Tinetx Value Lead, as Data Controller (hereinafter “Owner”), considers privacy and the protection of personal data an important issue of its business. For this reason, it processes personal data both in compliance with the federal law on data protection (LPD, June 19, 1992) and in accordance with the provisions of EU Regulation 679/2016 or GDPR, General Data Protection Regulation, (hereinafter “Regulation” ). We therefore invite you, before communicating any personal data to the Data Controller, to carefully read this Privacy Policy because it contains very useful information on the protection of your personal data.
This Privacy Policy:
- it is intended for the website www.Valuelead.com (hereinafter “Site”) and applies in all cases in which reference is made or there is a link to this information;
- forms an integral part of the Site and the services we offer;
- is given to those who interact with the web services of the Site.
The processing of your personal data will be based on principles of correctness, lawfulness, transparency, purpose limitation and conservation, minimization and accuracy, integrity and confidentiality, as well as the principle of accountability. Your personal data will therefore be processed in accordance with the laws and confidentiality obligations in force.
We inform you that the personal data being processed may be constituted – also depending on your decisions on how to use the services – from textual information, photographic images or any other information suitable for making the interested party identified or identifiable, depending on the type. of services requested.
1. HOLDER OF THE TREATMENT
The data controller is Itnetx Value Lead, with registered office in Via Cantonale 38, 6928, Manno CH
2. PERSONAL DATA OBJECT OF TREATMENT
We inform you that the personal data being processed may be constituted – also depending on your decisions on how to use the services – by an identifier such as the name, an identification number, one or more characteristic elements of your identity suitable for making the identified or identifiable interested party, depending on the type of services requested (hereinafter only “personal data”).
The personal data processed through the Site are as follows:
a. Navigation data
During their normal operation, the computer systems and software procedures used to operate the Site acquire some personal data, the transmission of which is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties and the Data Controller will in no way attempt to relate the data contained in the protocols of its servers with the people who have visited the site. However such data, through processing and merging with data held by third parties, by their very nature could allow users to be identified. By way of example, this category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, URI (Uniform Resource Identifier) sequences of the requested resources, 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 given by the server and other parameters relating to the user’s operating system. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site, in order to check its correct functioning, identify anomalies and / or abuses, as well as to better structure the Site itself. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Site or third parties.
b. Data provided voluntarily by you
Except for the reference to specific information, this Privacy Policy is also intended for the processing of data voluntarily provided by you through the Site. In particular, you can provide data by filling in the newsletter subscription form (hereinafter form). request for information, services or products, as well as data transmitted by you via e-mail. In this regard, we invite you not to enter information in the forms contained within the Site that may fall within the category of special categories of personal data referred to in art. 9 of the Regulations (for example, data referring to your political opinions, your religious beliefs or your state of health).
c. Third party data provided voluntarily by you
In the use of particular services, the processing of personal data of third parties, communicated by you to the Data Controller, may occur. With respect to these hypotheses, you act as an independent data controller, assuming all the obligations and responsibilities of the law. In this sense, you grant the widest indemnity on this point with respect to any dispute, claim, request for compensation for damage from processing, which should reach the Data Controller from third parties, whose personal data have been processed through your use of Site services in violation of the applicable personal data protection rules. In any case, if you provide or otherwise process personal data of third parties in the use of the Site, you guarantee from now – assuming all related responsibility – that this particular hypothesis of treatment is based on the prior acquisition – by you – of the consent. of the third party to the processing of information concerning him.
d. Cookies
Information on the cookies served by the Site is available at the following link.
3. PURPOSE OF THE TREATMENT
Your personal data will be processed, where necessary with your consent, for the following purposes:
3.1. fulfill any obligations established by applicable laws, regulations or community legislation, as well as satisfy requests from the authorities;
3.2. allow navigation of the Site and the provision of the services of the Data Controller, in addition to the purposes strictly connected and / or instrumental and / or necessary for the fulfillment of the contracts entered into with the interested party;
3.3. find specific requests addressed to the Data Controller, in order to provide the information, services or products requested, as well as respond to messages sent by you;
3.4. send the newsletter you have signed, without prejudice to the possibility of unsubscribing from the list of recipients, by selecting the appropriate link in each message;
3.5. for statistical purposes, without it being possible to trace your identity.
The processing of your data may be carried out using manual, IT and telematic tools, also through automated methods designed to store, manage and transmit them; will take place using suitable tools, as far as reason and state of the art is concerned, to ensure security and confidentiality through the use of appropriate procedures that avoid the risk of loss, unauthorized access, illicit use and dissemination.
The data are stored in computerized, telematic archives, and – in a residual way – on paper, with full assurance of the security measures provided for by the legislator.
Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access.
4. LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF THE PROCESSING
The purpose referred to in section 3.1 represents a legitimate processing of personal data as it is necessary to fulfill a legal obligation to which the data controller is subject. In fact, once the personal data has been provided, the processing is indeed necessary to fulfill legal obligations to which the Data Controller is subject.
