PRIVACY POLICY INTENDIME S.R.L.
Art. 13 – 14 REG. EU 679/2016 (GDPR)
INTRODUCTION
INTENDIME S.R.L. (hereinafter also just the “Company” or “INTENDIME”) put the utmost attention to privacy and to the protection of personal data. Therefore, we hereby intend to inform you about the ways in which we will process your personal data that will be collected when you use the following website: www.intendime.com (hereinafter, also the “Platform” or “Website”) or through other form of personal data collection by INTENDIME (e.g., conferences, courses, questionnaires, etc.).
We may collect information about you in connection with:
– your registration for Platform services by completing the appropriate online forms on the Website or newsletter service;
– the provision of the services and content available to registered users of the Platform;
– requests for information sent via the appropriate contact form on the Platform
– at conferences, courses, questionnaires, etc., managed by INTENDIME either directly or indirectly.
In particular, we need to process the data provided to us when you register or request a service or subscribe to our newsletter, etc.
In addition, only with your consent, we may, use your personal data for sending promotional and commercial material and we may use, exclusively for service purposes, your data of a particular nature, with particular reference to data disclosing a state of health ex art. 9, paragraph 1, EU Reg. 679/2016 (GDPR).
This Privacy Policy (together with our Terms and Conditions, if any, applicable to the relevant services, our Cookie Policy and any additional disclosures that may be provided in connection with individual services) sets out the basis on which your personal data will be processed.
DATA CONTROLLER
The Data Controller of your data acquired during the navigation, or the activities performed on the Platform is:
NAME: INTENDIME S.R.L.
REGISTERED OFFICE: PIAZZA REPUBBLICA, 28 – CAGLIARI
OPERATING OFFICE: VIALE LA PLAIA 15
VAT NUMBER: 03616060921
1. TYPE OF DATA PROCESSED – PURPOSES – LEGAL BASIS
We may collect and process the following personal data, for the following purposes and with the following legal basis:
|
Data |
Purposes |
Legal basis |
|
Common personal data such as but not limited to: – first and last name – tax code – residence or domicile – telephone number – date of birth |
(a) To provide INTENDIME’s products and services. b) To enable you to use our Platform. c) For all related contractual and administrative purposes; d) To provide services reserved for registered users and/or requested information; e) To support users and communicate changes related to our services, including bug fixes. |
Based on the user’s contract or supply order. Art. 6(1)(b) GDPR. Data processing necessary for the purpose of supplying the product or service, Common personal data may also be processed by INTENDIME in cases of legitimate interest. Art. 6, paragraph 1, lett. f), without the need for consent. Common personal data may also be processed by INTENDIME for the fulfillment of legal obligations or to comply with any orders from the judicial authorities (Art. 6, para 1, lett. c, GDPR) or for statistical purposes, in completely anonymous and aggregate form (Art. 5, para 1, lett. b GDPR) |
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Common personal data, such as but not limited to: – first and last name – residence or domicile – telephone number |
Subscription to INTENDIME’s newsletter service Sending promotional and commercial information We may, for example, send you emails or instant messages (e.g., SMS and WhatsApp, messenger, direct), or contact you by telephone through an operator to submit you commercial offers, initiatives and promotions related to products and services (including those different from those you have requested) from us and/or third parties. Profiling |
Based on the user’s expressed consent. Article 6(1)(a) GDPR. Optional processing on the basis of consent, but failure to provide it will not allow the provision of the newsletter service Common personal data may also be processed by INTENDIME in cases of legitimate interest. Art. 6(1)(f), without the need for consent. Consent must be free, express and distinct, both for sending promotional material and for any profiling. In case of lack of consent for profiling NTENDIME will not be able to carry out any profiling activities of its users. |
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data concerning health – information related to users’ hearing |
Provision of the products and services of INTENDIME |
Based on the consent given by the user. Art. 9(2)(a) GDPR. Optional processing on the basis of consent, but failure to provide it will not allow the provision of INTENDIME’s products and/or services If the user has manifestly made his health-related data public, it may be freely processed by INTENDIME in accordance with this privacy policy and the GDPR, on the basis of Art. 9, para. 2, lett. f). |
|
Data collected by social media |
Provision of INTENDIME’s products and services Newsletter service Commercial and promotional information We may, for example, send you emails or instant messages (e.g., SMS and WhatsApp, messenger, direct), or contact you by phone through an operator to submit commercial offers, initiatives and promotions related to products and services (including those different from those you have requested) from us and/or third parties |
