Privacy Policy
PRIVACY POLICY
In compliance with EU Reg. 2016/679 (European Regulation for the protection of personal data) we provide the necessary information regarding the processing of personal data provided. The information is provided pursuant to art. 13 of EU Reg. 2016/679 - GDPR (European Regulations for the protection of personal data).
Traceable personal data: any information concerning an identified or identifiable natural person ('data subject'); it's identifiable a identified person, either directly or indirectly, with particular reference to an identifier particular such as a name, identification number, location data, an online identifier or one or more characteristic elements of his physical identity, physiological, genetic, psychological, economic, cultural or social identity.
1. THE "DATA CONTROLLER” (Controller)
Art. 4 and 24 GDPR, is COMM42 SA (Comm42), via Serafino Balestra 12, 6900 Lugano (CH), in the person of the legal representative pro-tempore. The contact email of the Controller is administration@comm42.eu.
2. FINALITY AND LEGAL BASIS OF TREATMENT
Personal data will be processed in compliance with the conditions of lawfulness pursuant to art. 6 EU Reg. 2016/679 for the following purposes: reception of communications, for direct marketing activities, newsletters, market researches or other sample searches and sale by automated mail, MMS or SMS messages or other types, as well as through phone calls and use of paper mail, information material by the Comm42 for the detection of the degree of satisfaction, promotional material, commercial and advertising or inherent events and initiatives by the Controller. The Controller, to compare and possibly improve the results of communications, uses systems for sending newsletters and promotional communications with reports. Thanks to the reports, the Controller will be able to know, for example: the number of readers, openings, unique "clickers" and clicks; the devices and operating systems used to read the communication; the detail on the activity of individual users; the details of the emails sent, e-mails delivered or not, of those forwarded; All these data are used for the purpose of comparing, and possibly improving, the results of communications.
LEGAL BASIS
The processing of data according to purpose is based on the consent. (Article 6 (1) (a) GDPR).
3. ADDRESSEES OR CATEGORIES OF ADDRESSEES OF DATA
The personal data will be communicated to recipients, who will process data as managers (Article 28 of EU Reg. 2016/679) and / or as natural persons acting under the authority of the Data Controller and the Data Processor (Article 29 of EU Reg. 2016/679), for the purposes listed above in point 3, and to third parties. Precisely, the data will be communicated to:
The list of managers is constantly updated and available at the headquarters of Comm42 Sa.
4. DATA TRANSFER TO A THIRD COUNTRY AND / OR AN INTERNATIONAL ORGANIZATION AND GUARANTEES
The personal data may be transferred to countries belonging to the European Union and to countries outside the EU, in order to comply with the aforementioned purposes. The data will be transferred according to Article 44 - General principle for the transfer; Article 45 - Transfer on the basis of an adequacy decision; Article 46 - Transfer subject to adequate guarantees, specifically the data will be transferred: - to third countries international organizations for which the Commission has intervened with an adequacy assessment (Article 45 EU Reg. 2016/679) - to third countries or international organizations that have provided adequate guarantees and in which the person concerned has rights to action and effective reminder (Article 46 EU Reg. 2016/679, also with contractual clauses and the other provisions referred to in Article 46, paragraph 3 ) - towards third countries international organizations on the basis of exceptions in specific situations (Article 49 of the EU Reg. 2016/679). For information on the guarantees regarding the transfer of data outside the EU, please write to administration@comm42.eu.
5. DATA STORAGE OR CRITERIA FOR DETERMINING THE PERIOD
The processing will be carried out in an automated and manual way, with methods and tools aimed at guaranteeing maximum security and confidentiality, by subjects specifically appointed to do so. In compliance with the provisions of art. 5 paragraph 1 letter e) of Reg. UE 2016/679 the personal data collected will be stored in a form that allows identification of data subjects for a period of time not exceeding the achievement of the purposes for which the personal data are processed. The retention of personal data provided depends on the purpose of the processing: receive newsletters or promotional communications in general via e-mail (maximum 24 months); timing determined on the basis of criteria that the interested party can have information by writing to administration@comm42.eu.
