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”).
Furthermore Apparound has appointed a Data Protection Officer. You can contact our DPO at firstname.lastname@example.org.
Purpose of the Processing
Your personal data will be processed for 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, personal e-mail address, role held in the company. Consider that also your IP address may be processed.
Nature of the request of personal data provisioning
We want to clarify that the provision of your personal data 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 purpose and nature of the processing, we believe to request your specific consent to the processing of your personal data for the purposes mentioned above.
In this situation, after reading this policy you can express, or not your consent in a specific “box”.
Scope of communication and dissemination
The collected data will not be disclosed and will not be communicated to third parties, except where a third party is working with Apparound to provide the product and services.
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 minimisation, pursuant to art. 5 GDPR, the retention period of your personal data is established in a period not exceeding two years. After two years, your personal data will be deleted.
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 Hubspot, Inc software tool and services.
Hubspot is a software tool used for marketing and sale activities offered by HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA.
The use of Hubspot by APPAROUND involves the transfer of some of your personal data such as name, surname, e-mail address and telephone number on Hubspot servers, or its sub-processors, located in the USA, therefore outside the European Union.
We need to specify that the company that owns Hubspot :
- has joined the EU-US Privacy Shield Framework and is compliant with the so called “Standard Contract Clauses” and that
- operates on the basis of a specific Data Processing agreement with Apparound and that
- personal data shall be transferred to be processed but not sold to Hubspot, Inc., therefore this latter will operate as an external data processor.
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 email@example.com.