“Processing of personal data” means any operation or set of operations, carried out with or without the use of automated processes and applied to personal data or sets of personal data, even if not recorded in a database as the collection, recording, organization, structuring, conservation, processing, selection, block, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of provision, the comparison or interconnection, the limitation, deletion or destruction. Jackie S.r.l. manifests the highest attention in respect of the protection of personal data having adopted measures that are appropriate and necessary to data protection and the preservation of the same by virtue of the application of national rules and European reference and having examined each risk related to the activities mentioned above. Access to some sections of the site and/or any requests for information or services on the part of the users of the site will be subject to the inclusion of personal data whose treatment by Jackie S.r.l. will take place in respect of the general Regulation on data protection (EU Regulation 2016/679) and of the national legislation in force which Jackie S.r.l. is always adequate. The purpose of this notice is to allow the users to know, even before access to the various sections of the site and to give their own data in that way Jackie s.r.l. treats personal data of the users and will still be necessary for the user to take vision before he gives his own personal data by filling the spaces in the various sections of the site, providing consent to the treatment of data. The treatment will be carried out in via manual (es: collection paper forms) and electronically or in any case with the aid of computerised tools or automated. In accordance with the rules of the Code and of the Regulation, the treatments carried out by the holder will be based on the principles of correctness, lawfulness and transparency and the protection of confidentiality.
2. The object of processing and personal data collection methods.
The holder is the personal data, identification (for example, name, surname, address, tax code, telephone, e-mail, bank reference and payment) - Later, "personal data" or even "data" press releases by the person concerned on the occasion of the conclusion of the contract for the services offered by the holder thereof. The personal data subject to treatment were collected directly from the person concerned. In addition to personal data conferred directly by the user, in the phase of connection to the site of the computer systems and software procedures used for the operation of the site itself indirectly acquire some personal data whose transmission is implicit in the use of internet communication protocols.
3. The primary goals of the treatment.
The conferment of data is optional, but it is partly necessary (i.e. for data where the boxes are marked with an asterisk) so JACKIE S.r.l. can satisfy the needs of the user in the context of the functionality of the siteThe failure, partial, inexact conferral of personal data marked with an asterisk, in so far as is necessary for the execution of the required service, makes it possible to execute it; while the failure, partial, incorrect conferment of optional personal information will have no consequence whatsoever. The personal data will be treated by the holder in the primary track exclusively for purposes strictly connected and instrumental to the fulfilment of the obligations inherent in the contractual relationship, of pre contractual obligations and tax and the fulfillment of the obligations provided for by the legislation in force and, in particular: a) to conclude contracts for the services offered by the holder; b) fulfill the obligations the pre-contractual, contractual and tax arising from relationship being with the person concerned; c for the management of cash receipts and payments; d) to fulfill the obligations provided for by the rules of civil law and/or tax; eto comply with the obligations set out in a regulation, both on a national and international level, by Community legislation or by an order of the Authority (as for example in the field of money laundering); f) to exercise the rights of the holder, for example, the right of defense in legal proceedings. 3.2 Access, communication and dissemination of personal data for the pursuit of the primary goals of treatment.
In all the cases illustrated above for the pursuit of the primary goals of the data of the person concerned can be made accessible and brought to the knowledge of: • Employees, workers and internal consultants responsible for administrative formalities, secretarial, technical or other type and collaborators of the holder which, operating under the direct authority of the latter, have been appointed in charge of the treatment and have received adequate operative instructions as regards the subject; • Third party companies or other subjects (indicative: professional studies, consultants responsible for the conduct of legal activities and/or tax, to individuals who perform data processing activities and/or the keeping of the accounts and consequent procedures on behalf of the holder) carrying out activities on behalf of the holder, in the quality of external responsible of the treatment and who have in turn imparted suitable operational instructions in this regard in respect of their employees and managers. The holder may also disclose personal data outside the following the third parties to whom the communication is necessary for the fulfilment of the contract and of the bonds from the same welling, of precontractual obligations and tax and, more in general, for the fulfillment of the obligations provided for by the legislation in force. In this perspective the personal data may be communicated by the holder to the following subjects:
The judicial and police authorities or other public administrations for the fulfilment of legal obligations;
Credit Institutions for the management of cash receipts and payments;
To companies that perform the activities of management and maintenance of the equipment of electronic communication;
To all natural and legal persons in the cases in which the communication is necessary for the primary purpose of the treatment. The said subjects will treat the data in their capacity as autonomous holders of treatment.
