CONCEPTIO In Itinere S.n.C.
Via delle Sette Chiese 44/46,
00145 Rome – Italy
Contacts D.P.O. designated
as a data controller, pursuant to art. 13 Legislative Decree 30.6.2003 n. 196 (hereinafter, “Privacy Code”) and art. 13 EU Regulation n. 2016/679 (hereinafter “GDPR”) your data will be processed in the following manner and for the purposes stated below.
Types of Data Collected
Among the Personal Data collected by this Structure, either independently or through third parties, there are: Usage data, name, surname, telephone number and email address, data relating to payment systems, economic and financial data. The Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of third-party applications .. Unless otherwise specified, all the Data required by this structure are mandatory. If the User refuses to communicate them, it may be impossible for this facility to provide the Service. In cases where this structure indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation. Users who have doubts about which data are mandatory, are encouraged to contact the owner.
Purpose of the processing
Your personal data is processed:
A) without your express consent (art. 24 letter a), b), c) Privacy Code and art. 6 lett. b), e) GDPR), for the following Service Purposes:
– conclude the contracts and / or professional assignments to the Owner and Contact the User.
– fulfill the pre-contractual, contractual and fiscal obligations deriving from existing relationships with you;
– to fulfill the obligations provided for by the law, by a regulation, by EU legislation or by an order of the Authority (such as in the field of anti-money laundering);
– exercise the rights of the Owner, for example the right to defend in court;
B) Only with your specific and distinct consent (Articles 23 and 130 of the Privacy Code and Article 7 GDPR), for the following Marketing Purposes:
send you via e-mail, post and / or text message and / or telephone contacts, newsletters, commercial communications and / or advertising material on products or services offered by the Data Controller and detection of the degree of satisfaction with the quality of services; send you via e-mail, post and / or text message and / or telephone contacts commercial and / or promotional communications from third parties (for example, business partners, insurance companies).
We inform you that if you are already a customer of ours, we will be able to send you commercial communications relating to the services and products of the Data Controller similar to those that you have already received, unless you disagree (Article 130 c. 4 of the Privacy Code).
Mode and place of processing of the collected Data
The Data Controller uses appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. All security measures are listed in the GDPR’s Personal Data Protection Register. Processing is carried out using IT and / or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the organization of this Structure (administrative, commercial, marketing, legal, system administrators) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Owner. The updated list of Data Processors may always be requested from the Data Controller Without the need for express consent (pursuant to art. 24 letter a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in (Purposes of Processing 2.A) to Supervisory Bodies (eg PRIVACY GUARANTEE), Judicial Authorities, insurance company for services of insurance services, as well as to those subjects to whom the communication is obligatory by law for the accomplishment of the said purposes. These subjects will treat the data in their capacity as independent data controllers. Your information will not be disseminated.
Legal basis of the processing
The Owner processes Personal Data relating to the User if one of the following conditions exists:
the User has given consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorized to process Personal Data without the User’s consent or another legal basis specified below, as long as the User does not object (“opt-out”) to such treatment. However, this is not applicable if the processing of Personal Data is regulated by the European legislation on the protection of Personal Data New European Regulation 679/2016.the processing is necessary for the execution of a contract with the User and / or the execution of pre-contractual measures;processing is necessary to fulfill a legal obligation to which the Owner is subject;processing is necessary for the performance of a task of public interest or for the exercise of public powers vested in the Data Controller;processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.
It is in any case always possible to ask the Owner to clarify the concrete legal basis of each treatment and in particular to specify if the treatment is based on the law, provided for by a contract or necessary to conclude a contract.
The Data are processed at the Data Controller’s headquarters and in any other place where the parties involved in the processing are located. For more information, contact the owner.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of treatment, the User can refer to the section on the details on the processing of Personal Data.
The User has the right to obtain information regarding the legal basis of the transfer of Data outside the European Union or to an international organization of public international law or constituted by two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.
If one of the transfers described above takes place, the User may refer to the respective sections of this document or request information from the Data Controller by contacting him at the details indicated at the beginning.
Period of conservation
The Data is processed and stored for the time required for the purposes for which it was collected. Therefore:
The Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.The Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information on the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.
When the treatment is based on the consent of the User, the Owner may keep the Personal Data for longer until such consent is revoked. Furthermore, the Data Controller may be obliged to keep the Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the storage period the Personal Data will be deleted. Therefore, upon expiration of this term the right of access, cancellation, rectification and the right to the portability of the Data can no longer be exercised.
Users can exercise certain rights with reference to the Data processed by the Owner. In particular, the User has the right to:
As an interested party, you have the rights set forth in art. 7 Privacy Code and art. 15 GDPR and precisely the rights to:
obtain the indication: a) of the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in the case of processing carried out with the aid of electronic instruments; d) of the identification data concerning the data controller, data processors and the representative designated pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or appointees;obtain confirmation of the existence or not of personal data concerning you, even if not yet recorded, and their communication in an intelligible form;obtain: a) updating, rectification or, when interested, integration of data; b) the deletion, transformation into anonymous form or blocking of data processed in violation of the law, including data which does not need to be kept for the purposes for which the data was collected or subsequently processed;the attestation that the operations referred to in letters a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the case where such fulfillment is revealed impossible or involves the use of means manifestly disproportionate to the protected right;object, in whole or in part: a) for legitimate reasons to the processing of personal data concerning you, even if pertinent to the purpose of collection; b) to the processing of personal data concerning you for the purpose of sending advertising materials or direct sales or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by phone and / or mail. Please note that the interested party’s right of objection, set out in the previous point b), for direct marketing purposes by automated means, extends to the traditional ones and that the possibility for the interested party to exercise the right of opposition also remains valid only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.where applicable, it also has the rights referred to in Articles 16-21 GDPR (Right of rectification, right to oblivion, right to limitation of treatment, right to data portability, right to object), as well as the right to complain to the Guarantor Authority.
Details on the right to object
When Personal Data is processed in the public interest, in the exercise of public authority over which the Data Controller is invested or to pursue a legitimate interest of the Data Controller, Users have the right to oppose the processing for reasons connected to their particular situation. Users are reminded that, if their Data is processed for direct marketing purposes, they may oppose the processing without giving any reason. To find out if the Data Controller is processing data for direct marketing purposes, Users can refer to the respective sections of this document.
How to exercise rights
To exercise User rights, Users can address a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within one month.
Further information on treatment
Defense in court
The User’s Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of this Application or of the connected Services by the User. The User declares to be aware that the Owner may be required to disclose the Data by order of the public authorities
Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.