Privacy Policy

Privacy Policy pursuant to Articles 13 and 14 of Regulation (EU) 2016/679

Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (the “Regulation”), DIMITRI DALENO S.R.L., hereinafter provides its existing and potential clients, as well as third parties in general (e.g., delegates, legal representatives, etc.) who come into contact with it on behalf of or under instruction from existing or potential clients (the “Data Subjects”), with the information required by law regarding the processing of their personal data (“Personal Data”).

DIMITRI DALENO S.R.L. (VAT no. 13678990964), in the person of its pro tempore legal representative, is the entity that processes the data of Data Subjects and, for legal purposes, is considered the Data Controller of Personal Data. In this capacity, it is responsible for ensuring the application of adequate organizational and technical measures for data protection in compliance with current legislation.

DIMITRI DALENO S.R.L. has appointed a Data Protection Officer (DPO), responsible for ensuring compliance with privacy protection regulations, who can be contacted for issues concerning the processing of Personal Data at the following address: INFO@DIMITRIDALENO.COM

Personal Data subject to processing activities by the Data Controller may be acquired from the Data Subject, including through remote communication techniques used by the Data Controller (e.g., websites, smartphone and tablet apps, call centers, etc.);

Personal Data processed by the Data Controller include, by way of example:

i. browsing data (e.g., IP addresses or domain names of the computers used by users connecting to the website, the time of the request, the method used to submit the request to the server, the numerical code indicating the status of the response given by the server, and other parameters relating to the operating system and browser used by the user, logs);

ii. personal identification data (e.g., name, surname, tax code, address, date and place of birth, nationality);

iii. contact data (e.g., telephone numbers, landline and/or mobile, email address);

iv. profiling and marketing data (e.g., interests and passions);

v. other data falling within the categories listed above.

Personal Data, if the specified conditions apply, will be processed for the purposes indicated below:

• website registration and management of contact requests and/or information material

The processing of the Data Subject's personal data takes place in order to carry out preliminary and subsequent activities to the website registration request, if applicable, as well as for the management of requests for information and contact and/or sending of information material, and for the fulfillment of any other resulting obligation.

The legal basis for such processing is the fulfillment of services related to the registration request, information and contact and/or sending of information material, and compliance with legal obligations.

The provision of data is optional; however, any refusal by the Data Subject to provide the data makes it impossible for the Data Controller to fulfill the requested service.

• contract execution

Personal Data will be processed for the management of the contractual relationship (for example, for invoicing fees, for managing payments or complaints that you may submit to us) and for the provision of requested services available through the website.

The legal basis for such processing is the fulfillment of services related to the contractual relationship and compliance with legal obligations.

The provision of data is optional; however, any refusal by the Data Subject to provide the data makes it impossible for the Data Controller to fulfill the requested service.

• fulfillment of legal obligations, defending a right in judicial or extrajudicial proceedings, and fraud prevention

Personal Data will be processed for the fulfillment of legal obligations, as well as to ascertain, exercise or defend a right of the Data Controller and/or defend against claims from others, in judicial or extrajudicial proceedings. In particular, the Data Controller may process Personal Data for the fulfillment of accounting and tax obligations and for the fulfillment of judicial authority provisions aimed at preventing and suppressing crimes.

The legal basis for such processing is the pursuit of the Data Controller's legitimate interest, taking into account the balancing of the rights of the Data Controller and the Data Subject.

• promotional activities on Services/Products similar to those purchased

The processing of the Data Subject's personal data takes place for sending communications relating to promotions and offers of the Data Controller's Services/Products identical and/or similar to those covered by the ongoing contract with the Data Subject, unless the Data Subject has objected to such processing initially or on the occasion of subsequent communications.

The legal basis for such processing is the legitimate interest of the Data Controller to promote products or services in which the customer may reasonably be interested, taking into account the balancing of the rights of the latter and the Data Controller.

The Data Subject has the right to object at any time, for reasons related to their personal situation, to the processing of their personal data for the purpose in question.

• Promotional activities on Services/Products offered by DIMITRI DALENO S.R.L.

The processing of the Data Subject's personal data takes place for sending, with specific consent, communications of promotions and offers of the Data Controller's Services/Products through traditional methods (e.g., ordinary mail, phone calls with an operator) and/or automated methods (e.g., e-mail, SMS, MMS, fax, prerecorded calls).

The legal basis for such processing is the consent given by the Data Subject prior to the processing itself, which can be freely and at any time revoked, without prejudice to the lawfulness of the processing carried out previously.

Any refusal by the Data Subject to give consent makes it impossible to use the related services, without this entailing prejudicial consequences for the contractual relationship with the Data Controller.

• marketing purposes related to products or services of DIMITRI DALENO S.R.L partners

The processing of the Data Subject's personal data takes place for sending, with specific consent, communications of promotions and offers of Services/Products from commercial partners of DIMITRI DALENO S.R.L through traditional methods (e.g., ordinary mail, phone calls with an operator) and/or automated methods (e.g., e-mail, SMS, MMS, prerecorded calls).

The legal basis for such processing is the consent given by the Data Subject prior to the processing itself, which can be freely and at any time revoked, without prejudice to the lawfulness of the processing carried out previously.

