PRIVACY DISCLOSURE NOTICE
This privacy disclosure notice was compiled pursuant to art. 13 of Legislative Decree 196/2003, i.e. the Italian “Personal Data Protection Code” (hereinafter the “Code”) and is given to users accessing the website owned by Paperlit S.p.A., Via Sassari, 3 – Cagliari – VAT Number 03297020921 (“Paperlit”) on www.apps-builder.com and www.paperlit.com (the “Website”).
Its purpose is to describe terms and conditions for the use and processing of users’ personal data within the Website.
This notice is only intended for the Website above and does not relate to the other websites users may access by clicking on the hyperlinks featured in the Website.
This notice is also designed to inform the Website users of the terms and conditions for Paperlit’s processing of any personal data they should decide to provide.
Users are required to carefully read this notice before providing any personal information and/or completing any e-form available on the Website.
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: email address; first name; last name; