PRIVACY POLICY IN ACCORDANCE WITH ARTICLE 13 OF EU REGULATION 2016/679

With respect to data processed through the website https://coccolatevi.it/

 

For us, data protection is a very serious matter so we would like to inform you about the way in which data is processed and the rights you can exercise under current data protection legislation, in particular EU Regulation 2016/679 (hereinafter also: “GDPR”).

 

For further processing activities not made explicit in this policy, carried out through Euthalia's other platforms and websites, please refer to the corresponding privacy policies made available by the Owner.

 

1. Data controller

 

Euthalia Ltd.
Registered Office:

Ignazio Ciampi Street No. 18,
00162 - Rome (RM)
E-mail contact: privacy@euthalia.it

                                                                                                                           

2. The categories of data that are processed

The categories of “personal data” (ex. Art. 4.1 of the GDPR) processed by the Controller may include, but are certainly not limited to:

• Personal and identifying data (such as, for example, first name, last name, etc.);
• Contact data (such as, for example, e-mail address, phone number, IP address, etc.):
• Data related to the role played in the Company or Entity for which the data subject is a contact person (e.g., if it is mentioned in the contact request made);
• Personal data related to any services provided (such as, for example, as part of the processing of the request made through the form in the “CONTACT US” section).

 

3. Purposes covered by the data subject's consent (ex Art. 6(1)(a) GDPR)

The purposes requiring consent are:

1. Respond to requests or questions submitted and sent to the contacts listed on this site, to receive information about our products and services, as well as about Euthalia's activities in the broadest sense.

 

The period of preservation Of personal data, relative to the purposes set forth in this section is:

For the purpose: a, until the processing of the request, unless the feedback provided and the information exchanged, are necessary to demonstrate the fulfillment of any contractual obligations or arising from any legal relationships established (in which case the retention period will be equal to that indicated in the appropriate notices, issued within the framework of the aforementioned relationships).

 

4. Recipients or categories of recipients of personal data (ex Article 13 paragraph 1 (e) of the GDPR) *.

As part of the above purposes, the Data Controller may communicate your data to:

• Holder's own internal offices and functions;
• Companies and professionals providing IT services, including electronic data processing, software management, site management, and IT consulting;
• Mailing and hosting provider companies.

 

The complete and updated list of the Recipients (ex Art. 4.9 of the GDPR) is available from the Data Controller at the contact details above.

 

5. Recipients or categories of recipients of personal data (ex art. 13 paragraph 1 (f) of the GDPR) * and transfer of data to countries outside the EU

The Data Controller informs you that within the scope of the above-mentioned purpose, it may transfer your data to countries outside the EU and the EEA, including through third parties appointed by it, acting as Data Processors, as well as through the latter's Sub-Processors. In such cases, the transfer will take place in accordance with the provisions of Articles 44 et seq. of the GDPR and applicable legal provisions by entering into agreements, if necessary, that guarantee an adequate level of protection. Therefore, whenever your personal data should be transferred outside the EEA and, in particular, to States that do not benefit from an adequacy decision of the European Commission **, the Controller will adopt one of the safeguards for this purpose provided by the applicable Legislation.

 

* The complete and updated list of Recipients (ex art. 4.9 of the GDPR) is available from the Data Controller at the above contact details.

 

** The updated list of suitable non-EEA countries deemed adequate by the European Commission can be obtained at the website: Adequacy decisions (europa.eu)

 

6. Rights of the data subject (ex Art. 13 paragraph 2 (b) of the GDPR)

The data subject, in relation to the personal data covered by this notice, is entitled to exercise his or her rights under the EU Regulation below:

