STATEMENT ON CUSTOMERS’ PERSONAL DATA PROCESSING IN ACCORDANCE WITH ART. 13 AND 14 OF REG. (EU) 2016/679.
1. OWNER AND PERSONAL DATA PROCESSOR
The personal data processor is ’MORE DI GAO XUEFENG. Registered Office: Sestiere San Marco, 1037-30124 Venice, Italy. Tel. +39 041 2960602. E-MAIL: firstname.lastname@example.org Website : www.morevenezia.com P.IVA 04581530278.
2. DATA PROTECTION OFFICER
‘MORE in accordance with art. 37 of Reg. (UE) 2016/679, has decided not to nominate a data protection officer (DPO) since it is not a public organism and it does not regularly and systematically monitor large-scale data, data on art. 9 and 10 included, as primary activity.
3. PURPOSES, METHODS AND PLACE OF PROCESSING
Customers’ personal data handled by ‘MORE, properly collected, will be processed:
- a. For purposes related to the agreement established between the parties;
- b. For purposes of a civil, fiscal and accounting nature;
- c. To fulfill obligations provided for by law, by a regulations, by Community legislation or by an Authorities disposition (such as on the subject of anti-money-laundering);
Only upon your clear and distinct consent, your data will be processed:
- d. For commercial and marketing purposes and to send newsletters concerning services offered, invitations to trade shows, events, etc.
Personal data is processed with automated and manual tools, for the strictly necessary time to achieve purposes for which it has been collected.
Specific safety measures are observed in order to avoid data loss, illicit or improper use and non-authorized access.
Processing related to services take place at aforementioned headquarters of ‘MORE and at the offices of suppliers of electronic processing services on behalf of the Company, processing is handled only by technical staff specifically nominated as responsible and/or appointed in charge of personal data processing, or by possible appointed in charge of casual maintenance operations.
4. LEGAL BASIS
The legal basis of your personal data processing is established by the law for purpose described at point b) and c) and by the agreement for purposes described at point a).
Communications of data to Public Authorities have law as legal basis too.
Your personal data processing, for the purpose described at point d) will be based on your consent, which will be revocable at any time without prejudice for processing activities conducted until the suspension.
5. PERSONAL DATA CATEGORIES AND RECIPIENTS, COMMUNICATION AND DIFFUSION FIELD
‘MORE collects personal data to supply services as described on the agreement in effect, such as, for illustrative, yet incomplete purposes: business name, telephone, e-mail address and tax code, P.I/VAT number, bank data, etc.
Data may be communicated to:
- Public Administration, for the execution of institutional functions
- Debt collection agencies
- Lawyers for legal assistance in case of controversies on the agreement
- Consultancy agencies, experts and corporations that work in several branches for the Company
- Accountant agencies
- Bank Institutes and financial societies for the usage of financial, banking and other related services
- Suppliers in order to properly fulfill the stipulated agreement
- Inspection and supervision corporations
- Internal staff for the execution of business functions
- Trading agents to support commercial negotiation
The aforementioned individuals will process data as independent data processing controller.
The aforementioned data will not be disclosed.
‘MORE also collects customers’ comments. Such content includes creative ideas, suggestions, proposals, plans, or other materials, sent to us by you whether online, by email or by postal mail.
You agree that we may, at any time, without restriction, edit, copy, publish, distribute, translate and otherwise use in any medium any comments that you forward to us. We are and shall be under no obligation (1) to maintain any comments in confidence; (2) to pay compensation for any comments; or (3) to respond to any comments.
We may, but have no obligation to, monitor, edit or remove content that we determine in our sole discretion are unlawful, offensive, threatening, libelous, defamatory, pornographic, obscene or otherwise objectionable or violates any party’s intellectual property or these Terms of Service.