The legal basis for the processing of personal data for the purposes referred to in sections 3.2, 3.3 and 3.4 is the need to execute a contract of which the interested party is a party or pre-contractual measures adopted at the request of the same, as the treatments they are necessary for the provision of services. The provision of personal data for these purposes is optional, but failure to provide it would make it impossible to activate the requested services. With particular reference to the processing of your data belonging to particular categories (such as, for example, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, as well as genetic data, biometric data, intended to uniquely identify a natural person, data relating to health or sexual life or sexual orientation), in the unlikely event that, despite our contrary notice, you communicate them to us, it has a legal basis in your express consent.
Finally, it is specified that the treatment referred to in section 3.5 is not performed on personal data; therefore it can be freely carried out by the Owner.
5. RECIPIENTS OF PERSONAL DATA
Tinext does not sell, transfer or otherwise transmit your personal data to third parties.
Personal data may be shared, for the purposes referred to in section 3 of this Privacy Policy, with:
5.1. subjects who typically act as data processors, namely: i) people, companies or professional firms that provide assistance and advice to the Data Controller in accounting, administrative, legal, tax and financial matters; ii) subjects delegated to carry out technical maintenance activities; iii) credit institutions, insurance companies and brokers; iv) parent companies, subsidiaries and affiliates of the Data Controller, limited to the pursuit of administrative-accounting purposes and / or related to the performance of organizational, commercial, administrative, financial and accounting activities;
5.2. subjects, bodies or authorities to whom it is mandatory to communicate your personal data by virtue of legal provisions or orders of the authorities;
5.3. persons authorized by the Data Controller to process personal data necessary to carry out activities strictly related to the provision of services, who are committed to confidentiality and adopt standards compliant with the GDPR.
6. TRANSFERS OF PERSONAL DATA
Your personal data are processed in the country where the Data Controller is located, as well as in Italy. For greater clarity, we inform you that Switzerland is a country in which personal data can be processed and transferred also in accordance with the GDPR, as it guarantees adequate protection to the standard required by European standards, pursuant to art. 45 of Regulation (EU) 2016/679. In fact, the European Commission adopted the Decision of 26 July 2000, in which it established that Swiss legislation offers a level of protection adequate to European standards. According to the Regulation, this decision remains valid “until they are modified, replaced or repealed by a decision of the Commission”. The Data Controller also ensures that the processing of your personal data by the Recipients takes place in compliance with the Regulations.
7. STORAGE OF PERSONAL DATA
Personal data processed for the purposes referred to in section 3.1 will be kept until the time required by the specific obligation or applicable law.
The personal data processed for the purposes referred to in sections 3.2, 3.3 and 3.4 will be kept for the time strictly necessary to achieve the aforementioned purposes, in execution of the services you want. In any case, since these are treatments carried out for the provision of services, the Data Controller will keep personal data for the period of time provided and allowed for the fulfillment of contractual, administrative, fiscal or judicial requirements.
8. RIGHTS OF THE INTERESTED PARTY
The following are recognized:
1) the right of access, or to obtain from the Data Controller confirmation that personal data is being processed or not, as well as to obtain information regarding the purposes and methods of processing, the recipients of the data, the criteria used to determine the period data retention, at the origin of the data (if not collected from the interested party), as well as the existence of an automated decision-making process; the Data Controller provides a copy of the personal data being processed;
2) the right to obtain the rectification and integration of incomplete personal data, including by providing a supplementary declaration;
3) the right to delete data; this right may find limits in the event that the processing is necessary for the assessment, exercise or defense of a right in court;
4) the right to obtain from the Data Controller the limitation of the processing;
5) the right to revoke the consent, in cases where it was previously provided without prejudice to the lawfulness of the treatment based on the consent given before the revocation;
6) the right to object, for legitimate reasons, to the processing of their personal data, even in the case of processing for direct marketing purposes;
7) the right to data portability;
8) the right to object to an automated decision-making process relating to individuals, including profiling;
9) the right to lodge a complaint with a supervisory authority.
If your requests are unfounded or excessive, the Owner may charge you a fee or refuse to satisfy the request.
These rights may be exercised by sending an e-mail to the address provided by the Data Controller.
9. EXISTENCE OF AN AUTOMATED DECISION-MAKING PROCESS
There is no automated decision-making process for customer profiling.
10. REPRESENTATIVE OF THE DATA CONTROLLER
In order to provide an interlocutor for all matters concerning the processing, the Data Controller has appointed a representative established in the EU pursuant to art. 27 Regulation (EU) 2016/679, by virtue of the Legal Affairs office which can be reached at the e-mail address privacy@valuelead.com.
11. CHANGES
The Owner reserves the right to modify or simply update the content of this Privacy Policy, in part or completely, also due to changes in the applicable legislation. The Data Controller will inform you of these changes and they will be binding as soon as they are published on the Site. The Data Controller therefore invites you to regularly visit this section to become aware of the most recent and updated version of the Privacy Policy, in order to always be updated on the data collected. and on the use made of it by the Owner.
12. CONTACTS
To exercise the above rights or for any other request, you can send an e-mail to privacy@valuelead.com.