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This privacy policy is provided in accordance with the art. 13 of Regulation 2016/679 (GDPR) and with the art. 13 of Italian d.lgs n.196/2003 and is related to all personal data processed according to the methods indicated below.

DATA CONTROLLER

Data Controller for the collected and processed data is Lawyer Giovanni Carotenuto, Via G.B. Martini, 6 Rome – 00198 Italy.
Collected personal data may be communicated to selected organizations properly appointed as Data Processor, in order to reach the purpose of the treatment, as stated below.
The complete Data Processor list may be obtained sending proper request to the e-mail info@carotenutolex.com.

DATA TRANSFER

If Personal Data are transferred outside European Union, for technical purposes and to ensure service continuity, the Data Controller ensures that the transfer is based on an adequacy decision by the Commission, to ensure that the level of protection of the personal data guaranteed by current legislation and in particular by EU Regulation 2016/679 is not affected.

COLLECTED DATA

Personal Data are collected by direct user submission or automatic processes.

Personal Data collected by user submission are all the data submitted to Data Controller in any way or form by the user itself.

Data collected by user submission are those ones provided directly to Data Controller by the user itself.

Personal data collected by automatic means are browsing data. These data, even if not directly collected to be associated to the user identity, may indirectly, with elaboration and association with other data collected by Controller, consent the identification of the user.

The newsletter sending platform can track back e-mail opening and click on newsletter links, with ip address and browser/device details. This data collection is useful for the implicit renewal systems (see Data Processing) and part of the sending system itself.

LEGAL BASIS AND PURPOSE OF THE PROCESS

The provision of personal data has as its legal basis in the processing of contractual or pre-contractual requirements or the fulfillment of legal obligations by the Data Controller.

Any refusal to the processing or the incorrect or partial submission of data could led to the unavailability of the service or the impossibility, for the Data Controller, to respond to requests for information sent by the user.

Only on explicit consent by the user, to allow access to specific and further services such as the sending of information and promotional communications by e-mail or by electronic means.

The submission of data for the purposes of sending newsletters for promotional, informational or research purposes is optional and the refusal to give consent to this process will result in the impossibility of being updated about commercial initiatives and / or promotional campaigns, to receive offers or other promotional material and / or to receive personalized offers.

RIGHT TO OBJECT

User can revoke his consent to receive commercial and promotional communications any time, sending a request to the e-mail address info@carotenutolex.com or clicking on the unsubscribe link on every commercial or promotional e-mail received.

THIRD PARTIES

Collected personal data may be communicated to selected organizations properly appointed as Data Processor, in order to reach the purpose of the treatment, as stated below.
Data Controller does not communicate to third parties any personal information without user’s consent, unless required by law. Personal data will never be spread or broadcasted by any means.
The complete Data Processor list may be obtained sending proper request to the e-mail info@carotenutolex.com.

PROCESSING DETAILS

Personal user data are processed with automatic tools for the time needed to reach the purposes they were collected for, with an annual check of the collected data, in order to delete obsolete ones, unless for additional archiving required by law.

Data processing is mainly achieved in the Controller head office, by personnel or external collaborators duly appointed as data processors.

The complete list of Data Processors may be requested by a proper mail request to info@carotenutolex.com.

The subscription and the connected processing are valid until the unsubscription of the user, or after 12 months from last communication user have interacted with (by opening the e-mail or by clicking any link in it).

Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access.

USER RIGHTS

Pursuant to art. 15 – 21 of the GDPR, each user has some rights, as stated below.

– Data Access: pursuant to art.15, user has the right to obtain confirmation of processing of his or her personal data, even if not yet registered on service/platform, and has the right to obtain his or her data copy in an intelligible form. He has also the right to obtain information about purpose of the processing and processing methods, data controller and data processors, information about treatment duration and about other rights.
– Right to rectification: The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her, as stated in art.16
– Right to erasure: pursuant to art.17 the data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay.
– Right to restriction of processing: pursuant to art.18 the data subject shall have the right to obtain from the controller restriction of processing.
– Right to data portability: pursuant to art.20 the data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format.
– Right to object: pursuant to art.21 the data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her. Data subject has also the right to propose a complaint to the competent control authority.

Every request mentioned in this chapter has to be addressed via e-mail to info@carotenutolex.com, that will provide promptly response, in the term disposed in the current law.

UPDATES AND CHANGES

Data controller have the right to periodically modify, integrate or update this Privacy Policy in accordance to applicable legislation.

These updates will be notified to users by links to the Privacy Policy page on website and will be communicated to the users via e-mail.

We invite users to visit this page on regular basis, to check for updated informations and decide if continue to use the services offered.

I consent to the processing of my personal data (Regulation 2016/679 – GDPR and legislative decree n.196 of 30/06/2003).