PRIVACY POLICY

In compliance to European Regulation on Data Protection (General Data Protection Regulation) 2016/679, with reference to Article 13, we are providing the following information on collection and processing of your personal data in the context of services and activities provided by modefinance.


Controller:

modefinance S.r.l.,

Headquarters: Building A, AREA Science Park, Padriciano 99 - 34149 Trieste (TS) - Italy

Data Protection Officer (DPO)


Please see the website (link).

Purposes of data processing:

Purposes:

  1. Creation of accounts for the ‘S-peek’ application (essential activity for providing services). Technical management, mandatory relationships, contractual and fiscal duties. Archive management, backup of report requests submitted by users (including the necessary steps to verify the correct meeting of contractual obligations). Legal basis for processing: Art. 6(1)(b) GDPR - Performance of a contract
  2. Submission of updates related to purchased reports, as well as management of comments and notes shared by users belonging to the same ‘team’ (if applicable). Legal basis for processing: Art. 6(1)(b) GDPR - Performance of a contract
  3. Providing future communications on products and services provided by the Controller, similar to the ones requested by contract, considering the legitimate interests pursued by the Controller (Art. 6(1)(f) of Reg. 2016/679), as well as your right to withdraw your consent to such type of communication after any transmission. Legal basis for processing: Art. 6(1)(f) GDPR - legitimate interests pursued by the Controller, with reference to Whereas (47) of GDPR

We also inform you that modefinance may perform statistical analysis and processing on queries submitted by users (after pseudonymisation and anonoymous rendering).

Your personal data may also be transferred to other subjects or general categories of subjects, such as

Third parties: Società informatiche

Objectives: Management, maintenance, upgrade of systems and software used by the Controller; archive management and digital record-keeping.

Comments: Art. 28 GDPR: external processors. Information: contact DPO (link)


Third parties: Network, ICT providers, providers of archive and digital record-keeping services.

Objectives: Network, ICT providers, providers of archive and digital record-keeping services.

Comments: Art. 28 GDPR: external processors. Information: contact DPO  (link)


Third parties: Advisors, professionals, law firms, technical professionals, insurance companies, brokers

Objectives: Management of fiscal and administrative aspects of the contract; court, litigation, ADR, insurance activity.

Comments: Information: contact DPO (link)


We present the period of record-keeping concerning personal data, or, if not possible, the criteria used to determine such period:

Personal data and documents: Account data

Record-keeping periods and criteriaI:  The data will be kept until the account is active on our IT systems. In case of a cancellation request

Personal data and documents: Data on the use of the service and logs

Record-keeping periods and criteriaI: The data on the use of the purchased service are kept for the period necessary to prove the correct performance of the contract, until the rights defined in the contract expire. For more information please contact DPO. (link)


We also inform you on the existence of some rights on your personal data and the procedures available to exercise them:

Right: Art. 13(2)(c) and Art. 9(2): Right to withdraw the consent

Description: You have the right to withdraw consent in any moment for any data processing for which you have given consent, as described in the above table of purposes.

In particular, the withdrawal of consent apply to processing activities used for communication of advertisement or direct marketing activities, or to perform market research or promotional activities, even if they are carried out under Art. 130(4) of Italian D.Lgs. 196/03. Withdrawal of consent does not impact on the lawfulness of previous data processing activities.

Procedures: Form available in our website (link)


Right: Art. 15: Right to access data

Description: You have the right to obtain from the controller confirmation as to whether or not your personal data concerning are being processed, and, where that is the case, access to the personal data and the following information:

  • (a) the purposes of the processing;
  • (b) the categories of personal data concerned;
  • (c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  • (d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • (e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
  • (f) the right to lodge a complaint with a supervisory authority;
  • (g) where the personal data are not collected from the data subject, any available information as to their source;
  • (h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

You have the right to receive a copy of your personal data subject to processing.

Procedures: Form available in our website (link)


Right: Art. 16 Rectification data

Description: You have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning yourself. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Procedures: Form available in our website (link)


Right: Art. 17 ‘Right to be forgotten’

Description: You have the right to obtain from the controller the erasure of personal data concerning yourself without undue delay and the controller shall have the obligation to erase your personal data without undue delay where one of the following grounds applies:

  • (a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • (b) you withdraw consent on which the processing is based, and where there is no other legal ground for the processing;
  • (c) you object to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2);
  • (d) your personal data have been unlawfully processed;
  • (e) your personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
  • (f) your personal data have been collected in relation to the offer of information society services.

This right does not apply to the extent that processing is necessary:

  • (a) for exercising the right of freedom of expression and information;
  • (b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  • (c) for reasons of public interest in the area of public health;
  • (d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, in so far as the right is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
  • (e) for the establishment, exercise or defence of legal claims.

Procedures: Form available in our website (link)


Diritto: Art. 18 Right to restriction of processing

Description: You have the right to obtain from the controller restriction of processing where one of the following applies:

  • (a) the accuracy of your personal data is contested by yourself, for a period enabling the controller to verify the accuracy of your personal data;
  • (b) the processing is unlawful and you oppose the erasure of your personal data and requests the restriction of their use instead;
  • (c) the controller no longer needs your personal data for the purposes of the processing, but they are required by yourself for the establishment, exercise or defence of legal claims;
  • (d) You have objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.

Procedures: Form available in our website (link)


Diritto: Art. 20 Right to data portability

Description: You have the right to receive your personal data, which you have provided to the controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which your personal data have been provided, if the processing is carried out on the basis of consent, on contracts and made by automated means, unless processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, and it does not adversely affect the rights and freedoms of others.

Procedures: Adequate procedures by contacting DPO (link)


Right: Right to lodge a complaint with the national Supervisory Authority for Personal Data Protection

The exercise of such rights is subject to limitations, rules and procedures provided by the Regulation and that the data subject shall be aware of and put in place. The controller shall provide information on action taken on a request to the data subject without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. The controller shall inform the data subject of any such extension within one month of receipt of the request, together with the reasons for the delay. Where the data subject makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the data subject.


Si informa che a seguito dell’adozione della Deliberazione dell'autorità Garante per la protezione dei dati personali n. 479/15 del C.D. “Codice di deontologia e buona condotta per il trattamento dei dati personali effettuato a fini di informazioni commerciali” pubblicato sulla G.U. n. 238 del 13/10/2015, modefinance srl ha istituito il portale privacy.modefinance.it per la gestione delle informazioni e delle istanze in materia di dati personali di soggetti interessati alle informazioni commerciali trattate dal Titolare nell'esercizio della Sua attività.
Per ogni approfondimento sulle politiche di privacy e sul rispetto della normativa e del codice deontologico si rinvia allo stesso.