Complete Privacy Policy

Legal basis of processing

The Data Controller processes User’s Personal Data if one of the following conditions exists:

• The User has given consent for one or more specific purposes; Note: In some jurisdictions, the Data Controller may be allowed to process Personal Data without the User’s consent or another legal basis specified below until the User objects (“opt-out”) to such processing. However, this is not applicable if the processing of Personal Data is regulated by European data protection law;
• processing is necessary for the performance of a contract with the User and/or for the execution of pre-contractual measures;
• processing is necessary to comply with a legal obligation to which the Data Controller is subject;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
• processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.

It is always possible to request the Data Controller to clarify the legal basis of each processing and in particular to specify whether the processing is based on the law, provided for by a contract, or necessary to conclude a contract.

Further information on storage time

Unless otherwise specified in this document, Personal Data is processed and stored for the time required by the purposes for which it was collected and may be retained for a longer period in order to comply with legal obligations or at the request of Users. Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until such contract has been fully performed.
• Personal Data collected for purposes related to the legitimate interests of the Data Controller will be retained until such interests are fulfilled. Users may find specific information regarding the legitimate interests pursued by the Data Controller within the relevant sections of this document or by contacting the Data Controller.

When processing is based on the User’s consent, the Data Controller may retain Personal Data for a longer period until such consent is revoked. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority. At the end of the storage period, the Personal Data will be deleted. Therefore, upon expiration of this term, the right of access, deletion, rectification, and the right to data portability cannot be exercised anymore.

User’s rights

Users may exercise certain rights regarding their Data processed by the Data Controller. In particular, within the limits provided by law, the User has the right to:

• withdraw consent at any time. The User can withdraw consent previously expressed for the processing of their Personal Data.
• Object to the processing of their Data. The User may object to the processing of their Data when it is done on a legal basis other than consent.
• Access their Data. The User has the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing, and to receive a copy of the processed Data.
• Verify and request rectification. The User can verify the accuracy of their Data and request its update or correction.
• Obtain the restriction of processing. The User may request the restriction of the processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than its storage.
• Obtain the erasure or removal of their Personal Data. The User may request the erasure of their Data from the Data Controller.
• Receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to have it transmitted to another controller without hindrance.
• Lodge a complaint. The User may lodge a complaint with the competent data protection authority or take legal action.

Users have the right to obtain information about the legal basis for transferring Data to countries outside the European Union or to any international organization governed by public international law or established by two or more countries, such as the UN, as well as information on the security measures taken by the Data Controller to protect their Data.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of official authority vested in the Data Controller, or for the purposes of the legitimate interests pursued by the Data Controller, Users have the right to object to such processing on grounds relating to their particular situation. Users are reminded that if their Personal Data is processed for direct marketing purposes, they can object to that processing at any time without providing any justification. If Users object to processing for direct marketing purposes, their Personal Data will no longer be processed for such purposes. To find out if the Data Controller processes Personal Data for direct marketing purposes, Users can refer to the relevant sections of this document.

How to exercise rights

To exercise their rights, Users can address a request to the Data Controller using the contact details provided in this document. The request can be made free of charge, and the Data Controller will respond as soon as possible, in any case within one month, providing the User with all the information required by law. Any rectifications, deletions, or restrictions on processing will be communicated by the Data Controller to each of the recipients, if any, to whom the Personal Data has been transmitted, unless this proves impossible or involves a disproportionate effort. The Data Controller will inform the User of these recipients if requested.