Privacy Policy

PRIVACY INFORMATION MODEL

pursuant to and for the purposes of art. 13, of EU Regulation 2016/679 concerning the protection of individuals with regard to the processing of personal data, as well as the free movement of such data and which repeals Directive 95/46 / EC

This information is provided pursuant to art. 13 of EU Regulation no. 2016/679 ("General Data Protection Regulation" or "GDPR"), as well as of Legislative Decree no. 196/2003 ("Italian Personal Data Protection Code"), as amended by Legislative Decree no. 101/2018, concerning the processing of personal data and the protection of privacy, including in the electronic communications sector. To this end, it is specified that the law applicable to the processing is Italian law.

Data Controller: Marco Migozzi (sole trader – libero professionista), VAT no. IT18375681006, with registered office in Via Pier Alessandro Guglielmi 76d, 00144 Rome – Italy, informs you pursuant to art. 13, EU Regulation no. 2016/679 (hereinafter, "GDPR") that your data will be processed in the manner and for the following purposes:

1. Object of the processing

The Data Controller takes care of the protection of your personal data and complies with the applicable personal data protection legislation (Law n.190/18 and GDPR 2016/679). Your personal data is treated confidentially and is transferred to third parties solely on the basis of the provisions of this Policy, or with your consent. We process the personal data that you provide to us while using the website and/or after registering on the website and/or through the process of purchasing ZipTv products and during the execution of the related contractual relationships.

In particular, we deal with:

personal, identifying and non-sensitive data (in particular, email address - hereinafter, "personal data" or even "data") directly provided by you, with registration on the site and/or request to use individual services and products traded through the ziptv site;
data not directly supplied by you – and in any case acquired within the limits of the provisions of art. 14, paragraph 5, GDPR – the transmission of which is connected to the use of Internet communication protocols (by way of example, page accesses, amount of data transferred, status message upon accesses, session ID numbers, IP addresses, URL addresses, etc.). These data allow the path of your visits to the site to be reconstructed.

2. Purpose of the treatment

Your personal data are processed:

A) without your express consent (art. 6(1)(b), (c), (e), (f), GDPR), for the following Service Purposes:

to process a contract request or a pre-contractual request;
implement pre-contractual measures adopted upon your request;
process internal statistics;
fulfill the tax obligations deriving from existing relationships;
fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority;
prevent or detect fraudulent activity or abuse harmful to the website;
pursue a legitimate interest of the Data Controller or of third parties, within the limits and under the conditions set out in art. 6, letter f), GDPR;
exercise the rights of the Owner, (by way of example, the right of defense in court);

B) Only with your specific and unequivocal consent (art. 6(1)(a) and art. 7, GDPR), for the following Marketing Purposes:

send via email newsletters, commercial communications and/or advertising material on products and/or services, different and/or dissimilar from those already purchased, offered by the Owner.

3. Nature of the provision of personal data

The provision of your data for the purposes described in point 2 is necessary. In the absence of the conferment we cannot guarantee your registration on the site, nor can we proceed with the sale of any product on our site.

The provision of data for the purposes described in point 2, lett. b), is instead optional in nature. You can therefore decide not to provide any data or revoke the possibility of processing data previously provided by us. In this case, you will no longer receive our newsletters, while you will continue to receive our services and you will retain the right to register on the site.

4. Processing methods

The processing of your personal data is carried out by means of the operations indicated in art. 4, no. 2), GDPR and precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. The processing of your data will be based on principles of correctness, lawfulness and transparency and may also be carried out through automated methods designed to memorize, manage and transmit them and will take place using suitable tools, as far as is reasonable and state of the art,

5. Data retention period

The Data Controller will process personal data for the duration of the contract and for no more than 2 years from the collection of data for Marketing Purposes. After this retention period, the data will be destroyed or made anonymous.

6. Access to Data

The personal data processed by the Data Controller will not be disclosed, or will not be disclosed to indeterminate subjects, in any possible form, including that of making them available or simple consultation. Instead, they may be communicated to workers who work for the Data Controller and to some external subjects who collaborate with them. In particular, your data may be made accessible to:

employees and collaborators of the Data Controller;
consultants authorized to manage the site and provide the related services (for example: customer services, complaints service, legal office, etc.), in their capacity as internal managers and/or persons in charge of personal data processing and/or system administrators;
Your data may also be communicated, within the strictly necessary limits, to subjects entitled to access it by virtue of the provisions of the law, regulations, community regulations.

7. Data communication

Without your express consent (ex art. 6(1)(b), (c), GDPR), the Data Controller may communicate your data for the purposes indicated to Supervisory Bodies, Judicial Authorities as well as to all other subjects to whom the communication is mandatory by law for the accomplishment of said purposes.