Our Platform may offer you the opportunity to fill out application and/or registration forms by taking advantage of the social media authentication process (e.g., Facebook and Google). In this case, should you decide to use social media authentication methods, we may access certain data (e.g., first name, last name, public profile photo, email) that you have entered into your account according to the terms of use of such social media platforms and your privacy settings. |
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Browsing data (especially IP address) |
To examine your preferences and the ways in which you interact with us. In particular, in order to better understand your tastes and interest in our services and communications, we may examine – including through the use of automated systems – the information you provide when you register for the Platforms and other services provided by the Platforms, your interest with respect to the communications and newsletters we send you, how you use our Platforms, and your interest in our social channels (e.g., Facebook, LinkedIn, Twitter, YouTube, Instagram, Pinterest). |
Even in the absence of log-in, the computer systems used to ensure the proper functioning of the Web Site acquire in the course of their normal operation, some personal data whose transmission is implicit for the purpose of using electronic communication systems. This information is not collected in order to be associated with identified data subjects, but, by its very nature, could, through processing and association with data held by third parties (e.g. other providers), allow your identification. This category includes, for example, the IP addresses or domain names of the computers you use to access our site, the browser type and version, the types and versions of browser plug-ins, the mobile device identifier (IDFA or AndroidID) and other parameters related to your operating system and computing environment, the URIs (Uniform Resource Identifiers) of the requested resources, the time of the request, the size of the file obtained in response, and the numeric code indicating the status of the response given by the server. These data, in the absence of your specific consent to the processing for further purposes, are used only for the purpose of obtaining anonymous statistical information on the use of the sites and applications and to optimize their use and proper functioning, and are deleted immediately after processing. Some of this data, however, may be processed – at the exclusive request of the competent Judicial Authorities authorized to do so by express provision of law – for the purpose of preventing/preventing crimes. |
2. UNTIL WHEN WILL WE KEEP YOUR DATA?
Your Personal Data will be kept, from the time it is received/updated, for an appropriate period congruent with the processing purposes stated above.
Herebelow is the duration of the different processing:
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categories |
duration |
legal references |
|
Legal referencesCommon personal data processed for contract execution or other purposes related to INTENDIME’s product or service. |
5 – 10 years from the date of termination of the contract. |
art. 2948 Civil Code, which provides for a 5-year statute of limitations for periodic payments; art. 2220 Civil Code, which provides for 10-year retention of accounting records; art. 22 of Presidential Decree no. 600 of September 29, 1973. |
|
Common personal data processed for commercial and promotional purposes and sending newsletters. |
In compliance with the terms prescribed by law for the type of activity and in any case until the revocation of consent or until the exercise of the right to object |
Art. 23 of Legislative Decree 196/03; General Prov. of 15/05/13; Art. 6, para. 1(a) GDPR; Art. 21 EU Reg. 2016/679. |
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Health-related data, with particular reference to information related to users’ hearing. |
In compliance with the terms prescribed by law for the type of activity and in any case until the revocation of consent or until the exercise of the right to object |
Art. 9, par. 2, lett. a) GDPR; art. 21 GDPR |
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Users or other parties, for commercial and promotional purposes. |
In compliance with the terms prescribed by law for the type of activity and in any case until the revocation of consent or until the exercise of the right of opposition |
Art. 23 of Legislative Decree 196/03; General Provv. of 15/05/13; art. 21 EU Reg. 2016/679. |
3. TO WHOM WILL WE SHARE YOUR DATA?
Your personal data may be shared, for administrative purposes, with:
(a) suppliers, distributors, business partners for the provision of the requested services and products who act as data processors on the basis of a specific contract ex art. 28 GDPR. A list of external data processors will be available upon request forwarded to INTENDIME by data subjects.
b) employees, collaborators, directors of the Company, on the basis of special instructions and authorizations of the Company ex art. 29 GDPR
4. WILL YOUR DATA BE TRANSFERRED TO COUNTRIES OUTSIDE THE EU?
Personal data are processed mainly within the European Union. For some services we use tools (e.g., Google Inc., MailChimp, dropBox, Amazon AWS, etc.) from companies with registered offices in the United States of America and adherents of the Privacy Shield, which ensures that the processing of personal data is in line with European data protection legislation.
5. WHAT RIGHTS CAN YOU EXERCISE?
You have the right to request access to, rectification or deletion of personal data, restriction of processing and to object to their use by us, as well as the right to request delivery of some of them.
