The present policy is provided in accordance with Article 13 of Regulation 2016/679 (GDPR), pursuant to Article 13 of the Legislative Decree n. 196/2003 (Code relating to the protection of personal data) and it is related to all personal data processed through the methods indicated below.
The Data Controller is Alessia Scotti Belli c/o Paidea Sas of Alessia Carm
en Scotti Belli & Co. firstname.lastname@example.org
The personal data provided can be communicated to appropriately appointed recipients as data processors and/or persons in charge of processing, in order to comply with contracts or connected purposes.
The complete list of the data controllers and persons in charge of the processing of personal data can be demanded by sending a specific request to the e-mail address email@example.com
In case personal data are transferred outside the European Union, for operational technical purposes and to guarantee a high level of service continuity,the Data Controller ensures that the transfer is based on a Commission adequacy decision, in order to assure that the level of protection of physical persons, guaranteed by the current law and in particular by the EU Guidelines 2016/679, is not undermined.
The processed personal data are directly provided by the data subject or collected automatically.
Data provided directly by the data subject is all the personal data provided by any means to the Data Controller.
Automatically collected data is navigation data. Such data, although is not collected for the purpose of being associated with the user’s identity, could indirectly allow his/her identification, through processing and association with data collected by the Data Controller .
Following the sending of newsletters, the platform allows to detect the opening of the message and when you click through to the newsletter, together with details concerning the ip address and the browser/device used. The collection of these data is essential for the operation of implicit renewal of processing systems (see the section Methods of Processing) and an integral part of the efficiency of the sending platform.
PURPOSE OF PROCESSING
The provision of personal data has, as its legal basis, the processing of contractual or pre-contractual requirements or the fulfilment of legal obligations to which the Data Controller is subject. For this reason, failure to provide the data or partial or inaccurate provision will result in the impossibility of a proper provision of the service or in the impossibility for the Holder to answer the information requests submitted by the users.
The provision of personal data to receive newsletter for promotional, informative commercial or research purposes is optional and the refusal to give consent for data processing will lead to the impossibility to be updated on commercial initiatives and/or promotional campaigns, to receive offers or other promotional materials.
WITHDRAWAL OF CONSENT
The interested party can immediately revoke its consent to receive promotional and commercial communications by sending an email to [firstname.lastname@example.org] or by clicking on the specific unsubscribe link that you can find in the footer of every promotional and commercial e-mail received.
The personal data provided can be communicated to appropriately appointed recipients as data processors and/or persons in charge of processing.
The Data Controller does not communicate to third parties any of the information of the data subjects without their consent, except when required by law. In any case, the dissemination of the processed personal data is excluded. The complete list of the people responsible for the processing, of joint controllers and of the ones in charge of the processing of personal data may be required by sending an email to [insert email]
METHODS OF PROCESSING
Personal data is processed with automated tools for the time strictly necessary to achieve the purposes for which it was collected, providing in any case the annual verification of the stored data in order to delete the one deemed obsolete, unless the law provides for obligations of storage.
The processing of data normally takes place at the headquarter of the Holder, and is carried out by members of the staff or external collaborators duly appointed as data processors. The complete list of the responsible for the processing and of the data processors may be requested by sending an email to email@example.com.
Specific security measures have been put in place in order to avoid the loss of data, or illegal or improper use thereof, or unauthorised access thereto.
The registration and the relative data processing are considered valid until the user decides to unsubscribe him/her from the platform/service by clicking on the unsubscribe button that is present in every email; in addition their validity ceases after 12 months since the last communication where he/she has evidence of direct interaction (clicking, opening, answering).
RIGHTS OF THE INTERESTED PARTY
In accordance with articles 15 – 21 of the EU Regulation 2016/679, each data subject is granted a set of rights.
Right of access: The data subject, in accordance with article 15, has the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, to receive a copy. He/She also has the right to get access to his/her personal data and to further information, such as the purpose of the processing, the categories of recipient, the envisaged period for which the personal data will be stored and the rights that may be exercised.
Right to rectification: The data subject, in accordance with article 16, has the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her or their completion.
Right to erasure: the data subject has the right to obtain the erasure of personal data concerning him/her, without undue delay, if there is one of the reasons provided by the article 17.
Right to restriction of processing: the data subject has the right, in the cases referred to in the article 18 of Regulation 2016/679, to obtain restriction of processing.
Right to data portability: the data subject has the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as provided for in the article 20 of Regulation 2016/679;
Right to object to processing: the data subject has the right to object to processing of personal data concerning him/her as provided for in the article 21 of Regulation 2016/679.
The data subject has also the right to lodge a complaint with the competent supervisory Authority, the Privacy Guarantor.
The requests referred to in the preceding paragraphs shall be addressed in writing to the Data Controller. It will provide, within the time limits set by current legislation, a prompt response to the requests to exercise the rights of data subject.
Any explanation or request for clarification must be addressed to the data controller.
UPDATES AND CHANGES
The Data Controller reserves the right to regularly modify, integrate or update the current policy in accordance with the applicable legislation or the measures adopted by the Privacy Guarantor