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Reputation Manager

Information on the processing of personal data

INFORMATION ON THE PROCESSING OF PERSONAL DATA of the users visiting this website

Pursuant to Article 13 of the EU Regulation 2016/679

Pursuant to the EU Regulation 2016/679 (hereinafter, the “Regulation”), this page describes the processing operations performed on the personal data of the users visiting the website www.reputationmanager.it and the company services, in strict compliance with the general principles established by Articles 5 and 6 of the GDPR, i.e., according to correctness, accuracy, completeness and congruity with respect to the indicated purposes.

1) DATA CONTROLLER

The controller of the data of the users visiting this website is the company Reputation Manager S.p.A. Società Benefit (hereinafter the “Company”), with registered office in Via C. Mangili 2, 20121, Milan. The Data Controller can be contacted at infoprivacy@reputationmanager.it.

2) PURPOSES OF DATA PROCESSING

The purposes for processing the data of the interested parties are attributable to the commercial information activity expressly requested by the users who are interested in the Company’s services and use the contact form published on this website.

Data may be collected for the subscription to newsletters sent by the data controller for informative and commercial purposes.

The data collected may be necessary to fulfil any legal, accounting and tax obligations. They may be used to assert or defend rights in court, in case of abuse in the use of the website and/or our services or for contractual or non-contractual disputes.

Some personal data deriving from navigating on this website may be used to process navigation statistics and to improve the navigation when using this website.

3) LEGAL BASIS

Your personal data are processed pursuant to the Article 24 of the Privacy Code and the Article 6 of the GDPR.

A) Personal data are processed without your express consent (Article 24 letter a, b, c of the Privacy Code, and Article 6 letter b, e of the GDPR) for the following service purposes:

  • the purpose of concluding contracts with the Data Controller regarding the services offered by the latter. Data processing is also exercised for all pre-contractual, contractual, and tax obligations deriving from commercial relationships in place or in progress;
  • the purpose of fulfilling the obligations established by law, by regulations, by the European legislation or Authority regulations;
  • the processing of data is necessary to pursuit the legitimate interest of the data controller or third parties, provided that the interested party’s interests, fundamental rights, and freedoms do not prevail.

B) Only with your specific and explicit consent (Articles 23 and 130 of the Privacy Code, and article 6 1.f of the GDPR), data are processed for the following marketing purposes:

  • the purpose of sending you newsletters, commercial communications and/or advertising material – via e-mail, paper mail and/or SMS and/or telephone calls – on products or services offered by the Data Controller, or materials for evaluating the satisfaction with the quality of services;
  • the purpose of sending you commercial communications and/or advertising material from third parties (for example, partners or other companies belonging to the Group) via e-mail, paper mail and/or SMS and/or telephone calls.

4) PERSONAL DATA THAT ARE SUBJECT OF DATA PROCESSING

The Data Controller may collect information suitable for directly or indirectly identifying the interested parties through the collection of information related to the name, an identification number, an online identifier or to one or more elements that characterize the identity of the interested party. Other personal data provided in the information request forms may be processed. Any sensitive data (Article 9.1 of Regulation 2016/679/EU) should not be processed without the explicit consent of the interested party.

  • Data provided on a voluntary basis:

The personal data processed to date are only those entered during registration, namely: Surname, Name, E-mail, Telephone number, VAT number. The request for further data will be made known each time to users, who will be asked to give their consent.

  • Navigation data (see point 9)

5) DATA RECIPIENTS

The data provided by the interested party through contact forms will not be transferred to third-party companies for commercial or other purposes. Instead, they will be sent to those who are responsible in the commercial and administrative areas of ​​the Company, in order to fulfil the actions indicated in paragraph 2 (purposes).

The data will be shared with subjects who typically act as data processors pursuant to Article 28 of the Regulation, namely: 1) persons, companies or professional firms that provide assistance and advice to the Company in accounting, administrative, legal, tax, financial, and credit recovery matters relating to the provision of the services; 2) subjects with whom it is necessary to interact for the provision of the services (e.g. hosting providers); 3) or subjects delegated to carry out technical maintenance activities, including the maintenance of network equipment and electronic communication networks; (collectively “Recipients”); the list of data processors can be requested from the Data Controller.

The data may be shared with independent data controllers (subjects, bodies or authorities) to whom it is mandatory to communicate your personal data due to legal provisions or orders from the authorities.

Further data recipients are the persons authorized by the Company to the necessary processing of personal data (Article 29 of the Regulation), in order to carry out activities which are strictly related to the provision of the services. These individuals are committed to confidentiality or have an appropriate legal obligation of confidentiality.

Third-party companies may be used by the data controller only in the case of sending emails for marketing purposes, the receipt of which needs to be previously authorized by the interested party. This information will be attached to the email, indicating the third-party company used and whether it is based outside the EU.

