E.Built S.r.l. with registered office at ____ Naples, Italy, acting as Data Controller (hereinafter, “E.Built”), advises, in accordance with Article 13 of Regulation (EU) No. 2016/679 of the European Parliament and of the Council of 27 April 2016 (the General Data Protection Regulation or “GDPR”), that it will use the data of users (hereinafter, “User” and/or “Users”) collected through the website www.compassesworld.com (hereinafter, the “Website”) in the manner and for the purposes described below.
I. TYPE OF DATA PROCESSED BY E.BUILT THROUGH THE WEBSITE
E.built processes the following types of personal data (hereinafter, “Data”) provided by Users of the Website when browsing and/or subscribing to the newsletter:
- Data obtained while a User is browsing on the Website
- Data provided by Users
Most of the pages and content on the Website are accessed by the User (“Unregistered User”) without requiring his/her identification for browsing purposes. Logging on and browsing the Website does not require any registration, except when subscribing to the newsletter. In this case, the User shall provide the following personal details to E.built: full name (first name and surname), e-mail address, country of residence, telephone number.
II. PURPOSE OF THE PROCESSING
The Data provided by Users, both registered and non-registered, will be processed without the Users’ prior consent in accordance with Article 6, letter b) of the GDPR, for the following purposes of the service:
- to manage and process statistical surveys on Website use;
- to perform the maintenance and technical assistance necessary to ensure the proper functioning of the Website and its related services;
- to improve the quality and structure of the Website and to create new services, functions and/or features thereof;
- to process any contact request submitted by the User while filling out the specific form or by e-mail, for example to receive explanations on the services offered by E.built;
- to enable E.built to exercise its rights in court and to crack down on illegal conduct;
- to fulfil legal obligations or comply with regulations.
The Data provided by registered Users and by Professional Users will be processed with the Users’ consent, which will be separate, specific and individual for every item of this paragraph, in accordance with Article 6, letter a) of the GDPR, for the following purposes:
- to allow sending commercial, promotional and advertising notices to registered Users through automated systems, such as e-mail, on products, activities and/or services offered by E.built and newsletters containing insights on the main topics related to architecture;
- The data provided by the registered User will be processed with the User’s consent, which will be separate, specific and individual for every item of this paragraph, in accordance with Article 6, letter a) of the GDPR, for the following purposes:
- to allow sending commercial, promotional and advertising notices to registered Users through automated systems, such as e-mail, on products, activities and/or services offered by E.built.
III. NATURE OF THE PROVISION OF DATA
The provision of data by the User is mandatory for the purposes of the service referred to under Clause 2, paragraph 1 above. However, any refusal to provide such data may make it impossible to provide the services.
However, the provision of data by the User is voluntary and optional (and may be withdrawn without any formality, even after providing the service, by sending an e-mail to firstname.lastname@example.org) for the purposes referred to under Clause 2, paragraph 2 and. Any refusal to provide Data will therefore only result in, failure to send commercial notices on products, activities or services to the User offered by E.built. In any event, the User may still use the services described under Clause 2, paragraph 1 above.
IV. MEANS OF PROCESSING AND STORAGE
- The processing of the User’s personal data is carried out through the operations indicated in Article 4(2) of the GDPR, and specifically: collection, recording, organisation, storage, consultation, elaboration, modification, extraction, comparison, access, use, alignment, restriction, dissemination, erasure or destruction;
- The User’s Data are processed manually and with automated instruments, and only for the period necessary for the purposes for which they were collected and, in any case, for a period no longer than 10 years from their collection for the purposes of the service referred to at Clause II, paragraph 1, above, and for a period no longer than 10 years from their collection for the purposes referred to at Clause II, paragraphs 2 and 3, above.
- The User’s data will be processed by persons specifically authorised to carry out the tasks referred to at Clause I above; they will always be duly identified and instructed and informed on any security obligations imposed by the GDPR and E.built.
V. ACCESS TO DATA
Data may only be made accessible for the above purposes to the following persons:
- Employees and staff of E.built or its affiliates and/or parent company, in their capacity as persons authorised to process the Data;
- Third-party entities or other persons (including, without limitation, associations or professional firms providing consulting and advisory services and especially, without limitation, IT management services for the IT system used by E.built S.p.A. and telecommunication networks, providers, and email management services, in their capacity as processors.