3.3 Consent to the treatment.
In all the cases illustrated above in paragraphs 3.2 and 3.3 (for the hypotheses of communication to third parties) the holder has no obligation to acquire the specific consent to the treatment of data since all the above discussed treatments are pursuing the primary goals for which Article 24 of the privacy code and the art. 6, paragraph 1(b), (c) (e) and (f) of the Regulation excludes the need to acquire a specific consent, you want because the treatment is necessary in order to fulfill an obligation under the law (and reflected by the federal rules and statutes), by a regulation or by Community legislation, or because the treatment is necessary to perform the obligations arising from the contractual relationship which is part of the person concerned or to fulfill, before the conclusion of the contract, to specific requests of the person concerned. Where the person concerned does not intend to give any personal data requested and necessary on the basis of the foregoing, the result would be the impossibility for the holder to fulfill obligations and to perform the contract.
4. Promotional purposes, advertising and marketing in the broadest sense.
4.1 The secondary purpose of the treatment of personal data having a promotional nature, advertising and marketing in the broadest sense.
The personal data collected in the framework of the subscription of the contract or of the previous reports that have led to the formalisation of the same may also be processed by the owner, both in paper mode (es: compilation of forms, coupons and the like next paper use electronically) that with automated mode/informatics, for purposes of commercial promotion and advertising communication, stress to purchase behavior, market research surveys (even telephone, online or using forms), statistical processing (in identifying shape), other sample searches of marketing in a broad sense (including the demonstrations to the prize, games and competitions), hereinafter referred to collectively as the "Treatment for marketing purposes". By giving your consent to the processing for marketing purposes the person concerned takes specifically act of these promotional purposes, commercial and marketing in the broadest sense of the treatment (including activities management and administrative consequent) and expressly authorises the holder to proceed to such treatment both within the meaning of Article 23 of the Privacy Code (where the means employed for the treatment for the purpose of marketing are the phone with operator or other means not electronic, telematic not or not supported by mechanisms and/or automatic procedures, electronic or telematic), that pursuant to art. 130 of the Privacy Code (where the means employed for the treatment for marketing purposes are e-mail, fax, sms, mms, automatic systems without operator intervention and the like, including electron platforms-that and other telematic means), which - finally - within the meaning of art. 6, paragraph 1, letter (a) of Regulation. Within the meaning of the general provision of the Guarantor for the privacy of 15 May 2013 entitled "consent to the processing of personal data for the purpose of "Direct Marketing" through the traditional instruments and automated contact", specifically refers to the attention of the person concerned to the fact that:
any consent given for the sending of commercial communications and promotion on the basis of art. 130, paragraphs 1 and 2 of the Code (i.e., by the use of e-mail, fax, sms, mms, automatic systems without operator intervention and the like, including electronic platforms and other telematic means) will imply receiving these communications not only through said automated mode of contact but also through traditional modes, such as Mail or the call by the operator;
the right of opposition of the person concerned to the processing of their personal data for the purpose of "Direct Marketing" through the above-mentioned automated mode of contact, will extend in each case to the traditional ones and, also in this case, remains save the possibility of exercising this right in part, as foreseen by the art. 7, paragraph 4 of the Code, both with respect to certain means that with respect to certain treatments;
It remains the possibility for the person who does not intend to give my consent in the terms indicated above, to manifest any intention to receive notifications for the aforesaid purposes of marketing exclusively through traditional modes of contact, where provided: this will could be exerted for free by sending a simple email to the email address: email@example.com or the purposes of the principle of fulfilment of obligations privacy for the owner in respect of the principles of simplification of the same obligations (Art. 2 of the Code) and pursuant to the said general measure of the Guarantor for the privacy of the 15 May 2013, the holder shall inform the person concerned that the formula of specific consent to the provision on the basis of the collection procedure of consent from time to time provided will be unitary and overall and will refer to all the possible means of processing marketing, former Articles 23 and 130 of the Code, without prejudice to the possibility for the person concerned to notify via email to the email address: firstname.lastname@example.org a different intention with regard to the use of certain means and not others for receiving, prior consent, marketing communications. Furthermore, always for the purposes of the principle of fulfilment of obligations privacy for the owner in respect of the principles of simplification of the same obligations (Art. 2 of the Code), the holder of the authorization shall inform the person concerned that the formula of specific consent will be unitary and overall and will also refer to all the different possible purpose marketing here made explicit (i.e. without multiply the formulas of consent for each separate marketing purposes pursued by the holder), without prejudice to the possibility for the person concerned to notify via email to the email address: email@example.com a different selective determination as to consent or refusal of consent for individual marketing purposes.
