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Privacy Policy

This Web Site collects some Personal Data of its Users.

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Data Controller

No Digital Brain srls – via F. Baracca 26 – 00043 Ciampino (RM)

Holder’s email address: info@nodigitalbrain.com

 

Data Protection Officer (in Italian, Responsabile della Protezione dei Dati)

Paolo Meliddo

DPO email address: dpo.nodigitalbrain@paolomeliddo.it

 

Types of Data Collected

Among the Personal Data collected by this Web Site, either independently or through third parties, are: first name; last name; phone number; email; Curriculum Vitae; Tax Identification Number; payment information; billing address; Tracking Tool; Usage Data; answers to questions; clicks; keypress events; motion sensor events; mouse movements; position relative to scrolling; and touch events.

Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected during the use of this Web Site.
Unless otherwise specified, all Data requested by this Web Site is mandatory. If the User refuses to disclose them, it may be impossible for this Web Site to provide the Service. In cases where this Web Site indicates certain Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
Users who are in doubt about which Data are mandatory are encouraged to contact the Data Controller.
Any use of Cookies – or other tracking tools – by this Website or the owners of third party services used by this Website, unless otherwise specified, is for the purpose of providing the Service requested by the User, in addition to the additional purposes described herein and in the Cookie Policy, if available.

The User assumes responsibility for third party Personal Data obtained, published or shared through this Web Site and warrants that he or she has the right to communicate or disseminate it, releasing the Owner from any liability to third parties.

 

Purposes of the Processing of Collected Data

User Data is collected to enable the Owner to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), detect possible malicious or fraudulent activities, as well as for the following purposes: Contacting the User, Sending commercial offers, Collecting and evaluating applications for work collaborations, Statistics, Protection from SPAM, Payment management and Displaying content from external platforms.

To obtain detailed information on the purposes of processing and the Personal Data processed for each purpose, the User may refer to the section “Personal Data Processing Details.”

 

Method and place of processing of collected Data

Mode of treatment

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out by means of computer and/or telematic tools, with organizational methods and logic strictly related to the indicated purposes. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Web Site (administrative, sales, marketing, legal, system administrators personnel) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller may have access to the Data. An up-to-date list of Data Processors can always be obtained from the Data Controller.

Legal basis for processing

The Owner processes Personal Data related to the User if one of the following conditions exists:

  • The User has given consent for one or more specific purposes, such as:
    1. Contact activities and operational communication with the Owner;
    2. Communication for commercial offers;
    3. Evaluation of applications for work collaborations;

Note: In some jurisdictions, the Data Controller may be authorized to process Personal Data without the need for the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such processing. However, this does not apply if the processing of Personal Data is regulated by European legislation on the protection of Personal Data;

  • processing is necessary for the performance 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 Controller is subject;
  • the processing is necessary for the performance of a task of public interest or the exercise of public authority vested in the Controller;
  • processing is necessary for the pursuit of the legitimate interest of the Owner or third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.

Location

The Data are processed at the operational offices of the Data Controller and at any other place where the parties involved in the processing are located. For more information, contact the Holder.
The User’s Personal Data may be transferred to a country other than the country in which the User is located. To obtain more information about the location of processing, the User may refer to the section on Personal Data Processing Details.

The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect the Data.
The User may verify whether any of the transfers just described takes place by reviewing the section of this document on details of the processing of Personal Data or request information from the Controller by contacting it at the contact details given at the beginning.

Retention period

Data are processed and kept for the time required by the purposes for which they were collected.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract (including billing) between the Owner and the User will be retained for 10 years from when the performance of that contract is completed.
  • Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until that interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.
  • Personal Data collected with the User’s consent will be stored as follows:
    • operational contact data, only for the period necessary for the contact itself (in the absence of contractual finalization) or until the end of the contractual relationship between the Owner and the User;
    • data for sending commercial offers, for 24 months from the collection of consent, unless extended for an additional 24 months with new consent collection;
    • data of applicants for labor collaborations, for 12 months for unsuccessful applications, or for 10 years from when the labor collaboration relationship is terminated.

