Data Controller
SINCRONIS S.R.L.
Via Ferri, 6
20092 Cinisello Balsamo (MI) – ITALY
e-mail address: info@sincronis.eu
Types of Data Processed
Among the Personal Data processed by this Application, either independently or through third parties, there are: name; surname; e-mail; Cookie; Browsing Data.
Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific privacy policies displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Browsing Data, collected automatically during the use of this Application.
Unless otherwise specified, all data requested by this application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates some Personal 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 personal data are mandatory are encouraged to contact the owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third party services used by this Application, unless otherwise specified, is intended to provide the Service requested by the User, in addition to further purposes described in this document.
The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third parties.
Methods and Place of Processing
Methods of Processing
The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The 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 subjects involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external subjects (such as suppliers of third party technical services, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller, may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.
Basis of Processing
The Data Controller 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 of the legal bases 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 governed by European legislation regarding the protection of Personal Data;
- the processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;
- the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
- the processing is necessary for the performance of a task of public interest or for the exercise of public authority vested in the Owner;
- the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.
It is, however, always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.
Place of processing
The Data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, please contact the Data Controller.
The Data is processed at the server farm chosen by the owner within the European Union and is only handled by technical staff from the office in charge of processing. No personal data provided in the use of this Application is disseminated.
To obtain further information about the place of processing, the User can refer to the section relating to the details on the processing of Personal Data.
The Data Controller does not directly carry out any transfer of data outside the European Union. We inform the User that the Data Controller uses IT services from suppliers who could transfer data to the United States. The transfer will be made by adopting standard contractual clauses in compliance with the requirements of the European Commission.
The data is not subject to profiling.
Terms of processing
The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes.
Therefore:
- Personal Data collected for purposes related to the execution of a contract between the Data Controller and the User will be retained until the execution of the contract is completed. The personal and fiscal data and those data necessary to document the service performed are kept for the following ten years also to fulfill legal obligations to which the Data Controller is subject.
- Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until the same interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.
When the processing is based on the User’s consent, the Data Controller may keep the Personal Data longer until such consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of a legitimate authority.
At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this term the right of access, cancellation, rectification and the right to data portability can no longer be exercised.
Purpose of processing
The User’s Data are collected to allow the Controller to provide the Service, fulfill legal obligations, respond to requests or executive actions, protect their rights and interests (or those of Users or third parties), identify any malicious activities. or fraudulent, as well as for the following purposes: Contacting the User and Statistics.
To obtain detailed information on the purposes of the processing and on the Personal Data processed for each purpose, the User can refer to the “Details on the processing of Personal Data” section.
Details of Data Processing
Personal Data is collected for the following purposes and using the following services:
Contact Form (this Application)
By filling in the contact form with their data, the Users consents to their use to respond to requests for information, quotes, or any other nature indicated by the form header. Personal Data processed: surname; e-mail; name, any additional data provided voluntarily by the user in the contact form.
Mailing list or newsletter (this Application)
By registering with the mailing list or newsletter, the User’s email address is added to a list of contacts to which email messages containing information, including commercial and promotional information, relating to this Application may be sent.
Informative Communications (this Application)
The Data Controller may carry out direct informative communications to customers or to subjects who have registered with this Application on the basis of their legitimate interest. Personal Data processed: surname; e-mail; first name.
Browsing Data
The computer systems and software procedures used to operate this Application acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow Users to be identified. This category of data includes the IP addresses or domain names of the computers used by Users who connect to the site, the addresses in the Uniform Resource Identifier (URI) notation 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 (successful, error, etc.) and other parameters relating to the operating system and the User’s IT environment.
Cookies
Cookies or other identifiers consist of small portions of code, placed on the user’s device within the browser, that assist the Data Controller in providing the service based on the purposes described.
Some of the purposes of using Coookies may also require the User’s consent. If it has already been given, consent can be freely revoked at any time by following the instructions contained in this document.
Cookies are data that are sent from the website and stored by the Internet browser on the user’s computer or other device (for example, tablet or mobile phone). Technical cookies and statistical cookies may be installed from this Application or its subdomains.
In any case, the user can manage or request the general deactivation or deletion of cookies by changing the settings of their Internet browser. The deactivation, however, may slow down or prevent access to this Application or some of its parts.
The settings to manage or disable cookies may vary depending on the internet browser used. Therefore, for more information on how to perform these operations, we suggest that the User consult the manual of their device or the “Help” or “Help” function of their Internet browser.
Technical Cookies
The use of technical cookies, which are cookies strictly necessary for the Data Controller to provide the service requested by the User, allows the safe and efficient use of this Application.
Session cookies may be installed in order to allow access and stay in the reserved area of the portal as an authenticated user.
