pursuant to art. 13 and 14 EU Regulation 2016/679
Life Evolution Srls. considers the protection of the personal data of its customers and users, actual and / or potential, to be of fundamental importance.
With this document (hereinafter, the “Information”), we intend to renew our commitment to ensure that the processing of personal data carried out in any manner, whether automated or manual, takes place in full compliance with the safeguards and rights recognized by the Regulations (EU) 2016/679 (hereinafter, “GDPR” or “Regulation”) and by the additional applicable rules on the protection of personal data.
The term personal data refers to the definition contained in art. 4 co. 1 of the Regulation, ie “any information concerning an identified or identifiable natural person; the natural person is considered identifiable who can be identified, directly or indirectly, with particular reference to an identifier such as the name, an identification number, location data, an online identifier or one or more characteristic elements of his physical identity, physiological, genetic, psychological, economic, cultural or social “(hereinafter, the” Personal Data “).
The Regulation provides that, before proceeding with the processing of Personal Data – this term being understood, according to the relevant definition contained in art. 4 co. 2 of the Regulation, “any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, such as 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 “( hereinafter, the “Treatment”) – it is necessary that the person to whom such Personal Data belongs is informed about the reasons for which such data are requested and how they will be used.
In this regard, this Information – drafted on the basis of the principle of transparency and inclusive of all the elements required by art. 13 of the Regulation – aims to provide you in a simple and intuitive way with all the useful and necessary information so that you can provide your Personal Data in a conscious and informed way and, at any time, exercise your rights.
A. THE HOLDER OF THE TREATMENT
The company that will process your Personal Data for the purposes referred to in Section C of the Information and which, therefore, will play the role of data controller according to the relevant definition contained in art. 4 co. 7 of the Regulation, namely “the natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data” is:
Life Evolution Srls. (hereinafter, the “Owner”), with registered office in Via Panica 116, 36063 – Marostica (hereinafter, the “Headquarters”).
B. CONTACTS OF THE PERSONAL DATA PROTECTION OFFICER
In order to facilitate relations between you, as an interested party, that is the “identified or identifiable natural person” to whom the Personal Data refers pursuant to art. 4 co. 1 of the Regulations (hereinafter, the “Interested”) and the Data Controller, the Regulations have provided, in some specific cases, for the appointment of a control and support figure who, among the various tasks entrusted, also acts as a contact point with the interested party.
The Data Controller has adopted this figure of “data protection officer”, so-called “Data Protection Officer”, identifying and appointing, pursuant to art. 37 of the Regulation, Life Evolution Srls. (hereinafter, the “DPO”).
The DPO, pursuant to and for the purposes of art. 39 of the Regulation, is called upon to carry out, inter alia, the following activities:
inform and provide advice to the Data Controller as well as to the employees who carry out the processing operations regarding the obligations deriving from the Regulation or other provisions of the Union or of the Member States relating to the protection of Personal Data;
monitor and supervise compliance with the Regulations, the applicable regulations on the protection of Personal Data as well as the policies and procedures adopted by the Data Controller;
provide support in the feedback to the interested party;
cooperate with the competent Authority for the Protection of Personal Data.
As required by art. 38 of the Regulations, you can freely contact the DPO for all questions relating to the processing of your Personal Data and / or if you wish to exercise your rights as provided for in Section G of this Information, by sending a written communication to the email firstname.lastname@example.org.
C. PURPOSE AND LEGAL BASIS OF THE PROCESSING
The processing of your Personal Data will be conducted by the Data Controller to allow you, therefore, to get in touch with the company, send requests for information, download free resources, purchase courses and products as well as take advantage of all the other services offered from time to time by the Site in which you are browsing.
To allow the Data Controller to carry out the processing activities for the above purposes, it will be necessary provide to the Personal Data mark with the symbol [*].
This treatment will be lawful under art. 6, paragraph 1, letter b) of the Regulations.
In the absence of the provision of even one of the marked data, it will not be possible to proceed with the processing of your Personal Data and, consequently, it will not be possible to provide you with the information and services requested.
