INFORMATION PROCESSING OF PERSONAL DATA
(ART. 13 and 14 EU REG. 2016/679)
HOLDER OF THE TREATMENT
The Data Controller is the person responsible for the processing of your personal data and who determines the purposes and means of processing your data. In this case the Data Controller is: Imanager S.R.L. - Via santa Maria Valle 3, Milan 20123, registered in the chamber of commerce of Milan Monza Brianza Lodi, VAT number: 10275570967. Owner email address: firstname.lastname@example.org. If you wish to object to the collection, processing or use of your personal data by the site in compliance with data protection legislation, you can express your opposition to us by e-mail at the address indicated above. However, this may mean that the service is no longer usable.
Types of data collected
Among the Personal Data collected by this Application, independently or through third parties, there are: Cookies, Usage data, name, surname, date of birth, telephone number, address, city, email, Email, gender, company name and geographic location.
Method and place of processing the collected data
Processing methods The Data Controller adopts the appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. The treatment is carried out using IT and / or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Owner, in some cases, other subjects involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, may have access to the Data). hosting provider, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Owner. The updated list of Managers can always be requested from the Data Controller.
Legal basis of the treatment
The Data Controller 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 systems, the Data Controller may be authorized to process Personal Data without the consent of the User or another of the legal bases specified below, as long as the User does not object ("out-put") 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; • processing is necessary for the execution of a contract with the User and / or for the execution of pre-contractual measures; • the processing is necessary to fulfill a legal obligation to which the Data Controller is subject; • processing is necessary for the performance of a public interest task or for the exercise of public powers with which the Data Controller is invested; • the processing is necessary for the pursuit of the legitimate interest of the owner or third parties. However, it is always possible to request the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for in 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 relating to the details on the processing of Personal Data. The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data. If one of the transfers described above takes place, the User can refer to the respective sections of this document or request information from the Data Controller by contacting him at the details indicated at the beginning.
The data are processed and stored for the time required by the purposes for which they were collected. It will be our commitment to delete them and provide for destruction after 24 months from consent, unless agreements expressly accepted by the User at the time of consent and except as provided below.
• 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.
• Personal Data collected for purposes related to the legitimate interest of the Owner will be retained until this interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.
When the treatment is based on the User's consent, the Data Controller can keep the Personal Data longer until such consent is revoked. In addition, the Data Controller may be obliged to keep 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, Personal Data will be deleted. Therefore, at the end of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.
Purpose of the processing of the collected data
User Data is collected to allow the Owner to provide its Services, as well as for the following purposes: Statistics, Access to accounts on third party services, Contacting the User, Business affiliation, Contact management and sending messages, Management of Users database, Payment management, Tag management, Hosting and backend infrastructure, Interaction with live chat platforms, Location-based interactions, Registration and authentication, Remarketing and behavioral targeting and Display of content from external platforms. To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant for each purpose, the User can refer to the relevant sections of this document.
Facebook permissions required by this Application
The basic information of the User registered on Facebook which normally includes the following Data: id, name, image, gender and location language and, in some cases, the "Friends" of Facebook. If the User has made publicly available additional Data, the same will be available.
Provides access to the primary email address of the User. Details on the processing of personal data Personal data are collected for the following purposes and using the following services:
• Access to accounts on third party services
• Commercial affiliation
• Contact the user
• Contact management and sending messages
• Management of User databases
• Payment management
• Tag management
• Hosting and backend infrastructure
• Interaction with live chat platforms
• Location based interactions
• Registration and authentication
• Remarketing and behavioral targeting
• Display of content from external platforms
• Further information on Personal Data
• Push notifications
• Selling goods and services online
You have the right to receive clear information from iManager srl for free regarding the personal data we have stored about you;
The interested parties can exercise certain rights with reference to the data processed by the owner. In particular, the User has the right to:
- Access their 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.
- Obtain the limitation of treatment from the owner. When certain conditions are met, the User can request the limitation of the processing of their Data. In this case the Data Controller will not process the Data for any other purpose other than their conservation.
