Privacy and Cookie policy

PRIVACY POLICY

of 18/05/2018

pursuant to art. 13 of the EU General Data Protection Regulation 679/2016 hereinafter referred to as GDPR.

This Policy is general and concerns all the processing included in the web application or mobile device application (hereinafter ‘Application’): please, refer to the specific policies of each processing with the related consent request where needed.

Infoteam Srl registered office in Pescara(PE), Viale Pindaro,14, VAT number: 01538680685, as the Controller, informs you, under the EU General Data Protection Regulation n. 2016/679 (hereinafter, “GDPR”), that your data will be processed in accordance with the procedures and for the following purposes according to the definitions listed below:

  1. Processing: means any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  2. Personal Data: means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
  3. Controller: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;
  4. Data subject: the User, natural person, who uses the application
  5. Application: hardware or software tool used to collect the User Personal Data, namely a website, an application for mobile devices or a web based software.
  6. Form: it is a word used to identify the interface of an application enabling the client User to enter and send to the web server one or more data freely typed by him/her. It’s more commonly known as "form to be completed" in order to enter data.
1. IDENTITY OF THE CONTROLLER AND OF THE LEGAL REPRESENTATIVE PRO-TEMPORE (under art. 13, par. 1 lett. a)

Controller: Infoteam Srl nthrough its legal representative Mr Massimo Di Remigio, tel. 085 4516370, registered office: Pescara(PE),Viale Pindaro,14, mail: go@goinfoteam.it, PEC amministrazione@pec.goinfoteam.it.

2. DATA PROTECTION OFFICER (UNDER art. 13, par. 1 lett. b) WHERE APPLICABLE

Data Protection Officer (DPO): Email: dpo@goinfoteam.it.

3. PROCESSING

  • PURPOSE: Contacting the user
    The application includes specific forms that, once filled in with the contact details, allow the user to be contacted by the Controller in order to receive information.
    Personal data collected: contact data and IP address.
    Nature of the provision of data and consequences of failure to provide such data under art. 13 par. 2 lett. e): the provision of data for this purpose is mandatory. The failure to provide the required data shall not allow the service to be provided.
    Consent: for the implementation of this purpose no explicit consent is required, which shall be considered to be given by entering the contact data.
    Period for which the personal data will be stored under Art. 13, par. 2 lett. a): the data are processed for the time necessary to provide the service requested by the user or required by the purposes described in this document and in any case no later than 12 months from collection.
    Legal basis for the processing: the processing is necessary under Art.6 par.1 lett. b) of the EU General Data Protection Regulation 679/2016 (GDPR).
    Processing recipients: authorized staff of the company commercial area, company staff in charge of the application management and of the communication with the users via email.

  • PURPOSE: Marketing activity
    By subscribing our mailing list or newsletter, the email address, the telephone number or the address of the User are automatically added to a list of contacts to which send emails, SMS (Short Message Service), telephone calls or printed materials - including commercial and promotional information - can be sent.
    Personal data collected: contact data and IP address.
    Nature of the provision of data and consequences of failure to provide such data under art. 13 par. 2 lett. e): the provision of data for this purpose is optional and it does not affect the fulfillment of your requests and the performance of the contracts, but it will preclude the transmission of marketing communications by the Controller.
    Consent: for the implementation of this purpose an explicit consent is required, which is given by filling in a specific form in the application.
    Period for which the personal data will be stored under art. 13, par. 2 lett. a): the data are processed for the time necessary to provide the service requested by the user or required by the purposes described in this document and in any case no later than 12 months from collection.
    Legal basis for the processing: EU General Data Protection Regulation 679/2016.
    Processing recipients: Company staff in charge of the application management, of the marketing systems and the staff in charge of the customer service. The updated list of the abovementioned recipients is available at the Controller office and may be requested sending an email to the following address: go@goinfoteam.it or by registered letter to: Viale Pindaro,14, Pescara (PE).