Any refusal by the Data Subject to give consent makes it impossible to use the related services, without this entailing prejudicial consequences for the contractual relationship with the Data Controller.

• profiling

The processing of Personal Data, including location data, socio-demographic data acquired during the provision of electronic communication services and from public sources, of the Data Subject takes place, with specific consent, for profiling purposes such as analysis of transmitted data and purchased Services/Products in order to propose advertising messages and/or commercial offers in line with the choices expressed by the users themselves. This activity will be carried out in an aggregated and anonymized form through the implementation of models for analyzing customer data using statistical algorithms, predictive models, and aggregations only for the time strictly necessary for the purposes pursued, the type of goods marketed or services rendered.

In any case, Personal Data will not be subject to decisions based solely on automated processing, including profiling, which produce legal effects or similarly significantly affect the data subject.

The legal basis for such processing is the consent given by the Data Subject prior to the processing itself, which can be freely and at any time revoked, without prejudice to the lawfulness of the processing carried out previously.

Any refusal by the Data Subject to give consent makes it impossible to use the related services, without this entailing prejudicial consequences for the contractual relationship with the Data Controller.

The personal data collected may be communicated to subjects who will act, as the case may be, as independent Data Controllers or Data Processors, for the purposes indicated above, in compliance with legal and regulatory obligations and/or those deriving from EU legislation or because they hold a legitimate interest.

In particular, Personal Data may be made available to:

– subjects appointed to carry out activities connected and instrumental to the processing (archiving service companies, IT service companies, social media management service companies, marketing companies, insurance companies, banking institutions);

– commercial partners of DIMITRI DALENO S.R.L;

– Public Administrations, Authorities and other subjects in fulfillment of legal obligations;

Personal Data will not be disseminated (made available to indeterminate subjects).

The Data Subject's Personal Data is stored in archives located in countries within the European Union. Where necessary for the pursuit of the stated purposes, the Data Subject's Data may be transferred abroad, to countries/organizations outside the European Union that guarantee a level of personal data protection deemed adequate by the European Commission with its decision, or in any case based on other appropriate safeguards, such as, for example, the Standard Contractual Clauses adopted by the European Commission or the consent of the Data Subject. The Data Subject has the right to obtain a copy of any Data transferred abroad, as well as a list of the countries/organizations to which the data has been transferred by writing to INFO@DIMITRIDALENO.COM

The Data will be stored in a form that allows the identification of the Data Subject for a period not exceeding that necessary to achieve the purposes for which they were collected, taking into account the laws applicable to the activities and sectors in which the Data Controller operates. After the terms thus established, the Data will be deleted or transformed into anonymous form, unless their further retention is necessary to fulfill obligations (e.g., tax and accounting) that remain even after the termination of the contract (Article 2220 of the Italian Civil Code) or to comply with orders issued by Public Authorities and/or Supervisory Bodies.

The duration of the cookies used on the website can be found in the specific Cookie Policy below.

In the event of a dispute, the retention period indicated above may be extended up to 10 years from its resolution.

Processing will be carried out by authorized personnel who need to be aware of it in the performance of their duties, with the aid of electronic tools, according to principles of lawfulness and fairness, in order to protect the privacy and rights of the data subject at all times, in compliance with current legislation.

Profiling related to marketing (analysis of consumption habits and choices) occurs through an automated process aimed at studying and analyzing behavioral profiles and the characteristics of the customer base to optimize promotional activities for products and services.

The Data Subject has the right to ask the Data Controller:

i. confirmation as to whether or not Personal Data concerning him or her are being processed, and, where that is the case, access to the Personal Data (right of access);

ii. the rectification of inaccurate Personal Data or the integration of incomplete Personal Data (right to rectification);

iii. the erasure of Personal Data if one of the reasons provided for in the Privacy Regulation exists (right to be forgotten);

iv. the restriction of processing of Personal Data when one of the hypotheses provided for in the Privacy Regulation occurs (right to restriction);

v. to receive the Personal Data provided to the Controller in a structured, commonly used and machine-readable format and to transmit those data to another data controller (right to data portability);

vi. to object, in whole or in part, at any time to processing carried out for the pursuit of a legitimate interest of the Controller and for marketing and profiling purposes (right to object);

vii. to withdraw any consent to the processing of Personal Data, at any time, without affecting the lawfulness of processing based on consent given before its withdrawal.

Consent given for marketing activities using automated contact methods (e.g., SMS, MMS, fax, voice calls, emails, web applications) also extends to traditional contact methods (paper mail or telephone calls with an operator). Similarly, objection to marketing activities using automated contact methods also extends to traditional contact methods. Your right to provide consent or exercise the right to object in relation to only one of the two methods of carrying out marketing activities remains unaffected.

To exercise their rights, the Data Subject may send a message to the email address or a written communication to the Controller at the registered office of DIMITRI DALENO S.R.L

The Data Subject also has the right to lodge a complaint with the competent supervisory authority in Italy (Garante per la protezione dei dati personali) or with the one that performs its duties and exercises its powers in the Member State where the violation occurred, as provided for in Article 77 of the Regulation, as well as to bring appropriate judicial proceedings pursuant to Articles 78 and 79 of the Regulation.

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