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Privacy Policy

Updated 08/03/2021

— General Informations .

We are committed to protecting your privacy and treating your data clearly and transparently. In compliance with the obligations deriving from the national legislation – Legislative Decree 30 June 2003 n. 196, coordinated with the text of Legislative Decree 101/2018, and the obligations deriving from community legislation – GDPR EU Regulation no. 679/2016 – We invite you to read this information to understand the methods of processing personal data.

The document provides evidence of the nature of the personal data collected and the purposes of the processing, indicating the user’s rights in relation to the data processed. This Privacy Policy also illustrates how the personal information provided while using our website, app, platform and services (hereinafter the “services” in general) will be processed.

– 1. Holder of the treatment of personal data

Owner and manager of the processing of personal data and usage data (together “Personal Data”), is Justin Mcgill, resident in Campobello di Mazara (TP) at Via Siena n. 19 – Tax Code MCRDRA99T06C286Y / VAT number 02709360818 – email address: jmcgill@pulsing.io (hereinafter also the “Manager”).

Data processing means any operation or set of operations concerning: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, connection, communication, dissemination, destruction of data.

By not accepting the use of personal data in accordance with this information, the user should not use the Services.

The Personal Data Protection Officer (DPO) is Davide Casale, who can be contacted at the following e-mail address: jmcgill@pulsing.io.

– 2. Type of data collected

Personal data of users will be collected during navigation or when requesting the activation of services through the appropriate data collection forms / forms. Information about users may be acquired by obtaining it from the interaction methods performed. For example, cookies (small text files installed in the user’s browser) that can collect personal data may be used. Further information on how to use cookies and how to manage them can be found in the cookie policy (cookie policy). The personal data collected, also through specific forms / forms, may include: name and surname, telephone number, e-mail address, residential address, job position, company / organization you work for, professional title, IP address, type browser and language used, timing of access to the site, information on how to use the services and any other information provided. Special categories of personal data (such as data revealing racial or ethnic origin, political opinions, religious denominations) will not be processed through our services. Our services are not aimed at minors and the collection or storage of such data is not part of the policies adopted.

The data deriving from:

  • Use of our website;
  • Filling out forms on our website;
  • Registration via online forms or wizards integrated into our site and application;
  • Timing of access to the site and information on how to use the services;
  • Analysis of the aggregate or individual user behavior to evaluate the effectiveness of the strategies adopted online and offline;
  • Receiving queries from users, for example on maintenance, updating, repair or upgrade of a service or product and on the fulfillment of our obligations towards users and users;
  • Marketing initiatives relating to services;
  • Contact with support / customer service;
  • Fulfillment of obligations deriving from laws, contracts, in tax matters;
  • Fulfillment of accounting and tax obligations;
  • Consulting activities; administration of justice;
  • Litigation management.

3. Purpose of data collection and processing – Legal basis

In compliance with the provisions of art. 6 and 7 of the GDPR EU Regulation n. 679/2016, personal data will be processed for the following purposes:

  • Fulfillment of pre-contractual, contractual and tax obligations deriving from existing relationships;
  • Fulfillment of obligations under the law, a regulation, community legislation or an order of the Authority (such as for anti-money laundering);
  • Exercise of the rights of the Data Controller, for example the right to defense in court;
  • Keeping the general accounts;
  • Management purposes (invoicing, any document management, etc.);
  • Credit management;
  • Statistical analysis and quality control;
  • Browsing behavior analysis, information on the device, type of interaction;
  • Technical assistance.

Personal data will be processed for commercial and / or marketing and / or profiling purposes, with specific consent, in order to:

  • Send via e-mail, post and / or sms and / or telephone contacts of newsletters, commercial communications and / or advertising material on products or services offered by the Data Controller and / or survey of the degree of satisfaction with the quality of services;
  • Sending via e-mail, post and / or sms and / or telephone contacts of commercial and / or promotional communications from third parties (for example, business partners);

The collection and processing of the user’s personal data, for the purposes indicated above, will take place on the assumption of the following conditions of legitimacy (legal basis of the processing):

  • Technical and functional access to services and / or the site;
  • Advanced navigation and / or personalized content management purposes;
  • Statistical purposes, profiling and analysis of user navigation;
  • Compliance with legal obligations, compliance with requests from Authorities, Public Bodies and Bodies, for the exercise of rights, including possibly third parties, in court as well as, where required, in administrative offices or in arbitration or conciliation procedures;

As regards the disabling of profiling cookies, please refer to what is specifically provided for in the document containing the cookie policy.

4. Processing methods

In compliance with the provisions of the GDPR EU Regulation no. 679/2016 – art. 4 n. 2), the processing of personal data is carried out by means of the operations of: collection, registration, organization, structuring, conservation, adaptation, modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation, destruction or blocking. Personal data are subjected to paper, electronic and / or automated processing. All treatments are carried out in such a way as to guarantee the security and confidentiality of the data.

5. Accesso, condivisione e comunicazione dati

Personal data will not be published, disseminated, exhibited or made available and / or consulted by indeterminate subjects.