  • PURPOSE: Assessment and solution of technical problems as required by the User
    Submitting a support ticket or using an online chat the User transmits some personal data in order to be contacted to report a technical problem in a product or service of the Controller.
    Personal data collected: contact data and IP address.
    Nature of the provision of data and consequences of failure to provide such data under art. 13 par. 2 lett. e): the provision of data for this purpose is mandatory. The failure to provide the required data shall not allow the service to be provided.
    Consent: for the implementation of this purpose an expressed consent is not required; it shall be considered to be given by filling in a specific form in the application.
    Period for which the personal data will be stored under art. 13, par. 2 lett. a): the data are processed for the time necessary to provide the service requested by the User or required by the purposes described in this document and in any case no later than 10 years.
    Legal basis for the processing: EU General Data Protection Regulation 679/2016.
    Processing recipients: company staff in charge of the application management and of the communication with the Users via ticket or email. The updated list of the company areas authorized to the processing is available at the Controller office and may be requested sending an email to the following address:go@goinfoteam.it or by registered letter to: Viale Pindaro,14, Pescara (PE).

  • PURPOSE: System and maintenance logs
    For needs related to its functioning and maintenance, this application and any third-party services may collect system logs.
    Personal data collected: files that record the operations carried out and that may also contain personal data, IP address.
    Nature of the provision of data and consequences of failure to provide such data under art. 13 par. 2 lett. e): the provision of data for this purpose is mandatory. The failure to provide the required data shall not allow the service to be provided.
    Consent: for the implementation of this purpose no explicit consent is required; it shall be considered to be given by entering the contact data.
    Period for which the personal data will be stored under art. 13, par. 2 lett. a):
    the data are processed for the time necessary to provide the service requested by the User or required by the purposes described in this document and in any case no later than 6 months.
    Legal basis for the processing: consent under art.6 par.1 lett. a) of the EU General Data Protection Regulation 679/2016 (GDPR).
    Processing recipients: company staff in charge of the management and maintenance of the application. The updated list of the abovementioned recipients is available at the Controller office and may be requested sending an email to the following address:go@goinfoteam.it or by registered letter to: Viale Pindaro,14, Pescara (PE).

  • PURPOSE: Interactions with social networks and external platforms
    It is possible to interact with the Controller using a chat available Cisco Webex Teams. These services allow the User to interact with the social networks or other external platforms directly from the pages of this application. The interactions and the information acquired by this Application shall in any event be under the User’s privacy settings concerning each social network. If an interaction service with the social networks is installed, it is possible that it collects traffic data related to the pages in which it is installed even if the Users do not use the service. Personal data collected: cookies, usage data and IP address.
    Nature of the provision of data and consequences of failure to provide such data under art. 13 par. 2 lett. e): the provision of data for this purpose is mandatory. The failure to provide the required data shall not allow the service to be provided.
    Consent: for the implementation of this purpose an explicit consent is required, which is given by filling in a specific form in the application.
    Period for which the personal data will be stored under art. 13, par. 2 lett. a): the data are processed for the time necessary to provide the service requested by the User or required by the purposes described in this document and in any case no later than 6 months from collection.
    Legal basis for the processing: consent under art.6 par.1 lett. a) of the EU General Data Protection Regulation 679/2016 (GDPR).
    Processing recipients: Cisco Webex Teams (also known as Cisco Spark) is a service of interaction with this application provided by Cisco Systems, Inc, based in USA. The list of the recipients is available at the Controller office and may be requested sending an email to the following address:go@goinfoteam.it o via raccomandata a/r presso Viale Pindaro,14, Pescara (PE).

