PRIVACY POLICY
1. Data Controller
This Privacy Policy explains how personal data is processed through the TR-1 Upgrade website and its business-to-business (B2B) dealer platform.
Business Name: Ditta Antonio Bruno
Trading Name: TR-1 Upgrade
VAT Number: IT02513560785
Business Address: Via dei Gelsi 3D/3E, 00171 Roma, Italy
Email: dealer@tr1upgrade.com
Ditta Antonio Bruno is the data controller responsible for personal data processed in connection with TR-1 Upgrade’s business activities.
2. Personal Data We Collect
Depending on how you interact with our website, we may collect and process:
Personal and business contact details, including names, email addresses, telephone numbers, company names and business addresses.
Dealer registration information submitted for account approval.
Account and authentication information.
Order details, including products, quantities, prices, billing and shipping addresses.
Invoice, VAT, payment confirmation and transaction reference information.
Shipping, tracking and Local Pickup details.
Communications submitted through our website or by email.
Technical information required for website security and operation, including IP addresses and server logs.
3. Purposes and Legal Bases of Processing
We process personal data for the following purposes:
Dealer Registration and Account Management
To review dealer applications, verify business eligibility, approve accounts and manage access to dealer services.
Legal basis: Article 6(1)(b) and, where applicable, Article 6(1)(f) GDPR.
Order Processing and Fulfillment
To manage orders, prepare Proforma documents, confirm prices, calculate VAT and shipping costs, record payments and arrange delivery or collection.
Legal basis: Article 6(1)(b) GDPR.
Accounting and Legal Compliance
To maintain financial and transaction records required by applicable laws.
Legal basis: Article 6(1)(c) GDPR.
Business Communications
To respond to inquiries and send necessary registration, account and order notifications.
Legal basis: Article 6(1)(b) or Article 6(1)(f) GDPR, as applicable.
Website Security
To protect accounts, prevent unauthorized access and maintain the security and reliability of our services.
Legal basis: Article 6(1)(f) GDPR.
Where consent is legally required for optional technologies, processing will be based on Article 6(1)(a) GDPR.
4. Dealer Registration and Approval
Visitors may browse publicly available product information without registering.
Dealer prices and purchasing functions are available exclusively to approved business accounts.
When a dealer submits a registration request, the information provided is reviewed by an authorized administrator.
Registration does not automatically grant purchasing privileges.
Once approved, dealers can access prices, submit orders and view their account and order information.
5. Orders, Invoicing and Payments
Orders are managed through our WordPress and WooCommerce-based B2B platform.
An administrator reviews order quantities, prices, applicable VAT and shipping costs before issuing the Final Proforma.
Payments are currently arranged by bank transfer.
Payment references, amounts, dates and confirmation records may be processed to reconcile payments with orders.
Customers are not required to enter payment card details into the current B2B ordering system.
Financial and accounting records are retained where required by applicable legislation.
6. Shipping and Local Pickup
For shipped orders, we process the delivery information necessary to prepare shipments, communicate tracking details and complete delivery.
Relevant shipping information may be shared with the selected carrier.
For Local Pickup orders, we process the contact and order details necessary to arrange collection and record completion.
7. Website Hosting and Service Providers
Our website uses WordPress, WooCommerce and related software to provide its services.
Hosting and technical service providers may process information necessary for website operation, data storage, security and technical support.
The website is currently being developed in a Hostinger staging environment. Hosting arrangements may change when the website moves to its final production environment.
Where required, appropriate contractual and technical safeguards are applied to personal data processed by service providers.
8. Cookies and Similar Technologies
Our website may use cookies and similar technologies necessary for login sessions, shopping carts, security, language preferences and other essential functions.
We use Complianz to manage cookie consent preferences.
Non-essential technologies requiring consent must be handled in accordance with applicable data protection and electronic communications legislation.
Further details about cookies and available preferences will be provided through our Cookie Policy and cookie consent controls.
9. Data Sharing and International Transfers
Personal data may be accessible to authorized personnel and shared where necessary with hosting providers, technical service providers, delivery companies, professional advisers or competent authorities.
We do not sell personal data to advertisers.
Where personal data is transferred outside the European Economic Area, applicable GDPR requirements and appropriate transfer safeguards must be respected.
10. Data Retention
Personal data is retained only for as long as necessary for the purposes for which it was collected, subject to applicable legal requirements.
Account information may be retained while the business relationship remains active.
Order, payment and accounting records may be retained for periods required by tax, accounting and other applicable legislation.
Data may also be retained where necessary for the establishment, exercise or defense of legal claims.
11. Data Security
We apply appropriate technical and organizational measures intended to protect personal data against unauthorized access, accidental loss, alteration or disclosure.
Access to administrative and dealer information is restricted according to account permissions.
No internet-based system can guarantee absolute security.
12. Your Data Protection Rights
Under the GDPR, subject to applicable conditions, you may have the right to:
Access your personal data.
Request correction of inaccurate or incomplete information.
Request erasure where legally applicable.
Request restriction of processing.
Object to certain processing activities.
Request data portability where applicable.
Withdraw consent where processing is based on consent.
Lodge a complaint with a competent supervisory authority, including the Italian Garante per la protezione dei dati personali.
To exercise your rights, contact dealer@tr1upgrade.com.
13. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes in our website, business operations, service providers or applicable legal requirements.
The current version will be published on this page.
14. Contact
For privacy-related inquiries or requests concerning personal data, please contact:
TR-1 Upgrade — Ditta Antonio Bruno