Information about the processing of users‘ Personal Data on artifexopera.com

Dichotomic Lab SAGL Via Belvedere 11 6952 Canobbio (Switzerland) 

Elisabetta Saccon is the administrator and legal representative. As the data controller (hereinafter the „Owner“), she wishes to inform her clients including users of the Website https://artifexopera.com/ (hereinafter referred to collectively as the „Website“) (the „Interested Party“) regarding the methods of processing Personal Data provided to the Data Controller. These are required by Legislative Decree no. 196/2003 (the „Privacy Code“) and the new European Regulation n. 679/2016 regarding the protection of Personal Data (the „General Data Protection Regulation“), became enforceable beginning 25 May 2018.

Owner and Data Controller

The Data Controller is Dichotomic lab SAGL, with registered office in Via Belvedere 11 6952 Canobbio (Switzerland), and can be contacted at the following email address: info@dichotomiclab.ch. The complete list of the responsible for the Personal Data processing, appointed by the Data Controller, is available on request by sending an email to the address indicated above.

Personal Data collected

In accordance with this Privacy Policy, the Data Controller processes the data provided by the interested parties, including:

1. The Personal Data and contact information provided to the Data Controller at any time, including those needed to create an account on the Website;
2. Data relating to purchases made through the Website;
3. Navigation data relating to the use of the services offered through the Website. These are collected through cookies in accordance with the Cookies Policy available at the following link https://artifexopera.com/cookie-policy/cookie-policy/;
4. The data provided in case of a request for information and assistance; 
5. The data provided and collected for the purposes and within the context of any participation in competitions and / or prize operations of the Data Controller. In this case, this Privacy Policy will be supplemented by the information that regulates the Personal Data processing of the relative competitions and / or prize operations.

The Owner does not process health data and particular categories of Personal Data are in accordance with article 9 of the European Privacy Regulation. The data of minors will be processed according to the methods referred to in paragraph 8 below.

The Owner processes the data indicated above only to the extent that they are necessary to achieve the purposes described in paragraph 4 of this Privacy Policy.

Data processing methods

The Personal Data of the Interested Party are processed with the support of computer and / or paper means and are protected through adequate security measures suitable to guarantee the confidentiality and security of Personal Data. In particular, the Data Controller adopts appropriate organizational and technical measures to protect the Personal Data against loss, fraud, use, disclosure or unauthorized modification of Personal Data.

The Data Controller proceeds with the anonymization of Personal Data and with the removal of identification data if there is no need to process Personal Data for the purposes of the processing and at the end of the retention period stated in paragraph 10 below.

Purposes of the processing

The Interested Party is requested to provide the Owner with his / her Personal Data for the following purposes:

1. Allow the Interested Party to register through the Website by creating a personal account and carry out the activities of the Website. These include purchase on the Website, use the services available through the Website, participate in prize competitions, customer support services, assert and defend the rights towards the Interested Party and third parties (hereinafter jointly defined as „Contractual Purposes“);
2. Comply with any legal and regulatory obligations (hereinafter referred to as „Legal Purposes“);
3. With the consent of the Interested Party, the Owner will send newsletters and commercial communications, through traditional and remote means of communication including email, SMS, MMS, social networks, instant messages, mobile applications, banners, faxes, mail and telephone, for promotion and / or sale of products and / or services marketed by the Data Controller and for customer satisfaction surveys („Marketing Purposes of the Data Controller“);
4. With the consent of the Interested Party, the Owner will send marketing communications from other companies of the group of the Owner and / or commercial partners belonging to the same categories of the Owner, in relation to their products and services in the manner referred to in point c) above, the list of which is available at the request of the Interested Party („Third Party Marketing Purposes“);
5. In case that the Interested Party has given consent to the processing of his / her data for the Marketing Purposes of the Data Controller, the Owner will send newsletters and communications relating to the products and services marketed by the Data Controller by email, SMS with a frequency not exceeding 3 communications per month to Users. These are identified solely on the basis of non-invasive categories of belonging, such as, the age group, the possible opening of previous newsletters received, the ways in which the Interested Party makes their purchases („Purpose of Legitimate Marketing Interest“); 
6. Carry out functional activities for company and company branch transfers, acquisitions, mergers, demergers or other transformations and for the execution of such operations („Purpose of Legitimate Business Interest“).