Technical cookies are essential for the correct functioning of this Application and are used to allow users to navigate normally and to take advantage of the advanced services available.
The technical cookies used are divided into session cookies, which are stored exclusively for the duration of the navigation until the browser is closed, and persistent cookies that are saved in the memory of the User’s device until their expiration or cancellation by the User (e.g. cookies to store customizations chosen by the User, such as those relating to the language).
As required by current legislation on Data Protection, the prior consent of the User is not required for the installation of these cookies. The latter, in any case, can freely block the installation of technical cookies by changing the browser settings as indicated above.
Statistical Cookies
The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.
Google Analytics with anonymized IP (Google Ireland Limited)
Google Analytics is a web analytics service provided by Google Ireland Limited (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google.
Google may use the Personal Data to contextualize and personalize the advertisements of its own advertising network.
This Google Analytics integration makes your IP address anonymous. Anonymization works by shortening the IP address of the Users within the borders of the member states of the European Union or in other countries adhering to the European Economic Area agreement. Only in exceptional cases, the IP address will be sent to Google’s servers and shortened within the United States. Personal Data processed: Cookies; Browsing Data.
Place of processing: Ireland – Privacy Policy – Opt Out. The contract with Google includes the Standard Contractual Clauses approved by the European Commission.
Rights of the Data Subject (User)
Users can exercise certain rights with reference to the Data processed by the Data Controller.
In particular, the User has the right to:
- withdraw consent at any time. The User can revoke the consent to the processing of their Personal Data previously expressed.
- oppose the processing of their data. The user can oppose the processing of their data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below.
- access their data. The User has the right to obtain information on the Data processed by the Data Controller, on the methods of processing and to receive a copy of the Data processed.
- verify and request rectification. The User can verify the correctness of their Data and request its updating or correction.
- obtain the restriction of the processing. When certain conditions are met, the User may request the restriction of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their conservation.
- obtain the erasure or removal of their data. When certain conditions are met, the User can request the cancellation of their Data by the Data Controller.
- obtain their data or have them transferred to another Data Controller. The User has the right to receive their Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain the transfer without obstacles to another Data Controller. This provision is applicable when the Data is processed with automated tools and the processing is based on the User’s consent, on a contract to which the User is a party or on contractual measures connected to it.
- file a complaint. The User can file a complaint to the competent personal data protection supervisory authority (Garante Privacy – https://www.garanteprivacy.it/home_en) or take legal action.
Details on the right object
When Personal Data are processed according to the public interest, in the exercise of public authority vested in the Data Controller or to pursue a legitimate interest of the same, Users have the right to object to the processing for reasons related to their particular situation.
Users are reminded that, if their Data is processed for direct marketing purposes, they can oppose the processing without providing any reasons. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.
How to exercise Your Rights
To exercise the User’s rights, Users can direct a request to the contact details of the Data Controller indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, within one month.
Further Information on Data Processing
Defense in court
The User’s Personal Data may be used by the Data Controller in court or in the preparatory stages for an eventual lawsuit for the defense against abuse in the use of this Application (or related Services) by the User.
The User acknowledges that the Data Controller may be obliged to disclose the Personal Data processed by order of the competent public authorities.
Other Policies
At the request of the User, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual policies regarding specific Services, or the collection and processing of Personal Data.
System log and maintenance
For needs related to operation and maintenance, this Application and any third party services used by it may collect system logs, which are files that record the interactions and which may also contain Personal Data, such as the User IP address.
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.
Response to “Do Not Track” requests
This Application does not support “Do Not Track” requests. To find out if any third-party services used support them, the User is invited to consult the respective privacy policies.
Changes to this privacy policy
The Data Controller retains the right to make changes to this privacy policy at any time by notifying Users on this page as well as, if technically and legally feasible, by sending a notification to Users through one of the contacts in possession of the Data Controller. Please consult this page frequently and refer to the date of the last modification indicated at the bottom.
If the changes concern processing based on consent, the Data Controller will collect the User’s consent again, if necessary.
Definitions and legal references
Personal Data (or Data)
Any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable constitutes personal data.
Browsing data
This is information collected automatically through this Application (including from third-party applications integrated into this Application), including: IP addresses, URI (Uniform Resource Identifier) addresses, time of request, etc.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor
The natural person, legal person, public administration and any other body that processes personal data on behalf of the Data Controller, as set out in this privacy policy.
Data Controller
The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.
This Application
The software tool through which the Personal Data of Users are collected and processed.
Service
The service provided by this application as defined in the relative terms (if available) on this site / application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.
Cookies
Small portion of data stored within the User’s device.
Legal Referencies
This privacy statement is drawn up on the basis of multiple legislative systems, including articles. 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy statement only concerns this Application.
