EXTENDED PRIVACY STATEMENT ON THE PROCESSING OF PERSONAL DATA
Fabio Benvenuti takes Privacy, the protection and safeguard of personal data of people interacting with him very seriously.
Please, read carefully all sections of this document, as it contains important information on how your personal data are managed in relation to this website.
The purpose of this document is also to inform, pursuant to art. 13 of of the Regulation EU 2016/679 (hereafter “Regulation”) and to the applicable national regulation on personal data processing, Legislative Decree 196/2003 and subsequent amendments and addenda, anyone who interacts with the web services provided by Easydive, owned by Fabio Benvenuti, electronically accessible at the following link: https://www.easydive.it/
EASYDIVE WEBSITE AND APPS
Besides this website, Easydive provides IOS Apps to Android that can be downloded for free from the store.
Easydive Apps allow the user to manage the reserved area in the E-commerce section of the website and to fully use the cases features in order to make the best use of your smartphone or tablet. The coverage of this policy includes data managed by the Apps.
The personal data controller is Easydive, owned by Fabio Benvenuti, registered office in Montaletto di Cervia (RA), Via dell’Industria, 13 - int. 6 - VAT n.: 03130020401 – e-mail: firstname.lastname@example.org.
A. TYPE AND PURPOSE OF PROCESSED DATA
Data directly provided by the user
We only require personal data from the users (e.g. first name, second name, e-mail address, etc.) if they want to get in touch or use the services provided by this website. In such cases, the users will receive a proper policy and, if necessary, will be asked to give their consent. Data provided by the user will be processed in line with the purposes and ways described by this policy and the specifications provided individually each time.
A.1 NEWSLETTER AND MARKETING COMMUNICATIONS
Type of processed data: E-mail address
Processing purpose: marketing and commercial promotion activities such as:
- Newsletter delivery in case of registration to the related service.
- Prior user consent, delivery of commercial information also via e-mail to promote products or services, performance of client satisfaction surveys, marketing researches, promotional activities in general.
Unsubscribing from the Service
To cancel your Newsletter subscription, just click on the “Cancel subscription”/“Unsubscribe” button at the bottom of each Newsletter e-mail or send a request to the above e-mail address.
Type of processed data: First name, Second name, Order number, E-mail address
FPurpose of the treatment :
- To manage the request sent by the user
- To deliver the requested service (e.g. subscription to events, webinars, newsletters, quotations, account verification/retrieval, etc.)
- Prior user consent, delivery of commercial information through an operator, via messaging services, to promote our products or services, to perform client satisfaction surveys, marketing researches, promotional activities in general.
A.3 RESERVED AREA – E-COMMERCE
Type of processed data: Registered name/First name - Surname, Gender, VAT number/tax code, date of birth, e-mail address, geographical address (Street, number, ZIP, City, Province, Country), telephone number, payment data (e.g. Credit Card, IBAN code)
Purpose of processing:
Data will be processed for the fulfillment of obligations deriving from entering an agreement ruled by “Conditions of sale”, also:
- To manage assistance and information/contact requests;
- To manage users accounts, show contents such as wish lists and customer reviews and recommend products and services that could be of interest for the users;
- Prior user consent, delivery of commercial information to promote our products or services, performance of client satisfaction surveys, marketing researches, promotional activities in general.
- Prior user consent, profiling activities, analysis of needs and propensity to purchase of customers and use of the services, to anticipate clients’ needs and consequently adjust the offer of products and services
A.4 OTHER PURPOSES
- Contractual purposes, connected and instrumental to the establishment and management of relationships with the customers and/or to the supply of goods and services, such as the acquisition of preliminary information in view of entering an agreement.
- Meet Government obligations, communitarian rules and regulations, i.e. provisions set for by legitimate authorities and control and supervision bodies (e.g. tax, accounting, administrative authorities, etc.);
- Exercise of Controller’s rights in court and management of any disputes that may arise.
Collection of aggregate and anonymous data and information to verify the proper functioning of the website, to improve the online shop and platform.
None of this information is related to the individual-website user, and are not personally identifiable.
Collection of data and information in order to protect the security of the website and its users (anti-spam filters, firewall, virus detection) and to prevent or detect any fraud or abuse.
Data are automatically registered and can include personal data (IP address) that could be used, pursuant to the applicable relevant laws, in order to block any attempts to cause damage the website or to other users, or any damaging activity or criminal offense. In no case are such data used to identify or create a profile of the user, and they are periodically deleted.
B. LEGAL BASIS
Data that are processed through this website and services provided through it are processed on the basis of the consent and/or on the basis of contractual agreements.
C. DATA PROCESSING MODES
The processing of personal data will always be based on the principles of fairness, lawfulness, transparency and protection of confidentiality, through technical and organizational security measures, in order to guarantee a suitable level of protection.
