The information is provided pursuant to Art. 13 of EU Regulation no. 2016/679 (hereinafter “GDPR”) and Art. 13 of Dlgs. 196/2003 as novated by Legislative Decree 101/2018, to all those who interact with Isapiens S.r.l. by browsing the website www.alivelearning.it by sending an email to email@example.com
We inform you that the processing of the data you provide will be carried out using methods and procedures aimed at ensuring respect for the fundamental rights and freedoms, dignity of the person concerned, with particular reference to confidentiality, security, personal identity and the right to protection of personal data and will be carried out according to rules of lawfulness, correctness, relevance and non excess, prescribed by Reg. EU 679/16.
1) Data Controller and Data Protection Officer.
The data controller is ISAPIENS S.R.L. – Via Dei Pellegrini 22 20122 Milan – email: firstname.lastname@example.org
Isapiens S.r.l. has formally appointed its Dpo (Data Protection Officer) in the person of Dr. Francesca Portella who can be contacted at the email address email@example.com
2) Object of treatment
The data processed by a refer to:
- Automatically collected data. Site Usage Information.
Your use of our sites involves processing data about the browser and device you are using and your IP address (this is the number that identifies a specific device on the Internet and is necessary for your device to communicate with the sites). We will be able to analyze which site you came from, what you accomplished and did not accomplish on our site. The computer systems and applications dedicated to the operation of this website detect, in the course of their normal operation, certain data (the transmission of which is implicit in the use of Internet communication protocols) potentially associated with identifiable users. The data collected include the IP addresses and domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) notation addresses of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters regarding the operating system, browser and computer environment used by the user. This data is processed, for the time strictly necessary, for the sole purpose of obtaining statistical information on the use of the site and to check its regular operation. The provision of such data is mandatory as it is directly related to the web browsing experience.The following information may be collected during Users’ browsing and stored in the log files of the site’s server (hosting):
- internet protocol (IP) address;
- browser type;
- Parameters of the device used to connect to the site;
- Internet service provider (ISP) name;
- Date and time of visit;
- Visitor’s source (referral) and exit web pages;
- possibly the number of clicks.
- Data voluntarily provided by the user. Data that you may voluntarily provide (such as your e-mail address, your first and last name, contact information, etc.), by sending an e-mail to the e-mail address on the site or by contacting the telephone numbers on the site will be processed (by way of example, for example, you may provide some of your data by forwarding to the above address or to the telephone contacts listed on the site, a request for information or a request for a quote).
By conferring your data you give your consent to its processing for the purposes indicated (e.g., to be contacted again to fulfill the request you have promoted).
3) Legal basis for processing
The legal basis for such processing is:
- establishment of the pre-contractual relationship as a consequence of the processing of your request(ex art. 6.1(b) of the GDPR);
- In fulfilling obligations under the law (ex Art. 6.1(c) of the GDPR);
- In the legitimate interest of the owner (ex Art. 6.1(f) of the GDPR).
4) For what purposes we use your personal data.
Personal data will be collected and processed without the need for your explicit consent:
– for purposes strictly related and instrumental to the fulfillment of the obligations inherent in the relationship with our company: for example, to finalize a contract in case it has accepted a quote requested and transmitted by email to the email address given on the site;
– possibly for fulfillments and obligations provided for by laws, regulations and EU standards or by provisions issued by authorities empowered to do so by law and by supervisory bodies;
– to protect the security of the website and users, to unmask and prevent fraud and/or abuse of the website;
– To enable you to navigate the website by collecting cookies of a technical nature;
– For the legitimate interest of the Data Controller, in case it wants to exercise a legitimate right in court;
– to respond to your inquiries sent via e-mail to the address listed on the website;
– for information request by entering their data in the dedicated form.
5) How long we keep your personal data.
The Personal Data collected to process any requests you may have promoted by email will be retained until such time as is necessary and instrumental to the purpose, however, not more than 10 years.
The Data Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation, regulation or EU legislation or to comply with an order from an authority, or for its own legitimate interest in order to protect its own right, including in court.
At the end of the retention period, the Personal Data will be deleted. Therefore, upon the expiration of this period, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.
6) The security of your personal data
Data will be processed using appropriate means to ensure their confidentiality, integrity and availability. The processing shall be carried out on paper and by means of computer and/or automated systems and shall include all the operations or complex of operations provided for in Art. 4 of the GDPR and necessary for the processing in question, including communication to the persons in charge of the processing itself. This data will not be disseminated.
7) Who can access your personal data
Only authorized persons within the scope of the tasks assigned by the Owner may access your data.
For the purposes indicated, the data will or may be communicated to third parties operating within the scope of the purposes described above, in the capacity of external data processors, appropriately appointed; the data may also be accessible or may be communicated to parties whose right to access your personal data is recognized by provisions of the law or secondary or EU regulations.
8) Where your personal information resides.
The management and storage of your personal data may be as follows:
– the data voluntarily provided by email to firstname.lastname@example.org, will be kept for as long as necessary to process your request, duly stored in special archives to which unauthorized persons are barred from access and/or on servers owned by the Owner allocated on the premises.
– For automatically collected browsing data, see email@example.com
The list of data controllers and data processors can be consulted at the owner’s office.
9) Is it mandatory to consent to the provision of your data?
Transmission of browsing data is necessary to continue browsing this site.
Providing data by email is voluntary, so it is optional.
The Holder does not require any other data.
10) What are your rights in relation to the GDPR?
According to the provisions of the GDPR, the Holder guarantees the following rights:
- Obtain confirmation as to whether or not personal data concerning you are being processed and if so, obtain access to the personal data (Right of Access Art. 15);
- Obtain rectification of inaccurate personal data concerning you without undue delay (Right to Rectification Art. 16);
- obtain the deletion of personal data about you without undue delay, the Data Controller has an obligation to delete your personal data without undue delay if certain conditions are met (Right to be Forgotten Art. 17);
- Obtain limitation of processing in certain cases (Right to limitation of processing Art. 18);
- To receive in a structured, commonly used and machine-readable format the personal data you have provided to us and to be able to transmit them, if necessary, to another Data Controller (Right to Data Portability Art. 20);
- object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning you (Right to object art 21);
- Receive without undue delay notice of the personal data breach suffered by the Data Controller and/or Managers if said breach poses a threat to the rights and freedoms of the data subject (Art. 34);
- Revoke express consent at any time (Conditions for Consent Art. 7).
11) Methods of exercising rights
To exercise any of the rights indicated in point 10) you can send a registered letter with return receipt to the data controller: Isapiens S.r.l. – Via Dei Pellegrini 22 20122 Milan, Italy, or you can send an e-mailto: firstname.lastname@example.org
In addition, if you feel that we have not respected your data protection rights, you can appeal to the Data Protection Authority. Alternatively, if you reside in another country, you can contact your local Data Protection Authority.
13) Update of this disclosure
This Notice is subject to change. Any substantial changes will be communicated to you by email or through our website.
DPO (Data Protection Officer)
Dr. Francesca Portella
Tel. 349 72 40 360