According to EU 2016/679 (GDPR) law and 196/03 decree (and subsequent modifications and integrations)
Last updated: June 21st, 2018
It also describes the data subject’s choices (you), as final user, regarding usage, access and correction of your personal data.
By using the Websites and services offered through the platforms distributed by The Digital Box, you give your consent that all personal data that you submit may be processed by us in the manner described in this Privacy Notice. If you do not agree to these terms, you are not authorized to use any services.
1. Important information
We may use different and specific privacy policies for each of the products, services, tools offered and/or used by The Digital Box.
1.2. Contact us
Data controller: the natural or legal person, public authority and any other authority, association or entity responsible, also together with another owner, for the decisions regarding the purposes, the methods for processing personal data and the tools used, including the security profile. In this specific case, the Data controller is The Digital Box SpA headquartered in Largo San Francesco, 5 – 70024 Gravina in Puglia (BA).
Data processor: the natural person, company, authority, association or entity which processes personal data on behalf of the controller; they are appointed according to their professional qualities and their knowledge of law and practice in terms of data protection.
Data Protection Officer: designated by the data controller or processor. The DPO is responsible for observing evaluating and managing personal data processing (and protection) inside a company, in compliance with European and national regulations.
Customer or Company: The Digital Box customers, its Licensee Partners and/or Resellers that represent substantially the “ADA” platform users.
End-User or Data subject: people browsing The Digital Box websites or APP, which are contacted or give their details through platforms designed and managed by The Digital Box, i.e. “ADA”.
Licensee Partners and Resellers: The Digital Box business partners and subsidiary, which sell digital marketing products to “customers”.
ADA: the digital marketing platform developed and designed by The Digital Box.
ChatBot: Chat bot, chatbot o chatterbot, is a software designed to emulate a conversation with a human being. The main purpose of these software programs is to mimic human intelligence; they are used for different intentions i.e. as guidelines or for providing answers to users’ FAQ when accessing a website and so on… The Digital Box may offer its end-users and customer the possibility to interact with a chatbot inside its website, in order to fulfil the contractual conditions and improve in offrire all’interno dei suoi spazi web la possibilità, per gli end-user e customeri, di interagire con un user experience.
Personal Data: Personal data means any information, you provide voluntarily, relating to an identified or identifiable natural person including contact information i.e. name, email address, company name, address, telephone number and other information about you or your business. Personal data could also include information on free or paid transactions, information available on the Internet i.e. Facebook, LinkedIn, Twitter and Google, or publicly available information.
Personal data also includes credit or debit card numbers, information on the capital asset, social security, Passport No. and ID.
Sensitive Data: Sensitive personal data encompasses information about racial or ethnic origin, physical and mental health, financial and legal information.
Browsing information: It refers to information on your computer and visits to this website (and other The Digital Box websites) such as IP address, geographical location, type of browser, reference source, duration of visit and the pages displayed.
Consent: It refers to any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action and previously informed by a data controller, signifies agreement to the processing of personal data relating to him or her.
How The Digital Box and our customers use the services of the digital marketing platforms
3.1. Services of the ADA platform
The services sold by The Digital Box, its Licensee Partners and Resellers, allow any company that buys an account on the ADA platform to create web pages for marketing purposes using our servers. Through these pages, visitors (end users) can learn more about companies, download content and provide data, contact details and other demographic information. This information, which is stored and managed on the servers of our service providers, is then used so that visitors can be contacted based on their interest in the company’s goods or services and interact with the company itself.
3.2. How The Digital Box uses ADA
3.3. How our customers use ADA
The Digital Box processes the data collected and managed by its customers (companies) and, in compliance with the existing contractual agreements, it stores them on the servers of its service providers. The Digital Box doesn’t have the control over the collection or management of data that companies process.
Our customers (companies) control and are responsible for correcting, deleting or updating information collected through the services of the ADA platform. If the Digital Box is required to be legitimately requested to work together to remove or access the data, an answer will be provided in a relatively short period of time.
The Digital Box offers the services of the ADA platform to allow the collection of data under the responsibility of its customers (companies) and does not have direct relationships with people (end users) whose personal data is processed. If you are an end user of one of our customers (companies) and no longer want to be contacted by a company that uses the services of the ADA platform provided by The Digital Box, please contact the company with which you interact directly. We also inform you that we may transfer personal data to companies that help us to provide our service and that we have appointed for processing data, operating under our control.