When processing is based on the User’s consent, the Data Controller may retain Personal Data for the periods indicated unless said consent is revoked. In addition, the Data Controller may be required to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period, the Personal Data will be deleted. Therefore, upon the expiration of this period, the right of access, deletion, rectification and the right to Data portability can no longer be exercised.

 

Details of the processing of Personal Data

Personal Data are collected for the following purposes and using the following services:

– Contact User

Contact Form (this Website)

Personal Data Processed: last name; first name; email; phone number.

The User, after filling in with their Data in the contact form, explicitly expresses consent to their use to respond:

  • to requests for information, quotation, or any other nature indicated by the header of the form;
  • For commercial or promotional purposes related to this Web Site and the Owner.

Contact by phone (this Website)

Personal data processed: phone number; email.

Users who have provided their phone number and email may be contacted for commercial or promotional purposes, as well as to fulfill support requests.

– Payment management

Personal Data Processed: last name; email; billing address; payment information; name; Tracking Tool.

Unless otherwise specified, this Web Site processes all payments by credit card, wire transfer, or other means through external payment service providers. Therefore, Users provide payment details and personal information directly to such payment service providers.
This Web Site is not involved in the collection and processing of such information: instead, you will only receive notification from the payment service provider in question about your payment.

Stripe

Stripe is a payment service provided by Stripe Technology Europe Ltd or Stripe Payments Ltd, depending on where this Web Site is used.

Place of processing: Ireland – Privacy Policy; United Kingdom – Privacy Policy.

– Protection from SPAM

This type of services analyzes traffic on this Web Site, potentially containing Users’ Personal Data, in order to filter it from parts of traffic, messages and content recognized as SPAM.

Google reCAPTCHA (Google LLC)

Google reCAPTCHA is a SPAM protection service provided by Google LLC.
Use of the reCAPTCHA system is subject to Google’s privacy policy and terms of use.

Personal Data Processed: clicks; Usage Data; keypress events; motion sensor events; touch events; mouse movements; scrolling relative position; answers to questions; Tracking Tool.

Place of processing: United States – Privacy Policy.

– Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to track 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 Website, compiling reports, and sharing them with other services developed by Google.
Google may use Personal Data to contextualize and personalize ads in its ad network.
This Google Analytics integration anonymizes your IP address. Anonymization works by abbreviating within the borders of the member states of the European Union or other countries that are members of the European Economic Area agreement the IP address of Users. Only in exceptional cases will the IP address be sent to Google’s servers and abbreviated within the United States.

Personal Data Processed: Usage Data; Tracking Tool.

Place of processing: Ireland – Privacy Policy – Opt Out.

– Viewing content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Web Site and interact with them.
This type of service may still collect data on web traffic related to pages where the service is installed, even when users are not using it.

Google Fonts (Google Ireland Limited)

Google Fonts is a font style display service operated by Google Ireland Limited that allows this Web Site to integrate such content within its pages.

Personal Data Processed: Usage Data; Tracking Tool.

Place of processing: Ireland – Privacy Policy.

 

Further information on the processing of Personal Data

– Online sale of goods and services

The Personal Data collected is used for the provision of services to the User or the sale of products, including payment and possible delivery. The Personal Data collected to finalize the payment may be those related to the credit card, bank account used for the transfer, or other payment instruments provided. The Payment Data collected by this Web Site depends on the payment system used.

 

User Rights

Users may exercise certain rights with respect to the Data processed by the Data Controller.

