PRIVACY POLICY PURSUANT TO EU REGULATION 2016/679
The current legislation on personal data processing, defined in compliance with the provisions contained in EU Regulation 2016/679 of April 27, 2016, regarding the protection of natural persons concerning the processing of personal data and the free movement of such data (hereinafter, the "Regulation"), includes provisions aimed at ensuring that the processing of personal data is conducted respecting the rights and fundamental freedoms of individuals, with particular regard to the right to personal data protection.
1. Purpose of the Processing
1.1. The data collected will be processed by TM95 Srl, with its registered office at Via Carlo Goldoni 1, Milan (VAT No. 12129160961) (hereinafter, the "Data Controller") for the purposes described below:
- to fulfill obligations under service supply contracts that will be entered from time to time;
- internal management and control;
- exercise the rights of the Data Controller, for example, the right of defense in court;
- to generally comply with legal obligations.
For the exclusive purpose of fulfilling contractual obligations, express consent is not required, as the legal basis for processing is the necessity for the execution of a contract to which the data subject is a party, or for the execution of pre-contractual measures adopted upon the request of the data subject.
2. Nature of the Provision of Data
2.1. We inform you that you are free to provide or withhold your personal data for the aforementioned purposes. However, we must inform you that your refusal to provide such data will make it impossible to pursue the purposes indicated in section 1.1.
3. Processing Methods and Data Retention Period
3.1. Your data will be processed by TM95 Srl – as the Data Controller – through operations or sets of operations, as provided by the current legislation. The processing will also take place with the aid of electronic or other automated means and will be carried out directly by the Data Controller. Additionally, within TM95 Srl, the data will be processed by employees and collaborators within their respective functions and in accordance with the instructions received, always and exclusively for achieving the specific purposes indicated in this policy.
3.2. All personal data concerning you is kept under the care of the Data Controller for the time strictly necessary to manage the purposes of the processing indicated herein. Data not required to be retained for legal obligations or legitimate interests will be deleted once the retention period related to any legal obligations or limitation periods has elapsed, starting from the date when needs associated with the purposes indicated in this policy cease to exist. Processing is also conducted with the aid of electronic and automated means, including computers and networked personal computers connected to a central server, through methods suitable for ensuring security and confidentiality.
3.3. Concerning data and/or images uploaded by you on the Eumeda® Platform following registration, TM95 Srl will act as the Data Processor.
4. Scope of Data Communication and Dissemination
4.1. Without the need for express consent (per art. 24 lett. a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data for the purposes outlined in art. 1 to supervisory bodies, judicial authorities, national and international diplomatic authorities, insurance companies for insurance services, and any parties to whom communication is required by law for the above purposes. These subjects will process the data in their capacity as independent data controllers.
4.2. Your data will not be disseminated.
4.3. The Data Controller may also use external specialized companies, as well as IT, telecommunication, archival, and postal service companies entrusted with technical or organizational tasks. These third parties will act following the instructions and security procedures defined by TM95 Srl to fully protect your privacy. These subjects, to safeguard you, will perform the function of "data processor" or "data handler" for your data.
4.4. Personal data will be used only through methods and procedures strictly necessary for the above-mentioned activities and will not be disseminated.
5. Data Transfer
5.1. Personal data is stored on servers located in Italy and/or within the European Union. However, if necessary, the Data Controller reserves the right to move servers outside the EU. In such a case, the Data Controller hereby assures that any data transfer outside the EU will be conducted in compliance with applicable laws and following the standard contractual clauses stipulated by the European Commission.
6. Data Processing Methods
6.1. Data processing may be carried out using manual, computer, or telematic tools designed to store, manage, and transmit the data.
6.2. Personal data is subject to electronic processing.
7. Use of Cookies
7.1. During browsing on our website, TM95 Srl acquires certain data, such as the pages visited and the time spent on each page. These data are collected solely to ensure that the portal is functional and navigable. We collect some data for your identification, which, however, remains anonymous. Such information is available in specific logs and may be communicated only to the Judicial Authority when required by law.
This "Cookies Policy" aims to provide information on the types, purposes, and methods of use/management of cookies sent during browsing on the TM95 Srl web portal.
What are cookies?
Cookies are small text strings that a website sends to the browser used by the user during browsing, stored on the user's device, and retransmitted to the same site on the user's subsequent visit. Based on the party installing cookies on the user's device, there are two types of cookies:
- "First-party" cookies when installed directly by the portal owner and/or editor (TM95 Srl);
- "Third-party" cookies when managed by entities unrelated to the website visited by the user through the owner and/or editor of the portal.
The web portal may use or may combine the following types of cookies
- Technical cookies, used for the proper functioning of the portal and to allow users to navigate the portal normally and use the available services. For instance, they are used to enable users to remember actions when returning to the previous page in a session and/or to store some information (e.g., language) to avoid re-entering them in subsequent visits to the portal. Without technical cookies, the site might not function properly.
- Session cookies, sent to users' browsers to transmit session identifiers (generated by the server) needed to ensure secure and efficient site exploration. These cookies are not persistently stored on users' computers and are deleted at the end of the "session" by simply closing the browser.
- Analytical cookies, used to collect aggregated and anonymous information for statistical analysis on site access to improve the services offered. In any case, they are not used for further purposes and do not allow the personal identification of users. For the installation of such cookies, users' prior consent is not required under art. 122 para. 1 of the Code (Privacy Guarantor, "Identification of simplified procedures for the disclosure and acquisition of consent for the use of cookies" of May 8, 2014, and in the EU, "Opinion 04/2012 on the exemption from consent for the use of cookies" adopted on May 7, 2012 by the Article 29 Data Protection Working Party).
Third-Party Cookies
To collect anonymous statistical information on how users interact with the website (visited pages, time spent on the portal, IP address, etc.), the portal utilizes Google Analytics, a web analysis service provided by Google, which may use cookies. For more information on data processing carried out by Google through Google Analytics, users can visit Google’s privacy policy page at http://www.google.com/intl/it_ALL/analytics/learn/privacy.html, as well as disable it according to the instructions provided.
Disabling Cookies via Browser Settings
Users can configure their web browser at any time to define the level of restriction on cookies, disabling them, in whole or in part, or limiting their reception based on the domain of origin. However, please note that disabling “technical” cookies, which are strictly necessary for the portal's functionality, may render the portal itself unusable. Below, users can find links to instructions for disabling cookies on the most common browsers:
8. Data Subject Rights
8.1. The Regulation grants you the exercise of specific rights, including the right to request from the Data Controller:
- Confirmation of whether or not your personal data is being processed and, if so, access to it (right of access)
- Rectification of inaccurate personal data or completion of incomplete personal data (right of rectification)
- Erasure of the data if one of the reasons provided by the Regulation applies (right to erasure)
- Restriction of processing under certain conditions outlined by the Regulation (right to restriction of processing)
- To receive the personal data you provided to the Data Controller in a structured, commonly used, and machine-readable format, and to transmit this data to another controller (right to data portability).
You also have the right to withdraw your consent to the processing of your data at any time, without affecting the lawfulness of processing based on consent before its withdrawal, and to object at any time to processing for marketing purposes (right to object).
Requests may be addressed to: TM95 Srl, Via Carlo Goldoni 1, 20129 Milan; email address: info@tm95.net