• data subject's right of access [Art. 15 of the EU Regulation] (consisting of the possibility to be informed about the processing carried out on one's personal data and, if necessary, to receive a copy of it);
• Right to rectification of one's personal data [Art. 16 of the EU Regulation] (the data subject has the right to rectification of inaccurate personal data concerning him or her);
• Right to the deletion of one's personal data without undue delay (“right to be forgotten”) [Art. 17 of the EU Regulation] (the data subject has, as well as will have, the right to the deletion of his or her data);
• Right to restrict the processing of one's personal data in the cases provided for in Article 18 of the EU Regulation, including in the case of unlawful processing or contestation of the accuracy of personal data by the data subject [Article 18 of the EU Regulation];
• right to data portability [Art. 20 of the EU Regulation], (the data subject may request in a structured format his or her personal data in order to transmit it to another Data Controller, in the cases provided for in the same article);
• Right to object to the processing of one's personal data [Art. 21 of the EU Regulation] (the data subject has, as well as will have, the right to object to the processing of one's personal data in the cases lent and regulated by Art. 21 of the EU Regulation);
• Right not to be subjected to automated decision-making [Art. 22 of the EU Regulation] (the data subject has, as will have, the right not to be subjected to a decision based solely on automated processing).

 

With respect to the purposes, for which consent is required, the Data Subject may revoke his or her consent at any time and the effects will run from the time of revocation, subject to the time limits prescribed by law. In general terms, revocation of consent has effect only for the future.

The above rights can be exercised in accordance with the Regulations by sending, also, an e-mail to privacy@euthalia.it.

Euthalia S.r.l. in compliance with Art. 19 of the EU Regulation proceeds to inform the recipients to whom the personal data have been disclosed, of any rectification, erasure or restriction of processing required, where possible.

 

7. Right to file a complaint (ex Art. 13 paragraph 2 (d) of the GDPR)

If the person concerned feels that his or her rights have been compromised, he or she has the right to lodge a complaint with the Supervisory Authority.

For more information on rights and their exercise, see http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524 or by sending written notice to the Data Protection Authority.

 

8. Possible consequence of non-disclosure of data and nature of provision of data (ex Article 13 paragraph 2 (e) of the GDPR)

8.1 In case of consent of the person concerned.

For the purposes for which consent is required, the Data Subject may revoke his or her consent at any time and the effects will run from the time of revocation, subject to the time limits provided by law. In general terms, revocation of consent has effect only for the future. Therefore, processing that was carried out prior to the revocation of consent will not be affected and will retain its legitimacy.

The failure or partial consent (or revocation of the same) may not guarantee the full delivery of services or activities, with reference to the individual purposes for which consent is withheld.

 

It should be noted that with reference to the request for information, while consent to the processing of personal data remains free and optional, it is necessary for the processing of the request. Therefore, sending the request or equivalent manifestation of will will be considered as giving consent, which will always be revocable with the consequences explained above.

 

When data are no longer needed these are routinely deleted, if deletion is impossible or possible only with disproportionate effort due to a particular storage mode the data cannot be processed and must be stored in inaccessible areas.

 

9. Existence of automated decision making (including profiling)

The use of purely automated decision-making processes as detailed in Article 22 of the GDPR is currently excluded. Should it be decided in the future to establish such processes for individual cases, the data subject will be notified separately if this is required by law or updated in this policy.

 

10. Method of treatment

Personal data will be processed in computerized and telematic form and included in the relevant databases that can be accessed, and therefore become aware of, the employees expressly designated by the Owner as Data Processors and Authorized Persons in charge of the processing of personal data, who may carry out consultation operations, use, processing, comparison and any other appropriate operation also automated in compliance with the provisions of the law necessary to ensure, among other things, the confidentiality and security of the data as well as the accuracy, updating and relevance of the data to the stated purposes.

 

Processing of data useful for navigation purposes

The computer systems and software procedures used to operate this website acquire, in the course of their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified.

Among the information that may be collected we have IP addresses, the type of browser or operating system used, addresses in URI (uniform resource identifier) notation, the domain name and addresses of the Web sites from which the access or exit was made (referring/exit pages), the time the request was made to the server, the method used and information about the response obtained, additional information about the user's navigation on the site (see also the section on cookies), and other parameters related to the user's operating system and computer environment.

These same data could, also be used to identify and ascertain responsibility in case of any computer crimes against the site.

