The purpose of this document is to inform the natural person (hereinafter “Interested”) regarding the processing of his personal data (hereinafter “Personal Data”) collected by the data controller, Culture Digitali Srl, with registered office in Via Coroglio 57 , Naples (NA), CF / VAT number 09465861210, 09465861210, e-mail address [email protected] , (hereinafter the “Owner”), through the website www.culturedigitali.eu (hereinafter the “Application”).
- Categories of Personal Data processed
The Data Controller processes the following types of Personal Data provided voluntarily by the Data Subject:
- Contact details: name, surname, address, e-mail, telephone, images, authentication credentials, any additional information sent by the interested party, etc.
- Tax and payment information: tax code, VAT number, credit card details, bank account details, etc.
- Data relating to the employment relationship: data entered in the curriculum vitae, data relating to the spouse or children, social security data, etc.
- Particular (sensitive) data: Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as genetic data, biometric data intended to uniquely identify the natural person, data relating to health or life sexual or sexual orientation, collected with the consent of the interested party. The interested party can revoke the consent at any time
- Judicial data: Personal data relating to criminal convictions, crimes or related to security measures, collected with the consent of the interested party. The interested party can revoke the consent at any time.
The Data Controller processes the following types of Personal Data collected in an automated manner:
- Technical data: Personal Data produced by the devices, applications, tools and protocols used, such as, for example, information on the device used, IP addresses, type of browser, type of Internet provider (ISP). Such Personal Data may leave traces which, in particular when combined with unique identifiers and other information received from servers, can be used to create profiles of natural persons
- Navigation data and use of the Application: such as, for example, pages visited, number of clicks, actions performed, duration of sessions, etc.
- Data relating to the exact position of the interested party: for example, geolocation data that accurately identify the position of the interested party that can be collected through the satellite network (eg GPS) and other means, collected with the consent of the interested party. The interested party can revoke the consent at any time.
Failure by the interested party to provide Personal Data for which there is a legal or contractual obligation or if they constitute a necessary requirement for the conclusion of the contract with the Data Controller, will make it impossible for the Data Controller to establish or continue the relationship with the Interested.
The interested party who communicates the Personal Data of third parties to the Data Controller is directly and exclusively responsible for their origin, collection, processing, communication or dissemination.
- Cookies and similar technologies
- Legal basis and purpose of the processing
The processing of Personal Data is necessary:
- for the execution of the contract with the interested party and precisely:
- fulfillment of any obligation deriving from the pre-contractual or contractual relationship with the interested party
- registration and authentication of the interested party: to allow the interested party to register on the Application, access and be identified also through external platforms
- support and contact with the interested party: to respond to the requests of the interested party
- payment management: to manage payments by credit card, bank transfer or other tools
- by law and precisely:
- the fulfillment of any obligation required by current regulations, laws and regulations, in particular, in tax and fiscal matters
- on the basis of the legitimate interest of the Data Controller, for:
- marketing purposes via email of the owner’s products and / or services to directly sell the products or services of the owner using the e-mail provided by the interested party in the context of the sale of a product or service similar to the one being sold
- management, optimization and monitoring of the technical infrastructure: to identify and solve any technical problems, to improve the performance of the Application, to manage and organize information in a computer system (e.g. server, database, etc.)
- security and anti-fraud: to ensure the security of the Owner’s assets, infrastructures and networks
- statistics with anonymous data: to perform statistical analysis on aggregate and anonymous data to analyze the behavior of the interested party, to improve the products and / or services provided by the Data Controller and better meet the expectations of the interested party
- on the basis of the consent of the interested party, for:
- profiling of the interested party for marketing purposes: to provide the Data Subject with information on the Data Controller’s products and / or services through automated processing aimed at collecting personal information with the aim of predicting or evaluating his preferences or behaviors
- retargeting and remarketing: to reach with a personalized advertisement the interested party who has already visited or has shown interest in the products and / or services offered by the Application using his Personal Data. The interested party can opt out by visiting the page of theNetwork Advertising Initiative
- marketing purposes of the Controller’s products and / or services: to send information or commercial and / or promotional materials, to carry out direct sales of the Controller’s products and / or services or to carry out market research using automated and traditional methods
- marketing purposes of third party products and / or services: to send information or commercial and / or promotional materials to third parties, to carry out direct sales activities or to carry out market research of their products and / or services with automated and traditional methods
- communication of Personal Data for third party marketing purposes: to communicate Personal Data to third parties operating in the ICT consulting & Training sector so that they can use them to send them information or commercial and / or promotional materials or to carry out direct sales of their products and / or services or to carry out market research with automated and traditional methods
- detection of the exact position of the interested party: to detect the presence of the interested party, to control the accesses, times and presence of the interested party in a specific place, etc.
