the following are the methods of data processing that Cliptosleep, as better indicated below, collects and processes for the provision of its services.
1. Data controller
Cliptosleep® (hereinafter "Cliptosleep"), by Michele Tiralosi, Via Triulziana 38, 20097 San Donato Milanese, VAT 10846710969 is the data controller, in the figure of its sole director (or, if the form should be changed) governance, of the subject who will represent Cliptosleep).
As the owner of the processing of personal data collected while browsing the various sections and subsections of the www.cliptosleep.com site for the supply and performance of its services, Cliptosleep undertakes to guarantee compliance with the privacy discipline, such as modified by European Union Regulation no. 679/2016 (hereinafter, "GDPR"), providing its customers with all the related information both on how to collect, store and use the aforementioned data and regarding the rights of each user.
For any information and / or further clarification, it is possible to contact Cliptosleep, as data controller and protection of the aforementioned data, by writing to: firstname.lastname@example.org.
2. Personal data processed, purposes and legal bases of the processing.
A. Personal data processed
In order to perform and provide its services on time and according to market standards, as described on its website, Cliptosleep collects and stores the following data:
• The data and information provided by visitors / users of their website (www.cliptosleep.com) and the related subdomains and / or domains in any way connected, present and future, generated by accessing the site. The IT systems and software procedures prepared by Cliptosleep acquire the information sent to the user's browser and, in particular: (i) the IP address, (ii) the type of operating system and browser used, (iii) the settings, date and time of use as well as (iv) the location (understood as geo-location of the user) and the language used;
• the geographical area in which the device is used from which the data subject to this information and / or the various mobile devices are used, used from time to time by the user;
• the personal data (name, surname, username, e-mail address and contact details) provided by users of their website who subscribe (s) to the newsletter (s)
Cliptosleep and / or (ii) choose to register to (a) use the cd plan. "Free" and / or free trial of the chosen subscription plan, (b) to receive updates on our activities, and (c) to receive promotional communications and invitations to events;
• additional personal data (company name, company name, telephone numbers, billing address, VAT number as well as any other useful and / or necessary data required by the legislation applicable from time to time) provided by Cliptosleep users and necessary to complete any tax and administrative compliance, as required by applicable legislation;
• the content generated by users and uploaded to the system in relation to the use of the service (such as, by way of example and not limited to, the messages, posts, comments, pages, profiles, images, communications exchanged on the supported platforms, etc.) ;
• information voluntarily sent by users such as, by way of example but not limited to, questions to Cliptosleep's customer support, comments on the services provided by Cliptosleep, answers to surveys and / or other optional information such as links to social profiles networks authenticated, from time to time, through the use of your Cliptosleep account.
B. Purposes and legal bases of the processing
The personal data requested by Cliptosleep are collected and processed for the following purposes:
1. for the performance of the activities related and necessary for the performance of the contract In the case of use of the Cliptosleep services in trial, the data collected, and in particular those relating to the delivery, including e-mail addresses, to complete the test service, they can be used to receive feedback on the individual user experience of Cliptosleep and directly verify each experience of using the platform;
2. for accounting, tax, administrative purposes as well as for the fulfillment of legal obligations or in the event that the processing of the aforementioned data is necessary to process advanced requests from the judicial authority and / or from public authorities in the context of judicial and / or administrative procedures and for which there is an obligation to communicate the aforementioned data;
3. in the presence of specific consent from the user for the periodic sending, via e-mail and / or his / her Cliptosleep account, of newsletters / s and / or advertising material;
4. in the case of sending a curriculum vitae, exclusively in the context of selection processes for which the user has been previously informed or in which the user has voluntarily participated.
The additional data (such as, by way of example but not limited to, domain names, IP addresses and / or browser types), collected through the Cliptosleep website, are and / or will be used to track traffic statistics and for needs. to control how the services of part of the competent authorities are used and are not and / or will in any way be accompanied by any additional personal information which is not strictly necessary for the purposes specified therein.
3. Nature of the provision
The provision of data by the user for the purposes referred to in Article 2, letter B., point 2) above is absolutely necessary for the use and use of the Cliptosleep services and any refusal by the The user to provide his data will make it impossible for Cliptosleep to provide and perform his services, without this giving rise to any type of contractual breach by Cliptosleep.
The provision of data by the user for the purposes referred to in Article 2, letter B., points 1), 3) and 4) above is optional and its use is conditional on the release of an explicit consent by user. Any refusal by the user to grant consent does not affect the possibility of using the Cliptosleep services and has no other effect than to exclude the sending of newsletters / s and / or advertising material.