In particular, the User has the right to:

  • revoke consent at any time.The User may revoke consent to the processing of his or her Personal Data previously given.
  • object to the processingof your Data.You may object to the processing of your Data when it is done on a legal basis other than consent. Further details on the right to object are given in the section below.
  • access your Data.You have the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing, and to receive a copy of the Data processed.
  • verify and request rectification.Users may verify the accuracy of their Data and request that it be updated or corrected.
  • obtain restriction of processing.When certain conditions are met, the User may request restriction of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
  • Obtain the deletion or removal of their Personal Data.When certain conditions are met, Users may request that their Data be deleted by the Data Controller.
  • receive its Data or have it transferred to another owner.You have the right to receive your Data in a structured, commonly used, machine-readable format and, where technically feasible, to have it transferred unimpeded to another owner. This provision is applicable when the Data are processed by automated means and the processing is based on the User’s consent, a contract to which the User is a party, or contractual measures related thereto.
  • Proposea complaint.The User may propose a complaint to the relevant data protection supervisory authority or take legal action.

Details of the right to object

When Personal Data are processed in the public interest, in the exercise of public powers vested in the Data Controller or in pursuit of a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are advised that if their Data were processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise rights

To exercise the User’s rights, Users may address a request to the contact details of the Owner set out in this document. Requests are filed free of charge and processed by the Holder as quickly as possible, in any case within one month.

 

More information about the treatment

Litigation defense

The User’s Personal Data may be used by the Owner in legal proceedings or in the preparatory stages to its possible establishment for the defense against abuses in the use of this Web Site or related Services by the User.
The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific disclosures

Upon the User’s request, in addition to the information contained in this privacy policy, this Web Site may provide the User with additional and contextual disclosures regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For operation and maintenance purposes, this Web Site and any third-party services it uses may collect system logs, which are files that record interactions and 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 Web Site does not support “Do Not Track” requests.

Do Not Track (DNT) is a browser feature that allows users to have more control over the information collected by the websites they browse. Specifically, when the user activates the Do Not Track feature in his or her browser settings, every website he or she browses is prompted not to track the user. Because this website does not support Do Not Track requests, even if the browser sends them, DNT actually has no effect. To find out whether any third-party services used support them, the User is encouraged to consult their respective privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Website as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details it has. Therefore, please consult this page frequently, referring to the date of last modification indicated at the bottom.

If the changes affect processing whose legal basis is consent, the Owner will re-collect the User’s consent, if necessary.

Definitions and legal references

Personal Data (or Data)

Personal data is any information that, directly or indirectly, including in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data

This is the information collected automatically through this Web Site (including by third party applications integrated into this Web Site), including: the IP addresses or domain names of the computers used by the User who connects with this Web Site, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc..) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the length of time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the User’s operating system and computer environment.

User: the individual using this Web Site who, except where otherwise specified, coincides with the Data Subject.

Data Subject: the natural person to whom the Personal Data refers.

Data Processor (or Processor): the natural person, legal entity, public administration and any other entity that processes personal data on behalf of the Controller, as set out in this privacy policy.

Data Controller (or Controller) means the natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data and the means adopted, including the security measures relating to the operation and use of this Web Site. The Data Controller, unless otherwise specified, is the owner of this Web Site.

Data Protection Officer (or Data Protection Officer): the natural or legal person appointed by the Data Controller who oversees compliance with and application of the regulation and legislation on the protection of personal data, assesses risks, informs and raises awareness, and cooperates with the Data Protection Authority.

This Web Site (or this Application): the hardware or software tool by which Users’ Personal Data are collected and processed.

Service: the Service provided by this Web Site as defined in the relevant terms (if any) on this site/application.

European Union (or EU): unless otherwise specified, any reference to the European Union in this document shall be deemed to extend to all current member states of the European Union and the European Economic Area.

Cookies: Cookies are Tracking Tools that consist of small portions of data stored within the User’s browser.

Tracking Tool: Tracking Tool means any technology – e.g., cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting – that enables tracking of Users, for example, by collecting or storing information on the User’s device.

Legal references

This privacy policy is prepared based on multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679 and other Italian data protection laws such as Legislative Decree. 196/2003 and its revised Leg. 101/2018.

Unless otherwise specified, this privacy policy covers this Web Site only.

Last modified: February 15, 2023

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