Last updated: May 2020
SCOPE OF APPLICATION
The Data Controller scrupulously respects the privacy of all users who access the [LINK CHANNEL] website or the services linked to it (which we will hereinafter collectively refer to as the "Platform"), from any PC, application, mobile device, platform or other method of access or use.
In this policy we want to describe to you in a transparent, detailed and comprehensive manner how we:
your personal information.
By using the Platform and its services, you are aware that we will use your personal data as described in the policy.
The legal basis on which this notice is based is the European Data Protection Regulation No. 679/2016 of 27 April 2016 on the protection of individuals with regard to the processing and free movement of personal data, in particular Article 13 of the Regulation and Legislative Decree No. 101 of 10 August 2018.
WHAT THIS POLICY DOES NOT PERTAIN TO
This policy does not pertain to and does not regulate the services offered by third parties (which may be accessible by means of links placed on the Platform) and their methods of processing your personal data.
The Data Controller has no control over these third parties and therefore declines all responsibility for the processing of your personal data by these websites.
UPDATING OF THE POLICY
We will modify the policy with additions or changes in order to bring it up to date with respect to the law and to adapt it to any technical changes made to the Platform or to any changes in the purposes or methods of processing your data.
We will inform you of any changes with specific notices.
However, we advise that you periodically check this page to remain up to date.
Any updated version, which will be accompanied by its date, will be published on this web page and will become effective for you immediately after its publication.
PERSONAL DATA CONTROLLER
The data controller of your personal data through the Platform is the company, with a registered office in (), via , C.F. and VAT No. , e-Mail: (in this document we shall also refer to the company as the "Data Controller").
You can contact us by sending an email to [...........].
WHAT PERSONAL DATA WE COLLECT
When you use the Platform, we will only collect your personal data if you send it to us directly or through automated systems that allow the Platform to function properly.
Some personal data is compulsory for us to identify you, others are optional but may be necessary in order for you to use certain services of the Platform.
In particular, we may collect your personal data in these categories:
1. PERSONAL DATA THAT YOU VOLUNTARILY PROVIDE TO US
This is the data that you voluntarily provide to us, for example, when you send us an email to our email address indicated on the Platform or when you fill in our contact form.
The personal data that you may voluntarily provide to us are: identification data such as your name, last name, telephone number, email or other information that you send us via the forms on the Platform.
HOW WILL WE USE THEM?
We will use the data that you communicate to us in order to use the services accessible with your credentials exclusively for any purpose strictly related to the performance of the services that we offer you on the Platform.
Your data may also be transmitted to the police and to the judicial and administrative authorities, in accordance with the law, for the detection and prosecution of crimes, the prevention and protection against threats to public safety, as well as to allow the Data Controllers to exercise or protect their own rights or those of third parties before the competent authorities, as well as for other reasons related to the protection of the rights and freedoms of others.
The legal basis for these processing operations is the performance of a contract (art. 6.1-b of the GDPR) or, as the case may be, the performance of a legal obligation to which the Data Controller is subject (art. 6.1-c of the GDPR).
If you do not communicate this data to us, we will not be able to allow you to use some or all of the services we offer on our Platform.
3. BROWSING DATA
The telematic and information systems that allow the Platform to function automatically acquire, in the course of their normal operation, some of your personal data pertaining to your browsing.
In particular, while you are browsing the Platform we collect:
your IP address;
the number of times you access the website;
the duration of your browsing;
the name of your browser;
the pages you have viewed;
the date and time you have logged in;
other parameters relating to the operating system you used to connect.
HOW WILL WE USE THEM?
We only collect your browsing data in order to obtain anonymous statistical information on how you use our Platform and to check that it is working properly.
However, by their very nature, this data may allow us to trace back your identity, including through processing and association with other data held by third parties.
Your surfing data are not used in any case for marketing purposes, to define your profile or personality, to send you advertising material, to carry out market research or commercial communications - and we will keep them only temporarily.
The legal basis for these treatments is the pursuit of the legitimate interest of the data controller (art. 6.1-f of the Regulation).
