Owner and Data Controller
Cama S.r.l. Viale della Navigazione Interna 85 – 35027 Noventa Padovana – Padova firstname.lastname@example.org
TYPES OF DATA COLLECTED
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, Usage Data, first name, last name and email address.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.
MODE AND PLACE OF PROCESSING THE DATA
Methods of processing
The Owner takes 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 Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (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 Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
THE PURPOSES OF PROCESSING
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics and Contacting the User.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
THE RIGHTS OF USERS
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
DETAILS ABOUT THE RIGHT TO OBJECT TO PROCESSING
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
HOW TO EXERCISE THESE RIGHTS
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
This webpage records cookies, even of third parties, to improve the navigation experience and permit the users to exploit our online services and display advertisement in line with their preferences. The cookies used in this web page are part of the categories described below;
It is possible to disable the cookies from your browser; we remind you that this option can restrict the usability of the website.
INSTRUCTIONS TO DISABLE COOKIES FROM BROWSERS
In case you are using Internet Explorer click on “Instruments” then “Internet Options”. In the section Privacy, move the cursor upward to disable all the cookies or downwards to enable all the cookies, finally click on OK.
In case you are using Firefox click on “Settings” then “Options”, click on “Privacy”, remove the flag from “Enable cookies” then confirm by clicking on OK.
In case you are using Safari click on the menu “Modify” and select “Preferences”. Click on “Privacy” then select the setting “Cookies Block always” then click on OK.
In case you are using Google Chrome click on the menu Chrome placed in the toolbar of the browser. Select “Settings”. Click on “Show advanced settings”. In the “Privacy” section, click on the button “Contents settings”. In the “Cookies” section, select “Do not permit web pages to save data” and as control “block cookies of third parties”, then click on OK. In case you are using any other browser, search in the Settings page the cookies management tools.
What are cookies
The cookies, as described in the reference norm, are small dimension text strings that the visited web pages send to its terminal (usually to the browser), where they are recorded to be consequently transmitted to the very same web page during the following visit of the same user. During the surfing on a webpage, the user can receive on his/her terminal also cookies sent by other web site or servers (i.e. “third parties”), on which can be present some elements (such as images, maps, sounds, specific links to other domain pages) positioned on the page they are visiting. The cookies are used for different purposes: informatics authentication executions, sessions monitoring, registration of specific settings concerning the users that enter the server, etc. We precise that according to the directive 2009/136/CE, it is foreseen the obligation to obtain a previous and informed authorization for the installation of the cookies used for different reasons from the merely technical ones (cfr. Art. 1 comma 5, lett. A) of the Decreto Legislativo (Italian legislative decree) 28 may 2012, n. 69 which modified art. 122 of the Legislative Decree 196/2003 – The “Codice”). Therefore we distinguish two macro-categories: “technical” and “profiling” cookies.
a. Technical cookies The technical cookies are the ones used only to “transmit a communication over an electronic communication net, or exclusively to supply the service by the company explicitly authorized by the user or member” (cfr. Art. 122, comma 1 of Italian Code). They will not be used for purposes beyond the declared and are usually installed directly either by the owner or manager of the web site. They can be divided into session or surfing cookies, which guarantee the normal surfing and experiencing on the web site (they enable, for example, to purchase an item or log in for the reserved area); cookies analytics, associated to the technical cookies when used directly by the manager of the site to receive information, in aggregated way, on the number of users and on how they visit the same web site; functionality cookies, that permit the user to surf the web page in a determined way (i.e. language, items selected for purchasing) in order to improve the service given. To install these cookies it is not necessary to ask for the consent of the user, while it is compulsory to give information according to art. 13 of the Italian Code.
b. Profiling cookies. The profiling cookies are necessary to create profiles of the user and they are used to send advertisement messages in line with the preferences showed by the user during the surfing on the net. According to the particular invasivity these devices can have on the personal sphere of users, the European and Italian norms foreseen that the user should be adequately informed on their usage in order to express their valid consent. Art. 122 of the Italian Code at the paragraph “the filing of information in the terminal device of a contractor or user who expressed his or her consent after having being informed with the modalities simplified of art. 13, comma 3 (art. 122, comma 1 of the Italian Code). Further information on cookies can be found at this URL: http://it.wikipedia.org/wiki/Cookie http://www.allaboutcookies.org
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