This information is provided in compliance with art. 13 of the Regulation 2016/679 (GDPR), pursuant to art. 13 of the Legislative Decree no. 196/2003 (Legislation Code regarding the protection of personal data) to users who access the website www.justcreative.ch and is related to all personal data processed in the manner indicated below.
THE HOLDER OF THE SERVICE
The Data Controller of personal data collected is Just Creative sagl – Vicolo Maderno, 1 – CH, 6816 – Bissone email: firstname.lastname@example.org.
The personal data processed are collected as provided directly by the interested party or automatically provided.
The data provided directly by the interested party are all personal data that are provided to the Data Controller in any way, directly by the data subject. In particular, the following personal data are collected and processed: name, surname, physical address, nationality, province and municipality of residence, telephone and/or mobile numebr, fax numebr, fiscal code, e-mail address, IBAN and bank/postal details (except credit card number).
The data collected automatically is the navigation data. Such data, although not collected in order to be associated with the identity of the user, could indirectly, through processing and associations with data collected by the Data Controller, allow its identification. In particular: Log, IP address of origin.
Just Creative does not require the interested party to provide data c.d. “Special”, or, according to the provisions of the GDPR (art. 9), personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometrics data intended to uniquely identify an individual, data relating the health or sex life or sexual orientation of the person. In the event that the service requested from Just Creative required the processing of such data, the interested party will receive a specific notice in advance and will be required to provide appropriate consent.
LEGAL BASIS AND PURPOSE OF THE TREATMENT
The data is processed exclusively for the purposes for which it was collected, as described below.
We use the data provided by interested parties to:
a) the registration and the requests for contact and/or for information material
The processing of the personal data of the interested party takes place in order to carry out the preliminary activities and consequent to the request for registration, to the management of requests for information and contact and/or sending of informative material, as well as for the fulfillment of any other obligation arising.
The legal basis of these treatments is the performance of the services inherent to the application for registration, information and contact and/or sending of informative material and compliance with legal obligations.
b) management of the contractual relationship
The processing of personal data of the interested party takes place in order to carry out the preliminary activities and consequent to the purchase of a Service and/or a Product, the management of the relative order, the supply of the Service itself and/or the production and/or the shipment of the purchased Product, the relative invoicing and payment management, the handling of complaints and/or reports to the assistance service and the provision of assistance, fraud prevention and the fulfillment of any other obligation deriving from from the contract.
The legal basis of these treatments is the performance of the services relating to the contractual relationship and compliance with legal obligations.
c) promotional activities on Services/Products similar to those purchased by the interested party (Recital 47 GDPR)
The data controller, even without your explicit consent, may use the contact details provided by the interested party, for the purpose of direct sales of their Services/Products, limited to the case in which they are Services/Products similar to those covered by the sale, unless the interested party explicitly opposes it.
d) commercial promotion activities on Services/Products other than those purchased by the interested party
The personal data of the interested party may also be processed for commercial promotion purposes, for surveys and market research with regards to Services/Products that the Owner offers only if the interested party has authorized the processing and does not object to this.
This processing can be done in an automated way, with the following methods:
– telephone number
and can be done:
– if the interested party has not revoked his consent for the use of the data;
– if, in the event that the processing is carried out through contact with a telephone operator, the interested party is not registered in the register of oppositions as per D.P.R. n. 178/2010.
The legal basis of these treatments is the consent given by the interested party prior to the treatment itself, which can be revoked freely by the interested party at any time (see Section III).
e) computer security
The Data Controller, in line with the provisions of Recital 49 of the GDPR, treats, even through its suppliers (third parties and / or recipients), the personal data of the interested party related to the traffic to a strictly necessary and proportionate extent to ensure the safety of the networks and information, namely the ability of a network or information system to withstand, at a given security level, unforeseen events or unlawful or malicious acts that compromise availability, authenticity, or integrity and confidentiality of personal data stored or transmitted.
The Owner will promptly inform the interested parties, if there is a particular risk of violation of their data without prejudice to the obligations deriving from the provisions of art. 33 of the GDPR concerning notifications of personal data breach.