4. Data collected
4.1. While visiting our websites
You are free to browse websites without providing any personal data about yourself. When you visit websites or register to allow your company to use subscription services of our platform (i.e. ADA), we may ask you to provide personal data about you and we will collect data about browsing our websites.
4.2. While using our mobile application
We use data analysis software that enables us to understand better the functionality of our apps on your mobile device. This software can record information such as how often the application is used, events occurring within the application, aggregate usage, performance data, and where the application was downloaded from. In addition to the information we collect on our websites, when using our mobile apps, we may also collect and store your geographical location, model and version of the device, device identifier, operating system version and credentials of the ADA account.
We send push notifications from time to time in order to update you on events or promotions. If you no longer wish to receive such communications, you can deactivate them on your device.
We could link the information we store in the analysis software to the personal data sent to the mobile app. We do this to improve the services we offer and improve our marketing, analytics and site capabilities.
4.3. Information on minors
The Digital Box websites and services offered through the ADA platform are not intended for minors under the age of 16 nor do we knowingly or intentionally collect data about children under 16. If you believe that, for reasons unknown to us, information on children under 16 has been collected in an improper and without parental consent, please contact us at email@example.com, so we can intervene.
5. How we use the data we collect
Data transfer abroad: the data collected will not be transferred abroad.
5.2. We never sell personal data
The Digital Box will not sell/hand over in any case your personal data to third parties nor will they be disclosed.
5.3. End users and Customers’ personal data
(a) improving the browsing experience by customizing websites and improving the ADA platform;
(b) collecting and processing statistical data on users of our platforms and websites, but this data will not be used to identify individual users without specific consent.
(c) if you have granted your specific consent, you may be contacted by companies for marketing purposes.
(d) if you have granted your specific consent, you can be profiled for marketing purposes to allow companies to offer specific promotions dedicated exclusively to you.
In addition, companies that use the ADA platform for the intended and contracted purposes are allowed to collect sensitive data that is processed and stored according to the principles of confidentiality and lawfulness of the processing, with the specific consent of the end user.
With regard to the data collected through the subscription services of ADA (of companies), data is processed for the following purposes:
(a) providing the subscription service (which may include the identification, prevention and resolution of technical and security problems);
(b) responding to requests of technical assistance;
(c) fulfilling the obligations set out in the Terms and Conditions;
5.4. Service providers
5.5. Personal data security
We use a wide variety of security technologies and procedures to protect your personal data from unauthorized access, use or disclosure. We protect personal data stored on servers and computers in a controlled and secure environment, protected from unauthorized access, use or disclosure. When sensitive data (such as geo-location) is collected on our websites and/or transmitted to other websites, it is protected by cryptography, such as the Secure Socket Layer (SSL) protocol.
Should you have any questions about the security of your personal data, please contact us via email at firstname.lastname@example.org.
5.6. Functionalities of social media
5.7. External websites
5.8. Storage of personal data
We retain the personal data of our customers (companies) as long as we believe that they are potentially useful to allow the necessary contacts related to subscription services that have been purchased on ADA or, if necessary, to comply with our legal obligations, resolve complaints and enforce our agreements. At the end of the processing period and at the conclusion of the contract, we will safely delete all the data involved in accordance with the contractual conditions between The Digital Box and the companies.
If, however, as end-users/data subject you provide information to our customers (companies) to stay in touch with them or use the services they offer, our customers will decide how long to store the personal data they have collect. In any case, The Digital Box, internally and for the platforms managed, applies rules that prevent the retention of data indefinitely and therefore it limits the storage time in accordance with the principle of minimization of data processing. If our customer (company) interrupts the use of the subscription service with ADA, we will provide the customer with access to all stored information, including personal data provided by end-users, in a format that can be exported. In the case of early conclusion of contract, we could eliminate all end users’ information except for legal limits.
5.9. Forced disclosure
We reserve the right to use or disclose personal data if required by law or if The Digital Box believes that the use or disclosure are necessary to protect its own rights, protect the end users’ security or the safety of others, allow investigations into frauds or to comply with a law.