Paying therefore the consent optional , the person concerned takes specifically act and authorizes such further possible secondary treatments. In any case, even where the person concerned has consented to authorize the holder to pursue all the objectives mentioned in points 1 to 5 above, will remain free at any time to withdraw it, sending without any formality clear communication in this respect to the email address of e-mail: firstname.lastname@example.org Following the receipt of such a request of the opt-out, the holder will promptly to the removal and deletion of data from the database used for the treatment for marketing purposes and to inform for the same purposes of cancellation any third parties to whom the data have been communicated. The simple receipt of the request for cancellation will automatically which confirmation of cancellation. We inform you specifically and separately, as required by art. 21 of Regulation that where personal data are processed for the purpose of direct marketing, the person concerned has the right to oppose in any moment to the processing of personal data that concern it made for such purposes and that if the applicant objects to the treatment for the purpose of direct marketing, personal data will no longer be the subject of treatment for these purposes.
4.2 Communication and dissemination of personal data to a third party business partners.
For the same purposes as referred to in paragraphs 1 to 5 of paragraph 4.1, the holder shall inform the person concerned that the data may also be communicated to a third party business partners. The consent to the processing for marketing purposes - where provided by the person concerned - not also covers the different and further treatment marketing represented by communication to third parties of the data for the same purposes. To proceed to this communication to the outside is mandatory to acquire from the person concerned informed consent further, separate, additional, documented, expressed and entirely optional. As in fact clarified in the general provision of guarantor of 4 July 2013 laying down the guidelines of contrast to spam:
with respect to the communication to third parties for marketing purposes in general, communication or transfer to third parties of personal data for marketing purposes may not be based on the acquisition of a single and generic consent on the part of those concerned for such purposes;
the holder of the treatment which it intends to collect personal data of the person concerned even for communicating (or sell them) to third parties for their promotional purposes must previously issued to them an appropriate information that individuals also each of third parties or, alternatively, please indicate the categories (economic or merchandise) of membership of the same;
it is necessary that the holder to acquire a specific consent to the communication (and/or disposal) to third parties personal data for promotional purposes, as well as distinct from that required by the same proprietor to play it the same promotional activities;
where the person concerned releases such consent to the communication to third parties, they will be able to carry out in his regard promotional activities with the automated mode referred to in art. 130, paragraph 1 and 2 of the Privacy Code without having to acquire a new consensus for the promotional purpose. Within the meaning of the above-mentioned general provision of guarantor of 4 July 2013 the third parties to whom the communication of personal data by the parties concerned for the subsequent treatment for marketing purposes are identified with reference to the following product categories or economic: books, sports clubs, suppliers of goods and services of electronic communication, Internet service providers, communication agencies, companies that provide insurance and financial services companies in the food sector and the food & beverage, clothing, ICT hardware and software, banks and credit institutes, travel agencies, companies offering services in the field of tourism, companies that offer goods and services for the person, including goods and health services. The personal data subject to processing for marketing purposes will not be object of diffusion. In the case both request - for the purposes outlined above in paragraphs 4.1 and 4.2 - the indication of the phone number of the person concerned and these have consented optional and specific to the processing of such personal data for the purposes of commercial promotion and marketing in the broadest sense, the holder shall inform the person concerned that both the holder the same as any third parties may lawfully deal with telephone users for marketing purposes even if it is entered in the public register of the oppositions, since it treats from different source from public directories and covered by specific consent, unless the opposition right next The treatment where it is formally withdrawn the consent.
4.3 Consent to the treatment.
We recall with particular attention to the fact that the transfer of personal data to the holder and the performance of both the consent to the processing for marketing purposes that the distinct consent to the communication to third parties for the treatment for marketing purposes for the purposes and in the manner described above in paragraphs 4.1 and 4.2 are absolutely optional and optional (and still be revocable without formalities also after the performance) and the lack of conferment will not lead to different consequences from the impossibility for the holder and for any third party to proceed to only marketing treatments mentioned. In the event of refusal of consent marketing there will be no interference and/or consequence on the contractual relationship or on bonds from the same welling or other type and whose treatments of personal data within the primary goals of the treatment referred to in paragraphs 3.1 and 3.2 of this privacy statement. Exclusively with reference to the use of the email address indicated by the applicant at the time of conclusion of the contract, we inform you that it will be possible for the holder to send (without the need to acquire a specific consent, as required by Article 130, paragraph 4 of the Privacy Code) information and publicity material only if relative only to products and/or services similar to those for which originally the person concerned has loaned a consensus marketing. Remains in this particular assumption latch to the person concerned the right to oppose in every moment to treatment (notifying its opt-out at the email address e-mail: email@example.com) On the occasion of the reception. In every case the person concerned, on the occasion of the delivery of each email communication carried out by the holder for the purposes provided for herein, will be duly informed of the possibility to oppose in every moment to treatment, easily and free of charge. This opposition will not produce any consequence on the contractual relationship or on bonds from the same welling or other type and whose treatments of personal data within the primary goals of the treatment referred to in paragraphs 3.1 and 3.2 of this privacy statement.