METHODS OF PROCESSING
The processing of your personal data that you have communicated to us will be carried out by us, with or without the aid of electronic instruments, in accordance with principles of correctness, lawfulness and transparency, so as to protect your confidentiality and your rights at all times in compliance with the provisions of current legislation.
This data will not be disseminated or communicated in any way to external parties, without prejudice to the obligations under the laws in force.
RECIPIENTS OF PERSONAL DATA
Unless otherwise specified in relation to the individual purposes of the processing as specified above, your personal data may be communicated to - or come to the attention of – data controllers/processors (including external entities), in relation to the skills and functions of each, in order to fulfil the purposes or to implement specific regulatory and/or contractual obligations.
The personal data you have communicated to us are generally not communicated to other subjects, unless this is necessary for regulatory or contractual provisions or to fulfil specific obligations.
In these cases, we may have to communicate your personal data to some of these subjects:
internal and/or external consultants or collaborators, in order to comply with current legislation and/or for the performance of contractual services in dealings with the individual concerned (e.g., employment consultants, legal consultants, accountants, tax advisors, auditors, etc.) exclusively after appointment as external/authorised personal data controllers;
judicial authorities or other public authorities, in compliance with the purposes of processing your data or for legal obligations.
You can request a full list of the data processors by sending an email request to this address: [.........].
LOCATION AND POSSIBLE TRANSFER OF YOUR PERSONAL DATA
Your personal data is stored within the European Economic Area (also referred to as the 'EEA'), and specifically stored on servers on Google Cloud.
PROTECTION OF YOUR PERSONAL DATA
We use advanced encryption technologies and regular backups to protect the integrity and confidentiality of your data.
RETENTION PERIOD FOR YOUR PERSONAL DATA
We will also retain your personal data for as long as necessary to fulfil our legal obligations, resolve disputes and enforce agreements.
Your personal data will therefore be kept, in accordance with the law, for a period of time not exceeding the period necessary to achieve the purposes for which we are processing it, in particular
in relation to the management of the existing contractual relationship, the data will be retained for the time period defined by the reference legislation as well as, upon termination of the relationship, for an additional ten-year period for the retention of civil law data only.
WHAT ARE YOUR RIGHTS
As a data subject concerned by the processing of your personal data, you have the right to ask us for:
confirmation as to whether or not your personal data is being processed and, if so, to obtain access to it (right of access);
rectification of your inaccurate personal data, or to complete any incomplete personal data (right of rectification);
the deletion of your data, if one of the reasons provided for in the GDPR applies (right to be forgotten);
the restriction of the processing of your data when one of the cases provided for by the GDPR applies (right of restriction);
to receive your data in a structured, commonly used and machine-readable format and to transmit, where technically possible, such data to another data controller (right to portability).
the right to withdraw consent to the processing of your data, at any time, without prejudice to the lawfulness of the processing that was carried out based on the consent given prior to the withdrawal and to object at any time to the processing for marketing or other further purposes (right to object)
the right to object, on legitimate grounds, to the processing of your data, even if pertinent to the purpose of its collection;
the right to object to the processing of your data for the purpose of sending advertising or direct sales materials or for carrying out market research or commercial communications.
AUTOMATED DECISION-MAKING PROCESS
Please note that you also have the right not to be subject to a decision based solely on the automated processing of your personal data that produces legal effects concerning you or significantly affects you in a similar way (unless such automated activity is necessary for the conclusion or performance of a contract between you and the Controller, is authorised by the law of the European Union or of the Member State to which we are subject as Controllers (which shall also specify appropriate measures to protect your rights, freedoms and legitimate interests) - or is based on your explicit consent).
You may exercise the above rights at any time by sending a simple request to this email address [............].
We will contact you or inform you as soon as possible and, in any case, within 30 (thirty) days from the date of your request.
If you believe that there has been a breach of data protection legislation with regard to the processing of your data, you also have the right to lodge a complaint with the local Data Protection Authority within the European Economic Area ('EEA').
You can find the contact details of each Authority, depending on the country you are in, by clicking on this link [http://www.garanteprivacy.it/web/guest/home/footer/link].