  • PURPOSE: Statistics and marketing
    The services in this section allow the Controller to monitor and analyse the traffic data and to track the User’s behavior in order to send commercial communications about products and services, to carry out direct marketing activities using the analysis results or profiling. This makes it possible to process, in a partially or totally automated way, the personal data and the consumption habits in order to propose offers that meet the User’s personal needs.
    Personal data collected: contact data, usage data, User preferences and IP address.
    Nature of the provision of data and consequences of failure to provide such data under art. 13 par. 2 lett. e): the provision of data for this purpose is optional and it does not affect the fulfillment of your requests, the performance of the contracts or other services provided by the Controller.
    Consent: for the implementation of this purpose an explicit consent is required, which is given by filling in a specific form in the application.
    Period for which the personal data will be stored under art. 13, par. 2 lett. a): the data are processed for the time necessary to provide the service requested by the User or required by the purposes described in this document and in any case no later than 14 months from collection.
    Legal basis for the processing: consent under art.6 par.1 lett. a) of the EU General Data Protection Regulation 679/2016 (GDPR).
    Processing recipients: company staff in charge of the application management and of the management of direct marketing campaigns and promotional activities. Third-party companies of data analysis. The list of the recipients is available at the Controller office and may be requested sending an email to the following address: go@goinfoteam.it or by registered letter to: Viale Pindaro,14, Pescara (PE).

    • 4. COLLECTED DATA PROCESSING METHODS

    The processing is performed through IT and/or telematic tools with methods of organization and rationale strictly connected to the specified purposes.

    5. WITHDRAWAL OF CONSENT

    You have the right to withdraw any previously expressed consent at any time and the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal in accordance with art. 7 par. 3 of the EU Regulation 679/2016.

    6. EXERCISE OF THE RIGHTS OF THE DATA SUBJECT

    With regard to the processing described in this Policy, as a data subject you may exercise, under the terms of the GDPR, the rights laid down in articles from 15 to 21 of the GDPR and, in particular, the following rights:

    • Right of access – article 15 of the GDPR: the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and have a copy of them.
    • Right of rectification – article 16 of the GDPR: the right to obtain without undue delay the rectification of inaccurate personal data concerning you and to have incomplete personal data completed.
    • Right to erasure ('right to be forgotten') – article 17 of the GDPR: the right to obtain the erasure of personal data concerning you without undue delay.
    • Right of restriction of processing – article 18 of the GDPR: the right to obtain restriction of processing where:

      1. the accuracy of the personal data is contested by the data subject, for a period enabling the Controller to verify the accuracy of the personal data;
      2. the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
      3. the personal data are required by the data subject for the establishment, exercise or defence of legal claims;
      4. the data subject has objected to processing pursuant to Article 21 of the GDPR pending the verification whether the legitimate grounds of the Controller override those of the data subject.

    • Right to data portability – article 20 of the GDPR: the right to receive the personal data concerning you, which you have provided to a Controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another Controller without hindrance where the processing is based on consent and is carried out by automated means. Furthermore, you shall have the right to have your personal data transmitted directly from one Controller to another, where technically feasible.
    • Right to object – article 21 of the GDPR: the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you based on the conditions governing the lawfulness of the legitimate interest or of the performance of a task carried out in the public interest or in the exercise of official authority, including profiling, unless there are legitimate grounds for the Controller to go on with the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. Moreover, the right to object at any time to processing of personal data concerning you where personal data are processed for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing.

    The rights referred to above may be exercised against the Controller through the aforesaid contact points.

    The exercise of your right, as the data subject, is free of charge pursuant to art. 12 of the GDR. Nevertheless, where requests are manifestly unfounded or excessive, in particular because of their repetitive character, the Controller may charge a reasonable fee taking into account the administrative costs of providing the information requested or refuse to act on the request.

    7. RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY (under art.13 par. 2 lett. d) and art. 77 of the GDPR)

    Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes the GDPR. The supervisory authority shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to art. 78 of the GDPR.

    8. MODALITIES FOR THE EXERCISE OF THE RIGHTS

    In order to exercise the abovementioned rights, the data subject shall send written communication through registered letter or registered email or email to the Controller referred to in art. 1 of this Policy.

    Notice is hereby given that, pursuant to art. 12 par. 5 of the GDPR, the information in this document and any communications and actions taken pursuant to art. from 15 to 22 and art. 34 of the GDPR, shall be provided free of charge. Where requests from a data subject are manifestly unfounded or excessive or repetitive, the controller may either a): charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested or b) refuse to act on the request. The Controller shall bear the burden of demonstrating the manifestly unfounded or excessive character of the request.

