Privacy Policy
The
purpose of this document is to inform the natural person (hereinafter “Data Subject”) about the processing of
his/her personal data (hereinafter “Personal
Data”) collected by the data controller, MoveWise S.R.L., with registered office
in Via San Gregorio 25, 20124 Milano, Tax Code/VAT No. 13223480966, e-mail
address info@movewise.net, (hereinafter “Data
Controller”), via the website MoveWise (hereinafter “Application”).
Changes
and updates will be effective as soon as they are published on the Application.
In case of non-acceptance of the changes made to the Privacy Policy, the Data
Subject shall stop using this Application and may ask the Data Controller to
delete his/her Personal Data.
1 Categories of Personal Data processed
The Data
Controller processes the following types of Personal Data voluntarily provided
by the Data Subject:
·
Contact Data: first name, last name, address,
e-mail address, phone number, pictures, authentication credentials, any further
information sent by the Data Subject, etc.
·
Fiscal and payment Data: tax code, VAT number, credit card
data, bank account details, etc.
·
Data on the employment relationship: data entered in the curriculum
vitae, data on spouse or children, social security data, etc.
· Judicial Data: Personal Data related to criminal convictions, offences or security measures, collected with the consent of the data subject. The Data Subject may withdraw consent at any time.
The Data
Controller processes the following types of Personal Data collected
automatically:
·
Technical Data: Personal Data produced by
devices, applications, tools and protocols such as, for example, information
about the device used, IP addresses, browser type, type of Internet provider
(ISP). Such Personal Data may leave traces which, combined with unique
identifiers and other information received by the servers, can be used to
create profiles of individuals
·
Usage Data: such as, for example, pages
visited, number of clicks, actions taken, duration of sessions, etc.
If the Data
Subject decides not to provide Personal Data for which there is a legal or
contractual obligation, or if such data is a necessary requirement for the
conclusion of the contract with the Data Controller, it will be impossible for
the Data Controller to establish or continue any relationship with the Data
Subject.
The Data
Subject who communicates Personal Data of third parties to the Data Controller
is directly and exclusively liable for their origin, collection, processing,
communication or divulgation.
2 Cookies and similar technologies
The
Application uses cookies, web beacons, univocal identifiers and other similar
technologies to collect the Data Subject's Personal Data on visited pages and
links and other actions performed during the use of the Application. This data
is stored and then used the next time the interested party browses the
Application. The full Cookie Policy can be viewed at the following address: https://www.movewise.net/en/movewise-cookie-policy
3
Legal basis and purpose of data
processing
The
processing of Personal Data is necessary:
·
for
the performance of the contract with the Data Subject and especially:
1
fulfillment of any obligation
arising from the pre-contractual or contractual relationship with the Data
Subject
2
registration and authentication of
the Data Subject:
to allow the Data Subject to register in the Application, to access it and to
be identified in it, also via external platforms
3
support and contact with the Data
Subject: to answer
the Data Subject's requests
4
management of payment: to manage payments by credit
card, bank transfer or other methods
·
for
legal obligations and especially:
1
the fulfilment of any obligation
provided for by the applicable norms, laws and regulations, in particular, on tax and
fiscal matters
·
for
the legitimate interest of the Data Controller, for:
1
marketing purposes by e-mail of
products and/or services of the Data Controller to directly sell the Data
Controller's products or services using the email provided by the Data Subject
in the context of the sale of a product or service similar to the one being
sold
2
management, optimization and
monitoring of the technical infrastructure: to identify and solve any technical issue, to
improve the performance of the Application, to manage and organize the
information in a computer system (e.g. server, database, etc.)
3
security and anti-fraud: to guarantee the security of the
Data Controller’s assets, infrastructures and networks
4
anonymous data
based statistics: in order to carry out statistical analysis on aggregated and anonymous
data in order to analyze behaviors of the Data Subject to improve products
and/or services provided by the Data Controller and better meet the
expectations of the Data Subject
·
on
the basis the Data Subject's consent, for:
1
retargeting and remarketing: to reach with a customized
advertisement the Data Subject who has already visited or shown interest in the
products and/or services offered by the Application using his Personal Data.
The Data Subject may opt-out by visiting the Network Advertising Initiative page
2
marketing purposes of the Data
Controller’s products and/or services: to send information or commercial and/or promotional
materials, to perform direct sales activities of the Data Controller’s products
and/or services or to conduct market research with automated and traditional
methods
On the
basis of the legitimate interest of the Data Controllerowner,
the application allows interactions with external web platforms or social
networks whose processing of personal data is governed by their respective
privacy policies to which please refer. The interactions and information
acquired by this Application are in any case subject to the privacy settings
that the Data Subject has chosen on such platforms or social networks. Such
information - in the absence of specific consent to processing for other
purposes - is used exclusively to allow the use of the Application and to
provide the information and services requested.
The Data
Subject's Personal Data may also be used by the Data Controller to protect
itself in judicial proceedings before the competent courts.
4
Data processing methods and
receivers of Personal Data
The
processing of Personal Data is performed via paper-based and computer tools
with methods of organization and logics strictly related to the specified
purposes and through the adoption of appropriate security measures.
Personal
Data are processed exclusively by:
·
persons
authorized by the Data Controller to process Personal Data who have committed
themselves to confidentiality or have an appropriate legal obligation of
confidentiality;
·
subjects
that operate independently as separate data controllers or by subjects
designated as data processors by the Data Controller in order to carry out all
the processing activities necessary to pursue the purposes set out in this
policy (for example, business partners, consultants, IT companies, service
providers, hosting providers);
·
subjects
or bodies to whom it is mandatory to communicate Personal Data by law or by
order of the authorities.
The
subjects listed above are required to use appropriate measures and guarantees
to protect Personal Data and may only access data necessary to perform their
duties.
Personal
Data will not be indiscriminately shared in any way.
5 Place
Personal
Data will not be transferred outside the territory of the European Economic
Area (EEA).
6 Personal Data storage period
Personal Data will be stored for the period of time that is required to fulfill the purposes for which it was collected. In particular:
·
for
purposes related to the execution of the contract between the Data Controller
and the Data Subject, will be stored for the entire duration of the contractual
relationship and, after termination, for the ordinary prescription period of 10
years. In the event of legal disputes, for the entire duration of such
disputes, until the time limit for appeals has expired
·
for
purposes related to legitimate interests of the Data Controller, they will be
stored until the fulfilment of such interest
·
in
compliance with legal obligations, by order of an authority and for legal
protection, they shall be stored according to the relevant timeframes provided
for by such obligations, regulations and, in any case, until the expiry of the
prescriptive term provided for by the rules in force
·
for
purposes based on the consent of the Data Subject, they will be stored until
the consent is revoked
At the end
of the conservation period, all Personal Data will be deleted or stored in a
form that does not allow the identification of the Data Subject.
7 Rights of the Data Subject
Data Subjects may exercise specific rights regarding the Personal Data processed by the Data Controller. In particular, the Data Subject has the right to:
·
be
informed about the processing of their Personal Data
· withdraw consent at any time
·
restrict
the processing of his or her Personal Data
·
object
to the processing of their Personal Data
· access their Personal Data
·
verify
and request the rectification of their Personal Data
·
restrict
the processing of their Personal Data
·
obtain
the erasure of their Personal Data
·
transfer
their Personal Data to another data controller
·
file
a complaint with the Personal Data protection supervisory authority and/or take
legal action.
In order to
use their rights, Data Subjects may send a request to the following e-mail
address info@movewise.net. Requests will be immediately treated by the Data Controller
and processed as soon as possible, in any case within 30 days.
Last update: 20 November 2023