6. RIGHTS OF DATA SUBJECTS
You will be able to assert your rights as expressed in EU Regulation 2016/679, by contacting the Controller, by sending an e-mail to administration@comm42.eu.com or by writing to the office of the Controller indicated above. You have the right, at any time, to ask the Controller to access your personal data (Article 15), the correction (Article 16) or the cancellation (Article 17) of the same, or the limitation of processing ( art 18) or to oppose their treatment based on legitimate interest (Article 21). Finally, you have the right to data portability (Article 20).
Withdrawal of consent. If the treatment is based on consent, you have the right to withdraw the consent at any time without prejudice to the lawfulness of the treatment based on the consent given prior to the revocation. To oppose the treatment and to exercise the other rights you can write to administration@comm42.eu. In order not to receive more direct automated marketing communications (e-mail, SMS, MMS, fax) it will be sufficient to write an e-mail at any time to administration@comm42.eu with the subject "automatic cancellation", and will no longer be disturbed. In order not to receive traditional direct marketing communications, it will be sufficient to write an e-mail at any time to administration@comm42.euwith the subject "traditional cancellation" and will no longer be disturbed.
You have the right to lodge a complaint with a supervisory authority. There is no automated decision making process.
7. NATURE OF CONFERRALITY AND REFUSAL
The provision of data for the purposes referred to in point 2 is optional but necessary. Any refusal to provide the necessary data with respect to point 2 makes it impossible to use the services of the Controller.
8. MODIFICATIONS ON THE PRIVACY POLICY
The Controller reserves the right to modify, update, add or remove parts of this privacy policy at his discretion and at any time. The data subject is required to periodically check for any changes. In order to facilitate this verification, the information will contain the indication of the update date of the information. The use of the site, after the publication of the changes, will constitute acceptance of the same. Last update: may 2018
In compliance with EU Reg. 2016/679 (European Regulation for the protection of personal data) we provide the necessary information regarding the processing of personal data provided. The information is provided pursuant to art. 13 of EU Reg. 2016/679 - GDPR (European Regulations for the protection of personal data).
Traceable personal data: any information concerning an identified or identifiable natural person ('data subject'); it's identifiable a identified person, either directly or indirectly, with particular reference to an identifier particular such as a name, identification number, location data, an online identifier or one or more characteristic elements of his physical identity, physiological, genetic, psychological, economic, cultural or social identity.
1. THE "DATA CONTROLLER” (Controller)
Art. 4 and 24 GDPR, is COMM42 SA (Comm42), via Serafino Balestra 12, 6900 Lugano (CH), in the person of the legal representative pro-tempore. The contact email of the Controller is administration@comm42.eu.
2. FINALITY AND LEGAL BASIS OF TREATMENT
Personal data will be processed in compliance with the conditions of lawfulness pursuant to art. 6 EU Reg. 2016/679 for the following purposes: reception of communications, for direct marketing activities, newsletters, market researches or other sample searches and sale by automated mail, MMS or SMS messages or other types, as well as through phone calls and use of paper mail, information material by the Comm42 for the detection of the degree of satisfaction, promotional material, commercial and advertising or inherent events and initiatives by the Controller. The Controller, to compare and possibly improve the results of communications, uses systems for sending newsletters and promotional communications with reports. Thanks to the reports, the Controller will be able to know, for example: the number of readers, openings, unique "clickers" and clicks; the devices and operating systems used to read the communication; the detail on the activity of individual users; the details of the emails sent, e-mails delivered or not, of those forwarded; All these data are used for the purpose of comparing, and possibly improving, the results of communications.
LEGAL BASIS
The processing of data according to purpose is based on the consent. (Article 6 (1) (a) GDPR).