 

Legal basis of the processing

The Personal Data processing for contractual purposes is mandatory, as it is necessary for the purpose of registration, to carry out the activities on the Website, to purchase products also online and to use specific services provided by the Website. The provision of Personal Data for the Purpose of the Law is mandatory as required under applicable laws. In the event that the Interested Party does not want their Personal Data to be processed for these purposes, it will not be possible to use the Website and the services available through the Website itself.

The Personal Data processing for the Marketing Purposes of the Owner and Third Party Marketing is optional and subject to the prior consent of the Interested Party. Any failure to provide consent determines the impossibility for the Data Controller, the companies of the Data Controller group and / or the selected commercial partners to keep the Data Subject updated. The updates concern new products or services, promotions, personalized offers, as well as to carry out market surveys and to send communications or other information material that may be consistent with his / her interests. 

The processing for the Purposes of Legitimate Marketing Interest is functional to the pursuit of a legitimate interest of the Owner and the Users within the limits imposed on such processing illustrated in paragraph 4 f). It will be in effect from 25 May 2018, effective date of the General Data Protection Regulation.

The processing for the purposes of legitimate business interest is carried out pursuant to article 24, paragraph 1, letter d) of the General Data Protection Regulation. It pursuits the legitimate interest of the Owner and its counterparties in carrying out the economic operations in accordance with the article 6, letter f) of the General Data Protection Regulation. It is properly balanced with the interests of the Users as the processing takes place within the limits strictly necessary to execute of these operations.

Communication scope and data dissemination

For the purposes referred to in paragraph 4, the Data Controller may communicate the data of the Interested Parties that are strictly necessary for each type of processing to the following subjects:

1. to the collaborators, employees and suppliers of the Data Controller, as part of their duties and / or any contractual obligations with them, concerning commercial relations with Users;
2. to subcontractors and / or subcontractors engaged in activities related to the services and the products offered by the Owner;
3. to other companies of the Owner’s group in Italy and abroad, both national and international, located in countries as better specified in paragraph 7 below;
4. to post offices, shippers and couriers for shipping the products and / or other material relating to the performance of the Owner’s services;
5. to legal, administrative and tax consultants within the limits necessary or functional to the performance of the Owner’s activity, in the manners and for the purposes described above; 
6. to banks for the management of collections and payments deriving from the execution of contracts with the Interested Party.

The Personal Data of the Interested Party will not be disclosed.

Personal Data are transferred abroad

Personal Data may be freely transferred outside the national territory to countries located in the European Union. Any transfer of the Interested Party Personal Data to countries of the European Union will take place in compliance with the appropriate safeguards in accordance with applicable legislation.

The Interested Party will have the right to obtain a copy of the data held abroad and to obtain information about the place where data is stored by expressly request to the Data Controller using the address in paragraph 9 of this Privacy Policy.

People under 18 years old

The Data Controller also offers services through the Website that people under the age of 18 can use as well. In these cases, the Data Controller collects and processes the Personal Data of minors exclusively for the purposes and with the methods declared in this Privacy Policy. It complies with the rules on the processing of Personal Data of minors referred to in art. 8 of the General Data Protection Regulation with the prior consent of the parent and / or guardian and / or person who takes its place, whose data may be collected only to obtain this consent. 

Rights of the interested parties

At any time and free of charge the Interested Party may:

(a) Obtain confirmation and communication of the data concerning him / her; 

(b) Know the origin of the data, the purposes of the processing and its methods, as well as the logic applied to the processing carried out through electronic tools; 

(c) Request updating, rectification or – if interested – integration of data; 

(d) Obtain the cancellation, the transformation into anonymous form or blocking of any data processed in violation of the law, as well as to oppose, for legitimate reasons, the processing; 

(e) Object, in whole or in part, to the processing of data concerning him / her for direct marketing purposes carried out through automated and / or traditional methods; 

(f) Withdraw consent to the processing of data at any time, without this could undermine the lawfulness of the processing based on the consent given before the revocation.