The data collected may be made accessible, for the purposes referred to in the previous point n. 4 of this Privacy Policy, to:

  • Employees and collaborators of the Data Controller in Italy and abroad, in their capacity as persons in charge and / or internal managers of the processing and / or system administrators. In any case, access to personal data is reserved solely and exclusively for the persons, employees and collaborators of the Data Controller, who “need to know” such information;
  • Third parties for the installation of cookies as required by the cookie policy of this site, these subjects will process the data in their capacity as independent data controllers;
  • Competent authorities, for the performance of their institutional functions within the limits established by laws or regulations, these subjects will process the data in their capacity as independent data controllers.

6. Data transfer

Personal data are stored on devices located at the headquarters of the Data Controller, at the provider or server within the European Union. The Data Controller has adopted appropriate technical and organizational measures to ensure an appropriate level of security, in full compliance with the provisions of art. 32 of the EU Regulation, for the storage and management of personal data on their devices, providers and servers in use. The Data Controller, if necessary, will have the right to move the data even to non-EU countries. In this case, the transfer of non-EU data will take place in compliance with the applicable legal provisions, subject to the stipulation of the contractual clauses and standard checks provided by the European Commission.

7. Nature of the provision of data and consequences of refusal to respond

The granting of consent to the processing of Personal Data provided by the Customer is necessary for the purposes indicated in this document. The provision of data is mandatory for the purposes of: fulfillment of pre-contractual, contractual and tax obligations deriving from existing relationships; fulfillment of obligations under the law, a regulation, community legislation or an order of the Authority (such as for anti-money laundering); exercise of the rights of the Data Controller, for example the right to defense in court; keeping the general accounts; management purposes (invoicing, any document management, etc.); credit management; statistical analysis and quality control; browsing behavior analysis, information on the device, type of interaction; technical assistance. In case of refusal to provide consent, it will not be possible for the Manager to provide the Service to the Customer. The provision of data, for commercial and marketing purposes, is optional. In this case, the user may decide not to provide any data or subsequently deny the possibility of processing data already provided. It is understood that, in this case, the user will not be able to receive newsletters, commercial communications and advertising material and / or anything else related to the services offered by the Data Controller.

8. Data retention times and information deletion

The Data Controller will keep and process personal information for as long as necessary for the purposes of what is indicated in point n. 4 of this Privacy Policy and in compliance with the periods provided for by the applicable regulations and provisions. With reference to the personal data being processed for marketing purposes or processing for profiling purposes, the same will be kept in compliance with the principle of proportionality and in any case until the purposes of the processing have been pursued or until the revocation of the specific consent by the interested party. Personal data will, in any case, be processed lawfully, according to fairness and transparency, protecting the privacy and rights of the user. The information and personal data collected will be deleted when they are no longer necessary for the purposes for which they were originally collected. Compliance with the laws in force at the time of cancellation will be guaranteed. In any case, the user can send a request to the Data Controller or Data Processor to obtain the cancellation of their data, also by registered letter or certified e-mail.

9. Rights of the interested party and methods of exercise

In relation to personal data, the user has the right to:

  • Confirmation of the processing of personal data and request a copy of the same;
  • Request the updating, integration, correction of personal data that it deems incorrect or incomplete;
  • Request the deletion of personal data or limit the methods of use of the same;
  • Withdraw consent to the processing of personal data (to the extent that the processing is based on consent);
  • Receive a copy of their personal data in a structured, commonly used format and transmit the same to a third party (to the extent that the processing is based on consent or a contract);
  • Oppose the processing of personal data;
  • Data portability, i.e. to receive a copy of personal data processed on the basis of the consent of the same user and obtain the transmission of personal data to another owner, if technically feasible;
  • Lodge a complaint with the Guarantor for the protection of personal data or appeal to the judicial authority.

In case of transfer of personal data to a third country or to an international organization, the interested party / user will have the right to be informed of the existence of adequate guarantees pursuant to art. 46 of the EU Regulation relating to the transfer. The interested party will have the right to request a copy of the personal data being processed, upon request addressed to the Data Controller. In the event of a request for further copies, the Data Controller will have the right to request the payment of an expense contribution proportionate to the administrative costs. If the access request is made by electronic means, unless otherwise indicated by the interested party, the requested information will be provided in a commonly used electronic format. In any case, the right to obtain a copy of the personal data being processed must not affect the rights and freedoms of others. The interested party, at any time, may exercise the right to revoke any consent already expressed without prejudice to the lawfulness of the processing based on the consent given before the revocation.

The interested party, at any time, also in order to exercise all the rights listed above, may contact:

  • Justin Mcgill – owner and manager of data processing – by sending a communication by registered letter with return receipt to the address: Via Siena n. 19 – 91021 Campobello di Mazara (TP) or by sending communication by email to the address: jmcgill@pulsing.io;
  • Davide Casale – responsible for the protection of personal data (DPO) – by sending communication by email to the address: jmcgill@pulsing.io

10. User Obligations

The user, user of the services, undertakes to guarantee the truthfulness of the information provided. All personal data transmitted must be truthful, correct and up to date. The user assumes full responsibility for ensuring that the information provided is accurate, updated and compliant with this principle.

11. Changes to the privacy policy

The introduction of new sector regulations and the constant examination and updating of the services offered may lead to the need to vary the methods of processing personal data. This information, therefore, may undergo any changes over time. It will be the responsibility of the user / interested party to periodically consult this page by viewing the revision date of the information. The new amended or corrected information will apply from the revision date.

12. Forms and useful links

This information is regularly reviewed, the most recent version will be made available on the website. This privacy policy was updated on 06.07.2021.