6. Browsing information
COOKIES. A cookie is a small file placed on your computer’s hard drive. You can refuse to accept cookies by properly configuring your browser. However, if you select this setting, you may not be able to access some of the ADA platform services or the website you are visiting. Unless you have adjusted your browser settings to reject cookies, our system may issue cookies while using the ADA platform. In the browser, you can disable the storage of cookies or remove cookies registered, but this may result in a reduction in functionality, a slowdown or the inability to use some sections of the ADA platform. For more information on cookies and how to delete them based on the type of browser used, please refer to: www.allaboutcookies.org.
The ADA platform uses the following types of cookies:
The strictly necessary cookies are cookies that allow you to consult the ADA website, use its functions and access protected areas reserved for registered users. If the use of these cookies is disabled, some sections of the ADA platform may not be able to be used properly.
Functional cookies and saving preferences are cookies that allow the ADA platform to record choices (such as user name, language and country choice, font and script size, password and so on…), as well as visitor preferences (such as pages visited, and so on…), in order to facilitate the use of the platform and be able to offer visitors a more relevant and personalized experience.
6.2. Browsing information collected by our customers (companies)
Our customers (companies) using ADA may use tools provided by third parties to collect browsing information when visiting their web pages managed through our digital platforms. The Digital Box does not control how our customers (companies) use these tools, nor controls the information they collect or how they use it.
6.3. Single Sign-On
You can access our web pages and/or platforms by using a single sign-on service (SSO) as your Google account. This service will authenticate your identity and give you the opportunity to share some personal data with us such as your name and e-mail address to pre-fill our registration form. These services may give you the ability to publish information about your activities on this website on your profile page to be shared with your network.
7. Data subjects’ rights
7.1. Revision, correction and removal of personal data
Upon request, The Digital Box will provide you with information on the possession of any of your personal data. If you provide us with your personal data, you have the following rights:
To exercise any of these rights, please contact us via email at: email@example.com or contact The Digital Box Largo San Francesco, 5 – 70024 Gravina in Puglia (BA) Italy, Email subject: Privacy. We will respond to your request in a relatively short period of time and inform you about the actions we have taken.
If you are an end user, you have the same rights as above and you can contact directly the companies to which you have consented to the processing of your data.
Furthermore, it is important that you know that if you believe that the processing of your personal data violates the data protection law or that your right to data protection has been infringed in any other way, you can contact the competent authority. In Italy it is the Privacy Supervisor (European Data Protection Supervisor).
7.2. Anti-spam policy
Any commercial communication sent without the consent of the recipient is spam. The use of the services offered by The Digital Box is intended for the sole and exclusive purpose of sending messages to recipients who have accepted and confirmed that they wish to receive communications. No other commercial use is accepted and allowed. Among the non-commercial uses of the ADA Service, it is granted that referable, for example, to sending transactional messages to individual recipients with whom a relationship has been established. We request all our customers to agree and adhere to the no-spam policy; any rule violations on the use of The Digital Box platforms could result in the suspension or conclusion of subscription services.
7.3. Unsubscribe from our communications
If you are subscribed to one of our newsletters, you can unsubscribe from our marketing communications by clicking on the “cancel” link at the bottom of our e-mails or by sending an email at firstname.lastname@example.org or via email at The Digital Box Largo San Francesco, 5 – 70024 Gravina in Puglia (BA) Italy, Email subject: Privacy.
7.4.Unsubscribe from the communications of our customers
Our customers (companies), which use digital marketing services of The Digital Box, are solely responsible for their marketing e-mails and other communications; we can not unsubscribe from their communications. You can unsubscribe to the marketing communications of our customers by clicking on the “delete” link at the bottom of their e-mails or by contacting them directly.
7.5. Responsible for data protection
The data controller has designated the data protection officer who can be contacted at email@example.com
We provide links to the main services connected or integrated on the website. These policies are also referred to the processing of third-party cookies.
Google Analytics: http://www.google.com/intl/en/policies/privacy/
Facebook: https://www.facebook.com/about/privacy/ – https://www.facebook.com/help/cookies
Google Plus and Youtube: https://www.google.fr/intl/en/policies/privacy/
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