With effect from 25 May 2018, in addition to the rights listed above, the Interested Party may be entitled to the rights referred to in paragraph 10, lett. b) of this Privacy Policy.

At any time, the Interested Party can exercise the above rights, modify the contact methods, notify the Owner of any data updates, request the removal of their Personal Data communicated by third parties, or obtain further information about how the Owner uses the Personal Data. In these cases, please contact the Owner using the email info@dichotomiclab.ch.

Provisions applicable beginning May 25, 2018

The following provisions will become effective from May 25, 2018, as consequence of the beginning of the effectiveness of the General Data Protection Regulation.

1. a) Personal Data storage: the Data Controller will store Personal Data for the period necessary to fulfill the collection purposes pursuant to paragraph 2 above. In any case, the following storage periods apply to the processing of Personal Data for the purposes indicated below:

• The data collected for the Contractual Purposes referred in paragraph 4, lett. a) are stored for the entire duration of the contract and for 10 years following the expiration of the agreement for defense purposes and / or to assert a right of the Owner in court and / or out of court in case of disputes related to the execution of the contract ;
• The data collected for legal purposes referred to in paragraph 4, lett. b) are stored for a period equal to the duration prescribed by law for each type of data;
• The data collected for the Data Controller’s Marketing Purposes referred in paragraph 4, lett. c) are stored for a period equal to the entire duration of the registration of the Interested Party on the Website through their account and / or participation in the competition and / or […] as well as for the 2 years following the end, deactivation and / or cancellation of the same;
• The data collected for Third Party Marketing Purposes referred to in paragraph 4, lett. d) and e) are stored for a period of 12 months from the moment of collection;
• The data collected for Legitimate Marketing Interest Purposes referred to in paragraph 4, lett. f) are stored for a period equal to the entire duration of the registration of the Interested Party on the Website, through their account and / or participation in the competition and / or […] as well as for a 2 years following the end, deactivation and / or cancellation of the same;
• The data collected for Legitimate Business Interest Purposes referred to in paragraph 4, lett. g) are stored for a period of 10 years from the moment of collection.

Once these terms have expired, the data of the Interested Party can be deleted, anonymized and / or aggregated.

1. (a) Additional rights: the Interested Party may at any time, in accordance with the procedures referred to in paragraph 9 above,
   • (a) Request the limitation of the processing of Personal Data in the event that (i) he / she questions the accuracy of the Personal Data, for the period necessary to verify the accuracy of such Personal Data. (ii) The processing is unlawful and the Interested Party opposes the cancellation of Personal Data and instead requests to limit their use. (iii) Although the Data Controller no longer needs it for processing purposes, Personal Data are necessary for the Interested Party to ascertain, exercise or defend a right in court. (iv) The Interested Party opposed the processing pursuant to art. 21, paragraph 1, of the Privacy Regulation waiting for the legitimate reasons of the Data Controller compared to those of the Interested Party; 
2. (b) Object to the processing of Personal Data at any time; 
3. (c) Request the deletion of Personal Data concerning him without undue delay; 
4. (d) Obtain the portability of Personal Data concerning him / her; 
5. (e) Propose a complaint to the Data Protection Supervisor if the conditions exist.

 

Modifications and updates

This Privacy Policy is effective starting from the date indicated in the header. The Data Controller may also make modifications and / or additions to this Policy, also as consequence of any subsequent changes and / or regulatory additions to the General Data Protection Regulation. The changes will be notified in advance and you can refer to the constantly updated Privacy Policy version at link https://artifexopera.com/privacy-policy.

If the Interested Party has doubts, observations or complaints about the methods of collection or use of his / her Personal Data, please contact the Owner through the Contact section of the Website.