Based on the legitimate interest of the Data Controller, the Application allows interaction with external platforms or social networks whose processing of Personal Data is governed by the respective privacy policies to which please refer. The interactions and information acquired by this Application are in any case subject to the privacy settings that the interested party has chosen on such platforms or social networks. This information – in the absence of a specific consent to the processing for further purposes – is used for the sole purpose of allowing the use of the Application and providing the requested information and services.
The Personal Data of the interested party may also be used by the Data Controller to protect themselves in court before the competent judicial offices.
- Methods of processing and recipients of Personal Data
The processing of Personal Data is carried out using paper and computer tools with organizational methods and with logic strictly related to the purposes indicated and through the adoption of adequate security measures.
Personal data are processed exclusively by:
- persons authorized by the Data Controller who are committed to confidentiality or have an adequate legal obligation of confidentiality;
- subjects who operate independently as separate data controllers or by subjects designated as data processors by the Data Controller in order to carry out all the processing activities necessary to pursue the purposes referred to in this information (for example, commercial partners, consultants, IT companies , service providers, hosting providers);
- subjects or entities to which it is mandatory to communicate Personal Data by law or by order of the authorities.
The subjects listed above are required to use the appropriate safeguards to protect Personal Data and can only access those necessary to perform the tasks assigned to them.
Personal Data will not be disclosed indiscriminately in any way.
If necessary, Personal Data may be transferred to subjects located outside the territory of the European Economic Area (EEA). Whenever Personal Data should be transferred outside the EEA, the Data Controller will take all appropriate and necessary contractual measures to ensure an adequate level of protection of Personal Data, including – among others – agreements based on clauses standard contracts for the transfer of data outside the EEA, approved by the European Commission. To request information on the specific guarantees adopted, the interested party can contact the Data Controller at the following e-mail address [email protected]
- Fully automated decision-making processes
The Data Controller uses fully automated decision-making processes that can produce legal effects for the Data Subject or significantly affect them and that operate according to these criteria: Data processing for the purpose of simplifying decision-making processes.
- Retention period of Personal Data
Personal Data will be kept for the period of time necessary to fulfill the purposes for which they were collected, in particular:
- for purposes relating to the execution of the contract between the Data Controller and the Data Subject, they will be kept for the entire duration of the contractual relationship and, after termination, for the ordinary prescription period of 10 years. In the event of a judicial dispute, for the entire duration of the same, until the deadlines for appealing actions are exhausted
- for purposes related to the legitimate interest of the Data Controller, they will be kept until the fulfillment of this interest
- for the fulfillment of a legal obligation, by order of an authority and for legal protection, they will be kept in compliance with the timing provided for by said obligations, regulations and in any case until the limitation period provided for by the regulations in force
- for purposes based on the consent of the interested party, they will be kept until the consent is revoked. For marketing purposes for a period not exceeding 24 months.
At the end of the retention period, all Personal Data will be deleted or stored in a form that does not allow the identification of the interested party.
- Rights of the interested party
Interested parties may exercise certain rights with reference to the Personal Data processed by the Data Controller. In particular, the interested party has the right to:
- be informed about the processing of their Personal Data
- withdraw consent at any time
- limit the processing of your Personal Data
- oppose the processing of their Personal Data
- access your Personal Data
- verify and request the rectification of their Personal Data
- obtain the limitation of the processing of their Personal Data
- obtain the cancellation of their Personal Data
- transfer your Personal Data to another owner
- propose a complaint to the supervisory authority for the protection of personal data and / or take legal action.
To exercise their rights, interested parties can send a request to the following e-mail address [email protected] Requests will be taken over by the Owner immediately and processed as soon as possible, in any case within 30 days.
Last updated: 01/11/2021