D. OBLIGATORY OR OPTIONAL NATURE OF THE PROVISION OF THE REQUESTED DATA
Users can freely decide to whether or not provide their personal data through this website and/or its connected services. Failure to provide data, as specified on a case-by-case basis in the information provided to the user, may result in the impossibility to provide the requested service.
E. RECEIVERS AND DATA TRANSFER
Personal data will be processed by the staff in charge of developing and managing the website, who are authorized to process such data in order to achieve the aforementioned purposes and who are committed to the privacy of data or under a suitable statutory obligation of confidentiality.
Personal data will be processed by designated Data controllers who are in charge of processing data on behalf of the Controller (e.g. companies that manage and fulfill sale orders, individuals involved in the provision of Services, such as hosting providers, providers of platforms needed for the delivery of e-mail/text messages, or individuals in charge of technical maintenance services on the network hardware and electronic communication networks, developers of payment software, providers of the technological platform and payment gateway for orders placed within the framework of e-payments arrangements).
Personal data may be shared with third parties connected to the Company through agreements for the provision of services that are functional to perform the activity (such as, for example, couriers in charge of the delivery of products, auditing companies, individuals, companies or professional firms providing assistance and consultancy in administrative, legal, fiscal, financial and debt collection matters, in relation to the provision of the Services, etc.)
Data can be communicated, also without consent, to all inspection verification and control organizations, such as the Revenue Agency, ministerial bodies and competent authorities, local authorities, tax commissions of all types and at all levels, upon their request, who will process them as independent data controllers for institutional purposes and/or by law during investigations and controls. Personal data are not intended to be published or disclosed. However, in some cases, within the framework of specific campaigns promoted through the website, the users may be asked to provide their data (including photo images and audio-video files) in order to take part in extraordinary and temporary events, contests and thematic initiatives, the nature of which envisages their publication and disclosure. In such cases, the user will be notified in advance and specifically informed and, in any case, the disclosure will follow the consent acquisition.
The complete list of designated third parties can be obtained from the Controller.
The Controller within the European Union and the European Economic Area will process data. If, for technical, organizational and/or operational reasons it is necessary to resort to subjects (among those listed above) outside the European Union or the European Economic Area, please be informed that the Company will guarantee that those subjects in compliance with the applicable regulation will process data. Therefore, data transfers will be adequately guaranteed through decisions on adequacy, general contract terms models approved by the European commission or other guarantees deemed adequate. The user can request further information by contacting the following e-mail address email@example.com.
F. DATA RETENTION
Personal data processed for the purpose of Service delivery and Contractual obligations will be stored by the Controller only as long as it is necessary for the correct performance of the required service and the contract entered with the user. The Controller will keep login credentials active to allow the access to the website and the Services, until the user decides to delete the account from the Services. In any case, since personal data are processed for the delivery of Services and to allow the performance of the contract, the Controller may retain them for a longer period, in particular as long as it may be necessary to protect the Controller’s interests from any possible responsibility related to the Services. At the end of such period they will be deleted.
User’s requests and the data they contain, collected through the Contact/Customer Service area of the website, will be retained on a limited-time basis as long as it may be necessary to allow the Controller to identify the correct closure of the request and in any case as long as it may be necessary to protect the Controller’s interests from any possible responsibility. At the end of such period of time, data that allow the identification of an individual, directly or indirectly (such as first name, second name, e-mail), will be anonymized and retained as aggregate data, for statistical purposes.
The Controller will retain personal data that are processed to comply with legal obligations for the time specified by the law or by the applicable regulations.
Personal data that are processed for Marketing and Profiling purposes will be retained by the Controller until the user withdraws his/her consent. Once the user withdraws his/her consent, the Controller will not use personal data for said purposes, but may still retain them, in particular as it may be necessary to protect the Controller’s interest from any possible responsibility based on such processing.
Personal data that are processed for the purpose of Commercial Communication will be retained by the Controller until the user objects to their processing via the link included at the bottom of every information e-mail sent.
Unless otherwise stated, personal data will be processed as long as the user makes use of this website and of the services provided. In case of consent withdrawal, personal data will be retained by the Controller for demonstrating the fulfillment of his obligations, until their prescription.
G. RIGHTS OF DATA SUBJECTS
Personal data subjects may, at any time, exercise their rights of access, correction or deletion of data, of processing restriction, of opposition, of portability, as per Articles 15-21 of the Regulation, by submitting a request to the e-mail address firstname.lastname@example.org or by sending a registered letter with notification of receipt to the Controller’s address.
Please note that, for Marketing, Profiling and Commercial Communication purposes it is always possible to withdraw your consent using the relevant link included at the bottom of each communication or sending a specific request to email@example.com.
The user may also submit a complaint to the control authorities (for Italy: Data protection authority www.garanteprivacy.it), following the procedures set by the applicable law.