 

Notice regarding children under the age of 14

Minors under the age of 14 may not provide personal data. Euthalia S.r.l. will not be in any way responsible for any collection of personal data, as well as misrepresentations, provided by the minor, and in any case, should it be found to be used, Euthalia S.r.l. will facilitate the right of access and cancellation forwarded by the legal guardian or those exercising parental responsibility.

 

Changes and updates

This notice shows the date of its last update in its header.

Euthalia S.r.l. may also make changes and/or additions to said privacy policy as a consequence of any and all subsequent regulatory changes and/or additions.

 

Regulatory references on the rights of the data subject

Article 15

Data subject's right of access

1. The data subject has the right to obtain confirmation from the data controller as to whether or not personal data concerning him or her are being processed and, if so, to obtain access to the personal data and the following information:
2. (a) the purposes of processing;
3. (b) the categories of personal data in question;
4. (c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, particularly if recipients in third countries or international organizations;
5. (d) when possible, the expected period of retention of personal data or, if this is not possible, the criteria used to determine this period;
6. (e) the existence of the data subject's right to request from the data controller the rectification or erasure of personal data or the restriction of the processing of personal data concerning him or her or to object to their processing;
7. (f) the right to file a complaint with a supervisory authority;
8. (g) if the data are not collected from the data subject, all available information on their origin;
9. (h) the existence of an automated decision-making process, including profiling as referred to in Article 22(1) and (4), and, at least in such cases, meaningful information about the logic used, as well as the importance and expected consequences of such processing for the data subject.
10. Where personal data are transferred to a third country or international organization, the data subject has the right to be informed of the existence of appropriate safeguards under Article 46 relating to the transfer.
11. The data controller shall provide a copy of the personal data being processed. ln the case of further copies requested by the data subject, the data controller may charge a reasonable fee based on administrative costs. If the data subject makes the request by electronic means, and unless otherwise specified by the data subject, the information shall be provided in a commonly used electronic format.
12. The right to obtain a copy referred to in paragraph 3 shall not infringe on the rights and freedoms of others.

 

Article 16

Right of rectification

The data subject has the right to obtain from the data controller the rectification of inaccurate personal data concerning him/her without undue delay. Taking into account the purposes of the processing, the data subject has the right to obtain the integration of incomplete personal data, including by providing a supplementary declaration.

 

Article 17

Right to erasure («right to be forgotten»)

1. The data subject has the right to obtain from the data controller the deletion of personal data that he or she

concern them without undue delay, and the data controller is obliged to erase the personal data without undue delay if one of the following grounds exists:

1. (a) personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
2. (b) the data subject withdraws the consent on which the processing is based in accordance with Article 6(1)(a) or Article 9(2)(a) and if there is no other legal basis for the processing;
3. (c) the data subject objects to processing under Article 21(1) and there is no overriding legitimate reason for processing, or objects to processing under Article 21(2);
4. (d) personal data have been processed unlawfully;
5. (e) personal data must be erased in order to comply with a legal obligation under Union or Member State law to which the data controller is subject;
6. (f) personal data have been collected in connection with the provision of information society services referred to in Article 8(1).
7. Where a data controller has made personal data public and is obliged under paragraph 1 to erase it, taking into account available technology and the costs of implementation it shall take reasonable measures, including technical measures, to inform data controllers who are processing personal data of the data subject's request to erase any link, copy or reproduction of his or her personal data.
8. Paragraphs 1 and 2 do not apply to the extent that the treatment is necessary:
9. (a) for the exercise of the right to freedom of expression and information;
10. (b) for the performance of a legal obligation requiring the processing provided for by Union or Member State law to which the data controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller;
11. (c) for reasons of public interest in the field of public health in accordance with Article 9 (2) (h) and (i) and Article 9 (3);
12. (d) for the purposes of archiving in the public interest, scientific or historical research, or for statistical purposes in accordance with Article 89(1), insofar as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of such processing; or
13. (e) for the establishment, exercise or defense of a right in court.