The personal data of the interested party may also be processed for profiling purposes (such as analysis of the data transmitted and the chosen Services/Products, propose advertising messages and/or commercial proposals in line with the choices made by the users themselves) exclusively in the event that the interested party has provided explicit and informed consent. The legal basis of these treatments is the consent given by the interested party prior to the treatment itself, which can be revoked by the interested party freely and at any time (see Section III).
Communication to third parties and categories of recipients (art. 13, 1st paragraph GDPR)
The communication of the personal data of the interested party takes place mainly towards third parties and/or recipients whose activity is necessary for the performance of the activities pertaining to the relationship established and to respond to certain legal obligations, such as:
Categories of recipients:
Third party suppliers: a company that manages web services, specifically: Aruba Spa
Purpose: administrative, accounting and contractual fulfillment obligations and provision of services (assistance, maintenance, provision of additional services, connected to the requested service)
Digital credit and payment institutions, banking/postal institutions for the management of receipts, payments, reimbursements related to the contractual service
External professionals/consultants and consulting companies for the fulfillment of legal obligations, exercise of rights, protection of contractual rights, recovery of credit.
Financial administration, public bodies, judicial authorities, supervisory and control authorities for the fulfillment of legal obligations, defense of rights; lists and registers kept by public Authorities or similar bodies based on specific legislation, in relation to the contractual service
Subjects formally delegated or with a recognized legal title: Legal representatives, curators, guardians, etc.
* The Data Controller requires third-party suppliers and Data Processors to comply with security measures equal to those adopted in relation to the Data Subject by restricting the scope of action of the Data Supervisor to processing related to the requested service.
The Owner does not transfer your personal data to countries where GDPR is not applied (countries outside the EU) unless specifically indicated otherwise for which you will be informed in advance and your consent will be required if necessary.
The legal basis of these treatments is the performance of the services inherent in the relationship established, compliance with legal obligations and the legitimate interest of Just Creative to carry out treatments necessary for these purposes.
What happens if the interested party does not provide his identified data as necessary for the performance of the requested service? (Article 13, 2nd paragraph, lett. And GDPR)
The collection and processing of personal data is necessary to process the requested services as well as to provide the Service and/or supply the requested Product. If the interested party does not provide the personal data expressly provided for as necessary within the order form or the registration form, the Owner will not be able to continue the processing related to the management of the requested services and/or the contract and the Services/Products connected to it, nor to the obligations that depend on them.
What happens if the interested party does not consent to the processing of personal data for commercial promotion activities on services/products other than those purchased?
In the event that the interested party does not give his consent to the processing of personal data for these purposes, such processing will not take place for the same purposes, without this having effects on the provision of personal data.
In the event that the interested party has consented and should subsequently revoke it or oppose the processing for commercial promotion activities, your data will no longer be processed for such activities, without this involving consequences or effects detrimental to the Data Subject and to the services required.
How we treat the data of the interested party (art. 32 GDPR)
The Data Controller provides for the use of adequate security measures in order to preserve the confidentiality, integrity and availability of personal data of the interested party and imposes similar security measures on third party suppliers and Data Processors.
Where we process the data of the interested party
The personal data of the interested party are stored in paper and computer archives located in countries where the GDPR (EU countries) is applied.
How long is the data of the interested party stored? (Article 13, 2nd paragraph, letter a GDPR)
Unless they explicitly express their will to remove them, the personal data of the interested party will be kept until they are necessary with respect to the legitimate purposes for which they were collected.
In particular, they will be kept for the entire duration of your registration and in any case no later than a maximum period of 12 (twelve) months of inactivity, or if, within that period, the Services and/or products purchased are not associated with the the registry itself.
In the case of data provided to the Data Controller for the purposes of commercial promotion for services other than those already acquired by the Data Subject, for which he initially gave consent, these will be kept for 24 months, unless the consent given is revoked.
In the case of data provided to the Data Controller for the purposes of profiling, these will be kept for 12 months, unless the consent given is always revoked.
It should also be added that, in the event that a user submits unsolicited or unnecessary personal data for the purpose of performing the requested service or for the provision of a service closely connected to it, Just Creative cannot be considered the holder of this data, and will cancel them as soon as possible.
Regardless of the determination of the interested party to remove them, the personal data will in any case be kept in accordance with the terms established by the current legislation and/or national regulations, for the exclusive purpose of guaranteeing the specific fulfilments of certain services (by way of example but not exhaustive, Certified Electronic Mail, Digital Signature, replacement Storage – in this regard see the relevant section).
