The Website www.beprivacy.it (hereinafter “Site”) is managed by BePrivacy S.r.l. (hereinafter “Company” or “BePrivacy”, for Company details see section 7) as Data Controller. BePrivacy has adopted technical and security measures to ensure that information obtained from theirs users hereinafter, “user”, “users” or “you”) will be carried out in accordance with the principles of lawfulness, fairness, transparency, accuracy, purpose and storage limitations, data minimisation, integrity and confidentiality, in accordance with the national and european provisions.
This Policy s intended for this Site, whilst it does not apply to other websites that could potentially be accessed by clicking external links.
“Persona Data” means any information relating to an identified or identifiable natural person, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier.
Personal Data collected with the Site are the following:
a) Browsing data
The computer systems and software procedures used to operate the Website collect some Personal Data, the transmission of which is an integral part of Internet communication protocols. This information is not collected to be associated with you but, by its very nature, it may allow you to be identified by processing and associating it with data held by Third parties. Among collected Personal Data there are IP addresses or names of the devices used by you to connect to the Website, the URI (Uniform Resource Identifier) of requested resources, the time of the request, the method used to submit the request to the server, the size of the file received as a reply, the numeric code indicating the status of the reply given by the server (successful, error, etc.) and other parameters regarding your operating system and device environment.
This data is used exclusively for the purposes of obtaining anonymous statistics on the use and proper functioning of the Website and to control its correct functioning. Data could be used in case of violations by the web-users, or in order to protect the rights of BePrivacy.
b) Data provided on a voluntarily basis
Through the Site, user have the possibility to voluntarily provide Personal Data, such as name and e-mail address for subscribing to the newsletter, to request a demo or information through different form on the Site.
In that sense, user waive, in the full sense of the term, the right to all disputes, claims for damages due to processing and so on, which may be submitted to BePrivacy of the Third party whose Personal Data have been processed through your use of the Site in breach of the applicable law.
User could voluntarily provide us with Personal Data to receive commercial or promotional communications. These activities may be made by automated means (social networks, e-mail and newsletter).
In every communication we kindly remind that users may revoke their consent, or object to information already provided and processed, without difficulties. Personal data are deleted on simple request.
In particular, this Site uses a form to subscribe to our newsletter, provided by MailChimp. This is a specific newsletter service managed by Rocket Science Group, LLC, ‐ Atlanta, USA, which use cookie for statistical information on access and visits of the Site. For further information see section 8.
Users could request opt-out at any time. For further information see sections 2, 3 and 9.
The Personal Data that you provide surfing the Site will be processed by BePrivacy for the following purposes:
a) To propose services through the Site (.g., contact request made by using the form available on the Site, registration to the newsletter and so on);
b) To research/statistical analyses on aggregated or anonymous data, without the possibility of identifying the data subject, aimed at measuring the functioning of the Site, including solving any technical problems;
c) To send commercial and promotional communications and periodical updates related to BePrivacy’s products, services, initiatives and events organised by the Company (marketing);
d) to prevent or uncover fraudulent activities or misuse that is damaging to our Site or threatening the security of the operations;
e) To the compliance with a legal obligation to which the Data Controller is subject;
f) To establish, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
The legal basis for the processing of Personal Data for the purposes referred to in point a) is the provision of a service or the response to a request that does not require you prior consent under the applicable law.
The purpose referred to in point b) does not involve the processing of Personal Data, whilst the processing for the purpose referred to in point c) require and explicit and preventive consent of users. Users may opt-out in any time by clicking here.
Regarding the purpose referred to in point d) and f) constitutes a legitimate interest pursued by the BePrivacy.
In conclusion, the purpose referred to in point e) is a legitimate processing of Personal Data, since the processing is indeed necessary to comply with a legal obligation to which the Company is subject.
Providing information is voluntary and optional: user freely provide personal data through the forms on the Site and also share with the Data Controller in order to send of newsletter, commercial communications or other information. If you do not provide your personal data could make impossibile to obtain information requested.
The processing of users’ information is made only if necessary and is carried out, in electronic or automated way, by BePrivacy and/or by Third parties involved in order to collect, manage and transfer personal data processed (for further information, see section 5 above).
We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration.
BePrivacy will retain your Personal Data for a period of time necessary or permitted to comply with the Code, GDPR and other related applicable law. Further information regarding the period of retention of Personal Data and the criteria used to determine such period may be required to the Data Controller (see section 7 for Company details).
Your Personal Data may be disclosed, in relation to the purposes specified above in section 2, to:
subjects necessary for order fulfilment of the services offered through the Website e.g., sending e-mails and analysing data, which typically process Personal Data as data processors;
persons authorised by the Company to process Personal Data, that are committed to/ or under an appropriate statutory obligation of confidentiality (e.g., employees and consultants of BePrivacy);
User’s information may be communicated to Third parties for the following reasons:
to fulfill the obligation provided by the law, regulations, protocols and national and EU legislation;
to implement laws required by Public Authorities;
to allow BePrivacy’s defense in court, for example, in case of violations by the web-users.
The mentioned parties shall process the information in their quality of indipendent Data Controllers.
In particular, Company use MailChimp service to manage newsletter, owned by The Rocket Science Group, LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, Georgia 30308, and, therefore, data subjects may be transferred and disclosed to these company, which, participating in Privacy Shield Network, guarantee adeguacy level regarding personal data processed.
More details about this service are available at the following link: https://mailchimp.com/legal/terms/, https://mailchimp.com/legal/privacy/ e https://www.privacyshield.gov/welcome.
BePrivacy will inform you that, according to art. 7 of Code and to artt. 15 and following of GDPR, you have specific rights towards to BePrivacy. In particular, you could:
obtain the confirmation about the existence of personal data and access to it, even if they are not registered yet, and ask to know the source of data, the purposes, the data retention and modalities of the processing, as well as the the logic involved in the event of automated decision-making;
withdraw their consent on processing of personal data, without prejudice of lawfulness of processing before their withdrawal;
receive in a structured, commonly used and machine-readable format the Personal Data concerning you, and, unless it is not technically feasible, to transmit those data to another Controller without hindrance;
obtain erasure, anonymization or block of the information being processed as soon as they are no longer necessary for above-mentioned purpose;
obtain an update, rectification or integration of data processed;
object, fully or partially, to relevant processing activity for carrying out commercial communications described, or for legitimate reasons on the processing data concerning them;
lodge a complaint with the relevant Supervisory Authority.
The exercise of these rights should be without prejudice to the rights and freedoms of other data subjects.
You could exercise your rights writing to Data Controller address, or contacting it at the following e-mail address: firstname.lastname@example.org.
It is inteded that, where the data subject makes the request by electronic form means, the information shall be provided free of charge and in a commonly used electronic form.
In the event of requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, BePrivacy may either: charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or refuse to act on the request. In both circumstances, the Company shall bear the burden of demonstrating the manifestly unfounded or excessive character of the request.
BePrivacy therefore invites you to visit this section of the Website regularly in order to be aware of the most recent and updated version of the Policy, so that you are always updated on the processing activities that BePrivacy carries out.
BePrivacy will inform you on such amendments and relevant updates through their publication on the Website as soon as they are adopted.