Privacy Policy
The purpose of this privacy policy is to provide all the information on the processing of personal data carried out by Fyne S.r.l. when the User accesses and browses this Website (as better indicated below).
1.INTRODUCTION - WHO ARE WE?
Fyne S.R.L., with registered office in Via Berardi 8, Taranto 74123, P.IVA No. 03273410732 (hereinafter referred to asthe “Data Controller” or, simply, the “Controller”), owner of this Website and of the application branded “Syncro” (hereinafter referred to as the “Website”); as the data controller of the processing of the personal data of the users browsing the Website (hereinafter referred to as the "Users"), hereby provides the privacy policy pursuant to Art. 13 of the EU Regulation 2016/679 of 27 April 2016 (hereinafter, "Regulation", or "Applicable Law").
2.HOW TO CONTACT US?
The Data Controller takes the right to privacy and the protection of its Users’ personal data into the utmost consideration.
For any information in relation to this privacy policy, Users may contact the Controller at any time, using the following methods:
- By sending a registered letter with return receipt to the Controller's registered office at Via Berardi 8, Taranto 74123;
- By sending an e-mail to: privacy@appsyncro.com
The Data Controller has not identified the figure of the Data Protection Officer (DPO), since it is not subject to the designation obligation provided for in Article 37 of the Regulation.
3.WHAT DO WE DO? - PURPOSE OF PROCESSING
By browsing the Website, the User may download the “Syncro” application, developed by the Data Controller.
In addition, the User may:
- from the “Contacts” and “Help” sections, contact the Controller for various purposes such as, purely by way of example, to receive more information from the Controller on the services offered through the Website; receive assistance.
- subscribe to the newsletter, from the homepage of the Website, in order to stay up-to-date on the services and activities developed by the Controller
- through the “Work with Us”, “Collaboration”, “Ambassador” and “Investment” sections, contact the Data Controller to send a job application or proposal for collaboration or contributing to the growth of the project through an investment.
In connection with the activities that may be carried out through the Website, the Controller collects personal data relating to Users.
This Website and the services that may be offered through the Website are reserved for subjects who have reached the age of fourteen. The Data Controller therefore does not collect personal data relating to persons under the age of 14. At the request of Users, the Data Controller will promptly delete all personal data involuntarily collected relating to persons under the age of 14.
In particular, Users' personal data will be lawfully processed by the Controller for the following purposes:
a) Allowing browsing of the Website. The user data collected by the Data Controller for the sole purpose of browsing the Website include all those personal data whose transmission is implicit in the use of Internet communication protocols, such as: IP addresses used by users connecting to the Website, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, log files and other parameters relating to the User's operating system and computer environment.
b) Request for contact and/or information. The User's data collected by the Controller for the purposes of any contact request on the Website include: first name, last name, e-mail address, telephone number, as well as all the User's personal information that may be voluntarily communicated. The User's personal data will be used by the Data Controller for the sole purpose of ascertaining the User's identity, thus avoiding possible fraud or abuse, and contacting the User for service
purposes only (e.g. responding to his/her request for information). Without prejudice to what is provided for elsewhere in this privacy policy, under no circumstances will the Data Controller make Users' personal data accessible to other Users and/or third parties.
c) Sending a job application or proposal for collaboration. The User's personal data collected and processed by the Controller for the sole purpose of processing the request regarding the possibility of establishing a collaboration or work activity with the Controller include: first name, surname, e-mail address, telephone number, curriculum vitae, as well as all the User's personal information that may be voluntarily communicated. No other processing will be carried out by the Controller in relation to the Users' personal data. Without prejudice to what is provided for elsewhere in this privacy policy, under no circumstances shall the Controller make Users' personal data accessible to other Users and/or third parties;
d) legal obligations, i.e. to fulfil obligations laid down by law, by an authority, by a regulation or by European legislation.
The provision of personal data for the above-mentioned processing purposes is optional but necessary, since failure to provide such data will make it impossible for the User to browse the Website, register on the Website and use the services offered by the Controller on the Website.
Personal data that are necessary for the pursuit of the processing purposes described in this paragraph 3 are indicated with an asterisk within the forms on the Website.
4.FURTHER PURPOSES OF TREATMENT
4.1 Newsletter Some of the User's personal data (i.e. e-mail address) may also be processed by the Controller for the purpose of sending the newsletter. Therefore, the User will receive from the Data Controller a periodical newsletter that will contain information, updates, news and initiatives on the applications developed by the Data Controller.
If consent is not given, the ability to browse on the Website will not be affected in any way.
In the event of consent, the User may withdraw it at any time by making a request to the Controller through the modalities indicated in paragraph 9 below.