VI. DISCLOSURE OF DATA
Without the User’s prior express consent (under Article 6, points (b) of the GDPR), E.built may only disclose the User’s data for the purposes of the Service referred to at Clause II, paragraph 1, to supervisory bodies, judicial authorities and any other entities to which such disclosure must be made under the law for the above purposes, in their capacity as independent controllers. The User’s data will not be disclosed.
VII. TRANSFER OF DATA
The Data obtained from the registered User for the purpose of sending commercial messages via e-mail relating to E.built’s products, events and/or services and/or newsletters with insights on the main topics concerning pet nutrition, health, wellness are processed in computerised form. These Data will be processed and stored within the European Union.
In any other case, Data will be managed and stored in servers held by E.built within the European Union.
VIII. THIRD-PARTY WEBSITES
Please note that, to the extent the Website contains links to third-party websites, E.built has no control over their content and will not have access to personal data concerning the users of those websites.
The owners of those websites will be the exclusive data controllers and processors with regards to their users. E.built assumes no responsibility for third-parties’ activities or any liability, damage or cost resulting from any failed or incorrect processing by third-parties.
IX. USER’S RIGHTS
The User may exercise the rights referred to in Article 15 of the GDPR.
More specifically, the User will have the right to obtain from E.built confirmation as to whether or not Data concerning him or her are being processed, including prior to the User’s registration, and to obtain such Data in intelligible form.
The User will have the right to obtain confirmation as to:
- the origin of the Data;
- the purposes and means of the processing;
- the rationale of any processing carried out by automated means;
- the identification information on the controller, the processors and the designated representative;
- the persons or categories of persons to whom the Data may be disclosed in their capacity as designated representatives in Italy, processors or persons in charge of the processing;
- the retention periods.
The User will also have the right to obtain:
- the update, rectification or, when it is in his or her interest, integration of Data;
- the erasure or anonymisation, or the restriction of the processing, of any Data processed in violation of any laws, including Data whose retention is not necessary for the purposes for which they have been collected or processed;
- a certification that the activities indicated at letters (a) and (b) above were notified – including with regards to their content – to the persons that received that Data, unless this proves impossible or involves disproportionate effort compared to the right being protected.
The User will have the right to object, in whole or in part, to: (1) if he or she has legitimate grounds to do so, the processing of Data concerning him or her, including if they are within the scope of the processing; (2) the processing of Data concerning him or her for the purpose of sending advertising material or carrying out direct sales or market surveys or commercial communications (e.g. newsletters).
The User will have the right to
- obtain the restriction of the processing of Data or object to such processing;
- data portability, i.e. to receive the Data from the controller in a structured, commonly used and machine-readable format, and transmit those data to another controller without hindrance from the initial controller;
- withdraw his or her consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
- lodge a complaint with the Supervisory Authority.
Any rectification or erasure of Data or restriction of processing will be communicated to each recipient to whom the Data have been disclosed, unless this proves impossible or involves disproportionate effort. The User will have the right to receive a list of those recipients upon request.
The User may exercise these rights without any restriction, free of charge and by sending an e-mail to email@example.com.
X. WITHDRAWAL OF CONSENT AND OBJECTION
If the User has given his or her consent to the processing for the purposes referred to at paragraph 2 and 3, above, he or she may withdraw that consent at any time by sending a clear e-mail, without any specific formalities, at firstname.lastname@example.org or by clicking on the related link.
After receiving this opt-out request, E.built will immediately erase any Data and instruct any third-party to whom the Data has been disclosed to do so as well. The reception of this opt-out request will constitute confirmation that the Data have been erased.
The User is specifically and expressly informed that, under Article 21 of the GDPR, he or she will have the right to object at any time to processing of Data concerning him or her and, where the User objects to the processing of Data for direct marketing purposes, such Data will no longer be processed for such purposes.
XI. DATA CONTROLLER AND DATA PROCESSOR
- The data controller is E.built S.r.l.e-mail: email@example.com
- The data processors is E.built S.r.l. with registered office at Naples (Italy), e-mail firstname.lastname@example.org as Website operator.
A complete and updated list of the persons in charge of the processing is available at E.built’s registered office and may be requested as indicated at Clause X above.
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