Rights of the Data Subject:
Right of Access
The data subject has the right to obtain from the data controller confirmation 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:
(a) the purposes of the processing;
(b) the categories of personal data concerned;
(c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular whether recipients are from third countries or international organizations and, if so, the existence of appropriate safeguards
(d) when possible, the expected period of retention of personal data or, if this is not possible, the criteria used to determine this period;
(e) the existence of the data subject’s right to request from the 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
(f) the right to lodge a complaint with a supervisory authority;
(g) where the data are not collected from the data subject, all available information about their origin;
(h) the existence of an automated decision-making process, including profiling, which produces legal effects that
regard him or her or similarly significantly affects him or her 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.
Right to 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.
Right to erasure
The data subject has the right to obtain from the data controller the erasure of personal data concerning him or her without undue delay, and the data controller is obliged to erase the personal data without undue delay, if any of the following grounds exist:
(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(b) the data subject withdraws the consent on which the processing is based and there is no other legal basis for the processing;
(c) the data subject objects to the processing, and there is no overriding legitimate ground for the processing;
(d) personal data have been processed unlawfully;
(e) the personal data must be erased in order to comply with a legal obligation under European Union law or the law the Member State to which the data controller is subject;
Rights to limitation of processing
The data subject shall have the right to obtain from the data controller the restriction of processing when any of the following occurs:
(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;
b) the processing is unlawful and the data subject objects to the erasure of the personal data and instead requests that their use be restricted;
(c) although the data controller no longer needs the personal data for the purposes of the processing, the personal data are necessary for the data subject to establish, exercise or defend a legal claim; and
(d) the data subject has objected to the processing, pending verification as to whether the data controller’s legitimate reasons prevail over those of the data subject.
Right to object
The data subject has the right to object at any time to the processing of personal data concerning him or her based on the legitimate interest of the data controller, including profiling. The data subject has the right to object at any time to the processing of personal data concerning him or her carried out for direct marketing purposes, including profiling insofar as it is related to such direct marketing.
Right to data portability
The data subject has the right to receive in a structured, commonly used and machine-readable format personal data concerning him or her that has been provided to a data controller and has the right to transmit such data to another data controller without hindrance from the data controller to whom he or she has provided it if:
(a) the processing is based on consent or a contract; and
(b) the processing is carried out by automated means.
In exercising his or her rights with regard to data portability, the data subject has the right to obtain direct transmission of personal data from one data controller to another, if technically feasible.
6. HOW CAN YOU CHANGE YOUR PREFERENCES OR REVOKE CONSENTS?
At any time, you can check, change or withdraw your consents in relation to marketing purposes, as well as for personal data related to your health status.
It will be sufficient to write to INTENDIME at privacy@intendi.me expressly requesting revocation of consent for marketing and newsletter purposes and/or for the processing of data related to your health status.
Withdrawal of consent for marketing and newsletter purposes will prevent INTENDIME from sending you promotional and commercial information and newsletters, except in cases of sending information due to legitimate interest ex at. 6, paragraph 1, lett. F) GDPR.
Withdrawal of consent to the processing of data suitable for health status could prevent the provision of INTENDIME’s products and services.
7. HOW TO CONTACT THE OWNER TO EXERCISE YOUR RIGHTS?
You may exercise your rights by writing to the data controller at the contact details below:
INTENDIME S.R.L.
VIALE LA PLAIA 15
EMAIL: PRIVACY@INTENDI.ME
8. HOW TO CONTACT THE RELEVANT SUPERVISORY AUTHORITY FOR FILING ANY COMPLAINTS?
Any complaints may be submitted to the relevant supervisory authorities:
Garante per la Protezione dei Dati Personali
Piazza di Monte Citorio n. 121
00186 Rome
Italy
Fax: (+39) 06.69677.3785
Tel: (+39) 06.696771
E-mail: garante@gpdp.it
Certified mail: protocollo@pec.gpdp.it
9. HOW WILL YOU BE NOTIFIED OF ANY CHANGES TO THIS PRIVACY POLICY?
This Privacy Policy may be subject to changes and updates if changes are made to the way we process your Data or other information provided to you herewith. Any changes will, in all cases, ensure that your rights are fully protected. If any changes are made that may limit the safeguards protecting your Data or your rights compared to the current version, before the processing of your Data begins in the new manner, you will be promptly informed through the contacts provided to us and you will be granted the right to unsubscribe from your account or, in any case, to change your consents and preferences.
In any case, we encourage you to consult from time to time the updated Privacy Policy posted on the site: Privacy Policy
Last updated: 21/06/2021