This document describes the manner by which the site www.inthezon.com (“Site”) is managed, with reference to the processing of personal data belonging to the users (“User/Users”) consulting it.
It is an information notice issued in accordance with article 13 of the Italian Legislative Decree no. 196/2003 (“Privacy Code”) and articles 13 of the EU Regulation no. 679/2016 (“GDPR”), for anyone who visits the Site and/or communicate with Libera Brand Building S.r.l. (“Libera”) by filling the specific online form for asking information available at section “Contact us” of the Site or by sending an email message to the addresses indicated on the Site.
This information notice is provided only for the Site and not for any other websites viewed by users through the links.
1. The data controller
The data controller is Libera Brand Building S.r.l., with registered office in 10152 Turin, Via Andreis 18/16/M, Cortile del Maglio, e-mail address firstname.lastname@example.org (“Data Controller”).
2. Types of data processed
2.1 Browsing data
During normal use, the electronic systems and software procedures enabling this Site to operate, acquire certain personal data; transmission of same is implicit in the use of internet communication protocols.
This information is not being collected in order to be associated to well-identified data subjects, but its nature, by means of processing and associations with data held by third parties, could make the users identification possible.
The category of data could be listed as follow: (i) IP addresses or domain names of computers used by users connecting to the Site, (ii) addresses in URI (uniform resource identifier) notation for resources requested, (iii) the time of request, (iv) the method used to submit the request to the server, (v) the dimension of the file obtained in response, (vi) the numerical code indicating the status of the response given by the server (success, error etc) and (vii) other parameters regarding the user’s operating system and the IT environment.
This data is used only to glean anonymous statistical information on the use of the Site and to check that it operates correctly and this data is deleted immediately after processing.
2.3 Data provided by users of their own free will
In addition to this data, the Data Controller will also process any other information that User may spontaneously provide by sending an email message to the address indicated on the Site and/or by requesting information through section “Contact us” of the Site and/or by requesting marketing communication and newsletter. Such information are processed by the Data Controller only for the purposes set up under paragraph 3.
3. Purposes and lawfulness of data processing
The personal data of the Users are processed by the Data Controller in order to:
a) pursue, in accordance with article 6(1) let. f) of GDPR, an its own legitimate interests consisting in ensuring network and information security, i.e. the ability of a network or an information system to resist, at a given level of confidence, accidental events or unlawful or malicious actions that compromise the availability, authenticity, integrity and confidentiality of stored or transmitted personal data, and the security of the related services offered by, or accessible via, those networks and systems;
b) with the express consent of the User, in accordance with article 6(1) let. A) of GDPR, send marketing communications and/or informative newsletters by e-mail on Inthezon services;
c) allow the User to ask for information on the services promoted by the Data Controller on the Site and to send it, pursuant to article 6(1) let. b) of GDPR, the feedback and/or estimate of fee required.
4. Consequences of any refusal to respond
With the exception of the browsing data, which are necessary to allow to correct operation of the Site, the cookie and the data contained in the information requests, the Users are free to provide their personal data:
(i) in order to receive, by e-mail, marketing communications and/or informative newsletters on Inthezon services.
The refusal to allow their data to be processed would make impossible for the Users to obtain a Data Controller feedback, to remain updated on the news and/or on Inthezon services.
The Data Controller, in any case, informs the Users on the existence of the right to withdraw his consent, without affecting the lawfulness of processing based on consent before its withdrawal.
5. Manner of data processing
The personal data is processed through computerized, automated manual systems for such period of time that is necessary to achieve the purposes for which the data is collected.
The personal data, moreover, is processed only by those subject appointed to carry out such fulfilments, currently identified and duly educated on the constraints provided by the applicable law, as well as by adopting specific security measures aimed to ensure the protection of Your confidentiality and to avoid the loss of data, any unauthorized accesses to the data and any data processing which may be qualified as unlawful or not in compliance with the abovementioned purposes.
6. Communication of personal data
The personal data collected by the Data Controller through the Site will not be distributed, sold or transferred to third parties, save for those eventualities contemplated by law.
In any case, it remains understood that the Data Controller retains the right to communicate the Users personal data to the companies in charge for carrying out specific services within its activity and/or, in general, in its favor, that will operate as independent data controllers or processors, as well as the right to communicate and/or to distribute the User personal data that, in compliance with the applicable law, the police, the judicial authority, the information and security agencies or other public subjects might ask for purposes related to defense or State security or to preventing, detecting or suppressing crimes.
7. Data subject’s rights
1. confirmation of whether or not there is personal data concerning him/her, even if such data has not been registered yet, and is entitled to receive notice of such data in a form that is legible;
2. a copy of Your personal data;
3. rectification of Your personal data, if they are incorrect;
4. erasure of Your personal data;
5. restriction of Your personal data processing;
6. in a structured, commonly used and machine-readable format, personal data You have provided to the Data Controller or You have created – with the exception of the judgments created by the Data Controller or by the person in charge of the processing pursuant to article 8 of the Privacy Code / created by the persons who, under the direct authority of the controller or processor, are authorized to process personal data in accordance with article 4 of GDPR – and to transmit those data, directly or by means of Data Controller, to another data controller;
7. the indication of:
a) the source of personal data;
b) the categories of personal data processed;
c) the purposes and manner of data processing;
d) the reasoning applied in the event of processing undertaken with the aid of electronic systems;
e) details allowing identification of data controllers and data processors;
f) the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;
g) individuals or entities or categories of individuals or entities to whom personal data may be communicated or who may gain knowledge thereof in their capacity as designated representative in Italy, data processors or persons in charge of the processing in accordance with article 4 of Privacy Code / the persons who, under the direct authority of the controller or processor, are authorized to process personal data in accordance with article 4 of GDPR;
h) updating, rectification, and, when requested, integration of the data;
i) anonymization or blocking of data that have been processed unlawfully, including data which it is not necessary to preserve in respect of the purposes for which the data is collected or subsequently processed;
j) certification that the operations as per letter a) and b) have been brought to the attention, also with regard to their contents, of those to whom the data has been communicated or disseminated, with the exception of those cases in which such a legal obligation proves to be impossible or entails use of means which are patently disproportionate compared to the entitlement being safeguarded.
8. The data subject, moreover, shall have the right to object, either wholly or partially:
a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication survey.
In order to exercise the aforementioned rights, it is necessary to write to the Data Controller e-mail address, as it is indicated at the previous paragraph 1, specifying “Privacy – exercise of the data subject rights” as object.
Finally, we inform You that if You believe that your rights have been infringed by the Data Controller and/or by a third party, you have the right of lodging a complaint with a Italian Data Protection authority (“Garante Privacy”) and/or with another competent authority provided by GDPR.
8. Duration of the processing and retention period
The processing will last only for such period of time that is necessary for achieving the purposes mentioned at the previous paragraph 3. The Data Controller will then store Your personal data only in compliance with the legal obligations provided by the applicable laws, for administrative purposes and/or to claim or to defend an own right in the case in which a litigation or a pre-litigation procedure arise. The processing aimed to send newsletter, instead, will last until the User exercise his right of withdrawal.
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