Privacy Policy & Cookie Policy

This policy explains how we process personal data when you visit gardenpromo.com or place an order, in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”).

1. Data controller

MANY LEADS S.R.L., Via Pantanelle 16, 59100 Prato (PO), Italy · VAT IT02437270974
Email for privacy requests: [email protected]

2. What data we collect

  • Order data: name, phone number, email address, delivery address, postcode, product and quantity ordered.
  • Communication data: the content of emails and phone calls with our customer support, including the order-confirmation call.
  • Technical data: IP address, browser and device information, pages visited, and a device check used to prevent fake or duplicate orders (see section 8).

We do not collect payment card or bank data to place an order, because payment is made on delivery. If you ask for a refund, we collect the bank account (IBAN) you give us for that purpose.

3. Why we use your data and the legal basis

  • To process and deliver your order, confirm it by phone, handle returns, refunds and guarantee claims — necessary for the contract (Art. 6(1)(b) GDPR).
  • To meet legal obligations, such as tax and accounting records — Art. 6(1)(c) GDPR.
  • To prevent fraud and fake orders and keep the website secure — our legitimate interest (Art. 6(1)(f) GDPR).
  • To answer your questions — Art. 6(1)(b) or (f) GDPR.
  • To measure the results of our advertising (Google Ads conversion tracking) — only with your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time.

We do not use your data for automated decisions that have legal or similarly significant effects on you, and we do not sell your personal data.

4. Who receives your data

We share your data only as needed to fulfil your order and run the website, with:

  • order-management and customer-service partners who confirm orders by phone and handle fulfilment on our behalf;
  • couriers and logistics providers who deliver your parcel (name, address, phone number, amount to collect);
  • IT service providers: website hosting, content delivery and security, and automation services that pass order data to our order-management system;
  • Google Ireland Ltd., for advertising measurement, only if you consent (see section 8);
  • accountants and public authorities where required by law.

These recipients act as our processors under a data-processing agreement, or as independent controllers where the law requires (for example couriers).

5. Transfers outside the EU

Some IT providers may process data outside the European Economic Area. In that case the transfer is protected by an adequacy decision of the European Commission or by the Commission’s Standard Contractual Clauses.

6. How long we keep data

  • Order and invoicing data: 10 years, as required by Italian tax and accounting law.
  • Customer-support messages: up to 26 months after the end of the 24-month legal guarantee period.
  • Technical and security logs: up to 12 months.

7. Your rights

You have the right to access your data, to have it corrected or deleted, to restrict or object to processing, and to data portability. Write to [email protected]; we reply within one month. You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali, www.garanteprivacy.it) or the authority in your country.

8. Cookies and similar technologies

Cookies are small files stored on your device. We use:

  • Technical cookies needed for the website to work, for example to keep a shopping session, remember cookie choices and protect the site from abuse (WordPress, WooCommerce and our security/content-delivery provider). These do not require consent.
  • Order-validation check: when you open an order page, a script from our order-management partner reads basic device and browser information to detect fake, automated or duplicate orders. It is used only for this purpose.
  • Advertising measurement (Google Ads conversion tracking): on the order-confirmation page we use the Google Ads tag of Google Ireland Ltd. to measure how many orders come from our ads. It uses cookies and may involve transfers to Google LLC in the USA under the EU–US Data Privacy Framework. We use it only with your consent, which you give or refuse in the cookie banner and can change at any time from the “Cookie settings” link. More information: policies.google.com/technologies/ads.

We do not use profiling cookies to build a personal profile of you.

You can delete or block cookies in your browser settings. Blocking technical cookies may prevent parts of the website from working.

9. Changes

We may update this policy. The date of the latest version is shown on this page.

Last updated: 28 September 2026