8. Data transfer

The management and storage of personal data will take place on the servers of the Data Controller and/or of third-party companies appointed and duly appointed as Data Processors, located within the European Union, or in compliance with the provisions of articles 45 and following, GDPR. Currently the servers are located in the European Union. The data will not be transferred outside the European Union. In any case, it is understood that, if it becomes necessary to transfer the location of the servers, to Italy and/or the European Union and/or non-EU countries, this transfer will always take place in compliance with the articles 45 and following, GDPR. In that case, however,

9. Navigation data

The computer systems and software procedures used to operate the site may acquire, during their normal activity, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified (for example, parameters relating to the operating system and user's computer environment). These data are used by the Data Controller for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning and are canceled immediately after processing. These data can also be used to ascertain responsibility in the event of hypothetical computer crimes against the Site.

10. Cookies

While using the ZipTv site, cookies are stored on your computer. Cookies consist of small text files that are saved on your computer and provide us with certain information.

They are widely used in order to make websites work or operate more efficiently to improve the user experience, as well as to provide certain information to the site owners.

Our site uses Cookies which remain on your computer for different times. Some expire at the end of each session and some stay longer so that when you return to our Site, you can benefit from a better user experience. Web browsers allow you to exercise some control over Cookies through your browser settings.

Most browsers allow you to block Cookies or block Cookies from certain sites. Browsers can also help you delete Cookies when you close your browser. However, you should bear in mind that this may mean that any opt-outs or preferences you have set on the site will be lost.

Please consult the technical information relating to your browser for instructions. If you choose to disable the Cookies setting or if you refuse to accept a cookie, some parts of the service may not work properly or may be significantly slower.

Technical cookies that are strictly necessary to provide the service do not require your consent. Any non-technical cookies (for example, profiling or third-party analytics cookies) are installed only after you have given your prior consent through the dedicated cookie banner, in line with the Italian Data Protection Authority (Garante) guidelines on cookies and the ePrivacy rules; you can review or withdraw your choices at any time.

11. Rights of the interested party

In your capacity as an interested party, you have the rights referred to in art. 15, GDPR and precisely the rights to:

obtain confirmation of the existence or not of personal data concerning you, 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 processing, including through profiling;
- c) of 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 designated representative (DPO) pursuant to art. 3, paragraph 1, GDPR;
- e) of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as designated representative in the territory of the State, managers or agents;
obtain:
- a) updating, rectification or, when interested, integration of data;
- b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected 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 or disseminated, except in the case in which this fulfillment is proves impossible or involves the use of means manifestly disproportionate to the protected right;
oppose, in whole or in part:
- a) for legitimate reasons, to the processing of your personal data, even if pertinent to the purpose of the collection;
- b) to the processing of personal data concerning you for the purpose of sending advertising material or direct sales or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by email and/or by traditional marketing methods by telephone and/or paper mail. It should be noted that the right of opposition of the interested party, set out in the previous point b), for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the interested party to exercise the right to object, even only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or neither of the two types of communication. Where applicable, you also have the rights pursuant to articles 16 – 21, GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

THE INTERESTED PARTY MAY REVOKE THE CONSENT TO THE PROCESSING OF THE DATA PROVIDED AT ANY TIME. HOWEVER THIS MAY MAKE IT IMPOSSIBLE TO CONTINUE THE CONTRACTUAL RELATIONSHIP BETWEEN THE PARTIES.

12. Methods of exercising rights

You have the right to ask the Data Controller for access to data concerning you, their rectification or cancellation, integration of incomplete data, limitation of treatment; to receive the Data in a structured format, commonly used and readable by an automatic device; to revoke any consent given in relation to the processing of your sensitive data at any time and oppose all or part of the use of the data; to lodge a complaint with the Authority, as well as to exercise the other rights granted to you by the applicable legislation. You can exercise your rights at any time by sending: an email to: [email protected]

13. Minors

In relation to the direct offer of information society services, in Italy the consent of the data subject is valid from the age of 14 (art. 2-quinquies of Legislative Decree no. 196/2003, as amended). Where the person who provides the data is below that age, such processing is lawful only if and to the extent that consent is given or authorized by the holder of parental responsibility.

14. Data Controller and contact

The Data Controller is Marco Migozzi (sole trader – libero professionista), VAT no. IT18375681006, with registered office in Via Pier Alessandro Guglielmi 76d, 00144 Rome – Italy, who can be contacted at the email address: [email protected].

The updated list of data processors and persons in charge of processing is kept at the headquarters of the Data Controller.

15. DATA PROTECTION AUTHORITY (DPA)

The guarantor authority of personal data to which to submit any requests and/or complaints is: Garante Privacy - Piazza Venezia n. 11 - 00187 Rome

www.garanteprivacy.it

Switchboard: (+39) 06.696771

Fax: (+39) 06.69677.3785

E-mail: [email protected]

Certified e-mail: [email protected]

16. Changes to this Information

This Information may be subject to change. It is therefore advisable to check this information regularly and to refer to the most updated version.

17. DEMONSTRATION OF CONSENT

By registering on the ZipTv site and/or using and purchasing the products on the ZipTv site, the user expresses the unequivocal desire to give his consent to the processing of the data supplied by him in compliance with this information.