Privacy policy
Information document pursuant to Article 13 of EU Reg. 2016/679 (hereinafter, for brevity, “GDPR”)
Information for the processing of personal data collected directly from the interested party Unboxeed by Ginger Media platform owned by the company Smiling Srl.
In compliance with the provisions of EU Reg. 2016/679 (European Regulation for the protection of personal data) we provide you with the necessary information regarding the processing of the personal data provided. This information is provided pursuant to art. 13 of EU Reg. 2016/679 and in compliance with art.12 in the methods of providing information: in a concise, transparent, intelligible and easily accessible form. In order to make reading more understandable, useful definitions deriving from the Regulation are reported at the beginning of each paragraph.
DATA CONTROLLER
«Data controller»: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Pursuant to the articles. 4 and 24 of EU Reg. 2016/679, the data controller is Smiling Srl, with registered office in via Giovanni da Procida 35/a, 20149 – Milan (MI), in the person of the legal representative pro tempore.
PURPOSE AND LEGAL BASIS OF THE PROCESSING
«controlling»: any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, diffusion or any other form of making available, comparison or interconnection, limitation, deletion or destruction. The personal data provided will be processed in compliance with the conditions of lawfulness pursuant to art. 6 EU Reg. 2016/679 for the following purposes:
| Purpose | Legal basis – Condition of lawfulness | |
|---|---|---|
| A - | Website navigation. | Art. 6 par. 1 letter f), Activities strictly necessary for the functioning of the site and the provision of the navigation service on the platform. |
| B - | Check the validity of the email address entered, in order to proceed with registration or to verify that it is you personally, as an interested party, who requests registration on the Unboxeed platform | Art. 6 par. 1 letter f), Activity necessary for the owner to guarantee the correct acquisition of personal data referring to the person who is filling out the form in the pre-registration phase. Verification of the identity of the person who fills out the form and provides the data. |
| C - | pages.privacy.purposeTableCellC1 | Art. 6 par. 1 letter f), Activities strictly necessary for the functioning of the site and the provision of the navigation service on the platform. |
| D - | Service communications through e-mail, telephone with information relating to your account statement in accumulated points, in execution of the provisions of the Terms and Conditions of the Unboxeed platform | Art. 6 par. 1 letter b), Contract/service as legal basis for processing. |
| E - | Possible compilation of data collection forms for personnel selection (recruitment of personnel, execution of a possible contractual relationship, carrying out training courses and internships, formalization of the application, for the purpose of a possible selection and for future selections) | Art. 6 par. 1 letter b), Pre-contractual measure Art. 111 bis, Legislative Decree. 196/2003 |
| F - | Provide feedback to requests for information and questions that you forward by completing the data collection form. | Art. 6 par. 1 letter f), Legitimate interest of the owner in providing prompt feedback to users/consumers regarding requests of various kinds (e.g. technical, relating to products/services etc.) |
| G - | Subject to your consent and until you object, to carry out direct marketing activities in order to provide you with information on promotions, discounts, benefits, events, products and other services by the Owner, also by sending specific material (e.g. catalogues, flyers) in paper and/or electronic form, through newsletters (e-mail) or other tools (sms, mms, instant messaging or even through notifications via APP). | Art. 6 par. 1 letter a), Consent as legal basis for processing. |
| H - | Subject to consent and until your opposition: collection, profiling, recording and processing of purchase data, including those relating to the details of the frequency, quantity and type of purchases for the purpose of analyzing the propensity to purchase and profiling in general of the user to prepare and propose personalized promotions and offers. | Art. 6 par. 1 letter a), Consent as legal basis for processing. |
| I - |
| Art. 6 par. 1 letter f), legitimate interest of the owner balanced with analysis of the impacts of this activity on the interested parties. It is the legitimate interest of the owner to verify the payment of the goods/products offered to the consumer, payment which takes place by the consumer himself. |
| L - | Subject to consent and until your opposition: transfer of data to Smiling Srl for marketing purposes, market research or other sample research, for the detection of the degree of satisfaction, for receive informative, promotional, commercial and advertising material or material relating to competitions and initiatives, also by sending specific material (e.g. catalogues, flyers) in paper and/or electronic form, via newsletter (e-mail) or other tools (SMS, MMS, instant messaging or even through notifications via APP). Attention: without first having obtained the consent of the interested party, the personal data will NOT be used for the aforementioned purposes (referred to in this purpose G). | Art. 6 par. 1 letter a), Consent as legal basis for processing. |
RECIPIENTS OR CATEGORIES OF RECIPIENTS OF THE DATA
«data controller»: the natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller. «recipient»: the natural or legal person, public authority, service or other body which receives communication of personal data, whether it is a third party or not.