The Personal Data that will be requested from you for the pursuit of the aforementioned purposes will be those reported in the registration and / or contact and / or purchase form, i.e., by way of example and not limited to: name, surname, e-mail address , shipping address, telephone numbers of fixed and / or mobile users.
No Personal Data relating to your health and, in general, special categories of personal data referred to in art. 9 of the Regulation.
In addition to the aforementioned purposes, your Personal Data may be processed for promotional activities of the products and services provided by the Data Controller, in order to provide you with a better service, to promote products and services of your interest sold and / or provided by Life Evolution.
With regard to this direct marketing purpose, it should be noted that, by virtue of art. 6 co. 1 letter f) of the Regulations and art. 130 co. 4 of the Privacy Code (so-called soft spam exception), the Data Controller may carry out this activity based on its legitimate interest, regardless of your explicit consent and in any case up to your opposition or limitation (pursuant to the provisions of Section F letter d ) and f) of the Information) to this Treatment, as better explained in Recital 47 of the Regulation, in which it is “considered legitimate interest of the owner to process personal data for direct marketing purposes”.
This will be possible following the assessments made by the Data Controller regarding the possible prevalence of your interests, rights and fundamental freedoms that require the protection of Personal Data on your legitimate interest in sending direct marketing communications.
Moreover, you can lawfully and at any time oppose the receipt of promotional communications, without this in any way prejudicing the processing for other purposes.
The contact methods aimed at direct marketing activities can be both automated and traditional (in some cases providing calls from our operators, based on your specific requests). In any case, as better specified below in Section F of this Notice, you can also partially object (for example by consenting only to traditional contact methods).
D. SUBJECTS TO WHOM YOUR PERSONAL DATA MAY BE COMMUNICATED
Your Personal Data may be disclosed to specific subjects considered recipients of such Personal Data. In fact, art. 4 co. 9 of the Regulation defines Recipient of a Personal Data “the natural or legal person, public authority, service or other body that receives communication of personal data, whether or not it is a third party” (hereinafter, the “Recipients” ).
With this in mind, in order to correctly carry out all the processing activities necessary to pursue the purposes referred to in this Notice, the following Recipients may be in a position to process your Personal Data:
third parties who carry out part of the processing activities and / or activities connected and instrumental to them on behalf of the Data Controller. These subjects have been appointed as Data Processors pursuant to art. 28 GDPR, having to be understood individually with this term, pursuant to art. 4 co. 8 of the Regulations, “the natural or legal person, public authority, service or other body that processes Personal Data on behalf of the Data Controller” (hereinafter, the “Data Processor”);
individuals, employees and / or collaborators of the Data Controller, who have been entrusted with specific and / or more processing activities on your Personal Data. These individuals have been given specific instructions on the subject of security and correct use of Personal Data – also through specific training activities – and are defined, in accordance with art. 4 co. 10 of the Regulations, “persons authorized to process Personal Data under the direct authority of the Data Controller or Data Processor” (hereinafter, the “Authorized Persons”).
Where required by law or to prevent or suppress the commission of a crime, your Personal Data may be disclosed to public bodies or judicial authorities without these being defined as Recipients. In fact, pursuant to art. 4 co. 9 of the Regulation, “the public authorities that may receive communication of Personal Data in the context of a specific investigation in accordance with the law of the Union or of the Member States are not considered Recipients”.
E. PROCESSING TIME
One of the principles applicable to the processing of your Personal Data concerns the limitation of the retention period, governed by art. 5, co. 1 letter e) of the Regulation which states “Personal Data are stored in a form that allows identification of the Data Subjects for a period of time not exceeding the achievement of the purposes for which they are processed; Personal Data may be stored for longer periods provided that they are processed exclusively for archiving purposes in the public interest, for scientific or historical research or for statistical purposes, in accordance with art. 89 (1), without prejudice to the implementation of adequate technical and organizational measures required by these Regulations to protect the rights and freedoms of the interested party “.
