Privacy protection

Information on the processing of personal data collected by the interested party

Hereby we provide You, In compliance with the provisions of EU Reg. 2016/679 (European Regulation for the protection of personal data), the necessary information regarding the processing of the provided personal data. This is an information that is provided pursuant to art. 13 of EU Reg. 2016/679 (European Regulation for the protection of personal data) and is also inspired by the provisions of Directive 2002/58 / EC, as updated by Dir. 2009/136 / EC.

1. SUBJECTS OF THE TREATMENT
HOLDER OF THE TREATMENT, pursuant to art. 4 and 24 of EU Reg. 2016/679 is TOCTOC S.r.l., with registered office in Rome (Rm), Via Alessio Baldovinetti 83, tax code and VAT number 12925931003, in the person of its legal representative.

2. PURPOSE AND LAWFULNESS OF TREATMENT
The provided personal data will be processed in compliance with the conditions of lawfulness pursuant to art. 6 EU Reg. 2016/679 for the following purposes:
a) Management of inherent data processing (Article 6 letter b and following):

  • navigation on the website;
  • possible compilation of the data collection form in the pre-contractual phase (e.g. free demo access) and in the contractual phase by compilation of traditional contractual forms as well;
  • signing of online contracts with electronic signature;
  • video identification service related to the online contracts signing;
  • account creation (it is specified that the creation of the account will only be possible following an invitation to collaborate);
  • fulfillment of contract obligations, of law and administrative-accounting purposes and protection in case of litigation. For the purposes of applying the provisions on the protection of personal data, the treatments carried out for administrative and accounting purposes are those connected to the performance of organizational, administrative, financial and accounting activities, regardless of the nature of the data processed. In particular, internal organizational activities, those functional to the fulfillment of contractual and pre-contractual obligations, information activities pursue these purposes.
b) Management of inherent data processing (Article 6 letter a):
  • with prior consent and up to Your opposition to receive, via automated e-mail, commercial and promotional newsletters, information material for market research or other sample research, detection of the degree of satisfaction and sending of material related to events and initiatives of the Data Controller treatment.
The Partners of the Data Controller, as independent data controllers, will process the User's personal data for their own marketing purposes (direct sales, sending advertising material and commercial communication), and will be able to contact the User to propose the purchase of products and / or services offered by the same categories of third-party companies and / or by other companies and to present offers, promotions and commercial opportunities to the User. Once the transfer has taken place, it will be the responsibility of the Partner of the Owner to provide Users, pursuant to art. 14 c. 3 of the Regulation, all the information required by the same art. 14 of the Regulation.
Always with your explicit consent, your data will be processed if you fill out the callback form and if you chat with us, as long as You provide us with your personal data.

The data will be entered in the company CRM. The Data Controller, to evaluate and possibly improve the results of communications, uses systems for sending newsletters and promotional communications with reports. Thanks to the reports, the Owner will be able to know, for example: the number of readers, openings, unique "clickers" and clicks; the devices and operating systems used to read the communication; details on the activity of individual users; the details of the emails sent, emails delivered and not, of those forwarded; all these data are used for the purpose of interpreting, and possibly improving, the results of communications.

3. RECIPIENTS OR CATEGORIES OF DATA RECIPIENTS
The personal data provided may be disclosed to recipients, appointed pursuant to art. 28 of EU Reg. 2016/679, which will process the data as managers and/ or as natural persons acting under the authority of the Owner and Manager, in order to comply with contracts or related purposes. Specifically, the data may be disclosed to recipients belonging to the following categories:
  • Subjects providing services for the management of the information system and communication networks (including e-mail);
  • Studies or companies in the context of assistance and consultancy relationships;
  • Competent authorities for compliance with legal obligations and / or provisions of public bodies, upon request;
  • In the case of administrative and accounting purposes, the data may possibly be transmitted to commercial information companies for the assessment of solvency and payment habits and / or to subjects for credit recovery purposes.
The subjects belonging to the aforementioned categories perform the function of data processing manager, or operate in total autonomy as separate data controllers. The list of designated data processors is constantly updated and available at the headquarters of TOCTOC S.r.l ..

4. TRANSFER OF DATA TO A THIRD COUNTRY AND / OR AN INTERNATIONAL ORGANIZATION
The personal data provided will be managed and stored in countries within the European Union.
To send the following communications (newsletters - demo registered users - informative e-mails for registration or subscription expiration) the data controller made use of companies based in the USA duly appointed as data processors who make use of the standard contractual clauses. based on the decision of the EU Commission no. 2010/87 / EC of 5 February 2010.
The list of data processors is available on site.

5. CONSERVATION PERIOD OR CRITERIA
The processing will be carried out in an automated and / or manual form, with methods and tools aimed at guaranteeing maximum security and confidentiality, by persons specifically appointed to do so. In compliance with the provisions of art. 5 paragraph 1 letter. e) of EU Reg. 2016/679, the personal data collected will be stored in a form that allows identification of the data subjects for a period of time not exceeding the achievement of the purposes for which the personal data are processed. The retention of the personal data provided is determined on the basis of the following criteria:
  • Processing carried out for administrative and accounting purposes: 10 years;
  • Processing carried out for the fulfillment of legal obligations and for the protection in the event of litigation: until the statute of limitations for forfeiture of civil and criminal actions is reached;
  • The navigation data will be kept for 1 year;
  • Data processing carried out for direct marketing purposes: 2 years from the collection of consent with subsequent updating of the data and renewal of the consent given;
  • Data processing of potential customers (leads): once the negotiation phase is concluded, if the "potential" customer does not become an "actual" customer, the personal data will be immediately deleted or processed anonymously, if their conservation is not otherwise justified.


6. NATURE OF THE CONFERENCE AND REFUSAL
Apart from what is specified for navigation data, the user is free to provide personal data in dedicated areas on the site. The provision of personal data for the purposes referred to in point a) of this information document is necessary to refine the specific functions and use the services offered by the Data Controller. Failure to provide personal data may make it impossible to obtain the requested service or to use the services offered by the site.
The provision of personal data and consent to the processing of the same for the purposes referred to in point b) is optional. Failing this, TOCTOC srl may find it impossible to send you, via newsletter, information material, commercial or promotional communications or customer satisfaction questionnaires, invitations to events and initiatives promoted by the same.

7. RIGHTS OF THE INTERESTED PARTIES
You can assert your rights as expressed in articles 15, 16, 17, 18, 19, 20, 21, 22 of EU Regulation 2016/679, by contacting the Data Controller, by writing to: privacy@toctoc.me You have the right, at any time, to ask the Data Controller to access your personal data, to rectify it, cancel it or limit its processing. Furthermore, you have the right to object, at any time, to the processing of your data (including automated processing, eg profiling) as well as to the portability of your data. Without prejudice to any other administrative and judicial appeal, if you believe that the processing of data concerning you violates the provisions of EU Reg. 2016/679, pursuant to art. 15 letter f) of the aforementioned EU Reg. 2016/679, you have the right to lodge a complaint with the Guarantor for the protection of personal data and, with reference to art. 6 paragraph 1, letter a) and art. 9, paragraph 2, letter a), has the right to withdraw the consent given at any time.

In the event of a request for data portability, the Data Controller will provide you with your personal data in a structured format, commonly used and readable by an automatic device, without prejudice to paragraphs 3 and 4 of art. 20 of EU Reg. 2016/679.

Update date: 22/02/2021