pursuant to Regulation (EU) 2016/679 (GDPR)
Effective as of: 24/06/2025

INTRODUCTION

This privacy policy complies with the EU General Data Protection Regulation (GDPR – Reg. EU 2016/679) and Italian Privacy Code (Legislative Decree no. 196/2003, as amended). It also follows the guidelines issued by the Italian Data Protection Authority, including those on email marketing (July 4, 2013).

Data Controller:
Idea Group IGM, with registered office at via Trieste 28/bis, 35121 Padua, Italy
Email: info@shikumen101.com

The Data Controller has not appointed a Data Protection Officer (DPO). You can contact the Controller directly at the above email address.

This policy refers to the website shikumen101.com (“the Website”).

For detailed information on cookie usage, please refer to our Cookie Policy, available in the dedicated section of the Website.

The Website uses a Consent Management Platform (CMP) in compliance with the GDPR, allowing users to accept or decline non-essential data processing, such as profiling and advanced analytics.

1. PURPOSES AND LEGAL BASES OF DATA PROCESSING

1.1 Registration on the Website

Personal data provided during registration is processed to allow access to reserved areas and related services.
Legal basis: pre-contractual measures.
Optional, but necessary for registration.

1.2 Purchasing on the Website

Data is processed to manage purchases and comply with contractual and tax obligations.
Legal basis: contract execution and legal obligations.

We may also use your email address to send promotional messages about similar products (“soft-spam”), unless you object.
You may opt out at any time by clicking the unsubscribe link in our emails or by writing to info@shikumen101.com.

1.3 Responding to Inquiries

Your data will be processed to respond to your inquiries.
Legal basis: legitimate interest in responding to user requests.

1.4 Marketing (subject to consent)

If you provide consent, we may send promotional emails or newsletters about our own or third-party products.
Legal basis: your consent.
Optional; refusal does not affect access to other services.

1.5 Profiling (subject to consent)

If you provide consent, we may use your data to profile your purchasing behavior and preferences to send personalized promotions.

Tools used: CRM, Google Analytics, Meta Pixel.
Optional; refusal does not affect Website usage.

2. DATA DISCLOSURE AND RECIPIENTS

Your data may be disclosed to:

• public authorities, where required by law;
• consultants (legal, tax, administrative);
• couriers for order delivery;
• third-party platforms for email marketing (e.g. CRM tools);
• internal staff and collaborators.

Your data will not be sold to third parties without your explicit consent.

3. DATA RETENTION

• Marketing data: retained until you withdraw your consent; for inactive users, deleted after 12 months from the last email opened.
• Other data: retained as long as needed for contractual and legal purposes.

4. INTERNATIONAL DATA TRANSFER

The Data Controller is based in the EU. However, your data may be transferred outside the EU (e.g., to the USA), using:

• Standard Contractual Clauses (SCC); or
• in case of transfer to a country covered by an EU adequacy decision, including the EU-U.S. Data Privacy Framework (effective July 10, 2023).

5. YOUR RIGHTS

Under Article 13 GDPR, you have the right to:

• access, rectify, delete your data;
• restrict or object to processing;
• withdraw your consent at any time;
• request data portability;
• lodge a complaint with a supervisory authority (e.g., the Italian Data Protection Authority).

You can exercise your rights by contacting: info@shikumen101.com

6. CHANGES TO THIS POLICY

The Data Controller reserves the right to modify this privacy policy at any time.
In case of substantial changes, we may also notify you by email.

We encourage users to regularly review this policy for updates.