    9. LEGAL INFORMATION

    This Policy has been drawn up in fulfillment of the obligations under the EU Regulation n. 679/2016 and the legal basis of the processing consists in the consent under art. 6 par.1 lett.a) of this Regulation. This Privacy Policy concerns exclusively this Application.



    COOKIE POLICY

    pursuant to the decision n. 229/2014 of the Italian Data Protection Authority.

    Any use of cookies - or other tracking tools - by this Application or third party service providers used by this Application, unless otherwise specified, aims to identify the Users and save their preferences for purposes strictly linked to the provision of the service requested by the Users.

    This application uses cookies. In order to learn more and for a detailed account, you can read the following extended Cookie Policy.

    EXTENDED COOKIE INFORMATION NOTICE
    What are cookies?

    A cookie is a small data file which is sent by the web server to the user’s browser and stored by the browser on the user’s device (computer, tablet, smartphone, etc.). It can be read or retrieved later from the server itself. It allows the website to store some useful information inside a session or during the successive accesses performed by the user.

    Are cookies used in this Application?

    Yes. Cookies are used in order to improve the website and provide services and features to users. It is possible to restrict or disable the use of cookies through your web browser. Please note, however, that, in this case, you may not be able to use some of the features.

    Why are cookies used?

    Cookies can be used for different reasons. In some areas of the website cookies are essential and, for example, it would not be possible to browse properly without them. In some other areas they are a convenient way to get useful information in order to provide specific services; moreover, some external services (third party) may need the installation of dedicated cookies on the user’s browser in order to provide the related services.

    What kind of cookies are used in this application?
    • Technical cookies

      Technical cookies are those used exclusively with a view to “carrying out the transmission of a communication on an electronic communications network, or insofar as this is strictly necessary to the provider of an information society service that has been explicitly requested by the contracting party or user to provide the said service”. They are not used for further purposes and are usually installed directly by the Controller or the application manager. They can be grouped into:

    • browsing or session cookies

      which allow users to store data useful to the navigation and use of the website on the user’s pc (e.g. to remember the favourite size of the page in a list). Such cookies differ from each other with regard to the permanence on the user’s pc: the session cookies are deleted automatically at the end of each session. If, on the contrary, they persist for a longer period, they are called persistent cookies.

    • functional cookies

      These cookies allow the website to remember the choices that the users have made in order to optimize its features. For example, the functional cookies allow the application to remember the specific settings of a user, such as the Country or, if set, the permanent access.

    Third-party cookies

    Some features are implemented through third-party services, listed below.
    These services produce cookies connected to the services provided by third parties. The third party provides these services in exchange for information related to the visit of the user to our website. It follows, even for third-party providers of cookies, the obligation to comply with the legislation. For this reason, we refer to the links of the web pages of third-party websites, where the user can find the consent forms for cookies and the related disclosures. Should the services be provided by indirect contacts with the third parties, the user must refer to the websites of the subjects who act as intermediaries between us and the third parties:

    1. Google Analytics (Google)

      Google Analytics is a web analysis service provided by Google Inc. ("Google"). Google uses the personal information collected in order to track and examine the use of this Application, compile reports and share them with other services developed by Google. Google may use this personal information to contextualize and customize the ads of its advertising network.

      Personal data collected: Cookies and usage data. Place of processing: USA – Privacy Policy – Opt Out

    How can you disable or remove cookies?

    Most browsers accept cookies automatically, but it’s possible to set the browser in order not to accept them, automatically or upon request. We advise against such deactivation because the normal navigation may be compromised and some or all features of some websites may not be available. If you do not want your pc to receive and store cookies, you can modify the security settings of your browser.

    Listed below you will find the links to the most common browsers:





    On this site we use technical cookies, essential for the correct functioning of the website and to provide the service offered. With your consent, we also use third-party statistical and profiling cookies that allow us to monitor the progress of the site and offer better and safer navigation. By clicking ACCEPT ALL COOKIES, you consent to the use of all cookies. Alternatively, you can select the cookies to be enabled by clicking on CUSTOMIZE. In any case, if you close the banner by selecting the top-right X, the basic settings will remain with the use of the technical cookies only, without affecting the navigation


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