4. Data processing methods
The collected data will be processed through the use of automated electronic, IT and telematic tools and / or through manual processing with logic strictly related to the purposes for which the personal data were collected, guaranteeing, in any case, their safety.
The aforementioned data will be stored on IT media, in compliance with the security measures and in the protection of the security guarantees suggested by the GDPR.
The processing of personal data is carried out by means of the operations indicated in article 4 of Legislative Decree no. 30 June 2003, n. 196 (Privacy Code) and article 4, no. 2, of the GDPR and precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data.
All data are saved using a Cliptosleep server farm which is located in a state-of-the-art data center (ARUBA), highly secure and in any case in line with legal requirements. In order to prevent misuse of such data, Cliptosleep adopts some specific security measures such as, for example, the storage of confidential data in an encrypted format.
The main agreement for the processing of personal data (Master Data Processing Agreement or "MDPA"), describes the conditions and methods of treatment of personal data performed by Cliptosleep and the responsibilities
connected to the processing activities, including the commitment made as the person responsible for the processing of personal data pursuant to art. 28 GDPR.
5. Access to data
The data may be made accessible for the purposes indicated in articles 1), 2), 3) and 4) which precede:
• internal staff of Cliptosleep S.r.l., identified and authorized for this purpose for processing according to specific instructions given in compliance with current legislation;
• to third parties (for example professional firms and / or external consultants) who carry out assistance and consultancy activities on behalf of Cliptosleep, in their capacity as external data processors, only for the purposes strictly necessary for their use;
• to companies that perform services connected and instrumental to the execution of the aforementioned purposes such as, by way of example and not limited to, credit card payment management companies (Stripe).
6. Duration of treatment
The treatment will last no longer than necessary for the purposes for which the data were collected and, in any case, may vary in relation to the user's choices with reference to the contractual agreements entered into from time to time with Cliptosleep.
The user has the right, at any time, to request the interruption, limitation and / or cancellation of data by sending a request to: email@example.com. In this case, what is already indicated in Article 3 above will apply.
7. Data transfer
The management and storage of personal data will take place on servers owned by Cliptosleep and / or third-party companies specifically appointed by Cliptosleep and duly appointed as responsible for the processing of the aforementioned data. These servers will be located outside the territory of the European Union.
Cliptosleep's current cloud provider is Aruba., Operating in Italy. The provider has already adapted to the privacy criteria imposed by the GDPR.
The personal data provided by the user to allow the sending (i) of commercial communications via e-mail on products, initiatives and / or services offered by Cliptosleep and / or (ii) of newsletters containing insights are processed electronically through the use of software called Mailer Lite.
The "Mailerlite" service is provided by the site http://www.mailerlite.com
8. Rights of the interested party
Each user, in his capacity as an "Interested" subject, has the rights set out in article 7 of the Privacy Code and article 15 of the GDPR and, precisely, the rights of:
• obtain confirmation of the existence or not of personal data concerning him in the Cliptosleep archives, even if not yet registered, and their communication in an intelligible form;
• obtain the indication: a) of the origin of the personal data; b) the purposes and methods of treatment; c) the logic applied in case of treatment carried out with the aid of electronic instruments; d) of the identification details of the owner, of the managers and of the representative appointed pursuant to article 5, paragraph 2, of the Privacy Code and article 3, paragraph 1, of the GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of the aforementioned data as appointed representatives in the territory of the Italian state, managers or agents;
• obtain: a) updating, modification, updating or, in case of specific interest, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is unnecessary for the purposes for which the data were collected and / or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated and / or disseminated, except in the case where such fulfillment proves impossible or involves the use of means manifestly disproportionate to the protected right;
• object, in whole or in part: a) for legitimate reasons, to the processing of personal data concerning the user, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning the user for the purpose of sending advertising materials and / or direct sales and / or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods (ie by telephone and / or paper mail).
1. 1. In this regard, Cliptosleep points out that the right of opposition of the interested party, as explained above, for direct marketing purposes through automated methods also extends to traditional marketing. In any case, the possibility remains for the interested party to exercise the right to
even partially opposition. Therefore, the interested party can decide to receive only communications (i) using traditional methods or (ii) only automated communications or (iii) neither of the two types of communication.
Where applicable, the user also has the rights referred to in articles 16 to 21 of the GDPR (ie right of rectification, right to be forgotten, right to limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority for the Protection of Personal Data.
9. How to exercise your rights.
As already indicated above, the user has, at any time, the opportunity to object to the processing of their data and / or request the cancellation, modification or updating of all personal information in possession of cliptosleep.
These powers can be exercised by the user by sending a communication to the following email address: firstname.lastname@example.org.
Cliptosleep® is registered under Industrial Lab Manufacturing © 2020