Privacy Policy

With this Privacy Policy “Opera della Marca Srl.” intends to inform users who visit the website “www.hugbike.it” (hereinafter the “website“) of the policy adopted on the protection of personal data, underlining its commitment and attention with reference to the protection of the privacy of site visitors. Please read the Privacy Policy carefully.

Pursuant to and for the purposes of the General Data Protection Regulation, Opera della Marca Srl provides the following information.

BASIC PRINCIPLES OF THE PRIVACY POLICY OF OPERA DELLA MARCA SRL

• carry out the treatment (art. 4, comma 2, GDPR: “any operation or set of operations, performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as the collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction“) of personal data (art. 4, comma 1, GDPR: “ any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online identifier or one or more characteristic elements of his physical identity, physiological, genetic, psychic, economic, cultural or social”) exclusively for the purposes and according to the methods illustrated in the information to be provided which are presented to the user from time to time who accesses a section of the site in which the direct or indirect provision of personal data is envisaged;
• use the data that has been voluntarily released by the user;
• use technical cookies to facilitate navigation on the site and analytical cookies for statistical purposes;
• use profiling cookies only if the user has given consent to such use;
• transmit the data to third parties (data processors – art. 4, paragraph 8, GDPR: “art. 4, comma 8, GDPR: “the natural or legal person, public authority, service or other body that processes personal data on behalf of the data controller”) exclusively for purposes instrumental to what is expressly requested and carefully selected;
• communicate the data to third parties for activities connected to matters of interest or if this is required by law, regulation or community legislation;
• with your explicit consent (art. 4, comma 11, GDPR: “any manifestation of free, specific, informed and unequivocal will of the interested party, with which the same expresses his assent, by unequivocal declaration or positive action, that the personal data concerning him are object of treatment“), communicate the data to third parties for their independent processing;
• respond to requests for access to personal data, correction or cancellation of the same, exercise of the right to be forgotten, limitation of treatment or the right to oppose their treatment. Ensure the exercise of the right to data portability as well as oppose the processing of data for the purpose of providing information on our projects and requests for financial contributions to support our institutional activities;
• ensure correct and lawful processing of your data, safeguarding your privacy, as well as apply suitable security measures to protect the confidentiality, integrity and availability of the data.

INFORMATION TO BE PROVIDED PURSUANT TO ART. 13 OF THE GDPR AND CRITERIA USED TO DELIMITE THE LIMITS OF DATA CONSERVATION

As better explained in the sections that allow you to adhere – by releasing your personal data – to the services reserved for users of our site. In particular, all data collection – and subsequent processing – activities are aimed at pursuing the commercial purposes of Opera della Marca Srl.

Personal data will be processed, mainly electronically and with analysis tools, including statistical ones, by OPERA DELLA MARCA Srl with registered office in Viale della Repubblica, 253/E – 31100 Treviso – Italy C.F./P.IVA: 04843080260 for the fulfillment of all commercial phases as well as to comply with administrative and other mandatory rules by virtue of the law in force in our country or by virtue of EU decisions.

For the aforementioned purposes, the data will be kept until the conclusion of all the relative phases of the relationship established and within the terms and limits set out in the applicable regulations, in particular administrative, civil and fiscal ones.

The aforementioned activities may take place through both traditional contact methods (paper mail) and automated and similar (specifically via email).

Pursuant to articles 15-22, GDPR, by writing to the owner at the relevant postal address or email operadellamarca@operadellamarca.it, you can exercise your rights of access, consultation, rectification, cancellation and oblivion, limitation of data processing and – if necessary – obtain their transmission to another owner (data portability), as well as oppose their treatment for legitimate reasons or revoke your consent.

With particular reference to processing for profiled marketing purposes, it should be noted that the interested party has the right to object at any time, and without giving any reason, to the processing of his data for these purposes, and that he may also exercise the right to object separately for traditional contact activities and for automated ones: if it is not specified which contact methods it refers to, the opposition to the processing of data for profiled marketing will be understood as extended to all contact tools.

