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PRIVACY POLICY

The company Flyer Tech s.r.l., with registered office in Via Antichi Pastifici 8/A - Molfetta (Bari, Italy) - 70056, VAT Number: 03494761202, email: info@transactionale.com, CEM: flyertechsrl@legalmail.it (hereinafter referred to as “Data Controller”), in its capacity as Data Controller pursuant to Article 4, no.7 and 24 of the EU Regulation 2016/679 of 27th April 2016 related to the protection of natural persons with regards to the processing of personal data (hereinafter referred to as “Regulation”), informs that in accordance with Article no. 13 and 14 of the Regulation it will proceed with the processing of personal data relating to users of the website https://www.transactionale.com.

  1. Subject matter of the processing (what data are being processed)

Pursuant to the Regulation, legal persons cannot be considered data subjects and the Regulation therefore does not apply. However, if personal data relating to a natural person are provided in the context of the collection of company data, that person will be considered data subjects pursuant to the Regulation.

CLIENT ACCOUNT REGISTRATION: we will ask for personal information and contact information (email, shop name and shop URL).

BLOG: to leave comments, we will collect your first name (or that which you would like to provide), second name (or that which you would like to provide) and email address. We will also ask you if you would like to save data for future comments.

NEWSLETTER/: If you subscribe to our newsletter, you will provide your email address. You will always have the chance to opt out anytime.

USER CONTACT REQUEST / LEAVE A MESSAGE: If you intend to leave a message, we will ask you to provide name, email address and phone number. 

CONTACT US: If you fill in the contact form, we will ask you to include your personal information (first and second name), email address, company name, professional role, nationality and phone number.

BUSINESS CASE: To receive business cases, it is necessary to fill in the dedicated form with your email.

DOWNLOAD THE EBOOK: To receive our ebooks, we will ask you to include your personal information (first and second name), email address and phone number.

JOIN OUR EVENTS: if you decide to join the events organized by Transactionale, we will ask you to include your personal information and contact information for the registration.

 

In any case, we will process ip address and navigation logs.

 

  1. Legal basis and purposes of the processing

The processing of data will be carried out to allow the exercising of activities related to service introduction and management requested from the Data Controller.

The provision of the personal data is compulsory in all cases in which the legal basis is the execution of the contract or fulfillment of legal obligations arising from the purchase, while it is optional in all other cases; in any event of failed provision, it will not be however possible to carry out the requests.

The personal data in our hands will be managed legally, fairly and with the maximum confidentiality,  in compliance with the appropriate security measures as required by the Regulation.

The processing will be carried out with analog/digital means. Data will not however be subject to public dissemination except for those you will use to leave a comment (which will be publicly visible).

 

In particular:

 

CLIENT ACCOUNT REGISTRATION: the purpose is to allow you to access our website as a client, to ensure the exercising of activities related to service management. The legal basis is the execution of a contract and fulfillment of legal obligations (including accounting and fiscal ones).

BLOG: the legal basis is consent and your data will be processed to allow you to write articles.

NEWSLETTER/STAY UP TO DATE: the purpose is to keep you updated on the services provided by Transactionale and the legal basis is consent.

CONTACT REQUEST: The legal basis is the execution of pre-contractual measures adopted at the Data Subject’s request and your data will be processed to allow us to respond to your requests.

BUSINESS CASE: The legal basis is the execution of pre-contractual measures adopted at the Data Subject’s request and your data will be processed exclusively to allow us to send you our business case.

DOWNLOAD THE EBOOK: The legal basis is the execution of pre-contractual measures adopted at the Data Subject’s request and your data will be processed to allow us to send you our ebook.

JOIN OUR EVENTS: The legal basis is the execution of pre-contractual measures adopted at the Data Subject’s request and subsequently based on the contract and fulfillment of legal obligations; the purpose is to allow you to join our events.

 

Ip address and navigation logs: we will process data based on the legitimate interest of the company and fulfillment of legal obligations.

 

  1. The modalities of the processing – and period of data retention

The Data Controller will process personal data for the time needed to to achieve the above-mentioned purposes and in any case for:

 

CLIENT ACCOUNT REGISTRATION: until you decide to unregister; we will delete your account 7 years after the last login. Before this, we will send you an email to know whether you would like to keep your account active.

BLOG: we will keep articles online until the website is active or until they become obsolete. The Data Controller will verify obsolete data every 12 months. You will always be able to request to have the comment removed.

NEWSLETTER: We will delete data 5 years after the last email sent.

CONTACT US: data will be used to respond to your requests and subsequently deleted. The Data Controller will verify obsolete data every 12 months.

BUSINESS CASE: data will be used to send you our business case and subsequently deleted. The Data Controller will verify obsolete data every 12 months.

DOWNLOAD THE EBOOK: data will be used to send you our ebook and subsequently deleted. The Data Controller will verify obsolete data every 12 months.

JOIN OUR EVENTS: your data will be processed for 5 years from the participation in the event (in case it is free) and for 10 years in case it is a paid event.

 

  1. Data communication

The Data Controller can communicate data for the purposes referred to in Article no. 2 to all the subjects to whom communication is mandatory by law for the achievement of the purposes required by law. Data will not however be subject to public dissemination. 

 

  1. Place of data storage and transfer

The management and storage of personal data will take place on servers located within the European Union of the Data Controller and/or belonging to third-party companies duly appointed as data Controllers. Currently the servers are situated in Europe.