In addition, personal data will in any case be kept for the fulfillment of obligations (i.e. tax and accounting) which remain even after the termination of the contract (Article 2220 of the Civil Code); for these purposes the Data Controller will only keep the data necessary for the related prosecution.
The cases in which the rights deriving from the contract and/or the registry registration are asserted, in which case the personal data of the interested party, exclusively those necessary for such purposes, will be treated for the time necessary to the their pursuit.
What are the rights of the interested party? (articles 15 – 20 GDPR)
The interested party has the right to obtain from the data controller the following:
1. confirmation that personal data concerning him is being processed and, in this case, to have access to personal data and the following information:
2. the purposes of the processing;
3. the categories of personal data in question;
4. the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular if they are recipients of third countries or international organizations;
5. when possible, the period of storage of the personal data envisaged or, if this is not possible, the criteria used to determine this period;
6. the existence of the right of the interested party to request the data controller to rectify or cancel personal data or limit the processing of personal data concerning him or to oppose their processing;
7. the right to lodge a complaint with a supervisory authority;
8. if the data is not collected from the interested party, all information available on their origin;
9. the existence of an automated decision-making process, including profiling, and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of this treatment for the data subject.
10. the appropriate guarantees provided by the third country (outside the EU) or an international organization for the protection of any data transferred.
11 b) the right to obtain a copy of the personal data subject to processing, provided this right does not infringe the rights and the freedoms of others; In case of further copies requested by the interested party, the data controller may charge a reasonable fee based on administrative costs.
12. c) the right to obtain from the data controller the rectification of inaccurate personal data concerning him without unjustified delay
13. d) the right to obtain from the data controller the deletion of personal data concerning him without unjustified delay, if they exist the reasons provided by the GDPR in art. 17, among which, for example, in the event that they are no longer necessary for the purposes of the processing or if this is assumed to be illegal, and always if the conditions established by law exist; and in any case if the treatment is not justified by another equally legitimate reason;
14. e) the right to obtain the treatment limitation from the data controller, in the cases provided for by art. 18 of the GDPR, for example where you have disputed the accuracy, for the period necessary for the Owner to verify its accuracy. The interested party must be informed, in due time, even when the suspension period has been completed or the reason for the limitation of the processing has ceased, and therefore the limitation itself revoked;
15. f) the right to obtain communication from the holder of the recipients to whom the requests for any corrections or cancellations or limitations of the processing have been transmitted, unless this proves impossible or involves a disproportionate effort.
16. g) the right to receive in a structured format, commonly used and readable by automatic device, the personal data concerning him and the right to transmit such data to another data controller without hindrance by the data controller has provided, in the cases provided for by art. 20 of the GDPR, and the right to obtain direct transmission of personal data from one data controller to the other, if technically feasible.
For any further information and in any case to send your request, you must contact the Owner at email@example.com. In order to guarantee that the aforementioned rights are exercised by the interested party and not by unauthorized third parties, the Data Controller may request the same to provide any additional information necessary for the purpose.
How and when can the interested party object to the processing of their personal data? (Art. 21 GDPR)
For reasons related to the particular situation of the interested party, the same may object at any time to the processing of his/her personal if it is based on legitimate interest or if it occurs for commercial promotion activities, sending the request to the Owner at the firstname.lastname@example.org.
The interested party has the right to the cancellation of their personal data if there is no legitimate prevailing reason of the Owner with respect to the one that gave rise to the request, and in any case in the event that the Data Subject has opposed the processing for commercial promotion activities.
Who can the complainant propose? (Art. 15 GDPR)
Without prejudice to any other administrative or judicial action, the interested party may submit a complaint to the competent control authority in the Italian territory (Guarantor Authority for the protection of personal data) or to the one that carries out its tasks and exercises its powers in the Member State where the violation of the GDPR occurred.