The personal data provided will be communicated to recipients who will process the data as managers (art. 28 of EU Reg. 2016/679), as natural persons acting under the authority of the Data Controller and the Manager (art. 29 of EU Reg. 2016/679), for the purposes listed above.
Specifically, the data will be communicated to:
- staff within the owner's organization;
- subjects who provide services for the management of the information system and communication networks, including e-mail and websites;
- firms or companies in the context of assistance and consultancy relationships;
- companies that support the data controller for delivery/delivery of purchases (couriers);
- competent authorities for the fulfillment of legal obligations and/or provisions of public bodies, upon request.
The subjects belonging to the aforementioned categories perform the function of Data Processor, or operate in total autonomy as separate Data Controllers.
DATA TRANSFER TO A THIRD COUNTRY AND/OR AN INTERNATIONAL ORGANIZATION AND GUARANTEES
The personal data provided will NOT be transferred to countries belonging to the European Union and to non-EU countries.
DATA CONSERVATION PERIOD OR CRITERIA FOR DETERMINING THE PERIOD
The processing will be carried out in an automated and manual manner, with methods and tools aimed at guaranteeing maximum security and confidentiality, by persons specifically appointed for this purpose. In compliance with the provisions of the art. 5 paragraph 1 letter. e) of EU Reg. 2016/679, the personal data collected will be stored in a form that allows the identification of the interested parties for a period of time not exceeding the achievement of the purposes for which the personal data are processed. Specifically, the data will be processed in compliance with the timescales established within the relevant procedure, to be requested at amministrazione@smiling.video.
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NATURE OF THE PROVISION AND REFUSAL
Apart from what is specified for navigation data, the user is free to provide personal data. The provision of data is optional or necessary depending on the specific purpose for which the data is processed. Failure to provide data will make it impossible to obtain what is requested or to use the services of the data controller. In particular:
| Purpose | Nature of provision and refusal | |
|---|---|---|
| A - | Website navigation | The provision of navigation data is necessary if they serve to guarantee the correct and efficient use of the site (e.g. URL, browser, technical cookies). |
| B - | Checking the validity of the email address entered. | The provision of data is necessary in order to verify the actual correspondence between the email address indicated and your person, in order to guarantee that the registration request comes from you and not from third parties. Failure to provide it will make it impossible to carry out the registration procedure. |
| C - | Creating a registration account. | The provision of data is necessary for the purpose of creating an account on this website and issuing the Bennet Card. Failure to provide data will make it impossible to access these services. |
| D - | Institutional communications such as emails, text messages. | The provision of data is necessary to receive updates on ongoing campaigns and specific characteristics. |
| E - | Possible compilation of data collection forms for personnel selection. | The provision of data is necessary in order to send your application and CV. Failure to provide them will make it impossible to process the data for the purposes of managing the matching of job supply and demand, personnel search and selection. |
| F - | Provide feedback to requests for information and questions that you forward by completing the data collection form. | The provision of data is necessary in order to receive feedback on the request for information forwarded. Otherwise, the data controller will not be able to respond to you and give you the requested information. |
| G - | Direct marketing activities. | The provision of data is FREE. Failure to provide data will make it impossible to be contacted for direct marketing purposes |
| H - | Profiling, recording and processing of data | The provision of data is FREE. Failure to provide data will make it impossible to receive personalized commercial and promotional communications. |
RIGHTS OF INTERESTED PARTIES
You may assert your rights as expressed by EU Regulation 2016/679 by contacting the Data Controller by sending an email to amministrazione@smiling.video.
You have the right, at any time, to ask the Data Controller for access to your personal data, rectification, cancellation of the same, limitation of processing. Furthermore, you have the right to object, at any time, to the processing of your data. You may revoke the consent given for the profiling of your personal data at any time by using our automatic cancellation systems within the Unboxeed platform.
Without prejudice to any other administrative and jurisdictional 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. In the cases provided for, you have the right to the portability of your data and in this case the Data Controller will provide you with the personal data concerning you in a structured, commonly used and readable format, by automatic device.
CHANGE IN PRIVACY POLICY
The owner reserves the right to modify, update, add or remove parts of this privacy policy at its discretion and at any time. In order to facilitate this verification, the information will contain an indication of the update date.
