Aitasit Web & Mobile Policy collects some Personal Data from its Users.
Owner and Data Controller
Associazione Italiana Amministratori di Sistema e Telemedicina – via Morgagni, 9 – 37135 Verona (Italy)
Owner contact email: firstname.lastname@example.org
Types of Data collected
Among the types of Personal Data that Aitasit Web & Mobile Policy collects, by itself or through third parties, there are: Cookies; Usage Data; email address; first name; last name; profession; ZIP/Postal code; date of birth; city; phone number; address; country; province; various types of Data; Tax ID; field of activity; User ID; number of employees; Camera permission; Phone permission; Social media accounts permission.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Aitasit Web & Mobile Policy.
Unless specified otherwise, all Data requested by Aitasit Web & Mobile Policy is mandatory and failure to provide this Data may make it impossible for Aitasit Web & Mobile Policy to provide its services. In cases where Aitasit Web & Mobile Policy specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through Aitasit Web & Mobile Policy and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Aitasit Web & Mobile Policy (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Interaction with external social networks and platforms, Contacting the User, Backup saving and management, Remarketing and behavioral targeting, SPAM protection, Handling payments and Device permissions for Personal Data access.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Device permissions for Personal Data access
Depending on the User’s specific device, Aitasit Web & Mobile Policy may request certain permissions that allow it to access the User’s device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User’s device and software.
Please note that the revoking of such permissions might impact the proper functioning of Aitasit Web & Mobile Policy.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by Aitasit Web & Mobile Policy.
Used for accessing the camera or capturing images and video from the device.
Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.
Social media accounts permission
Used for accessing the User’s social media account profiles, such as Facebook and Twitter.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of Aitasit Web & Mobile Policy, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies; Usage Data.
Backup saving and management
This type of service allows the Owner to save and manage backups of Aitasit Web & Mobile Policy on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to Aitasit Web & Mobile Policy.
Backup on Google Drive (Google Inc.)
Google Drive is a service to save and manage backups provided by Google Inc.
Contacting the User
Mailing list or newsletter (Aitasit Web & Mobile Policy)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Aitasit Web & Mobile Policy. Your email address might also be added to this list as a result of signing up to Aitasit Web & Mobile Policy or after making a purchase.
Personal Data collected: city; date of birth; email address; first name; last name; profession; ZIP/Postal code.
Contact form (Aitasit Web & Mobile Policy)
By filling in the contact form with their Data, the User authorizes Aitasit Web & Mobile Policy to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: address; city; country; date of birth; email address; field of activity; first name; last name; number of employees; phone number; profession; province; Tax ID; User ID; various types of Data; ZIP/Postal code.
Device permissions for Personal Data access
Aitasit Web & Mobile Policy requests certain permissions from Users that allow it to access the User’s device Data as described below.
Device permissions for Personal Data access (Aitasit Web & Mobile Policy)
Aitasit Web & Mobile Policy requests certain permissions from Users that allow it to access the User’s device Data as summarized here and described within this document.
Personal Data collected: Camera permission; Phone permission; Social media accounts permission.
Payment processing services enable Aitasit Web & Mobile Policy to process payments by credit card, bank transfer or other means. To ensure greater security, Aitasit Web & Mobile Policy shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of Aitasit Web & Mobile Policy.
The interaction and information obtained through Aitasit Web & Mobile Policy are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on Aitasit Web & Mobile Policy isn’t being connected back to the User’s profile.
Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data collected: Cookies; Usage Data.
Remarketing and behavioral targeting
This type of service allows Aitasit Web & Mobile Policy and its partners to inform, optimize and serve advertising based on past use of Aitasit Web & Mobile Policy by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Aitasit Web & Mobile Policy with the Facebook advertising network.
Personal Data collected: Cookies; email address.
This type of service analyzes the traffic of Aitasit Web & Mobile Policy, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Google reCAPTCHA (Google Inc.)
Personal Data collected: Cookies; Usage Data.
Further information about Personal Data
Aitasit Web & Mobile Policy may send push notifications to the User.
Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through Aitasit Web & Mobile Policy to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more, about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User’s rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
Personal Data collected through sources other than the User
The Owner of Aitasit Web & Mobile Policy may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Aitasit Web & Mobile Policy or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, Aitasit Web & Mobile Policy and any third-party services may collect files that record interaction with Aitasit Web & Mobile Policy (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
Aitasit Web & Mobile Policy does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through Aitasit Web & Mobile Policy (or third-party services employed in Aitasit Web & Mobile Policy), which can include: the IP addresses or domain names of the computers utilized by the Users who use Aitasit Web & Mobile Policy, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using Aitasit Web & Mobile Policy who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
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, including the security measures concerning the operation and use of Aitasit Web & Mobile Policy. The Data Controller, unless otherwise specified, is the Owner of Aitasit Web & Mobile Policy.
Aitasit Web & Mobile Policy (or this Application)
The means by which the Personal Data of the User is collected and processed.
The service provided by Aitasit Web & Mobile Policy as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User’s device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
Latest update: May 31, 2018