You agree that your comments will not violate any right of any third-party, including copyright, trademark, privacy, personality or other personal or proprietary right. You further agree that your comments will not contain libelous or otherwise unlawful, abusive or obscene material, or contain any computer virus or other malware that could in any way affect the operation of the Service or any related website. You may not use a false e-mail address, pretend to be someone other than yourself, or otherwise mislead us or third-parties as to the origin of any comments. You are solely responsible for any comments you make and their accuracy. We take no responsibility and assume no liability for any comments posted by you or any third-party.
‘MORE utilizes cookies in our website. When you visit the Site, we automatically collect certain information about your device and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”. These data may include your:
- Device Registration Data (for example, the type of mobile device you use, your mobile device’s unique device or advertising ID, IP address, operating system and browser type),
- Device Settings (for example, your language preference)
- Mobile Carrier
- Information about how you use the Services (for example, how many times you use the Services each day)
- Requested and Referring URLs
- Location Data collected through your Device(including, for example, precise location data such as GPS and WiFi information)
We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
6. NATURE OF THE PROVISION OF DATA AND CONSEQUENCES OF A CONTINGENT REFUSAL TO ANSWER
The provision of data for the purposes described at art 3 a) b) c) is mandatory. Without it, we will not be able to guarantee services provided for in the contract. The provision of data for marketing purposes described at point 3 d) is optional and does not compromise the conclusion of the contract and the supply of the service. Therefore, you can decide not to provide any data or choose to deny, at a later stage, the possibility to process data previously provided.
7. INTERNATIONAL TRANSFER
Personal data aforementioned is transferred abroad for the following purposes:
8. DATA RETENTION PERIOD
Personal data processed for the purposes described at points a) b) c) will be stored throughout the duration of the contract relationship with our company, and also after the suspension of it for the period necessary to protect Company’s rights and allow the Company to prove the fulfillment of its obligations. Data processed for purposes different from those described at point d) will be processed for a 24-month period or, in any case, until you will not revoke your consent and/or you will not oppose to the related processing, or, at a later stage, to allow the Company to prove that the related processing activities took place in accordance with the law.
9. RIGHTS OF PERSONS CONCERNED
As person concerned, you have rights described at art. 15 GDPR and precisely the right to:
I. Obtain the confirmation of the existence or not of personal data that concerns you, even if not yet registered, and the communication of it in an intelligible form;
II. Obtain indications on:
- a) The origin of personal data;
- b) purposes and methods of processing;
- c) the logic applied in case of processing fulfilled with the aid of electronictools;
- d) The identity details of the owner and data controller, of the data processor and of the designated representative in accordance with art. 3, clause 1, GDPR;
- a)The update, the amendment or, when interested, the integration of data;
- b) the cancellation, the transformation in anonymous form or the ban of data processed in violation of law, including those for which storage, related to the purposes for which data has been collected and later processed, is not necessary;
- c) the attestation that operations described at points a) and b) have been brought to the attention, also as regards the content, of those to whom data has been communicated or disclosed, excluding the case this fulfillment turns out to be impossible or involves a use of means manifestly disproportionate compared to the customer’s right;
IV. Oppose, in whole or in part:
- a)For legitimate reasons concerning your personal data processing, even though pertinent to the purpose of data collection;
- b) to the processing of your personal data for the purpose of sending advertising material or of direct sale or of carrying out marketing research or business communication, by using automated call systems, without the intervention of an operator, via mail and/or through traditional marketing procedures via telephone and/or ordinary post.
V. We notify that the right to object of the person concerned, previously explained at point b), for marketing purposes managed via automated methods extends to traditional methods and, in any case, it does not affect the opportunity for the person concerned of exercising the right to object, even in part. Therefore, the person concerned can decide to receive communications only via traditional methods or only via automated communications or neither. When applicable, the person concerned has also rights described at art. 16-21 GDPR (Right of amendment, Right of oblivion, Right of limitation of processing, Right of data portability, Right of opposition), as well as the Right of complaint to Data Protection Authority.