It is also noted that the interested party has the right to lodge a complaint with the supervisory authority to assert his rights. By writing to the postal address indicated above or by sending an e-mail to operadellamarca@operadellamarca.it, you can request the complete and updated list of data controllers.

CRITERIA USED TO DEFINE THE LIMIT OF DATA RETENTION

They can be exercised at any time at the address operadellamarca@operadellamarca.it.(alternatively, by writing to Opera della Marca Srl Viale della Repubblica, 253/E – 31100 Treviso – Italy, the rights pursuant to articles 15-22, GDPR as indicated below:

Right of access (article 15, GDPR)

The person has the right to request whether his personal data is being processed and, therefore, has the right to access information concerning him and to have news on:

purpose of the processing (e.g.: management of a donation);
categories of personal data; (e.g. personal data, behavioral data)
recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular if recipients from third countries or international organisations;
when possible, the envisaged retention period of personal data or, if this is not possible, the criteria used to determine this period;
existence of the right to request the rectification or cancellation of personal data or the limitation of the processing of personal data or to oppose their treatment;
right to lodge a complaint with a supervisory authority;
if the data is not collected directly from the individual, all available information on its origin;
existence of an automated decision-making process, including profiling and significant information on the logic used, as well as the importance and expected consequences of such treatment for the person.

Right to rectification (article 16, GDPR)

The person has the right to obtain the rectification of inaccurate personal data concerning him without unjustified delay. Taking into account the purposes of the processing, the person has the right to obtain the integration of incomplete personal data, also by providing a supplementary declaration.

Right to erasure (“right to be forgotten”) (article 17, GDPR)

The person has the right to obtain the cancellation of personal data concerning him, he has the obligation to cancel personal data without unjustified delay, for one of the following reasons:

the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
the consent on which the treatment is based is revoked and if there is no other legal basis for the treatment (e.g.: own legitimate interest, regulatory or contractual obligations);
you oppose the processing for marketing and profiling purposes and there is no overriding legitimate reason to proceed with the processing;
the personal data have been processed unlawfully;
personal data must be deleted to fulfill a legal obligation under the law of the Union or of the Member State to which it is subject.

Right to restriction of processing (article 18, GDPR)

The person has the right to obtain the limitation of the processing of his personal data when one of the following reasons exists:

the person disputes the accuracy of the personal data, for the period necessary to verify the accuracy of such personal data;
the processing is unlawful and the person opposes the cancellation of personal data and instead requests that its use be limited; (e.g.: it does not mean that the treatment is carried out for marketing purposes but only for management and administrative purposes)
although the data is no longer needed for processing purposes, the personal data are necessary for the person to ascertain, exercise or defend a right in court;
the person has opposed the treatment if the treatment is based on his own legitimate interests, pending the verification of the possible prevalence of his legitimate reasons with respect to those of the person.

Obligation to notify in the event of rectification or erasure of personal data or restriction of processing (article 19, GDPR)

The person has the right to request that the rectification or cancellation of data or limitation of treatment be communicated by Opera della Marca Srl to other subjects to whom the data may have been communicated. The company may not comply with the request, if the means to be employed are disproportionate to the right to privacy invoked by the individual.

Right to data portability (“data portability”) (article 20, GDPR)

This right allows the person to receive, in a structured format, commonly used and readable by an automatic device, the personal data concerning him/her provided to a subject who subjects his/her data to treatment and has the right to want to transmit such data to a subject for use of the latter without impediments by the subject to whom it has been supplied. This right can be exercised in the following cases:

• the treatment is based on consent or on a contract or on pre-contractual measures requested by the same person and, simultaneously
  the processing is carried out by automated means.

  The person has the right to obtain that his data be transferred directly from one subject to another (from the one to whom he has given them to the one to whom he wants them to be transmitted), if technically possible.

  Right to object (article 21, GDPR)

  The person has the right to oppose the processing of his data for the pursuit of the legitimate interest of Opera della Marca Srl or of third parties, provided that the interests or the fundamental rights and freedoms of the person who require the protection of personal data do not prevail, also for profiling purposes.

