ACCOUNTABILITY FOR DATA PROCESSING
The body accountable for the processing of the data is
MTM Reality – Via Ludovico Ariosto, 25 – 70043 – Monopoli (BA) Italy – +39 080 897 84 93 – +39 080 897 84 93 email@example.com
TYPE OF DATA COLLECTED
Amongst the personal data collected by this application, either autonomously or through third parties, are: Cookies and usage Data.
Personal Data can be provided by the user on her/his own will or can be collected automatically while using this application, as it is the case for the usage Data.
Unless otherwise stated, the Data requested by this application is mandatory. In case the user refrains from providing it, it might be impossible for the Application to offer its Service. In cases where the Application states the data is optional, users are free to refrain from providing this Data without this having consequences on the efficiency or the functioning of the Service.
Users who might have doubts on which Data is mandatory are encouraged to contact the Holder.
METHODS AND PLACE FOR PROCESSING THE DATA COLLECTED
METHODS OF DATA PROCESSING
The Holder implements the necessary security measures aimed at preventing the non-authorized access, disclosure, modification or distribution of Personal Data.
The Data processing takes place through IT or/and telematic tools, with organizational methods and reasons strictly related to the aims mentioned above. In addition to the Holder, in some cases other subjects involved in the management of this Application could access the Data (Administrative, Commercial and Marketing personnel, lawyers and administrators of the system), or external subjects (such as suppliers of third technical services, freight forwarders, hosting providers, IT firms, communication agencies), which if necessary, are appointed in charge of the Data processing by the Holder. The updated list of the individuals in charge can be requested to the Holder anytime.
LEGAL BASIS FOR DATA PROCESSING
The data Holder can process the Personal Data related to the User when one of the following conditions exists:
- The user has given consent for one or more specific purposes; Be aware that according to some legal systems the Holder can be authorized to process Personal Data without the need to receive the user’s consent or one of the others legal basis specified below, until the user opts-out of processing; this however is not applicable in cases where the processing of Personal Data is regulated by the European legislation in the field of Personal Data protection;
- The processing of data is necessary for the implementation of a contract with the user and/or the precontract measures;
- The processing of data is necessary for the implementation of a legal obligation which the Holder has to comply with;
- The processing of data is necessary for the implementation of a task for the public interest or to exercise public authorities which are appointed to the Holder;
- The processing of data is necessary to pursue the legitimate interest of the Holder of third parties;
Nonetheless, it is always possible to ask the Holder to clarify the juridical basis of data being processed each time and more particularly to clarify whether the processing is complying with a law, is provided by a contract or is necessary to end a contract.
The Data processing takes place in the field offices of the Holder and in any other place where the parties r involved in the data processing are located. For further information, please contact the Holder.
The User’s Personal Data could be transferred to a country different than that in which the User is located. For further information on the place where the User’s data is processed, the User can refer to the section related to the details on the processing of Personal Data.
The User has the right to obtain information on the legal basis of the transfer of Data outside the European Union or to an international organization of international public law or made of two or more countries, such as the UN, and on the security measures adopted by the Holder to protect the Data.
In cases where the transfer of Data mentioned above takes place, the User can refer to the corresponding sections of this document or ask information contacting the Holder.
Data is processed and stored for the time requested to comply with the aims for which it was gathered. Therefore
- Personal Data gathered for the aims related to the implementation of the contract between the Holder and the User, will be held until the implementation of the contract is completed.
- Personal Data gathered for the aims referable to the legitimate interest of the Holder will be held until the completion of such interest. The User can obtain further information on the legitimate interest pursued by the Holder in the related sections of this document or contacting the Holder.
When the Data processing is based on the User’s consent, the Holder can store the Personal Data for a longer time, until the consent is revoked. In addition, the Holder might have to store the Personal Data for a longer time in order to comply with a legal obligation or an authority’s order.
At the end of the storage time, the Personal Data will be deleted. Therefore, upon expiry date of the storage time the right to access, deletion, modification and the right to the portability of Data cannot longer be exercised.
PURPOSE OF THE PROCESSING OF THE DATA GATHERED
User’s Data is gathered to allow the Holder to provide its Services, as well as for the following purposes:
Statistics and interaction with social networks and external platforms.
In order to obtain further detailed information on the purposes of the Data processing and on the Personal Data concretely relevant for each purpose, the User can refer to the relevant sections of this document.
DETAILS ON THE PROCESSING OF PERSONAL DATA
Personal Data is gathered for the following purposes and using the following services:
INTERACTION WITH SOCIAL NETWORKS AND EXTERNAL PLATFORMS
This type of services allows to carry out interactions with social networks, or with other external platforms, directly through the pages of this Application.
Information and the interactions obtained through this Application are always subject to the User’s privacy setting related to each social network.
In case a service of interaction with social networks is installed, it is also possible that, even in case the Users don’t use the service, the service gathers traffic data related to the pages in which it is installed.
LIKE BUTTON AND FACEBOOK (FACEBOOK, INC.) SOCIAL WIDGET
The Like button and the social widget of Facebook are interaction services with the social network facebook, provided by Facebook, Inc.
Personal Data gathered: Cookies and usage Data.
TWEET BUTTON AND TWITTER (TWITTER, INC.) SOCIAL WIDGET
The Tweet button and the social widget of Twitter are interaction services with the social network Twitter provided by Twitter, Inc.
Personal Data gathered: Cookies and usage Data.
+1 BUTTON AND GOOGLE+ SOCIAL WIDGET (GOOGLE INC.)