 

Article 18

Right to limitation of treatment

1. The data subject has the right to obtain from the data controller the restriction of processing when one of the following cases occurs:
2. (a) the data subject disputes the accuracy of personal data, for the period necessary for the data controller to verify the accuracy of such personal data;
3. (b) the processing is unlawful and the data subject objects to the deletion of personal data and instead requests that their use be restricted;
4. (c) although the data controller no longer needs them for the purposes of processing, the personal data are necessary for the data subject to establish, exercise or defend a right in court;
5. (d) the data subject has objected to the processing pursuant to Article 21(1), pending verification as to whether the legitimate grounds of the data controller outweigh those of the data subject.
6. Where processing is restricted pursuant to paragraph 1, such personal data shall be processed, except for storage, only with the consent of the data subject or for the establishment, exercise or defense of a right in court or for the protection of the rights of another natural or legal person or for reasons of substantial public interest of the Union or a Member State.
7. The data subject who has obtained the restriction of processing under paragraph 1 and informed by the data controller before such restriction is lifted.

 

Article 19

Obligation to notify in case of rectification or erasure of personal data or restriction of processing

The controller shall notify each of the recipients to whom the personal data have been transmitted of any rectification or erasure or restriction of processing carried out pursuant to Article 16, Article 17(1) and Article 18, unless this proves impossible or involves a disproportionate effort. The controller shall notify the data subject of such recipients if the data subject so requests.

 

Article 20

Right to data portability

1. The data subject shall have the right to receive in a structured, commonly used and machine-readable format personal data concerning him or her that have been provided to a data controller and shall have the right to transmit such data to another data controller without hindrance by the data controller to whom he or she has provided them if:
2. (a) the processing is based on consent under Article 6(1)(a) or Article 9(2)(a) or a contract under Article 6(1)(b): and
3. (b) the processing is carried out by automated means.
4. When exercising his or her rights regarding data portability under paragraph 1, the data subject has the right to obtain direct transmission of personal data from one data controller to another, if technically feasible.
5. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17, This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in connection with the exercise of official authority vested in the data controller.
6. The right referred to in paragraph 1 must not infringe on the rights and freedoms of others.

 

Article 21

Right of opposition

1. The data subject shall have the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her pursuant to Article 6(1)(e) or (f), including profiling on the basis of these provisions, The data controller shall refrain from further processing the personal data unless he or she demonstrates compelling legitimate grounds for processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
2. Where personal data are processed for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data concerning him or her carried out for such purposes, including profiling insofar as it relates to such direct marketing.
3. If the data subject objects to processing for direct marketing purposes, personal data are no longer processed for such purposes.
4. The right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information at the latest at the time of the first communication with the data subject.
5. In the context of the use of information society services and subject to Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using specific techniques.
6. Where personal data are processed for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1), the data subject shall have the right, on grounds relating to his or her particular situation, to object to the processing of personal data concerning him or her, except where the processing is necessary for the performance of a task carried out in the public interest.

 

Article 22

Automated decision-making related to natural persons, including profitability

1. The data subject has the right not to be subjected to a decision based solely on automated processing, including profiling, that produces legal effects concerning him or her or that significantly affects him or her in a similar way.
2. Paragraph 1 does not apply in case the decision:
3. (a) is necessary for the conclusion or performance of a contract between the data subject and a data controller;
4. (b) is authorized by the law of the Union or the Member State to which the data controller is subject, which also specifies appropriate measures to protect the rights, freedoms and legitimate interests of the data subject;
5. (c) is based on the explicit consent of the data subject.

3, In the cases referred to in paragraph 2 (a) and (c), the data controller shall implement appropriate measures to protect the rights, freedoms and legitimate interests of the data subject, at least the right to obtain human intervention by the data controller, to express his or her opinion and to challenge the decision.

4. Decisions under paragraph 2 shall not be based on the special categories of personal data referred to in Article 9(1) unless Article 9(2)(a) or (g) applies and appropriate measures are in place to protect the rights, freedoms and legitimate interests of the data subject.