- Oppose the processing of their data. The user can object to the processing of their data when it takes place on a legal basis other than consent. Further details on the right to object are indicated in the section below.
- Check and request correction. The User can verify the correctness of his Data and request its updating or correction.
- Obtain the cancellation or removal of your Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.
- Get data portability. The User has the right to receive their Data in a 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 are processed with automated tools and the treatment is based on the User's consent, on a contract of which the User is a party or on contractual measures connected to it.
- Revoke your consent at any time. The User can revoke the consent to the processing of their Personal Data previously expressed, without prejudice to the lawfulness of the processing based on the consent acquired before the revocation;
- Propose a complaint. The User has the right to lodge a complaint with the Guarantor for the protection of personal data.
You can also send the complaint to the supervisory authority of your usual place of residence or work. If you wish to exercise your rights as a data subject, do not hesitate to contact us in accordance with the contact information provided above.
Personal data is information from which we can directly or indirectly identify your person, it is data such as name and surname, address, telephone number, date of birth, data relating to your location or e-mail address.
Please provide us only with the information we strictly need.
It is our desire to provide you with a good overview of the various profiles relating to the processing of your data and we have chosen to illustrate them with tables. In fact, we believe that this will allow us to provide you with information in a transparent, understandable and easily accessible form, as well as in clear and simple language.
Details on the right to object
When Personal Data are processed in the public interest, in the exercise of public powers with 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 related to their particular situation. Users are reminded that, if their data were processed for direct marketing purposes, they can oppose the processing without giving any reasons. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.
How to exercise your rights
To exercise the rights of the User, Users can direct 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 a month.
Learn more about the treatment
Defense in court
The User's Personal Data may be used by the Data Controller in court or in the preparatory stages for its possible establishment for the defense against abuse in the use of this Application or related Services by the User. The User declares to be aware that the Data Controller may be obliged 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 used by it may collect system logs, i.e. files that record the interactions and which 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 to the Data Controller using the contact details.
Reply 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 their respective privacy policies.
FURTHER PROCESSING BASED ON OUR LEGITIMATE INTEREST
In addition to the purposes and legal bases mentioned above, we also process your personal data on the basis of the so-called legitimate interest. One of the main legitimate interests is for example the processing of personal data within a group of companies, treatments made necessary for the security of networks and information or in direct marketing activities. We use your personal data to pursue our legitimate interests, provided that your rights and freedoms do not prevail. To reconcile our interests with your rights, we have introduced appropriate control mechanisms. These treatments include:
Legitimate Interest Process Explanation Advertising
We will send you emails to offer you coupons, discounts and promotions, conduct opinion polls and surveys to improve our service. You can object to further data processing for advertising purposes with each e-mail you receive. Of course, if you wish to object to the processing of your data for advertising purposes or for further information on this question, you can also contact our data protection officer directly at: email@example.com
We want to avoid generic newsletters and uncontrolled marketing measures. Therefore, we select the offers that suit your interests and contact you if we believe that the information may be of interest to you. You can object to further data processing for advertising purposes with each email. Of course, if you wish to object to the processing of your data for advertising purposes or for further information on this question, you can also contact our data protection officer directly at: firstname.lastname@example.org
In order to improve our services we collect various measurement data, which we cannot trace back to you or a profile. This helps us optimize our advertisements.
Merger and acquisition, change of ownership
We also wish to inform you that in the event of a merger or acquisition by another company, we will provide the information to that company. Obviously, we will require that company to comply with legal data protection regulations.
We will obviously be happy if you want to voluntarily share information with us that goes beyond what is strictly mandatory. In this way, we can continue to improve our service. This is data that you voluntarily provide when you use our website, our apps, but also information from other sources such as social media or other (public) databases (for example User-ID of other platforms).
To offer you better and better services, we regularly evaluate the success or potential causes of marketing failure. For this we analyze for example if our newsletters are open and even if the contents are clicked.