PRIVACY AT WAY2GLOBAL
Dear Data Subject, Way2Global Srl SB considers User privacy to be of paramount importance. Any data disclosed by the User through the Site shall be processed with the utmost care, taking all reasonable steps to ensure data security, in accordance with applicable data-protection law. We would like to inform you that the European General Data Protection Regulation, no. 2016/679 (hereinafter, “GDPR”) has made safeguards for the processing of natural-person data a fundamental right. Pursuant to Art. 13 of the GDPR, therefore, we would like to advise you of the following:
A. CATEGORIES OF DATA:
The following types of personal data may be subject to processing:
a. Automatically collected data. IT systems and the software programs dedicated to the running of this website collect certain data (the submission of which is intrinsic to the use of Internet communication protocols) which may potentially be associated with identifiable users, as a routine part of their function. Amongst the collected data are IP addresses and the domain name of any computer used by users connected to the site, URI (Uniform Resource Identifiers) of any requested resource, the method used to relay the request to the server, the size of the file received in response, the numeric code denoting the server-response status (success, error, etc.) and other parameters regarding the operating system, the browser, and the IT environment used by the user, name of the ISP (Internet Service Provider), date and time of visit, webpage from which the visitor was referred, and any outgoing link the visitor follows.
d. Plug-in. The site incorporates social-media plug-ins and/or buttons in order to allow for easy sharing of contents through your favorite social-media sites. These plug-ins are programmed in a way to avoid installing any cookies when you access the page, in order to protect user privacy. Cookies would only be installed (if required by the social-media platform) when the user affirmatively uses the plug-in. Please note that if the user browses the site while logged into the social-media platform, they have already consented to the use of any cookies routed through that site upon subscribing to such social-media platform. The collection and use of information obtained through plug-ins is governed by the privacy policies for the individual social-media sites. Please consult those documents for further information.
B. DATA CONTROLLER
The data controller is Way2Global Srl SB, Via Padre Reginaldo Giuliani, 10/a - 20125 Milan (MI)
VAT no. 10013290969
Available via telephone at 02.66661366 or via email on firstname.lastname@example.org
C. SOURCE OF THE PERSONAL DATA:
Personal data in Data Controller's possession are collected directly from the Data Subject.
D. PURPOSES OF DATA PROCESSING AND LEGAL BASIS:
The purpose and legal basis for the processing of your data is:
1. For any automatically collected data, the legal basis for processing is the data controller’s legitimate interest; the purpose is to improve site experience.
2. For any data supplied voluntarily by the user, the legal basis is consent; for any email sent to our addresses, the purpose is to be able to reply to any specific requests made by the user; for the forms, the purpose is stated in the policy relating thereto.
E. RECIPIENTS OF PERSONAL DATA:
To the extent required by the stated processing purpose, your data may be disclosed to partners, consulting firms, private companies, third-party technical-service providers, hosting providers, IT firms, PR firms, etc.
F. TRANSFER OF PERSONAL DATA TO NON-EU COUNTRIES:
This site may share some collected data with services located outside the EU, for example, through social-media plug-ins and Google Analytics. Such transfer is authorized and governed by Article 45, paragraph 1, of EU Regulation no. 2016/679; therefore, no specific authorization is required.
G. STORAGE PERIOD:
Pursuant to the Storage Limitation principle (Art. 5, GDPR), a periodic review for obsolescence (with respect to the purposes for which they were collected) will be performed on all collected data. To wit:
a) Automatically collected data will be processed for the period strictly necessary, and solely for the purpose of receiving statistics on site usage and to ensure proper site function, including in terms of security, or for any retention period required by law.
b) Data supplied voluntarily by the user will be retained only for as long as needed to pursue the purposes for which they were collected, or for any retention period required by law.
H. RIGHTS OF THE DATA SUBJECT:
Data Subjects shall, at all times, have the right to request the Data Controller grant them access to the data, or to have them corrected or erased, to have their processing limited, or to object to processing, to request data portability, to revoke consent to processing. These and other rights contemplated under the GDPR may be asserted by contacting the Data Controller. Data Subjects may also file a complaint with the oversight authorities.
I. OPTIONAL OR MANDATORY SUBMISSIONS:
The submission of your data is required to navigate on our site in terms of those points listed in D.1 and D.2 of the processing purposes listed supra in order to allow for proper service delivery. Your consent under D.3, on the other hand, is optional, and shall in no way affect service delivery.
J. DATA-PROCESSING MODALITIES:
Personal data supplied by you shall become the object of processing operations as permitted under the aforementioned law, as well as the duty of confidentiality which Data Controller has voluntarily assumed. The data shall be processed both through electronic and hard-copy means, or in any other suitable medium (e.g. cloud computing, or digital filing and back-up systems, etc.), in accordance with the rules of adequate technical and organizational measures established by the GDPR.
K. FINAL NOTES; POLICY UPDATES:
This policy shall only apply to this website, and not to any other site visited by a user by following a link on this website. The policy may be subject to change as statutory updates require. Therefore, we kindly suggest you check back frequently to be kept-to-date on privacy law. Prior versions of this policy may be requested from the Data Controller at any time.
Way2global Srl SB