This Application collects some Personal Data from its Users.
Elshine Srl, Via Francesco Aquilanti 33, 00166 Rome
Owner email address: email@example.com
Types of Data Collected
Among the Personal Data collected by this Application, either independently or through third parties, there are: name; surname; telephone number; business name; profession; nation; e-mail; POSTAL CODE; business sector; website; Cookie; Usage data.
The Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.
Unless otherwise specified, all the Data required by this Application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation.
Users who have doubts about which data are mandatory, are encouraged to contact the owner.
The User assumes the responsibility of the Personal Data of third parties obtained, published or shared through this Application and guarantees to have the right to communicate or disseminate them, freeing the Owner from any responsibility towards third parties.
Mode and place of processing of the collected Data
The Data Controller uses appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
Processing is carried out using IT and / or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Owner, in some cases, other parties involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external parties (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Owner. The updated list of Data Processors may always be requested from the Data Controller.
Legal basis of the processing
The Owner processes Personal Data relating to the User if one of the following conditions exists:
• the User has given consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorized to process Personal Data without the User’s consent or another legal basis specified below, as long as the User does not object (“opt-out“) to such treatment. However, this is not applicable if the processing of Personal Data is regulated by European legislation on the protection of Personal Data;
• the processing is necessary for the execution of a contract with the User and / or the execution of pre-contractual measures;
• processing is necessary to fulfill a legal obligation to which the Owner is subject;
• processing is necessary for the performance of a task of public interest or for the exercise of public powers vested in the Data Controller;
• processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.
It is in any case always possible to ask the Owner to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.
The Data are processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, contact the owner.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of treatment, the User can refer to the section on the details on the processing of Personal Data.
The User has the right to obtain information regarding the legal basis of the transfer of Data outside the European Union or to an international organization of public international law or constituted by two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.
The User can verify if one of the transfers described above takes place by examining the section of this document concerning the details on the processing of Personal Data or request information from the Data Controller by contacting him at the details indicated at the beginning.
Period of conservation
The Data is processed and stored for the time required for the purposes for which it was collected.
• The Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
• The Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information on the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.
When the treatment is based on the consent of the User, the Owner may keep the Personal Data for longer until such consent is revoked. Furthermore, the Data Controller may be obliged to keep the Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period the Personal Data will be deleted. Therefore, upon expiration of this term the right of access, cancellation, rectification and the right to the portability of the Data can no longer be exercised.
Purposes of the processing of the collected data
The User Data is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User, Analytics, Displaying content from external platforms and Interaction with external social networks and platforms.
To obtain further detailed information on the purposes of the processing and on the Personal Data that are concretely relevant for each purpose, the User may refer to the relevant sections of this document.
Details on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Contact the user
Interaction with external social networks and platforms
• Display of content from external platforms
Users can exercise certain rights with reference to the Data processed by the Owner.
In particular, the User has the right to:
• withdraw consent at any time. The User can revoke the consent to the processing of his Personal Data previously expressed.
• object to the processing of your data. You may object to the processing of your data when it takes place on a legal basis other than consent. Further details on the opposition right are indicated in the section below.
• access their own data. The user has the right to obtain information on the data processed by the owner, on certain aspects of the processing and to receive a copy of the data processed.
• check and ask for rectification. The User can verify the correctness of his / her Data and request its updating or correction.
• obtain the treatment limitation. When certain conditions are met, the User can request the limitation of the processing of his / her Data. In this case, the Owner will not process the Data for any other purpose than their storage.
• obtain the cancellation or removal of your Personal Data. When certain conditions are met, the User can request the deletion of their Data by the Owner.
• receive your data or have it transferred to another owner. The User has the right to receive his / her Data in structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain its transfer without obstacles to another holder. This provision is applicable when the Data is processed by automated tools and the processing is based on the consent of the User, on a contract to which the User is a party or on contractual measures connected to it.
• make a complaint. The User can make a complaint to the competent personal data protection supervisory authority or act in court.
Details on the right to object
When Personal Data is processed in the public interest, in the exercise of public authority over which the Data Controller is invested or to pursue a legitimate interest of the Data Controller, Users have the right to oppose the processing for reasons connected to their particular situation.
Users are reminded that, if their Data is processed for direct marketing purposes, they may oppose the processing without giving any reason. To find out if the Data Controller is processing data for direct marketing purposes, Users can refer to the respective sections of this document.
How to exercise rights
To exercise User rights, Users can address a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within one month.
Further information on treatment
Defense in court
The User’s Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of this Application or of the connected Services by the User.
The User declares to be aware that the Owner may be required to disclose the Data by order of the public authorities.
System log and maintenance
For needs related to operation and maintenance, this Application and any third party services it uses may collect system logs, that is files that record the interactions and that may also contain Personal Data, such as the User IP address.
Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.
Response to “Do Not Track“ requests
This application does not support “Do Not Track“ requests.
To find out if any third-party services used support them, the User is invited to consult the respective privacy policies.
If the changes involve processing whose legal basis is consent, the Owner will collect the User consent again, if necessary.
Definitions and legal references
Personal Data (or Data)
Personal information is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes an individual identified or identifiable.
The information collected automatically through this Application (also from third-party applications integrated in this Application), including: the IP addresses or domain names of the computers used by the User that connects with this Application, the addresses in URI notation ( Uniform Resource Identifier), the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response from the server (success, error, etc.) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to to the sequence of the pages consulted, to the parameters relating to the operating system and the IT environment of the UIT you.
The individual who uses this Application which, unless otherwise specified, coincides with the interested party.
The natural person to whom the Personal Data refers.
Data Processor (or Manager)
Data Controller (or Owner)
The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of processing personal data and the instruments adopted, including security measures relating to the functioning and the use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.
The hardware or software tool through which Users’ Personal Data are collected and processed.
The Service provided by this Application as defined in the relevant terms (if any) on this site / application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.
Small portion of data stored in the User’s device.
This privacy statement is drafted on the basis of multiple legislative orders, including articles 13 and 14 of Regulation (EU) 2016/679.