3. ADDRESSEES OR CATEGORIES OF ADDRESSEES OF DATA
The personal data will be communicated to recipients, who will process data as managers (Article 28 of EU Reg. 2016/679) and / or as natural persons acting under the authority of the Data Controller and the Data Processor (Article 29 of EU Reg. 2016/679), for the purposes listed above in point 3, and to third parties. Precisely, the data will be communicated to:
- objects providing services for the management of the information system used by the Comm42 and telecommunications networks (including e-mail and platforms);
- studies or companies in the context of assistance and consultancy relationships;
- companies connected, controlled or contractually linked to Comm42 and / or part of its distribution network (such as branches, importers, distributors, shippers, etc.), possibly also based in countries outside the European Union;
- competent authorities for compliance with legal obligations and / or provisions of public bodies, upon request;
- the administration / distribution network on the territory.
The list of managers is constantly updated and available at the headquarters of Comm42 Sa.
4. DATA TRANSFER TO A THIRD COUNTRY AND / OR AN INTERNATIONAL ORGANIZATION AND GUARANTEES
The personal data may be transferred to countries belonging to the European Union and to countries outside the EU, in order to comply with the aforementioned purposes. The data will be transferred according to Article 44 - General principle for the transfer; Article 45 - Transfer on the basis of an adequacy decision; Article 46 - Transfer subject to adequate guarantees, specifically the data will be transferred: - to third countries international organizations for which the Commission has intervened with an adequacy assessment (Article 45 EU Reg. 2016/679) - to third countries or international organizations that have provided adequate guarantees and in which the person concerned has rights to action and effective reminder (Article 46 EU Reg. 2016/679, also with contractual clauses and the other provisions referred to in Article 46, paragraph 3 ) - towards third countries international organizations on the basis of exceptions in specific situations (Article 49 of the EU Reg. 2016/679). For information on the guarantees regarding the transfer of data outside the EU, please write to administration@comm42.eu.
5. DATA STORAGE OR CRITERIA FOR DETERMINING THE PERIOD
The processing will be carried out in an automated and manual way, with methods and tools aimed at guaranteeing maximum security and confidentiality, by subjects specifically appointed to do so. In compliance with the provisions of art. 5 paragraph 1 letter e) of Reg. UE 2016/679 the personal data collected will be stored in a form that allows identification of data subjects for a period of time not exceeding the achievement of the purposes for which the personal data are processed. The retention of personal data provided depends on the purpose of the processing: receive newsletters or promotional communications in general via e-mail (maximum 24 months); timing determined on the basis of criteria that the interested party can have information by writing to administration@comm42.eu.
6. RIGHTS OF DATA SUBJECTS
You will be able to assert your rights as expressed in EU Regulation 2016/679, by contacting the Controller, by sending an e-mail to administration@comm42.eu.com or by writing to the office of the Controller indicated above. You have the right, at any time, to ask the Controller to access your personal data (Article 15), the correction (Article 16) or the cancellation (Article 17) of the same, or the limitation of processing ( art 18) or to oppose their treatment based on legitimate interest (Article 21). Finally, you have the right to data portability (Article 20).
Withdrawal of consent. If the treatment is based on consent, you have the right to withdraw the consent at any time without prejudice to the lawfulness of the treatment based on the consent given prior to the revocation. To oppose the treatment and to exercise the other rights you can write to administration@comm42.eu. In order not to receive more direct automated marketing communications (e-mail, SMS, MMS, fax) it will be sufficient to write an e-mail at any time to administration@comm42.eu with the subject "automatic cancellation", and will no longer be disturbed. In order not to receive traditional direct marketing communications, it will be sufficient to write an e-mail at any time to administration@comm42.euwith the subject "traditional cancellation" and will no longer be disturbed.
You have the right to lodge a complaint with a supervisory authority. There is no automated decision making process.
7. NATURE OF CONFERRALITY AND REFUSAL
The provision of data for the purposes referred to in point 2 is optional but necessary. Any refusal to provide the necessary data with respect to point 2 makes it impossible to use the services of the Controller.
8. MODIFICATIONS ON THE PRIVACY POLICY
The Controller reserves the right to modify, update, add or remove parts of this privacy policy at his discretion and at any time. The data subject is required to periodically check for any changes. In order to facilitate this verification, the information will contain the indication of the update date of the information. The use of the site, after the publication of the changes, will constitute acceptance of the same. Last update: may 2018