In light of this principle, your Personal Data will be processed by the Data Controller limited to what is necessary for the pursuit of the purpose referred to in Section C of the Information.
In particular, your Personal Data will be processed for a period of time equal to the minimum necessary, as indicated in Recital 39 of the Regulation, i.e. until the termination of the existing relationship between you and the Data Controller in relation to your requests for information, without prejudice to the legitimate interest of the Data Controller referred to in Recital 47 of the Regulation as well as a further retention period that may be imposed by law as also provided for by Recital 65 of the Regulation.
B. RIGHT OF RECTIFICATION You will be able to obtain, pursuant to art. 16 of the Regulation, the correction of your Personal Data that are inaccurate. Furthermore, taking into account the purposes of the processing, you will be able to obtain the integration of your Personal Data which are incomplete, also by providing a supplementary declaration. c. RIGHT TO CANCELLATION You will be able to obtain, pursuant to art. 17 co. 1 of the Regulation, the deletion of your Personal Data without undue delay and the Data Controller will have the obligation to delete your Personal Data, if there is even one of the following reasons: a) the Personal Data are no longer necessary with respect to the purposes for the which have been collected or otherwise processed; b) you opposed the processing pursuant to art. 21 co. 1 or 2 of the Regulations and there is no longer any legitimate overriding reason to proceed with the Processing of your Personal Data; c) your Personal Data have been unlawfully processed; d) it is necessary to delete your Personal Data to fulfill a legal obligation provided for by a community standard or internal law. In some cases, as required by art. 17 co. 3 of the Regulation, the Data Controller is entitled not to delete your Personal Data if their processing is necessary, for example, for the exercise of the right to freedom of expression and information, for the fulfillment of a legal obligation. , for reasons of public interest, for archiving purposes in the public interest, for scientific or historical research or for statistical purposes, for the assessment, exercise or defense of a right in court. d. RIGHT TO LIMITATION OF PROCESSING You will be able to obtain the limitation of processing, pursuant to art. 18 of the Regulation, in the event that one of the following hypotheses occurs: a) you have contested the accuracy of your Personal Data (the limitation will continue for the period necessary for the Data Controller to verify the accuracy of such Personal Data); b) the processing is unlawful but you have opposed the cancellation of your Personal Data by requesting, instead, that its use be limited; c) although the Data Controller no longer needs it for the purposes of processing, your Personal Data are used to ascertain, exercise or defend a right in court; d) you opposed the processing pursuant to art. 21 co. 1 of the Regulations and you are awaiting verification of the possible prevalence of the Data Controller’s legitimate reasons with respect to yours. In case of limitation of processing, your Personal Data will be processed, except for storage, only with your consent or for the ascertainment, exercise or defense of a right in court or to protect the rights of a ‘other natural or legal person or for reasons of significant public interest. We will inform you, in any case, before this limitation is lifted. E. RIGHT TO DATA PORTABILITY You can, at any time, request and receive, pursuant to art. 20 co. 1 of the Regulation, all your Personal Data processed by the Data Controller in a structured, commonly used and legible format or request its transmission to another Data Controller without impediments. In this case, it will be your responsibility to provide us with all the exact details of the new Data Controller to whom you intend to transfer your Personal Data, providing us with written authorization. f. RIGHT OF OBJECTION In accordance with art. 21 co. 2 of the Regulation and as also reaffirmed by Recital 70, you can object, at any time, to the Processing of your Personal Data if these are processed for direct marketing purposes. g. RIGHT TO PROPOSE A COMPLAINT TO THE SUPERVISORY AUTHORITY Without prejudice to your right to appeal to any other administrative or judicial office, if you believe that the processing of your Personal Data conducted by the Data Controller is in violation of the Regulations and / or applicable legislation, you can propose a complaint to the competent Personal Data Protection Authority. To exercise all your rights as identified above, simply contact the Data Controller in the following ways:
by sending an e-mail to the DPO’s e-mail address email@example.com;
by sending an email to the Data Controller at firstname.lastname@example.org or a registered letter to the Headquarters of the Data Controller.