Data Controller
Spartivento Group SRL
Via Calabria 11, 00187 Rome
Share Capital: €110,000.00
VAT: 02055640805 - Rea: RC - 146003
Owner contact email: info@spartivento.it
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Tracking Tool; Usage Data; email; first name; last name; answers to questions; name; phone number.
Detailed information on each type of Data collected is provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory. If the User refuses to communicate it, it may be impossible for this Application to provide the Service. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published, or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner, releasing the Owner from any liability towards third parties.
Methods and place of processing the collected Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Personal Data.
The data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner processes Personal Data relating to the User if one of the following applies:
- the User has given their consent for one or more specific purposes; Note: In some jurisdictions, the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply whenever the processing of Personal Data is subject to European data protection law;
- processing is necessary for the performance of a contract to which the User is party or in order to take steps at the request of the User prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which the Owner 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 Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the User can always request that the Owner clarify the concrete legal basis for each processing operation, and in particular whether the processing is based on the law, stipulated by a contract, or necessary to enter into a contract.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located. For further information, please 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 find out more about the place of processing, the User can check the section containing the details about the processing of Personal Data.
The User has the right to obtain information about the legal basis for data transfers outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, as well as about the security measures taken by the Owner to safeguard their Data.
The User can check whether any of the abovementioned transfers takes place by checking the section of this document dealing with the details regarding the processing of Personal Data or inquire with the Owner using the information provided in the contact section.
Retention time
Data is processed and stored for as long as required by the purposes for which it has been collected.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for purposes related to the legitimate interest of the Owner shall be retained for as long as needed to fulfill such purposes. Users may find information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
When processing is based on the User's consent, the Owner may retain Personal Data for longer until such consent is revoked. Furthermore, the Owner may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
Purposes of processing collected Data
User Data is collected to allow the Owner to provide the Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as for the following purposes: Analytics, Contact management and sending messages, Managing data collection and online surveys, and Displaying content from external platforms.
For detailed information on the purposes of processing and the Personal Data processed for each purpose, the User may refer to the “Detailed information on the processing of Personal Data” section.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Contact management and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts, or contacts of any other kind used to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mailchimp (The Rocket Science Group LLC)
Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC.
Personal Data processed: last name; email; first name.
Managing data collection and online surveys
This type of service allows this Application to manage the creation, implementation, administration, distribution, and analysis of online forms and surveys in order to collect, save, and reuse Data from Users who respond.
The Personal Data collected depends on the information requested and provided by Users in the corresponding online form.
These services can be integrated with a wide range of third-party services to allow the Owner to perform subsequent actions with the processed Data - for example, contact management, messaging, analytics, advertising, and payment processing.
Data collected via self-managed online forms (this Application)
This Application uses forms to collect data from Users.
Personal Data processed: name; phone number; answers to questions.
Analytics
The services contained in this section allow the Owner to monitor and analyze web traffic and keep track of User behavior.
Google Analytics (Google Ireland Limited)
Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities, and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Usage Data; Tracking Tool.
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when users do not use it.
YouTube Video Widget (Google Ireland Limited)
YouTube is a video content visualization service provided by Google Ireland Limited that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; Tracking Tool.
User Rights
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, the User has the right to:
- withdraw consent at any time. Users may withdraw their previously given consent to the processing of their Personal Data.
- object to the processing of their Data. Users may object to the processing of their Data when it is carried out on a legal basis other than consent. Further details on the right to object are provided in the section below.
- access their Data. Users have the right to obtain information regarding the Data being processed by the Owner, certain aspects of the processing, and to receive a copy of the Data undergoing processing.
- verify and seek rectification. Users may verify the accuracy of their Data and ask for it to be updated or corrected.
- restrict the processing of their Data. Users may, under certain conditions, request the restriction of the processing of their Data. In such cases, the Owner will not process the Data for any purpose other than storing it.
- have their Personal Data deleted or otherwise removed. Users may, under certain conditions, request the deletion of their Data by the Owner.
- receive their Data or have it transferred to another controller. Users have 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 any hindrance. This provision is applicable when the Data is processed by automated means and the processing is based on the User's consent, on a contract which the User is part of, or on pre-contractual obligations thereof.
- lodge a complaint. Users may lodge a complaint with the competent data protection supervisory authority or take legal action.
Details on the right to object
When Personal Data is processed in the public interest, in the exercise of official authority vested in the Owner, or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation.
Users are informed that if their Data is processed for direct marketing purposes, they may object to such processing without providing any justification. To determine whether the Owner is processing data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise your rights
To exercise User rights, Users can direct a request to the Owner's contact details provided in this document. Requests are filed free of charge and processed by the Owner as quickly as possible, in any case within one month.
Further information on processing
Legal action
The User's Personal Data may be used by the Owner in court or in the stages leading to possible legal action arising from improper use of this Application or the related Services by the User.
The User declares to be aware that the Owner may be required to reveal the Data upon request of public authorities.
Specific information
At the User's request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.
System logs and maintenance
For needs related to operation and maintenance, this Application and any third-party services it uses may collect system logs, which are files that record interactions and may also contain Personal Data, such as the User's IP address.
Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from the Owner using the contact details.
Response to “Do Not Track” requests
This Application does not support “Do Not Track” requests.
To determine whether any third-party services used support them, the User is invited to consult their respective privacy policies.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Application as well as, if technically and legally feasible, by sending a notice to Users via any contact information the Owner has. Please check this page frequently, referring to the date of the last modification indicated at the bottom.
Should the changes affect processing activities based on the User's consent, the Owner will collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Personal data is any information that, directly or indirectly, including in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.
Usage Data
This is information collected automatically through this Application (including by third-party applications integrated into this Application), including: the IP addresses or domain names of the computers used by the User who connects with this Application, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the features of the browser and the operating system used by the visitor, the various time details per visit (for example, the time spent on each page) and the details about the path followed within the Application, with particular reference to the sequence of pages visited, the parameters related to the operating system and the User's IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural person, legal entity, public administration, or any other body that processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural person, legal entity, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data and the tools used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.
This Application
The hardware or software tool by which the Personal Data of Users is collected and processed.
Service
The service provided by this Application as defined in the relative terms (if available) on this site/application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union in this document includes all current member states of the European Union and the European Economic Area.
Cookie
Cookies are Tracking Tools consisting of small sets of data stored in the User's browser.
Tracking Tool
Tracking Tool means any technology—e.g., cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting—that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy has been prepared based on provisions of multiple legislations, including Articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy policy applies exclusively to this Application.
