- is intended for the www.key-one.it site, including dedicated areas where the user can freely and expressly provide a series of data concerning him to contact Find me or send requests;
- is made pursuant to art. 13 of the EU General Data Protection Regulation (General Data Protection Regulation, hereinafter “GDPR”) and illustrates how to use, share, access, modify or delete personal information provided by the user. The information is also inspired by Recommendation no. 2/2001 concerning the minimum requirements for online data collection in the European Union, adopted on 17 May 2001 by the Article 29 Working Group.
- Holder of the treatment
- Personal data subject to processing
- Data of minors
- Legal basis and purpose of the processing
- Recipients of personal data
- Transfer of personal data
- Retention of personal data
- Rights of the interested party
1. Holder of the treatment
The data controller is Trovami srl, with registered office in Milan (20131), Via Donatello n. 30, C.F. and VAT number 09792490964. The updated list of data processors and persons authorized to process the processing is located at the registered office of the Data Controller. For any further information or clarification, Trovami can be contacted at the e-mail address indicated, or at the e-mail address firstname.lastname@example.org.
2. Personal data being processed
2.1. Navigation data
The processing of personal data of users who visit and consult the Site is limited to the so-called navigation data whose transmission is necessary for the operation of the computer systems and programs necessary for the operation of the Site but which by their very nature could, in association with other data, allow the identification of users. These include the IP addresses or the names of the computers used by users who connect to the Site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained from the response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the IT platform used by the user. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning. These data may also be used to ascertain responsibility in the event of the commission of computer crimes against the Site in accordance with the procedures in force at the competent Authorities. Except for this eventuality, the navigation data are stored only temporarily in compliance with the applicable legislation.
2.2. Data provided voluntarily by the user
To access the contents of the site it is not necessary to register. However, there are services within the Site for the use of which it is necessary to provide your data. If Trovami acquires information and personal data, it will inform users in advance about the purposes for which such data are requested and how they will be used. By way of example, if the User decides to contact Find Me through the contact forms, personal data such as name and surname, telephone number, e-mail address and any other information that the user agrees to provide may be requested. In this case, the User consents to their use to respond to requests for information, quotes, or any other nature indicated by the form header. Where necessary, Trovami will acquire the specific consent of the user for the relative use of the data.
3. Data of minors
The Site is not aimed at minors and Trovami does not intentionally collect personal data from them. In the event of accidental registration of any information on minors, Trovami will delete them in a timely manner at the request of users.
4. Legal basis and purpose of the processing
The following table illustrates the legal basis and the reasons why the User’s data can be processed by Trovami
|Contract In some cases it is necessary to process the User’s personal data to execute our contract with reference to the use of the site||
|Legitimate interest We collect and process personal data to improve and monitor the efficiency of the Site and offer updated services||
|Fulfillment of legal obligations We may use the data provided to satisfy requests from the authorities and for the fulfillment of obligations related to safety||
|Consent With the user’s consent, we will be able to carry out marketing activities||
|With the user’s consent, we will be able to carry out profiling on site activity||
5. Recipients of personal data
- subjects who act as data processors such as, by way of example: people, companies or professional firms that provide assistance and advice to Trovami in accounting, administrative, legal, tax and financial matters; subjects delegated to perform services of a technical nature; credit institutions and insurance companies;
- persons authorized by Trovami to process personal data for activities strictly related to the provision of services, who have an adequate legal obligation of confidentiality;
- police forces, armed forces and other public administrations in order to fulfill the obligations established by laws, regulations and national or European legislation as well as agencies or professionals for debt collection (e.g. outstanding debts towards us) or to allow the legal defense of Trovami, for example in the case of network violations by users;
- only with the specific consent of the user, personal data may be disclosed to Trovami business partners or third parties (without prejudice to the adoption of security and data protection criteria in line with current legislation) for the purpose of marketing and profiling as described above.
6. Transfer of personal data
Trovami does not transfer personal data to third countries or to international organizations. However, it reserves the right to use cloud services. In this case, the service providers will be selected from those who provide adequate guarantees, as required by art. 46 GDPR 679/16. The processing, therefore, will take place according to one of the methods permitted by current law, such as the adoption of Standard Clauses approved by the European Commission, the selection of subjects adhering to international programs for the free circulation of data, (eg EU-USA Privacy Shield) or operating in countries considered safe by the European Commission.
7. Retention of personal data
The information systems and computer programs used by Trovami are configured in such a way as to minimize the use of personal and identification data; these data are processed only for the achievement of the specific purposes pursued from time to time; in any case, the criterion used to determine the retention period is based on compliance with the terms permitted by applicable laws and the principles of minimizing processing and rational management of archives.
8. Rights of the interested party