Privacy notice (GDPR EU Regulation 2016/679)
EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”) provide a series of rights to protect personal data and ensure treatment of same without prejudice to fundamental rights and freedom, dignity, security, personal identity and right to protection of personal data.
Treatment of personal data means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (art. 4 paragraph 1 no 2) GDPR).
Therefore, Noovle S.r.l., with offices in Via della Giustizia n. 10 – Milan – Italy, VAT/Tax code IT08212960960 acting as Data Controller (also referred to as “Data Controller” in this document), represented by its authorized acting legal representative, as per article 13 GDPR and applicable provisions of the Italian Legislative Decree no. 196/2003 and its subsequent modifications, hereby
You as Data Subject that, in relation to the discussions, activities and information exchanges relevant to potential agreement(s) for the provision to You (and/or to Your Company) of product and services of Noovle and affiliate companies (“Noovle Group”), and/or sale/provision by Noovle Group of third party goods/services, Your personal data will be processed by Noovle Group, acting as Data Controller, as follows:
1. TYPES OF DATA SUBJECT TO PROCESSING
The Data Controller, also acting through agents/employees/consultants, will process Your personal data, as voluntarily provided by You to Noovle Group after provision of this notice and/or acquired by Noovle Group through its website(s) and/or through employees/agents/affiliates.
Data will include, by way of example, name, surname, mobile phone number, email address and your contact details in general.
Your personal data, as above, will be processed in compliance with our internal privacy regulations and policies, including technical regulations, e-mail and Internet policies and security policies.
2. PURPOSE, LEGAL BASIS AND OPTIONAL NATURE OF THE PROCESSING
Your personal data will be processed for the following purposes:
a) execution of contract(s) and/or pre-contractual measures;
b) fulfil any legal obligations concerning personal data which is processed;
c) manage contracts with You, including, but not limited to, any processing required by Law for tax aspects and public security/health aspects;
d) keep our internal records updated and accessible to our employees, external agents and consultants, which are involved in the provision of services of Noovle Group to Noovle Group’s clients, but without any transfer, without consent, to third parties;
e) performing activities which allow You to evaluate Noovle product/services and/or products/services of Noovle partners, through dedicated events, communications (SMS, phone, e-mail, mail) activities of agents/affiliates;
f) Provide support on products/services;
g) Provide requested commercial information and fulfil Your commercial requests;
The processing legal basis for purposes a) and b), c) d) are respectively articles 6(1)(b) and 6(1)(c) of the Regulation. Providing your personal data for purposes a) and b), c) and d) above is optional and data will be processed by us only with Your consent unless article 6(1)(c) of the Regulation applies, but if data is not fully provided by You it will not be possible to provide information on products/services to You and/or allow You to take part in promotional events and, in case You wish to enter into an agreement to acquire products and services, it may not be possible to fully or partially execute the contract and provide requested services.
Your personal data will also be processed, only if further specific consent is provided, for the following purposes:
h) sending sales, promotional and marketing communications relevant to products of Noovle Group, including forwarding newsletters and market research, through automated (SMS, MMS, email, push notifications) and non-automated tools (paper mail, telephone with operator); if, however, you wish to oppose the processing of your data for marketing purposes performed with the means indicated herein in paragraph “e)”, as well as revoke the consent given; you may do so at any time by contacting the Data Controller at the addresses indicated in this statement, without prejudice to the lawfulness of the processing based on the consent given prior to the revocation;
f) sending sales, promotional and marketing communications relevant to products of trusted commercial partners of Noovle Group, including forwarding newsletters and market research, through automated (SMS, MMS, email, push notifications) and non-automated tools (paper mail, telephone with operator) and communicating Your personal data to said trusted partners operating in the fields of IT Cloud, Saas, IaaS, management/analysis software, web and similar sectors; if, however, you wish to oppose the processing of your data for marketing purposes performed with the means indicated herein, as well as revoke the consent given; you may do so at any time by contacting the Data Controller at the addresses indicated in this statement, without prejudice to the lawfulness of the processing based on the consent given prior to the revocation;
The processing legal basis for purposes e) and f) is art. 6(1)(a) of the Regulation.
Providing your Personal Data for the purposes referred to in point e) above is optional; in case of refusal the only consequence is that You will not receive any marketing/promotional information from Noovle and You will only receive communications which are essential to the provision of the specific service(s) You requested.
Processing of personal data as above will be carried out with paper and/or electronic means, always as provided by applicable data protection Laws and relevant security measures, as per article 32 of the Regulation.
