Privacy en for GDPR
The Words of the Angels - Le Parole degli Angeli
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Types of Data collected
Mode and place of processing the Data
The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases , the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.
Legal Basis for Data Treatment
- Consent: The data subject has freely given consent for their information to be processed for a specific purpose.
- Note: In some amendments, the Owner can be authorized to manage Personal Data without the presence of the approval of the user, or any other legal basis specified as follow, until the moment the User may deny (“opt-out”) such treatment. This is however not applicable when the treatment of Personal Data is regulated by the European Commission in matter of protection of Personal Data.
- Contract: Processing is necessary due to the fulfillment of a contract.
- Legal Obligation: Processing is necessary to comply with the law.
- Vital Interest: Processing is necessary to save or protect an individual’s life. Public Tasks: Processing is necessary to perform a public interest in official functions. (Primarily applies to governmental agencies/entities.)
- Legitimate Interests: Processing is necessary to the legitimate interests of an organization or a third-party affiliate.
It is however always possible to request the Owner to clarify the applied legal basis of each treatment, and in particular to specify if the treatment is based on a law, included in a contract, or necessary for the execution of a contract.
The Data is processed at the Data Controller's operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller. Personal Data of the User may be transferred to a different country than the one where the User resides. To obtain further information on the places of the data treatment, the User can refer to the section related to the details on treatment of Personal Data. The User has the right to obtain information in regard to the legal basis of the transfer of Data outside the European Union, or to an international organization of public international rights, or constituted by two or more countries, for example the ONU, and also with regard to the security measures implemented by the Manager to protect such Data. In case one of the above mentioned transfers may happen, the User can refer to the individual sections of this document, or request information to the Manager, by contacting him or her in the contact information section.
Length of data storage.
Data is treated and stored for the time requested by the purposes for which it was collected. Therefore:
- Personal Data collected for purposes connected to the execution of a contract between the Manager and the User will be stored until the execution of such contract.
- Personal data collected for purposes leading to the safeguard of the interest of the User will be stored until the completion of such interest. The User can obtain further information on the subject of his own interest managed by the Manager in the individual sections of this document, or by contacting the Manager.
When the data treatment is based on the consent of the User, the Manager may store Personal Data for longer, until such consent is revoked. Furthermore, the Manager could be obligated to conserve the Personal data for a longer period of time, to abide to a legal obligation or under the order of an authority. At the end of the period of data storage, the Personal data will be erased. Therefore, at the expiration of such term, the right to access, delete, alter and the right to transfer Data may no longer be exercised.
Objectives of Treatment of Data collected.
User data is collected to allow the Manager to provide his Services, and also for the following purposes: Statistics. To obtain additional information detailing the purpose of such data treatment, and the Personal Data actually relevant for each purpose, the User may refer to the individual sections of this document.
Details on Personal Data treatment.
Personal Data is collected for the following purposes, and utilizing the following services:
The services included in the present section allow the Data Management Manager to monitor and analyze the traffic data, and it helps track the User behavior.
Google Analytics (Google Inc.)
Google Analytics is an analysis service provided by Google Inc. (“Google”). Google uses Personal Data collected with the purpose of tracking and analyzing the usage of their Web Site, compiling reports, and sharing them with other services developed by Google. Google may utilize Personal Data to contextualize and personalize announcements of their own publicity network.
Subject is adhering to the Privacy Shield.
ShinyStat Free (Triboo Data Analytics S.R.L.)
ShynyStat Free is a statistics service provided by Triboo Data Analytics, S.R.L. This statistics service renders anonymous the IP address of the user.
Users may exercise certain rights with regard to the treatment of data from the Manager. In particular, the User has the right to:
1) Right to information
This right provides the data subject with the ability to ask a company for information about what personal data (about him or her) is being processed and the rationale for such processing. For example, a customer may ask for the list of processors with whom his or her personal data is shared.
2) Right to access
This right provides the data subject with the ability to get access to his or her personal data that is being processed. This request provides the right for data subjects to see or view their own personal data, as well as to request copies of the personal data.
3) Right to rectification
This right provides the data subject with the ability to ask for modifications to his or her personal data in case the data subject believes that this personal data is not up to date or accurate.
4) Right to withdraw consent
This right provides the data subject with the ability to withdraw a previously given consent for processing of their personal data for a purpose. The request would then require the company to stop the processing of the personal data that was based on the consent provided earlier.
5) Right to object
This right provides the data subject with the ability to object to the processing of their personal data. Normally, this would be the same as the right to withdraw consent, if consent was appropriately requested and no processing other than legitimate purposes is being conducted. However, a specific scenario would be when a customer asks that his or her personal data should not be processed for certain purposes while a legal dispute is ongoing in court.
6) Right to object to automated processing
This right provides the data subject with the ability to object to a decision based on automated processing. Using this right, a customer may ask for his or her request (for instance, a loan request) to be reviewed manually, because he or she believes that automated processing of his or her loan may not consider the unique situation of the customer.
7) Right to be forgotten
Also known as right to erasure, this right provides the data subject with the ability to ask for the deletion of their data. This will generally apply to situations where a customer relationship has ended. It is important to note that this is not an absolute right, and depends on your retention schedule and retention period in line with other applicable laws.
8) Right for data portability
This right provides the data subject with the ability to ask for transfer of his or her personal data. As part of such request, the data subject may ask for his or her personal data to be provided back (to him or her) or transferred to another controller. When doing so, the personal data must be provided or transferred in a machine-readable electronic format.
Details on right to refusal.
When personal data is treated in the public interest, within the exercise of public powers of which the Manager is in possession, or to pursue a legitimate interest of the Manager, the Users have the power to refuse to the treatment of their data for reasons connected to their own particular situation. It is noted that Users who, in case their Data was treated with purposes of direct marketing, may refuse the treatment of their date without providing any reason for it. To find out if the Manager is managing data with the purpose of direct marketing, the User may refer to the individual sections of this document.
How to exercise your rights
To exercise the rights of the User, each User may send a request to the Manager, whose contact information is listed in this document. Each request is deposited free of charge and acted upon by the Manager as quickly as possible, no later than one month from receipt of the request.
Additional information on data processing.
Legal Defense in a dispute
User Personal Data may be utilized by the Manager during a dispute or in the preparatory phases of an eventual defense in a dispute from abuse of the utilization of this Web Site or of the Services related by the User. The User declares to be aware that the Manager may be obligated to reveal Data as imposed by the public authorities.
Upon request by the User, in addition to the information contained within this privacy polity, this Web Site may provide the User with additional and contextual information regarding specific Service, or the collection and treatment of Personal Data.
System Log and Maintenance
Due to necessities linked to functionality and maintenance, this Web Site and eventual third party services utilized within it may collect a system log, which is a system of files that register interactions and that may also contain Personal Data, such as the IP user address.
Information not contained in this policy
Additional information in relation to the treatment of Personal Data may be requested at any time to the Manager of Data Treatment, using the contact information provided.
Reply to requests for “Do Not Track”
This Web Site does not support “Do not track” requests. To find out if eventual services from third parties support this policy, the User is invited to consult their respective privacy policies.