Privacy Policy of TWI SRL

1. Data Controller

The data controller of personal data is TWI SRL, with registered office at:
VIA XXIV MAGGIO 6, 22063 CANTÙ (CO), Italy
VAT / Tax ID: 04170040135
Email: giovanni@thirdway.it

Legal Representative: Giovanni Meroni

2. Types of Data Collected

We may collect and process the following categories of data:

Voluntarily provided data:

  • Name, address, email, phone number (for orders and shipping)

  • Newsletter subscription data (if you opt-in voluntarily)

Technical / analytical data:

  • Cookies and browsing data via the consent banner (if accepted)

  • Any anonymized data for statistics (e.g., anonymized Google Analytics)

All data collected is processed transparently and only to the minimum extent necessary.

3. Purpose and Legal Basis of Processing

We process data for:

a) Contract performance

  • Fulfilling orders

  • Managing payments and shipments
    Legal basis: Contractual necessity

b) Legal obligations

  • Fiscal and accounting compliance
    Legal basis: Legal obligation

c) Marketing & newsletter

  • Only if explicit consent has been given
    Legal basis: Explicit consent

d) Statistics and website improvement

  • Only with consent (e.g., anonymized GA)
    Legal basis: Explicit consent

4. Cookies and Tracking Tools

The website uses a consent banner which can block scripts and cookies before consent.

If you accept the consent:

  • Analytics may be activated (anonymized only)

  • Functional cookies for login/cart are handled by WooCommerce

Third-party cookies (e.g., YouTube embeds) are managed via the banner and are not stored without consent.

5. Data Retention

Personal data is retained only as long as necessary to:

  • Fulfill orders and fiscal obligations

  • Comply with legal requirements

  • Manage your requests

Marketing and tracking data are retained only until consent is withdrawn or as legally required.

6. Data Subject Rights

You have the right to:

  • Access your data

  • Rectify or delete your data

  • Restrict or object to processing

  • Request data portability

  • Withdraw consent at any time

To exercise your rights, contact: giovanni@thirdway.it.
You also have the right to lodge a complaint with the relevant Data Protection Authority.

7. Sharing Data with Third Parties

We may share your data with:

  • Shipping partners

  • Payment services (e.g., Stripe, PayPal)

  • Newsletter services (only with your consent)

  • Analytics tools if consented

All partners are selected for security and GDPR compliance.

8. Data Transfer Outside the EU

If your data is transferred outside the EU, it will be done only via Standard Contractual Clauses or equivalent legal mechanisms.

9. Contact

For questions or requests regarding your personal data, contact us at:

📧 giovanni@thirdway.it
📍 TWI SRL – VIA XXIV MAGGIO 6, 22063 CANTÙ (CO), Italy