PRIVACY POLICY PURSUANT TO EUROPEAN REGULATION 679/2016 (GDPR)
Dear user,
Thinx S.r.l. (VAT No. 09709190962), with registered office at Via Borgazzi, 2 – 20122 Milan (contact details: tel. +39 02 82783531, e-mail info@thinx.expert), in its capacity as Data Controller, pursuant to and for the purposes of the European Regulation 2016/679 (known as GDPR), hereby informs you that the processing of your personal data will be based on principles of fairness, lawfulness, transparency and protection of your privacy and your rights.
Pursuant to Article 13 of GDPR 2016/679, we provide you with the following information:
Purpose of Processing
The processing may involve your personal data such as:
Automatically collected data. The IT systems and software applications used to operate this website collect, during their normal operation, certain data (the transmission of which is implicit in the use of Internet communication protocols) that may be associated with identifiable users. This data includes IP addresses and domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) addresses of the requested resources, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the response from the server (successful, error, etc.), and other parameters relating to the user’s operating system, browser, and IT environment, name of the internet service provider (ISP), date and time of the visit, referring and exit web pages.
Data voluntarily provided by the user. The explicit and voluntary sending of emails to the addresses listed in the various access channels of this site does not require consent and entails the acquisition of the sender’s address and data, necessary to respond to requests, as well as any other personal data included in the message. Such data is deemed voluntarily provided by the user when requesting service. Specific short-form information notices can be found or displayed on the site pages dedicated to specific on-demand services (e.g. newsletter and contact forms). The user must explicitly consent to the use of the data entered in these forms in order to submit the request.
Cookies. The website uses cookies. Data collected through cookies may be used to access specific sections of the site, for statistical purposes, or to improve future navigation by evaluating user behavior and modifying content offering accordingly. For more information, a specific Cookie Policy is available.
Purpose and Legal Basis of Processing
The processing of your data is based on the following purposes and legal bases:
a. For automatically collected data, the legal basis is the legitimate interest of the data controller, and the purpose is to ensure and improve the user’s web browsing experience.
b. For voluntarily provided data, the legal basis is consent. For emails sent to our addresses, the purpose is to respond to specific user requests; for forms, the purpose is specified in the relevant information notice.
c. For cookies: refer to the specific cookie policy.
Data Recipients
Within the scope relevant to the aforementioned purposes, your data may be communicated to partners, consultancy firms, private companies, third-party technical service providers, hosting providers, IT companies, and communication agencies.
Processing Methods
The personal data you provide will be subject to processing operations in accordance with the above legislation and the confidentiality obligations that inspire the Data Controller’s activity. Data will be processed using both IT tools and paper-based and any other suitable support (e.g. cloud systems, digital archiving and storage systems), with appropriate technical and organizational security measures in line with the GDPR.
All processing is carried out in compliance with Articles 6 and 32 of the GDPR, and through the adoption of appropriate security measures.
Retention Period
In accordance with the principle of storage limitation (Article 5, GDPR), data retention is periodically reviewed to ensure data is not kept longer than necessary for the purposes for which it was collected. Specifically:
Automatically collected data is processed for the time strictly necessary to obtain statistical information on site usage and to ensure proper site functioning, also for security reasons or as required by law.
Voluntarily provided data will be retained no longer than necessary to fulfill the purposes for which it was collected or as required by law.
Data collected via cookies: refer to the cookie policy.
Nature of Data Provision and Consequences of Refusal
Providing data for the purposes in Article 2.a is mandatory to ensure proper service provision.
Providing data for the purposes in Article 2.b is mandatory to respond to specific user requests; it is optional for any other purposes specified in the forms.
Providing data for the purposes in Article 2.c is optional and will not affect service provision in any way.
Data Subject Rights
You have the right to request from the Data Controller access to your personal data, their rectification or erasure, restriction of processing, or to object to processing, as well as the right to data portability and to withdraw consent. These and other rights provided by the GDPR may be exercised simply by contacting the Data Controller. You also have the right to lodge a complaint with a supervisory authority.
Changes
This privacy policy is effective as of December 15, 2018. The Data Controller reserves the right to amend or update its content, in whole or in part, also due to changes in applicable legislation. Therefore, THINX invites you to regularly review this section to stay informed of the latest and most updated version of the policy, so you are always aware of what data is collected and how THINX uses it.