The +1 button and the social widget of Google+ are interaction services with the social network Google+, provided by Google Inc.
Personal Data gathered: Cookies and usage Data.
The services included in this section allow the Holder of the Data processing to monitor and analyze the traffic data and are useful to keep truck of the User’s behavior.
GOOGLE ANALYTICS WITH HARMONIZED IP (GOOGLE INC.)
Google Analytics is a service of web analysis provided by Google Inc. (Google). Google uses Personal Data gathered in order to track and examine the use of this Application, fill-in reports and share them with other services developed by Google.
Google could use the Personal Data to contextualize and customize the commercials of the User’s advertising network.
This integration of Google Analytics makes the User’s IP address anonymous. This takes place by shortening the IP address of the Users, within the limits allowed by the European Union or other Countries subject to the European Economic Area. Only in exceptional cases, the IP address will be sent to Google’s servers and shortened within the United States.
Personal Data gathered: Cookies and usage Data.
Users can exercise specific rights in reference to the Data transferred by the Holder.
More particularly, the User has the following rights:
- To revoke the consent in every moment. The User can revoke the consent to the processing of her/his Personal Data previously expressed.
- Oppose to the processing of Data. The User can oppose to the processing of her/his Data when this takes place on a legal basis different than the consent.
- Access her/his own Data. The User has the right to obtain information on the Data processed by the Holder, on specific aspects of the processing and to receive a copy of the processed Data.
- To verify and ask for rectification. The User can verify the accuracy of her/his own Data and require to update or rectify it.
- To obtain restrictions on the data processing. In cases where specific conditions are fulfilled, the User can require the restriction of the processing of her/his own Data. In this case, the Holder will process the Data for no purpose than that of conservation.
- To obtain the cancellation or removal of her/his own Personal Data. In cases where specific conditions are fulfilled, the User can request the cancellation of her/his own Data by the Holder.
- To receive her/his Data and to make them transfer to another Holder. The User has the right to receive her/his own Data in a structured format, of common usage and readable from an automatic device and, where technically possible, to obtain a transfer without obstacles to another Holder. This disposition is applicable when Data are processed with automated devices and the processing is based on the User’s consent, upon contract to which the User is a participant or upon contractual measures related to it.
- To make a complaint. The User can suggest a complaint to the authority monitoring the protection of Personal Data or can take legal action.
DETAILS ON THE RIGHT TO OPPOSE
In cases where Personal Data are processed for the purpose of public interest, and for the practice of public powers of which the Holder is appointed or to carry out a legitimate interest of the Holder, the Users have the right to oppose to the processing of Data for reasons related to their specific situation. The Users, whose Data is processed with direct marketing purposes, can oppose to the processing of Data without providing justifications. In order to find out whether the Holder uses the Data for direct marketing purposes the Users can refer to the relative sections in this document.
HOW TO RETAIN RIGHTS
In order to enjoy the User’s right, the Users can send a request to the Holder, which contact details are given in this document. Requests are free of charge and the Holder has to respond to them the soonest possible, in any case within one month.
ADDITIONAL INFORMATION ON THE DATA PROCESSING
The User’s Personal Data can be used by the Holder in legal contexts or in phases preparatory to their initiation for the legal defense from violation during the use by the User of this Application or of connected Services.
The User declares to be aware that the Holder could be required to reveal the Data, by the order of public authorities.
SPECIFIC ADVISORY NOTICES
SYSTEM AND MAINTENANCE LOG FILES
For needs related to functioning and maintenance, this Application and the possible third services used by the Application, could gather Log files, i.e. files which record interactions and which can also include Personal Data, such as the User’s IP address
Further information in relation to the processing of Personal Data can be requested to the Holder of the Data Processing in any moment using the contact details given in this document.
RESPONSES TO DO NOT TRACK REQUESTS
This Application does not support Do not truck requests. In order to find out whether possible third parties’ services being employed support them, the User is suggested to refer to the relative privacy policies.
In case amendments refer to data processing legally based on the consent, the Holder will collect the User’s consent again, if necessary.
DEFINITIONS AND LEGAL REFERENCES
PERSONAL DATA (OR DATA)
‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier including an identification number.
Usage Data are the information collected automatically through this Application (also through third parties’ application integrated to this Application), amongst these are: IP addresses or domain names of the computers used by the Users who log to this Application, addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method employed to forward the request to the server, the size of the file received in response, the numerical code indicating the state of the response from the server (successful, error, etc.), the country of origin, the features of the browsers and of the operating system used by the visitor, the various time connotations of the visit (for example the visit time on each webpage) and the details related to the itinerary followed within the Application, and more particularly the sequence of pages visited, the parameters related to the operating system and the User’s IT environment.
The User is the person who uses this Application and who, except where differently specified, coincides with the person concerned.
The person concerned is the natural person to whom the Personal Data are referred.
PERSON IN CHARGE OF THE DATA PROCESSING (OR PERSON IN CHARGE)
HOLDER OF DATA PROCESSING (OR HOLDER)
The natural or legal person, the public authority, the service or another body which individually or together with others determines the purposes and the means to process the Personal Data and the tools adopted, included the security measures related to the functioning and fruition of this Application. The Holder of the Data Processing, except when differently stated, is the Holder of this Application.
The hardware or software tool through which the Users’ Personal Data are gathered and processed.
The Service provided by this Application, as defined by the relevant words (if present) in this website/application.
EUROPEAN UNION (UE)
Except where differently specified, any reference to the European Union included in this document is conceived as extended to all the current member states of the European Union and of the European Economic Space.
Small portion of data saved on the User’s device.