To send commercial information, the Data Controller, furthermore, makes use of a provider which transfers data to non-EU countries. The Data Controller ensures from now on that data transfer to non-EU countries will take place in accordance with statutory provisions, if necessary entering into agreements designed to ensure a suitable level of protection and/or adopting the standard contract clauses envisaged by the European Commission. The list of data processors is available on-site.

  1. Rights of the interested party

As the interested party, the user has the rights set out in the Article no. 15 of the Regulation and, precisely:

  1. The interested party has the right to obtain the confirmation of the existence or not of personal data related to them, even if they are not yet recorded, and their communication in an intelligible form.
  2. The interested party has the right to obtain the indication:
  3. a) of the origin of the personal data;
  4. b) of the purposes and the methods of processing;
  5. c) of the logic applied in case of processing made by electronic instruments;
  6. d) of the identification details of the Data Controller, the Data Supervisor and the Representative;
  7. e) of the persons or categories of persons to whom the personal data can be communicated or disclosed as designated, statewide lien representative, Data Supervisors or persons in charge of the processing.
  8. The interested party has the right to obtain:
  9. a) the updates, rectification, or, when there is an interest therein, the data integration;
  10. b) the cancellation, conversion into an anonymous form or the block of the data processed in breach of law, including those data where the storage related to the purposes for which they were collected or successively processed is unnecessary;
  11. c) the confirmation that the operations stated in letters a) and b) have been acknowledged, even for their content, by those to whom the data has been communicated or disclosed, unless the case in which such performance is impossible or shall result in a disproportion between the enforceable right and the means used.
  12. The interested party has the right to object, in whole or in part:
  13. a) for legitimate reasons related to their personal data, even if pertinent to the purpose of the collection;
  14. b) to the processing of their personal data, for the fulfillment of the purposes which are not provided by the Article no.2

Even pursuant to the Articles no. 15 et seq. of the GDPR, the user has the right to ask at any time for access to their personal data, the rectification or the cancellation of the same, the limitation of the processing in the cases provided by the Article no.18 of the GDPR, to obtain their personal data in a structured, commonly used and machine-readable format - former article no.20 of the GDPR. In any case, the user shall revoke - former to Article no. 7 of the GDPR - the consent given; lodge a complaint with the control competent authority - former to Article no.77 of the GDPR - if they retain the processing of their personal data is against the relative laws and regulations in force.

The user shall file notice of objection to the processing of their personal data – former to Article no. 21 of the GDPR – where to give evidence of the reasons that justify the objection; the Data Controller reserves the right to evaluate the claim which shall not be accepted in case of the existence of legitimate binding reasons, in order to proceed with the processing that prevail over the user’s interests, rights and freedom.

The interested party shall at any time exercise the rights referred to the previous Article by sending:

- a registered letter a.r. to: Flyer Tech s.r.l., Via Antichi Pastifici 8/A - Molfetta (Bari, Italy) - 70056

- an email to: info@transactionale.com

- a certified email to: flyertechsrl@legalmail.it

  1. Data Controller, DPO

The Data Controller is Flyertech s.r.l whose contact information is shown at the beginning of this document. The Data Controller informs that it has appointed lawyer Antonino Polimeni (tax code PLMNNN78T04F158Z) as Data Protection Officer. He can be contacted at the following address: dpo@transactionale.com

 

COOKIES

Regarding cookies that are installed on your device, we inform you that the provision of data is optional. However, some cookies are needed to grant correct navigation on the website and therefore, in the absence of consent, the website might not work.

This information on the use of cookies on the website is provided in implementation of the provision of the Guarantor for the protection of personal data of 08.05.2014 "Identifying simplified ways for information and consent to use cookies", of the Guidelines on the use of cookies and other tracking tools of 10.06.2021 and in compliance with Article no. 13 of the GDPR.

 

HOW MANY TYPES OF COOKIES ARE THERE?

TECHNICAL COOKIES

They are generally necessary for the correct functioning of the website and to allow navigation; without them you might not be able to correctly view pages or use certain services. For example, a technical cookie is necessary to keep users logged in while visiting the website, or to memorize language settings, view settings, etc.

They are not used for further purposes and they are normally installed directly by the Data Controller or website operator.

The prior consent of users for the installation of cookies of this kind is not required.

These cookies are divided into the following types:

  1. Essential cookies, which are strictly necessary for the functioning of the website. In their absence, the site or some portions of it may not function properly. They include, for example, cookies that allow access to protected areas of the website. These cookies do not collect data for marketing or advertising purposes and cannot be disabled;
  2. Session cookies, which are immediately deleted when the browser is closed;
  3. Persistent cookies, which - unlike session cookies - remain within the browser for a certain period of time. They are used, for example, to recognize the device accessing the site and facilitate user authentication;
  4. Analytical cookies,  which can be treated as technical cookies when they are used directly by the website operator to collect aggregate data on the number of users and how they visit the website;
  5. Functionality cookies, which allow user navigation under a series of selected criteria (for example, language and products added to cart) in order to improve the service provided.

PROFILING COOKIES

These cookies are used to profile users and show ads based on their preferences expressed during navigation. This website does not use first-party profiling cookies, but only third-party profiling cookies, which will be dealt with in the following section.

THIRD-PARTY COOKIES

They are generated and managed by different subjects than the operator of the website on which users are browsing (typically this type of cookie works in force of a previous agreement between website manager and the third party)

In particular, this website makes use of the following third-party cookies:


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Last update: 05/08/2022