3. RECIPIENTS AND TRANSFER OF PERSONAL DATA
a) Your Personal Data may be shared, without necessity of specific consent with:
– the other companies belonging to the Group;
– natural persons authorized by the Data Controller to process the personal data after signing a confidentiality agreement (e.g. employees and system administrators of the Data Controller);
– consultants for accounting and administrative purposes, which typically act as Data Processors;
– persons, bodies or authorities to whom it is mandatory to communicate your Personal Data pursuant to legal provisions or orders from the authorities.
b) Your Personal Data may be shared, if we have your specific consent, with:
– commercial partners of Noovle for the purposes of directly sending to You their sales, promotional and marketing communications, including forwarding newsletters and market research, through automated (SMS, MMS, email, push notifications) and non-automated tools (paper mail, telephone with operator).
Providing your Personal Data for the purposes referred to in point b) above is optional; in case of refusal the only consequence is that You will not receive any marketing/promotional information from our Partners.
4. TRANSFER OF YOUR PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA
Regarding the possible transfer of Data to Third Countries, the Data Controller discloses that the processing will take place according to one of the methods permitted by the law in force, such as the consent of the interested party, the adoption of Standard Clauses approved by the European Commission, the selection of subjects adhering to international programs for free circulation of data (eg EU-USA Privacy Shield) or operating in countries considered safe by the European Commission. It is possible to have more information, upon request, from the Data Controller to the above contacts.
5. STORAGE OF PERSONAL DATA
Your Personal Data will be stored for the time strictly necessary to perform the services provided for in the mandate which, if not otherwise specified in the mandate or if Your requests do not require a superior duration, is estimated in 24 months.
This without prejudice to the further storage required by the applicable legislation. Further information is available from the Data Controller.
6. YOUR PRIVACY RIGHTS PURSUANT TO ART. 15 ET SEQ. OF THE REGULATION
You have the right to ask the Data Controller or the Data Processor (articles 12-22 of the Regulation), at any time, to access your data, correct or delete them or request the limitation of processing, or obtain in a structured format, commonly used and readable by automatic device, the data concerning you in the cases provided for by art. 20 of the Regulation.
We also inform you that you have the right to oppose ex art. 21 of the Regulation, for legitimate reasons, the processing of data. For example, you may oppose at any time the forwarding of direct marketing with automated (SMS, MMS, email, push notifications) and non-automated tools (paper mail, telephone with operator); furthermore, the possibility of exercising this right in part remains unaffected, that is, for example, by opposing solely the forwarding of promotional communications only via automated tools. At any time you may revoke under art. 7 of the Regulation any consent already given, without prejudice to the lawfulness of the processing carried out prior to the withdrawal of consent. Requests must be sent in writing to the Data Controller at the following address email@example.com .
In any case, you are always entitled to lodge a complaint with the competent supervisory authority, (e.g. if You are in Italy the Italian Data Protection Agency www.garanteprivacy.it, if You are in Malta, the Office of the Information and Data Protection Commissioner, https://idpc.org.mt/en/Pages/Home.aspx) pursuant to art. 77 of the Regulation, if you believe that the processing of your data is contrary to the law in force.
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7. GENERAL INFORMATION ON COOKIES AND SIMILAR MONITORING TECHNOLOGIES
GENERAL INFORMATION ON COOKIES AND SIMILAR MONITORING TECHNOLOGIES
- Cookies can remember your sign-in credentials, so you don’t have to enter those credentials each time you log on to a service.
- Cookies help us and third parties understand which parts of our services are the most popular because they help us to see which pages and features visitors are accessing and how much time they are spending on the pages. By studying this kind of information, we are better able to adapt the services and provide you with a better experience.
- Cookies help us and third parties understand which ads you have seen so that you don’t receive the same ad each time you access a service.
- Cookies help us and third parties provide you with relevant content and advertising by collecting information about your use of our services and other websites and apps.
When you use a web browser to access the Website, you can configure it to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the “Help” or “User Guide” menu of your browser, to learn how to change your cookie preferences. The operating system of your device may also contain additional controls for cookies. For example, in Microsoft Internet Explorer, you can disable or wipe cookies by selecting “Tools/Internet Options” and modifying the relevant privacy options or selecting the “block cookies” option.
Please note, however, that the Website is designed to work using cookies and that disabling them may affect your ability to use the Website itself.
We, along with certain third parties, may also use technologies called “clear gifs”, “web beacons” and/or “pixels”, that communicate information from your device to a server. This information can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed particular content or a particular email message, determine the time and date on which you viewed the beacon and pixels, and the IP address of your device. We and certain third parties use beacons and pixels for a variety of purposes, including to analyze the use of our Website and (in conjunction with cookies) to provide content and ads that are more relevant to you.