5. Processing of personal data for purposes of commercial profiling.
It is possible that for marketing purposes or improving the services the holder to proceed to the data processing of the so-called "profiling" to evaluate certain aspects or to analyze or predict aspects concerning the economic situation, preferences, interests, reliability, etc. The profiling activities may relate to personal data "individual" or personal data "aggregates" deriving from personal data detailed. In order to clarify what is the "profiling", you can do by way of example reference to the following parameters:
Data are structured and coordinated on the basis of predefined parameters identified from time to time, depending on your business needs (regardless of the marketing purposes, contractual, administrative, etc.);
The starting data, considered individually, may include personal information of varied type, but it is only after the profiling (i.e. structuring according to predetermined parameters) that it is possible to infer indications more referable to the person concerned, indications more (i.e. the "profile"), which do not arise from the mere aptitude disclosure of data individually or separately considered.
In other words, by profiling in a strict sense can achieve the availability of an information assets that goes well beyond the information considered individually and relative to each concernedfurthermore the profiling in the strict sense provides an added value given by the multiple correlations that it is possible to establish between the individual data collected, in order to obtain additional information useful. The foundational elements of the treatment of profiling will be:
the predetermination of the parameters for the structuring of data considered individually;
The comparison, the intersection, putting in relation to such data between them and the comparative analysis carried out on the basis of predefined parameters, also by means of automated processes (i.e. the cataloguing of the individual data in clusters);
The obtaining of a profile through the activities that precede and which allows us to identify the person concerned and the indications additional analytical compared to individual data and allows the dynamic creation of profiles.
The above discussed treatments will be hereinafter defined on the whole as "Treatment of profiling".
5.2 Consent to the treatment.
To proceed to a treatment of profiling is mandatory to acquire a specific consent, separated (also from marketing consent referred to in paragraphs 4.1 and 4.2. above), espresso, documented, estimate and entirely optional. Consequently, where the person concerned decides to pay the specific consent, must be previously informed and aware that the aim of the treatment pursued are of specific commercial nature, advertising, promotional and marketing in the broadest sense based on a treatment of profiling. In a context of absolute transparency, the holder shall inform, therefore, that the data collected on the basis of a specific provision of consent may be the subject of a treatment of profiling for the same purposes referred to in paragraph 4.1 of the present disclosure, while the scope of communication to third parties will be possibly the same already explained for the marketing treatments in paragraph 4.2. We recall with particular attention to the fact that the transfer of personal data to the holder and the performance of both the consent to the treatment of profiling that the distinct consent to the communication to third parties for the treatment of profiling are absolutely optional and optional (and still be revocable without formalities also after the performance) and the lack of conferment will not lead to different consequences from the impossibility for the holder and for any third party to proceed to just mentioned treatments. In the event of denial of the consent to the treatment of profiling there will not be any consequence or interference on the report on the contractual relationship or on bonds from the same welling or other type and whose treatments of personal data within the primary goals of the treatment referred to in paragraphs 3.1 and 3.2 of this privacy statement.
6. Transfer of personal data to countries not belonging to the European Union.
We inform you that some personal data of the person concerned may be transferred to third countries or to international organizations third located outside of the European Union to allow the pursuit of only the primary goals of the treatment. From time to time, the presupposition of lawful transfer of personal data can be represented: a) from the existence of decisions of suitability issued by the EU Commission for certain countries which guarantee the same level of protection of data transferred guaranteed in the European Union (with the result that it will be possible to proceed to transfer data without constraints or consent, as for example in the case of transfer of the data to the Australia, Argentina, New Zealand, Uruguay, Israel, Hong Kong, Switzerland); b) by the need of carrying out the obligations relating to the established contractual relationship, or to implement the commitments made by the holder in the interest and on behalf of the person concerned. The holder informs that it is therefore not necessary to acquire the consent to proceed to treatment represented by the transfer of personal data to third countries or to international organizations third located outside of the European Union on the basis of the assumptions of Lawfulness of processing illustrated above.