The User may also easily object to further sending of promotional communications by clicking on the appropriate link for the withdrawal of consent, which is present in each e-mail containing the newsletter. Once consent has been withdrawn,the Data Controller will show the User a message confirming that consent has been withdrawn.
5.LEGAL BASIS
Contractual obligations and fulfilment of the user's request (as described in para. 3(a), (b), (c) above): the legal basis is Art. 6(1)(b) of the Regulation, i.e. the processing is necessary for the performance of a contract to which the User is party or for the performance of pre-contractual measures taken at the User's request.
Legal obligations (as described in para. 3(b) above): the legal basis is Art. 6(1)(c) of the Regulation, as the processing is necessary to comply with a legal obligation to which the Data Controller is subject.
Further processing purposes: for the processing relating to the activity of sending the newsletter (as described in paragraph 4.1 above), the legal basis is Article 6(1)(a) of the Regulation, i.e. the provision by the data subject of consent to the processing of his/her personal data for one or more specific purposes. For this reason, the Data Controller asks the User for the provision of a specific free and optional consent, in order to pursue such processing purpose.
6.PROCESSING METHODS AND DATA RETENTION PERIODS
The Data Controller will process the Users' personal data by means of manual and computerised tools, with logics strictly related to the purposes themselves and, in any case, in such a way as to guarantee the security and confidentiality of the data.
The personal data of the Website's Users will be kept for the time strictly necessary to fulfil the primary purposes set out in paragraph 3 above, or in any case as necessary for the protection in civil law of the interests of both the Users and the Data Controller.
In the case referred to in paragraph 4.1 above, the Users' personal data shall be kept for the time strictly necessary to fulfil the purposes set out therein and, in any
event, until the User withdraws his or her consent.
In any case, any retention periods provided for by law or regulations are unaffected.
The personal data of the Users may be disclosed to the employees and/or collaborators of the Data Controller in charge of managing the Website and the Users' requests. These subjects, who have been instructed to do so by the Data Controller pursuant to art. 29 of the Regulations, will process Users' data exclusively for the
purposes indicated in this information notice and in compliance with the provisions of the Applicable Regulations.
Users' personal data may also be disclosed to third parties who may process personal data on behalf of the Data Controller in their capacity as Data Processors, such as, by way of example, suppliers of IT and logistical services functional to the operation of the Website, suppliers of outsourcing or cloud computing services, professionals and consultants.
Users have the right to obtain a list of any data processors appointed by the Controller by making a request to the Controller in the manner indicated in paragraph 9 below.
Users may exercise the rights guaranteed to them by the Applicable Law by contacting the Controller in the following ways:
- By sending a registered letter with return receipt to the Controller's registered office at Via Berardi 8, Taranto 74123;
- By sending an e-mail to: privcy@appsyncro.com
The Data Controller has not identified the figure of the Data Protection Officer (DPO), since it is not subject to the designation obligation provided for in Article 37 of the Regulation.
Pursuant to the Applicable Law, the Data Controller informs Users that they have the right to obtainin formation on (i) the origin of personal data; (ii) the purposes and methods of processing; (iii) the logic applied in the event of processing carried out with the aid of electronic instruments; (iv) the identification details of the data controller and data processors; (v) the subjects or categories of subjects to whom personal data may be communicated or who may become aware of such data
in their capacity as data processors or persons in charge of processing.
Furthermore, Users have the right to obtain:
(a) access, update, rectification or, where interested, integration of the data;
b) the cancellation, transformation into anonymous form or restriction of data processed in breach of the law, including data whose storage is not necessary in relation to the purposes for which the data were collected or subsequently processed;
c) certification that the operations referred to in points a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, unless this proves impossible or involves a manifestly disproportionate effort compared to the right protected.
In addition, Users have:
(a) the right to withdraw consent at any time, if the processing is based on their consent;
b) the right to data portability (the right to receive all personal data concerning them in a structured, commonly used and
machine-readable format);
(c) the right to object:
(i) in whole or in part, for legitimate reasons, to the processing of personal data concerning them, even if they are relevant to the purpose of the collection;
ii) in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication;
(iii) where personal data are processed for direct marketing purposes, at any time, to the processing of their data carried out for that purpose, including profiling insofar as it is related to such direct marketing.
d) if they consider that the processing concerning them is in breach of the Regulation, the right to lodge a complaint with a Supervisory Authority (in the Member State where they have their habitual residence, in the Member State where they work or in the Member State where the alleged breach has occurred). The Italian
Supervisory Authority is the Garante per la protezione dei dati personali, based in Piazza Venezia n. 11, 00187 – Rome (http://www.garanteprivacy.it/).
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The Data Controller is not responsible for updating all links displayed in this Policy, therefore whenever a link is not working and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the Websites referred to by that link.