HOSTING SERVICES PROPOSED ON SERVER IN CLOUD ARUBA.IT – Communication to third parties and categories of recipients
As part of the provision of registration services for a domain name with an extension (TLD) that does not belong to the following list:
.at .be .bg .cz .de .dk .ee .es .eu .fi .fr .gr .hr .hu .ie .it .lt .lu .lv .mt.nl .pl .pt .ro .se .si .sk .uk
Personal data, for purposes strictly related to the provision of the service, will be communicated to third parties (registration authorities and related accredited subjects) who are based in countries where GDPR is not applied (countries outside the EU), and in any case for which a provision of adequacy on the level of data protection by the European Commission is in force.
Furthermore, the interested party is informed that the registration of a domain name entails the insertion of his personal data in a publicly accessible register (“Whois”) kept by the competent Registration Authority for the chosen extension, except for the cases in which the interested party has requested the obscuring of personal data in the manner provided by the competent Registration Authority or by the contractual conditions relating to the Service.
The legal basis of these treatments is the performance of the services inherent in the relationship established, compliance with legal and regulatory obligations and the legitimate interest of Just Creative to carry out processing necessary for these purposes.
COOKIES – General information, deactivation and management of cookies
The Cookies are data that are sent by the website and stored by the internet browser, computer or other device (for example, tablet or mobile phone) of the user. Technical cookies and third-party cookies may be installed from our website or related subdomains.
In any case, the user can manage, or request the general deactivation or cancellation of cookies by changing the settings of his or her internet browser. However, this deactivation may slow down or prevent access to some parts of the site.
The settings to manage or deactivate cookies may vary depending on the internet browser used, therefore, for more information on how to perform these operations, we suggest that you consult the manual of your device or the “Help” function. “Help” of your internet browser.
The following are links to users that explain how to manage or disable cookies for the most popular Internet browsers:
Internet Explorer: http://windows.microsoft.com/it-IT/internet-explorer/delete-manage-cookies
Google Chrome: https://support.google.com/chrome/answer/95647
Mozilla Firefox: http://support.mozilla.org/it/kb/Gestione%20dei%20cookie
The use of technical cookies, i.e. cookies necessary for the transmission of communications on the electronic communication network or cookies strictly necessary for the supplier to provide the service requested by the customer, allows the safe and efficient use of our site.
Session cookies may be installed in order to allow access and stay in the reserved area of the portal as an authenticated user.
Technical cookies are essential for the proper functioning of our website and are used to allow users normal browsing and the possibility of using the advanced services available on our website. The technical cookies used are divided into session cookies, which are stored exclusively for the duration of the navigation until the browser is closed, and persistent cookies that are saved in the memory of the user’s device until their expiry or cancellation by the user same. Our site uses the following technical cookies:
Technical navigation or session cookies, used to manage normal navigation and user authentication; Functional technical cookies, used to store personalizations chosen by the user, such as, for example, the language; Analytics technical cookies, used to know how users use our website so that we can evaluate and improve the operation.
Third-party cookies may be installed: these are cookies, analytics and profiling cookies, Google Analytics, Google Doubleclick, Criteo, Rocket Fuel, Youtube, Yahoo, Bing and Facebook. These cookies are sent by the websites of the aforementioned third parties external to our site.
Analytical cookies of third parties are used to collect information on the behavior of users on the site. The survey takes place anonymously, in order to monitor performance and improve the site’s usability. Third-party profiling cookies are used to create user profiles, in order to offer advertising messages in line with the choices made by the users themselves.
The use of these cookies is governed by the rules established by the third parties themselves, therefore, users are invited to read the privacy information and instructions for managing or disabling cookies published in the following web pages:
For Google Analytics cookies:
– instructions to manage or disable cookies: https://support.google.com/accounts/answer/61416?hl=it
For Youtube cookies:
– instructions to manage or disable cookies: https://support.google.com/accounts/answer/61416?hl=it
For Yahoo cookies:
For Bing cookies:
They can be installed by the Owner (s), by means of software of c.d. web analytics, profiling cookies, which are used to prepare detailed, real-time analysis reports on information on: website visitors, search engines from where they come from, keywords used, language of use, and most visited pages.
The same can collect information and data such as IP address, nationality, city, date/time, device, browser, operating system, screen resolution, navigation source, pages visited and number of pages, duration of the visit, number of visits made.
These data can be transferred to each of the companies that work, they are partners of Just Creative, in compliance and with the limitations imposed by the current legislation and by the provisions of this Information.