7. Mode, retention of data and other information.
The personal data will be treated in a prevalently automated mode, with logics strictly correlated to the above mentioned aims by staff and by internal staff of the holder, by external subjects expressly appointed as responsible of the treatments. Outside of these assumptions the data will not be communicated to third parties nor spread if not in the cases expressly provided for by national law or of the European Union.The data will be processed for the entire duration of the contractual relationship and also subsequently for the time in which the holder is subject to obligations of conservation for legal purposes tax and for other purposes as provided by law and/or regulations. With reference instead to personal data subject to processing for marketing purposes or to processing for the purposes of profiling the same will be maintained in accordance with the principle of proportionality and in any case until they have been pursued the objective of treatment or up to that - if earlier - does not intervene the withdrawal of specific consent on the part of the person concerned.
8. Holder, accountable and responsible of the treatment.
Owner of the data treatment is the Jackie S.r.l., with registered office in Via Aurelio Saffi n.25 - 20123 Milan, CF and P.IVA 09591170965. The extremes that allow you to quickly contact the Jackie S.r.l. and to communicate directly and effectively with the same, including the email address, are: tel. +39 (0)445 60 22 60 firstname.lastname@example.org The updated list of responsible and of the responsible of the treatment is available at the registered office of the holder of the treatment and is accessible by informal request, also via email to the following email address: email@example.com).
9. Rights of the interested party.
Within the meaning of Article 7 of the Privacy Code and within the meaning of Articles 13, paragraph 2, subparagraphs (b) and (d), 15, 18, 19 and 21 of the Regulation, it shall inform the person concerned has the following rights: ahas the right to ask the Jackie S.r.l. as holder of the treatment The personal data access, correction or cancellation of the same or limitation of treatment which concern him or to oppose their treatment, in the cases provided for; b) has the right to propose in Interested quality of a complaint to the Guarantor for the protection of personal data in accordance with the procedures and the indications that have been published on the official web site of the Authority on www.garanteprivacy.it; cany adjustments or cancellations or limitations of the treatment carried out at the request of the person concerned - unless this proves impossible or involves a disproportionate effort - will be communicated by the holder to each of the addressees referred were transmitted personal data. The Proprietor may communicate to the person concerned these recipients if the party concerned so requests. In particular, the person concerned will be able to:
to obtain confirmation of the existence or not of personal data concerning him, even if not yet recorded, and their communication in an intelligible form;
to obtain the indication: a) the origin of personal data; b) the purposes and methods of processing; c) the logic applied in case of treatment carried out with the aid of electronic instruments; d) the identification data of the holder, of those responsible and the appointed representative within the meaning of art. 5, subparagraph 2 Privacy Code and art. 3, subparagraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data can be communicated or that can be informed in quality of representative designated in the State territory or persons in charge;
obtain: a) updating, rectification or, where interested therein, integration of the data; b) the cancellation, transformation in anonymous form or the block of data treated in violation of the law, including those whose preservation is not necessary in relation to the purposes for which the data were collected or subsequently processed; c) the attestation that the operations described in letters a) and b) have been brought to the knowledge, even as regards their content, of those to whom the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;
to oppose, in whole or in part: a) for legitimate reasons to the processing of personal data, pertinent to the purpose of collection; b) to the processing of personal data for purposes of sending advertising material or direct sale or for market researches or commercial communication, through the use of automated calling systems without the intervention of an operator by e-mail and/or by means of traditional marketing by telephone and/or paper mail. It should be noted that the right of opposition of the person concerned, explained above in point (b), for the purpose of direct marketing by automated mode extends the traditional ones and that remains without prejudice to the possibility for the person concerned to exercise the right of opposition also only in part. Therefore, the person concerned may decide to only receive notifications by traditional mode or only automated communications or none of the two types of communication.
10. How to exercise the rights of the interested party.
The exercise of the rights is not subject to any form constraint and is free. The address for the exercise of the rights is: firstname.lastname@example.org Alternatively the applicant may at any time exercise their rights by sending a registered letter with return receipt to the following address: JACKIE S.r.l., Via Aurelio Saffi n.25 - 20123 Milan.
Notice issued according to directives of the Data Protection Authority – May 8th 2014 and in compliance with art.13 of the Privacy Code (D.Lgs. n.196/2003)
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