art. 1 – Data controller
Mr Federico Colombo – Via Pier Carlo Boggio 59 – 10138 Turin (Italy)
art. 2 – Data collection and use
Users’ personal data can be collected and used for:
- Analysing personal or consumer habits, business, direct marketing activities;
- Customer profiling;
- Advertising purposes;
- Supply of goods and services;
- Electronic communication services’ monitoring;
- Market research and other statistics.
art. 3 – Data processing and data protection from unauthorised third parties
Personal data can be processed and elaborated through: a) Physical devices, b) Digital devices, c) Cloud storage, prevalently via automatic cloud backup.
Data sub a) and b) are normally kept inside the European Union territory. However, some exceptions are admitted. Conversely, data sub c), encrypted and password protected, are stored via servers owned or possessed by companies – such as Google LLC, Netsons –Supernova S.r.l., Amazon Web Services Inc. and so on. The latter can be accessed even from outside the EU, by both the data controller and third parties, entrusted with the tasks mentioned in Art. 2. In any event, personal data are always protected from access by unauthorised third parties; to this end, users’ passwords are registered through the Secure Hash SHA-512 system. Moreover, the minimum standards prescribed by the Italian Code on Personal Data Protection (legislative decree 30 June 2003, n. 196) are applied.
art. 4 – Duration
Wrebby will store data, which are collected with the data subjects’ consent, for a maximum period of fifteen years from the moment of registration. Afterwards, they will be automatically cancelled or permanently and definitively made anonymous, unless otherwise indicated by the data subject himself. In any event, Users may request removal or transmission (under art. 8 of this policy) of their personal information; likewise, they may decide to limit or to oppose to their processing.
art. 5 – Compulsory Nature
Customers have to fill in their personal data for the contract to be finalised and fully executed, unless otherwise indicated during the collection phase.
art. 6 – Nature of the processed data
Pursuant to Art. 9, lit. f) of the EU Regulation 2016/679/EU, handling of personal data may concern the storage and management of information willingly shared by the data subject (on Wrebby’s website or app or via any related devices, belonging either to the User, to Wrebby or to third parties), which concern the user’s identity, his tastes and habits, ethnic background, political opinions, religious and philosophical beliefs, trade union affiliation, family status, education, working experiences, business activities or other commercial information, health conditions, sexual habits and orientation, alongside the location of his device, or whatever information can be defined “sensitive” under the Italian Code on Personal Data Protection (legislative decree 30 June 2003, n. 196). Unauthorised third parties have no access to such information.
art. 7 – Transfer of personal data
Beside being handled by Wrebby’s employees, partners, outside contractors or affiliates, collected data may be transferred, for commercial purposes, to third parties, both public and private entities (Wrebby users, trade fair hubs, vendors or commercial agents), operating inside or outside the European Union territory, without prejudice to the data subject’s rights under Art. 8 of this policy.
art. 8 – Data subject’s rights
Upon request of the data subject, the data controller shall provide, without unjustified delay and, in any case, not later than one month from such request:
- Access to personal data and the chance to take copies;
- Possibility to modify, to limit the use, to partially or totally cancel personal data (NB this may give rise to the termination of the contract)
- Transfer of the collected data to the user through a commonly used hardware, which can be read by an automatic device, or, where technically possible, transfer of the above-mentioned data to another data controller selected by the user, against payment of a reasonable and proportionate fee.
In any event, the data subject can file a complain to the relevant supervisory bodies (In Italy, it would be the “Garante per la protezione dei dati personali” (Personal Data Protection Authority))