6) METHODS OF DATA PROCESSING

Your data may be processed electronically. Reputation Manager S.p.A. Società Benefit owns only the data which are necessary during the first registration phase indicated in paragraph 2. As for the processing of data relating to the website services, the Data Controller uses servers located in Europe. Reputation Manager S.p.A. Società Benefit owns only the data which are necessary during the first registration phase indicated in paragraphs 2 and 4. We inform you that the data will be collected, processed and stored in full compliance with the provisions on security, as well as in compliance with the measures deemed appropriate pursuant to the new EU Regulation 2016/679. The data will also be processed in full compliance with the self-regulation rules on the processing of personal data, which are provided by the codes of deontology in force in the sector.

7) DURATION OF THE DATA PROCESSING

The data will be processed for the time strictly necessary to achieve the purposes for which they are collected. In addition, they will remain available to the owner, the manager and the persons in charge for any data storage required by law (Article 22, paragraph 5 of the Code) only for the necessary duration or up to a date of cancellation request made by the user. In any case, the maximum duration is that established by law for contractual liability, i.e., 10 years.

8) RIGHTS OF THE INTERESTED PARTY

In your capacity as an interested party, you have the rights referred to in the Article 7 of the Privacy Code, and in the Article 15 of the GDPR. Specifically:

  • the right to obtain confirmation of the existence of personal data concerning you, even if not yet registered, and to obtain their communication in an intelligible form;
  • the right to obtain:
    • the origin of personal data;
    • the purposes and methods of data processing;
    • the logic applied in case of data processing carried out with the aid of electronic tools;
    • the identification details of the owner, the managers and any person designated pursuant to the Article 5, paragraph 2 of the Privacy Code, and the Article 3, paragraph 1 of the GDPR;
    • the subjects or categories of subjects to whom the personal data may be communicated or who can learn about personal data as appointed representative in the territory of the State, managers or agents;
  • the right to obtain:
    • the updating, the rectification or, if needed, the integration of data;
    • the cancellation, the transformation into anonymous form or the blocking of data processed in violation of the law, including data that do not need to be kept for the purposes for which data were collected or subsequently processed;
    • the declaration that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or shared, except in the case in which this fulfilment is impossible or involves the use of means that are manifestly disproportionate to the protected right;
  • the right to object to, in whole or in part:
    • for legitimate reasons, the processing of personal data concerning you, even if pertinent to the purpose of their collection;
    • the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator through e-mail and/or through traditional marketing methods by telephone and/or paper mail. The interested party’s right to object to direct marketing purposes using automated methods (point b) extends to traditional methods. The possibility for the interested party to exercise the right to object, even if only in part, remains unaffected. Therefore, the interested party can choose to receive only communications that use traditional methods, or only automated communications, or neither of the two types of communication. If applicable, the interested party also has the rights referred to in Articles 16-21 of the GDPR (right of rectification, right to be forgotten, right to limit data processing, right to data portability, right of opposition), as well as the right to complain to the Autorità Garante.

In particular, users have the right to receive a copy of their data from the Data Controller. All these rights can be exercised by writing an email to: infoprivacy@reputationmanager.it

9) NAVIGATION DATA

During their normal operation, the computer systems and software procedures used to operate this website acquire some personal data, whose transmission is implicit in the use of Internet communication protocols.

This information is not collected to be associated with identified interested parties. However, by its very nature, this information may allow the identification of users through data processing and association with data held by third parties.

This type of data includes: IP addresses or domain names of the computers used by the users who connect to this website; the URI (Uniform Resource Identifier) ​​addresses of the requested resources; the time of the request; the method used for submitting the request to the server; the size of the file obtained in response; the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and IT environment.

The collected data may be used to ascertain responsibility in the event of any computer crimes against this website.

With regard to IP addresses, the Data Controller uses third-party analysis services (Google Analytics) that use the IP addresses of the users in order to provide data and reports. These services install cookies through this website, including profiling cookies (see the specific information on the website).

10) CONTACT INFORMATION

Reputation Manager S.p.A. Società Benefit (hereinafter the “Company”), with registered office in Via C. Mangili 2, 20121, Milan, is the controller of your personal data. If you wish to contact us or receive more information on data processing, including an updated list of the subjects to whom the data may be communicated and who are responsible for data processing, write an email to infoprivacy@reputationmanager.it

11) CHANGES

At any time, Reputation Manager S.p.A. Società Benefit may modify the data processing criteria and procedures, or change and modify the methods for accessing this website or its content. In this case, Reputation Manager S.p.A. Società Benefit will promptly update the Privacy Policy, which is made known to users once published on the website.

This information was published on 25 May 2018

Last update: 5 October 2021

The owner reserves the right and the duty to make further changes according to subsequent provisions of the law or according to business needs.