THE PROTECTION OF YOUR PRIVACY IS ONE OF OUR MAIN OBJECTIVES
Technopartner, with registered office in Via delle Imprese 44, CAP (Postal Expedition Code) 24041 Brembate, Bergamo, undertakes to constantly protect the privacy on-line of its customers. This document outlines our policy on privacy, explaining how your personal data are managed when using our services, and to enable you to give aware and express consent to the processing of your personal data in the website sections requiring the entry of such data. We remind you that the various sections of the websites of Technopartner (hereinafter “Site”) requiring entry of your personal data contain specific disclosure requirements in accordance with art. 13 of the General Data Protection Regulation (EU) 2016/679 (hereinafter: the “GDPR”), which must be viewed by you before providing the requested data. The information and data supplied by you or otherwise acquired when registering for the various services of Technopartner will be processed in observance of the provisions of the GDPR and the obligations for confidentiality that lead the work of Technopartner.
In accordance with the provisions of the GDPR, the processing operations carried out by Technopartner will comply with the principles of lawfulness, fairness, transparency, purpose and retention limitation, data minimization, accuracy, integrity and confidentiality.
- Data Controller and Data Protection Officer
- Personal data undergoing processing
- a. Browsing data
- b. Data voluntarily provided by the data subject
- c. Cookies
- Purposes of the processing
- Legal basis and mandatory or optional nature of the processing
- Recipients of personal data
- Transfer of personal data
- Retention of personal data
- Data subjects’ rights
1. DATA CONTROLLER AND DATA PROTECTION OFFICER
The Controller of the processing operations carried out through the Site is Technopartner as specified above. The Data Controller’s organization comprises a Data Protection Officer (DPO). The DPO is available for any information regarding the processing of the personal data of Technopartner, including the list of data processors. It is possible to contact the DPO by writing to firstname.lastname@example.org
2. PERSONAL DATA UNDERGOING PROCESSING
Processing of personal data means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, diffusion or any other kind of data provision, comparison or interconnection, restriction, erasure or destruction.
We inform you that the personal data undergoing processing – depending also on how you intend to use the Services – will consist of an identifier such as name, e-mail address, ID number, location data, online identifier, purchases and other data enabling you to be identified or identifiable, depending on the type of Services requested (hereinafter “Personal Data”).
Specifically, the Personal Data processed through the Site are the following:
a. Browsing data
The computer systems and the software procedures used for operation of the Site acquire, during routine operation, some personal data, whose transmission is considered implicit in the use of the Internet communication protocols. This information is not collected in order to be associated with identified persons, but in its nature it may, through processing and associations with data retained by third parties, enable the identification of users. This category of data includes IP addresses or computer domain names used by the users to connect to the site, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the dimensions of the file obtained in the response, the numerical code indicating the status of the response sent by the server (successful, error, etc.) and other parameters regarding the operating system and IT environment of the user. These data are used exclusively to retrieve anonymous statistical information on use of the present site and the sites of our clients, and to ensure the correct operation of the latter, identify faults and/or abuse, and they are deleted immediately after processing. The same data may be used to ascertain responsibility in the hypothetical case of computer crime harmful to the site or third parties: with the exception of this case, the data on web contacts are not stored for more than fourteen days, unless requested otherwise by the user.
b. Data provided voluntarily by the data subject
When using specific Services, the Personal Data of third parties that you submit to the Service Manager may undergo processing. In such case, you are considered an independent data controller, assuming all the obligations and responsibilities according to the law. To this effect, you fully indemnify in this regard Technopartner against any complaints, claims and demands for compensation for damages arising from processing, etc., that Technopartner may receive from third parties whose Personal Data have been processed through your use of the Services in violation of the applicable rules on personal data protection. In any case, if you provide or in other way process Personal Data of third parties in using the Service, you henceforth guarantee – assuming all related responsibilities – that this specific processing is grounded on an appropriate legal basis (for example, the data subject’s consent) in accordance with art. 6 of the GDPR, which legitimizes the processing of the information in question.
You can get further information about cookies on the dedicated page.
3. PURPOSES OF PROCESSING
The purposes of the processing we intend to carry out following your express consent (where necessary) are the following:
a. to allow us to provide the Services you requested, the retention and processing of data for the establishment and subsequent operational, technical and administrative management of the relation arising from the provision of the Services, and the exchange of messages during the course of the relation;
b. to allow you to browse and explore Technopartner websites;
c. to answer requests for assistance or information, which we’ll receive via e-mail, telephone or chat through the “Contact us” section or “Contacts” or “Information” of our Site. With particular reference to answers to telephone requests for assistance received by Technopartner, we inform you that the calls may be registered so that Technopartner can prove it has properly handled requests;
d. to discharge legal, accounting and tax obligations;
e. to carry out direct marketing activities via e-mail for services similar to those you have subscribed to, unless you objected to such processing initially or in subsequent communications, to pursue Technopartner’s legitimate interest to promote products and services which you may be reasonably interested in;
f. to conduct studies, research, market statistics; to send you advertising and information material, commercial information, or surveys to improve the service (“customer satisfaction”) via e-mail or SMS, and/or over the telephone through operator and/or through the official pages of Technopartner on social media;
g. only with regard to certain services, the data may be processed to be disclosed to third parties for their marketing purposes, namely to provide you with information and/or to propose offers on products, services or initiatives offered or promoted by other affiliated and/or verified companies, and/or other business partners and outsourcers who act as independent data controllers;
h. to make personalised commercial proposals based on the products or services you have purchased, or about which you have shown interest while browsing on our Site, or on the basis of the group of customers you belong to (profiling). This means, for example, that if you are a retailer you will receive commercial offers intended for retailers; if you have browsed our Site to search for information on certain services, you will receive offers related to these services; finally, if you are using a service, on the basis of your use of the service, you will receive targeted communications from Technopartner (e.g. if the service capacity is reaching the limit, you will be warned and invited to increase the capacity of the service itself, or complementary and/or compatible services with the one you purchased will be offered). This type of analysis is typically performed on purchase data relating to both individuals and legal entities and the related decisions are not based solely on automated processing. This processing is necessary for the pursuit of the legitimate interest of the data controller to customize its commercial proposals. You can always object to this processing by writing to email@example.com;
i. solely for purposes of security and prevention of fraudulent conduct, the Data Controller puts an automated control system in place to track and analyze users’ behaviour on the Site, associated with the processing of Personal Data such as the IP address. The consequence of such processing is that, if a person attempts to engage in fraudulent conduct on Technopartner Site, for example in order to benefit several times from the same promotion without having the right to do so, Technopartner reserves the right to exclude such person from the promotion or to take any other appropriate measure for its own protection.
4. LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF THE PROCESSING
The legal basis of the processing of Personal Data for the purposes referred to in section 3 (a-b-c) is art. 6 (1) (b) of the GDPR, since processing operations are required in order to provide the services as per contract. The provision of Personal Data for these purposes is optional, however, failure to provide them would imply the inability to initiate the requested Services.
The purpose referred to in Section 3 (d) constitutes a lawful processing of Personal Data pursuant to art. 6 (1) (c) of the GDPR. Once Personal Data are provided, the processing may indeed be required to comply with legal obligations which Technopartner is subject to.
Processing operations carried out for the marketing purposes described under section 3 (f) and for disclosing to third parties described under section 3 (g) are based on the granting of your consent pursuant to art. 6 (1) (a) of the GDPR. The provision of your Personal Data for these purposes is entirely optional and does not affect your use of the Services. The processing activities under section 3 (e) performed for the purposes of e-mail marketing on products or services similar to those purchased by you, find instead its legal basis, pursuant to art. 6.1.f of the GDPR, in the legitimate interest of Technopartner to promote its products or services in a context in which the data subject can reasonably expect this type of processing, and which s/he can oppose at any time. Indeed, if you refuse to have your data processed for marketing purposes pursuant to section 3(e) and 3(f), you can at any time do so via your control panel (whenever available), by sending a request from here or through the link at the bottom of the e-mail. The profiling processing referred to in section 3 (h), which you can oppose at any time, is based on the legitimate interest of the Data Controller, pursuant to art. 6.1.f. of the GDPR, to personalise its commercial communication. The processing referred to in section 3 (i) is grounded as well in the legitimate interest of the Data Controller to detect fraud and scams committed against it in accordance with art. 6(1)(f) of the GDPR.
5. RECIPIENTS OF PERSONAL DATA
For the purposes referred to in Section 3 above, your Personal Data may be shared with:
a. subjects typically acting as data processors, namely: i) persons, companies or professional firms providing Technopartner with advice and consulting in accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services; ii) subjects to engage with in order to provide the Services iii) persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks); iv) Italian or foreign companies of the Technopartner Group for administrative and statistical purposes (collectively “Recipients”);
b. subjects, bodies or authorities to whom it may be mandatory to disclose your Personal Data to in accordance with the provisions of law or under the orders of the authorities (for example, during the course of criminal investigations, Technopartner may receive requests from the judicial authority to provide traffic logs);
c. persons authorized by Technopartner to process the Personal Data required for carrying out activities strictly related to the provision of the Services, who have committed themselves to confidentiality or have an appropriate legal obligation of confidentiality, for example Technopartner’s employees;
The full list of data processors is available by sending a written request at firstname.lastname@example.org.
6. TRANSFER OF PERSONAL DATA
Some of your Personal Data are shared with Recipients who may be located outside the European Economic Area. Technopartner ensures that your Personal Data are processed by these Recipients in accordance with the GDPR. Indeed, transfers can be based on an adequacy decision or on the Standard Contractual Clauses approved by the European Commission. Further information is available from the Data Controller. As this transfer is necessary for your use of the service, according to the current privacy law, it is justified under art. 49(1)(b) of the GDPR.
7. DATA RETENTION
The Personal Data processed for the purposes referred to in Section 3 (a-b-c) will be retained for the period deemed strictly necessary to fulfill such purposes. In any case, since the Personal Data are processed for the provision of the Services, Technopartner will process the Personal Data for the period allowed by Italian law to protect its interests (art. 2946 and ensuing articles of the Italian Civil Code).
8. DATA SUBJECTS’ RIGHTS
You are entitled to request Technopartner at any time to access your Personal Data, correct, erase or object to their processing in the cases provided for by art. 20 of the GDPR; you are entitled to request restriction of the processing in the cases under art. 18 of the GDPR, and to obtain, in a structured and commonly used and machine-readable format, the data regarding you (portability), in the cases under art. 20 of the GDPR.
Requests are to be sent in writing from at email@example.com
To exercise the right to portability and obtain further information on its content, please open the following link.
It should be noted that, in the case of requests from data subjects regarding the reporting of abuse in the use of the Services or of spamming – activities already prohibited by contract as set out in par. 8 of the General Conditions of Service – carried out by a Technopartner Customer (it is specified that such customer typically acts as a data controller pursuant to the GDPR), and in the case of any further requests for the exercise of the rights under art. 15 and ensuing articles of the GDPR, Technopartner, without going into the details of the request, will, on the one hand, promptly inform the customer/data controller and, on the other, provide the data subjects with the details of the customer/data controller.
In any case, you will be always entitled to file a complaint with the competent supervisory authority (the Italian Data Protection Authority, Garante per la Protezione dei Dati Personali), pursuant to art. 77 of the GDPR, if you believe that the processing of your data violates applicable law.