not:
- create an obligation to purchase;
- guarantee that suitable merchandise will become available;
- automatically constitute an assignment to search for merchandise.
Winterlude Group does not use these preferences to make decisions based solely on automated processing that produce legal or similarly significant effects.
5. Specific enquiries
If you contact us regarding a specific stock opportunity or ask us to look for a particular type of merchandise, we use the information provided to respond to your request and evaluate possible commercial opportunities.
The legal basis is the performance of pre-contractual measures requested by the user pursuant to Article 6(1)(b) GDPR.
6. Email delivery
Commercial communications are sent through systems managed by Winterlude Group and the technical infrastructure necessary for email delivery.
At present, Winterlude Group does not use tracking pixels or similar tools to monitor whether individual recipients open the emails they receive.
Technical information may nevertheless be processed when necessary to manage:
- successful or failed delivery;
- invalid email addresses;
- subscription confirmation;
- unsubscribe requests.
7. How personal data are processed
Personal data are processed mainly by electronic means and protected through appropriate technical and organisational measures designed to prevent:
- unauthorised access;
- unlawful use;
- accidental loss;
- alteration;
- unauthorised disclosure.
Access to personal data is limited to authorised persons and technical providers that require access to perform their services.
8. Recipients of personal data
Personal data are not sold or publicly disclosed.
Where necessary, they may be processed by technical providers used for:
- website hosting;
- email and server infrastructure;
- IT maintenance and security;
- data storage and backup.
They may also be disclosed to public authorities where required by law.
Where external providers process personal data on behalf of Winterlude Group, they are used in accordance with the requirements of applicable data protection legislation.
9. Data retention
Email addresses used to receive stock offers are retained until the user:
- unsubscribes;
- withdraws consent;
- requests deletion;
- or until the service is discontinued.
Purchasing preferences are retained while they remain useful for the service or until the user asks us to modify or delete them.
Information relating to specific commercial enquiries is retained for the time necessary to manage the request and any subsequent business relationship.
After an unsubscribe request, limited information may be retained where necessary to ensure that no further commercial communications are sent and to demonstrate compliance with the request.
Where a commercial transaction takes place, the relevant contractual, accounting and tax information is retained for the periods required by law.
10. Your rights
Under the GDPR, you have the right to:
- access your personal data;
- request correction of inaccurate or incomplete data;
- request deletion of your data where applicable;
- request restriction of processing;
- receive your data in a portable format where applicable;
- object to processing;
- withdraw your consent at any time.
You may object at any time to the processing of your personal data for direct marketing purposes.
Requests may be sent to:
You also have the right to lodge a complaint with the competent Data Protection Authority.
11. Cookie Policy
This website uses only technical cookies and similar technologies that are necessary for the operation, security and correct use of the website and its forms.
Technical cookies may be used, for example, to:
- maintain essential website functions;
- protect forms and prevent abuse;
- manage temporary sessions;
- remember technical preferences.
These cookies are not used for advertising, behavioural profiling or marketing purposes.
Because they are necessary to provide the website or a service requested by the user, prior consent is not required for their use. The Italian Data Protection Authority confirms that technical cookies are those necessary for navigation or for providing a service requested by the user.
12. Analytics and advertising cookies
Winterlude Group does not currently use Google Analytics or other analytics systems that install tracking cookies on the website.
The website does not use cookies or other tracking tools for:
- behavioural advertising;
- remarketing;
- advertising personalisation;
- profiling visitors;
- tracking users across unrelated websites.
13. Google Search Console
Winterlude Group uses Google Search Console to monitor the presence and performance of the website in Google Search, including information such as search queries, impressions and clicks.
Google describes Search Console as a service for monitoring how a website appears and performs in Google Search.
Search Console is not used on this website as an analytics or visitor-profiling system and no Google Analytics tracking code is installed for this purpose.
14. Changes to this policy
This Privacy and Cookie Policy may be updated if:
- the services offered by the website change;
- new technical tools are introduced;
- data processing activities change;
- applicable legislation or regulatory requirements change.
The date of the latest update is shown at the beginning of this page.