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The company Mooveo SRL, whose headquarters are based in Brescia (Italy), Borgo Pietro Whurer, with VAT number IT-03892380985 (“Controller” hereafter), acting as Controller, informs under Article 13 of the Legislat. Decree no. 30.6.2003 (“Personal Data Protection Code” hereafter) and under Article 13 of the Regulation (EU) no. 2016/679 (“GDPR” hereafter) that your personal data will be processed according the following modalities and purposes (For further information or privacy enquiries: email@example.com) :
1. Processing subject
The Controller processes the personal data, identity and contact details, and non-sensitive data (in particular, name, surname, VAT number, email, phone number - “personal data” or “data” hereafter) that you have provided:
- whilst signing up to the Controller’s website or to the Newsletter service provided by the Controller.
- whilst concluding a contract to use the Controller’s services.
2. Processing purposes
Your personal data is processed:
A) without your express consent (Personal Data Protection Code, Article 24 , letter a, b, c and GDPR, Article 6, letter b) for the following service purposes:
- concluding contracts to use the Controller’s services;
- fulfilling the pre-contractual, contractual and fiscal obligations from existing relationships;
- fulfilling the obligations established by the Law, a regulation, a Community legislation or by an order from the Authority (as regards Anti-money laundering for instance).
- allowing you to register to the website;
- managing and maintaining the website;
- allowing you to sign up to the newsletter service provided by the Controller and to other services you might request;
- exercising the Controller’s rights (the right of defence during trial for example)
B) only prior to your specific and explicit consent (Personal Data Protection Code, Article 23 and 130, and GDPR, Article 7) for the following marketing purposes:
- sending you through email, post and/or sms and/or phone contact, newsletters, business communications and/or advertising material on products or services provided by the Controller and satisfaction surveys on service quality;
- sending you through email, post and/or sms and/or phone contact, newsletters, business and/or promotional communications of third parties (business partners or other Group companies for instance).
We inform you that if you are already registered as customer, we shall send you business communications in relation to the services and products of the Controller, which are analogous to those you have already benefit from, except in case of disapproval (Personal Data Protection Code, Article 130, paragraph 4).
3. Processing modalities
Your personal data is processed by means of operations indicated in Article 4 of the Personal Data Protection Code and in Article 4 point 2) of the GDPR such as: collection, recording, organisation, keeping, interrogation, elaboration, modification, selection, retrieval, comparison, utilization, interconnection, blocking, communication, erasure and destruction of data. Your data is subject to both paper and electronic processing and/or automated processing.
The Controller will be processing the personal data during the necessary period of time in order to fulfil the above-mentioned purposes and for not over a 50-years time period from the expiry of the contract and for not over a 20-years time period from the data collection for marketing purposes.
4. Data accessYour personal data shall be accessible for the purposes referred to in Articles 2.A) and 2.B) of this text to the following parties:
- employees and associates of the Controller or of the Group companies the Controller is part of, acting as appointees and/or supervisors of the processing and/or system administrators.
- Group companies the Controller is part of or third-party companies or other subjects (for example, providers for the website management and maintenance, suppliers, credit institutions, professional firm, etc.) that practice outsourcing on behalf of the Controller, as external supervisors of the processing.
5. Data communication
Without the need for your express consent (Article 24, letter a), b), d) of the Personal Data Protection Code and Article 6, letter b) and c) of the GDPR), your personal data shall be disclosed for the purposes referred to in Article 2.A) to supervisory and/or judicial authorities as well as to all the other subjects for which the communication is mandatory by law for the purposes fulfilment. The above-mentioned subjects will process the data as independent controllers of the processing. Your personal data will not be disseminated.
6. Data transfer
The management and storage of the personal data will occur on servers, located in the European Union, of the Controllers and/or third-party companies duly named as Processing supervisors. The servers are currently located in Italy, in the company’s headquarters. The data will not be transferred outside the European Union. It is understood that the Controller, when necessary, shall relocate his servers to Italy and/or to the European Union and/or to non-EU countries. In such case, the Controller guarantees henceforth that the transfer of the data outside the EU will occur in compliance with legislative provisions stipulating, if necessary, agreements that ensure an appropriate level of protection and/or including standard contractual clauses provided for by the European Commission.
7. Nature of data provision and consequences of a refusal to respond
The data provision for the purposes referred to in Article 2.A) is mandatory. In the absence of such data, we will not be able to guarantee you neither the registration to the website nor the services of Article 2.A).
On the other hand, the data provision for the purposes referred to in Article 2.B) is optional. Therefore, you can decide not to provide any data or to refuse at a later time the possibility to process data you have already provided: in such case, you will receive no newsletters, business communication nor advertising material in relation to the services provided by the Controller. In any case, you will retain your right to benefit from the services referred to in Article 2.A).
8. Right of access by the data subject
Under Article 7 of the Protection Personal Data Protection Code and under Article 15 of the GDPR, the data subject shall have the right to:
- obtain from the Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data;
- obtain the indication of: a) the origin of the personal data; b) the purposes and modalities of processing; c) the logic applied in case of processing through electronic devices; d) identification details of the controller, data processors and representative designated under Article 5, paragraph 2 of the Personal Data Protection Code and Article 3, paragraph 1 of the GDPR; e) subjects or categories of subjects to whom the personal data can be disclosed or who are aware of it as representative designated in the territory of the State, as data processors or appointees;
- obtain: a) the update, rectification or integration of the data; b) the cancellation, anonymous modification or blocking of the data processed in breach of the law, included the data whose storage, relating to the purposes of its collection or at a later time processed, is not necessary; c) the proof that the operations referred to at letters a) and b) have been communicated, with regards to its content, to those to whom the data has been disseminated, except when such fulfilment turns out to be impossible or involves disproportionate means compared to the protected right;
- refuse, in whole or in part: a) for legitimate grounds, the processing of his or her personal data, even though it is relevant to the collection purposes; b) the processing of his or her personal data for advertising material or direct marketing or market statistics or business communication, by means of automated phone call systems without an operator intervention through email and/or through traditional marketing modalities (phone and/or letters). We inform that the right to object of the data subject, expressed to the previous point b), for direct marketing purposes through automated modalities is extended to the traditional modalities and the data subject may retain his or her right to object only in part. Therefore, the data subject may decide to receive communications either through traditional marketing modalities or only through automated communications or none of these two kinds of communication.
Where applicable, the data subject has the rights referred to in Articles 16 and 21 of the GDPR (right of rectification, right to be forgotten, right to object) as well as the right of lodging a complaint to the competent authority.
9. Modalities for the exercise of the right
At any time, you will be able to exercise your rights sending:
- a registered letter with notification of receipt
- an email at: firstname.lastname@example.org.
10. Controller, representative and appointees
The Controller of the processing is Mooveo SRL, Borgo Pietro Whurer, n° 27-29, 25123 Brescia, Italy.
The updated list of the representatives and appointees is safeguarded at the headquarters of the processing Controller.
- Security: RUNKD stores and keeps safe all information collected in any form preventing unauthorized access to your data. We use both physical and electronic defences. Further details regarding security
- Protection: Your personal information will not be sold, exchanged or sold to third parties. To improve the service we use statistical data with suppliers or sponsors NOT data from the individual user.
- Transparency: At any time you can refuse to receive promotional emails, just unsubscribe from the newsletters in your user profile or on the bottom of the newsletter itself.
At any time it is possible to be removed from our records
RUNKD uses external resources such as offered by the many social networks (facebook, twitter) to identify a user.
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