  If personal data are processed for marketing purposes, the person has the right to object at any time to the processing of personal data concerning him carried out for these purposes, including profiling to the extent that it is connected to such marketing activity.

  Automated decision-making process relating to natural persons, including profiling (article 22, GDPR)

  The person has the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or which significantly affects his person in a similar way. In particular, you have the right to oppose the profiling to which you are subjected through automated processes.

  This right cannot be exercised if the decision:

  it is necessary for the conclusion or performance of a contract;
  it is authorized by the law of the Union or of the Member State to which it is subject, which also specifies adequate measures to protect the rights, freedoms and legitimate interests of the person;
  is based on explicit consent.

The person has the right to express his or her opinion and to contest the decision of Opera della Marca Srl

CRITERIA USED TO DEFINE THE LIMIT OF DATA RETENTION

The data will be kept in the company’s archives (art. 4, paragraph 6, GDPR: “any structured set of personal data accessible according to specific criteria, regardless of whether this set is centralized, decentralized or distributed in a functional or geographical way”) according to variable criteria according to the category of the data, the nature of the treatment and the purposes of the treatment itself. The criteria or the precise retention limit are described in the information to be provided pursuant to art. 13, GDPR when providing personal data.

In principle, the following evaluations are valid for establishing the data retention policy:

all data is kept as long as the relationship remains active and for a number of years equal to that which laws, regulations, including community ones, impose for administrative and accounting purposes;
all data used for marketing activities with profiling, the treatment of which is supported by a positive action of the person to such treatment, explicitly declaring the desire to do so, are kept as long as the profile of the interested party is in line with the personalized communications created through cross-referencing of the information available.

Once the periods set out above have elapsed, the identification data are transformed into anonymous form and used only for statistical reports which do not allow the identity of the person to be traced.

RESPONSIBLE FOR THE TREATMENT

Your personal data may be processed, both manually and electronically or telematically, both directly by Opera della Marca Srl and by third parties who, with experience, technical skills, professionalism and reliability, carry out processing operations on behalf of Opera della Marca Srl , in compliance with the security and confidentiality of information and constantly monitored by us in their work. The data controller is “the natural or legal person, public authority, service or other body that processes personal data on behalf of the data controller” (art. 4, paragraph 8, GDPR) and is contractually bound by the company, with the definition of the operating limits on the data, of the data that it can process and of the categories of interested parties to which they refer, and with the prohibition of using it differently from the assignment entrusted. If formally authorized by Opera della Marca Srl, it may make use of other managers, who are contractually bound by the manager appointed directly by opera della Marca Srl: the violations committed by these other managers fall under the responsibility of the first manager and are not the responsibility of Work of Marca Srl..

The complete and updated list of data processors can be requested by email at operadellamarca@operadellamarca.it. (alternatively by writing to Opera della Marca Srl, Viale della Repubblica 253/E, Treviso 31100.

THIRD PARTIES TO WHOM YOUR DATA HAS BEEN COMMUNICATED

Your data may be made available to third parties, independent data controllers in compliance with laws and regulations that provide for their communication, as well as to supervisory bodies. For example, they will be made available to credit institutions or credit card issuers to allow the transactions necessary for commercial operations, as well as PayPal.

APPLICABLE LAW

This Privacy Policy is governed by EU Regulation 679/2016 “General Data Protection Regulation”.

The Regulation guarantees that the processing of personal data is carried out in compliance with fundamental rights and freedoms, as well as the dignity of the interested party, with particular reference to confidentiality, personal identity and the right to protection of personal data.

REVIEW CLAUSE

Opera della Marca Srl reserves the right to review, modify or simply update, in whole or in part, at its sole discretion, in any way and/or at any time, without notice, this Privacy Policy, also in consideration of changes to the rules law or regulation on the protection of personal data. Changes and updates to the Privacy Policy will be notified to users by publication on the Home Page of the site and will be binding as soon as they are published and communicated. Therefore, please access this section regularly to check the publication of the most recent and updated Privacy Policy.

The full text of EU Regulation 679/2016 can be consulted on the website of the Guarantor for the Protection of Personal Data www.garanteprivacy.it.