When you access and use our Website (except for websites provided by third party service providers), you will be asked to provide your separate consent to the storage of cookies (which includes other local storage technologies, beacons, pixels and other information on your devices) by us. You will also be asked to provide your separate consent to the access of such cookies (which includes local storage technologies, beacons, pixels and information) by us and by the third parties mentioned above. Your experience of our Website may be affected if you do not accept cookies, and further information will be provided to you at the time we ask you for this specific consent.
The Decision of the Italian Privacy Authority no. 229 adopted on the 8th of May 2014, published on the Official Journal (Gazzetta Ufficiale) of the Italian Republic no.126 on the 3rd of June 2014, obliges all websites providers using cookies and/or similar technologies to inform their users on the type of cookies used by the relevant website. According to the decision described above, we use the following types of cookies on the Website:
- Technical/Functional cookies
Technical/Functional cookies are those used to “effectively transmit a communication on an electronic communication network or used to the extent strictly necessary by a provider of an information society service to provide a service that has been explicitly requested by a subscriber of user of the service thereof”, as per art. 122, par.1 of the Italian Privacy Code (leg. decree n.196/2003).
They are usually memorized for the sole scope described above and are directly provided by the provider and/or manager of the website. They can be divided in navigation and session cookies, that grant normal navigation and use of a website (allowing the user, for example, to buy goods and/or to login on private areas of a website); cookie analytics, treated as technical/functional cookies where directly used by the provider of a website to collect aggregated information on the number of visitors and their behavior; functional cookies, allowing the user to browse a website following a series of selected criteria (for example: language, products to buy, etc.) to ensure him/her a better service.
No consent is required for installation of such cookies; however, the website owner must provide the users with a possibility to remove them and prevent their further installation.
- Profiling and/or Advertising Cookies
They profile the user, so to be able to send him advertisements targeted on his/her preferences and behavior during browsing. Since use of such cookies is particularly invasive for the privacy of users and visitors of a website, the European and Italian legislation require the user to be informed in advance on their use, so to be able to express his/her consent to the installation of these cookies.
According to the above, art. 122, par.1, of the Italian Privacy Code provides that “the storage of information on a device of a subscriber or a user or the access to information already stored inside such device is permitted only on condition that the subscriber or the user has given his/her prior consent after being informed through the simplified procedures referred to in article 13, paragraph 3”.
In Decision 229/2014, the Italian Privacy Authority has also categorized cookies based on the provider thereof, distinguishing between first-party cookies and third-party cookies.
- First-party cookies.
They are directly installed and managed by the website owner/provider/administrator. Therefore, the owner/provider has the obligation to provide all the necessary information thereof, also indicating the methods to block them.
- Third-party cookies.
They are installed and managed by a third party, not by the website owner/provider/administrator. Therefore, the third parties have the obligation to provide all the necessary information thereof, while the owner/provider/administrator of the website has the only obligation to provide its users with a link to the page of the third-party providers where such information may be found.
Consent to the installation of both types of cookies (first-party and third party), necessary if the cookie acts for profiling purposes, has to be given through a specific information banner in the home page of the website.
COOKIES USED BY THIS WEBSITE
The first grid lists all Technical/Functional cookies, the use of which does not require any prior consent by the users/visitors of the Website itself.
In the second grid you will find all Profiling cookies, if used by the Website.
For both groups of cookies, the grids show the following information:
- first-party or third-party cookie
- if a first-party cookie, instructions for its removal and/or blocking
- if a third-party cookie, a link to the third-party’s website, where all information and instructions for its removal and/or blocking should be provided.
Warning: please be once again advised that blocking technical/functional cookies may hamper the correct functionality and use of the Website.
LINKS TO OTHER WEBSITES
The user/visitor of the Website may in any moment contact the Company using the following addresses:
- by email/PEC: firstname.lastname@example.org
- by ordinary mail: Noovle S.r.l., via della Giustizia, 10, 2012 Milan (Italy)
Any further updates shall be published in this webpage.
|Types of cookies||Features||Purposes|
|Navigation or session cookies||They allow the normal navigation and use of the website. They can be automatically deleted at the end of each session or have a longer life
|They are used by Noovle Srl to manage the association of who is browsing the Application Server that provides the pages of the site.|
|Functionality cookies||Improve the User Experience||They are not used by Noovle Srl|
|Cookie Analytics||In an anonymous way, they collect information on how a website is used and allow to have a better knowledge of the operation of the site and its users||They are used to provide statistics on the use of the site|
|Third-party Cookie Analytics||Cookies managed by Google Analytics||They are managed for Noovle Srl by Google Analytics to collect data in aggregate form for statistical purposes|
|Profiling cookies||Create user profiles||They are intended to send advertising messages in line with the preferences expressed by the user within the pages of the Site. It is possible to use the opt-in tool referred to in the cookie settings section to deny consent to their use.|