Data Controller, person in charge and Data Protection Officer:
The data controller is APPAROUND ITALIA SRL with principal office in 56121 Montacchiello – Pisa, Via Umberto Forti, 1 – F.C. and VAT 02113280503 (hereinafter “Apparound”).
Apparound has appointed a DPO (Data Protection Officer). You can contact the DPO by writing to email@example.com.
Purpose of the Processing
Your personal data will be processed for two purposes:
- To comply with the legal obligations deriving from the contractual relationship between you and Apparound, therefore your personal data will be processed for the correct performance of the contract in place;
- marketing and promotion activities, therefore we’re going to send you information relating to Apparound products and services through:
- newsletters related to Apparound products and services;
- demo of Apparound products features;
- commercial email about products and services offered by Apparound;
- telephone calls.
Categories of personal data that may be requested
You will be asked to provide personal data such as name, surname, role held in the company, personal e-mail address, phone number.
Nature of the request of personal data provisioning
We want to clarify that the provision of personal data for the purpose described in point 1 above is mandatory, in fact, any refusal to process such data could affect Apparound ability to comply with contractual obligations and, therefore, expose Apparound to legal risks related to possible contractual non-performances.
On the contrary, about the purpose in point 2, the provision of personal data, and your consent to the processing, is not mandatory.
Legal basis of the processing and request for consent
The legal basis of the processing is your free consent.
For what above, and given the purposes and nature of the processings, we believe to request your specific consent to both the processing of your personal data for the purposes mentioned above.
In this sense, after reading this policy you can express, or not, your consent in a specific “box”.
Consider, however, that if you do not give your consent to the processing in point 1 of the purposes paragraph, Apparound may refuse to comply with the contract in place with you.
Scope of communication and dissemination
In relation to the purpose “complying with legal obligations deriving from the contractual relationship”, the collected data may be disseminated and/or disclosed to third parties, and in particular to accountant, lawyers, etc. .. or to companies for the that render services of administration and business management to Apparound.
On the contrary, relating to marketing activities, the collected data will not be disclosed and will not be communicated to third parties
Method of the processing and retention period
The Processing of your personal data will be carried out in an automated and/or manual manner, in compliance with the security measures referred to in sec. 32 of the GDPR, by persons specifically appointed, in compliance with the provisions of sec. 29 GDPR.
Please note that, in compliance with the principles of lawfulness, limitation and data minimization, pursuant to art. 5 GDPR, the retention period of your personal data is established in a period:
- not exceeding one year, for data collected and processed relating marketing and promotion activities;
- not exceeding ten years from the expiration of the term of the contract with APPAROUND, for data collected and processed relating to purpose “complying with legal obligations deriving from the contractual relationship”.
Transfer of personal data in relation to marketing and promotion activities
APPAROUND, for its marketing and promotion activities, uses different technological tools compliant with the requirements established by the GDPR.
We need to point out the use of Mailchimp and Calendly services.
A) Mailchmp is an e-mail marketing service offered by The Rocket Science Group, LLC 675 Ponce de Leon Ave NE Suite 5000 Atlanta, GA 30308 USA.
The use of Mailchimp by APPAROUND involves the transfer of some of your personal data such as name, surname, e-mail address and telephone number on Mailchimp servers, located in the USA, therefore outside the European Union.
We need to specify that the company that owns Mailchimp:
- has joined the EU-US Privacy Shield Framework and that
- operates on the basis of a specific Data Processing agreement with Apparound and that
- data transferred to the US will be processed and not transferred to The Rocket Science Group, LLC which, therefore, this latter will operate as an external data processor.
B) Calendly is a service offered by the company Calendly, LLC, 1315 Peachtree St NE Atlanta, GA 30309, is used to share your calendar with other users and to make appointments quickly and easily.
The use of Calendly involves the transfer of some personal data such as name, surname, e-mail address on servers located in the USA, therefore outside the European Union.
Until today Calendly has not joined the EU-US Privacy Shield Framework, therefore explicit consent is required for its use.
It is understood that the data transferred to the US will be processed and not transferred to Calendly who will then act as the external controller of the processing
Your rights under the GDPR
At any time, pursuant to articles from 15-22 of the GDPR, you can exercise the right to:
- request confirmation of the existence or otherwise of personal data;
- obtain information about the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data have been or will be communicated and, where possible, the retention period;
- obtain the correction and deletion of data;
- obtain the treatment limitation;
- obtain the “portability of the data”, i.e. receive them from Apparound, in a structured format, commonly used and readable by automatic device, and transmit them to another data controller without hindrance;
- oppose the processing, also in the case of treatment for direct marketing purposes;
- withdraw consent to the processing of the data provided;
- oppose to an automated decision-making process concerning individuals, including profiling activities;
- file a complaint with the Privacy Authority or other competent supervisory authority.
You can exercise your rights with a written request sent to Apparound Italia S.r.l., to the postal address of the registered office or to the email address firstname.lastname@example.org.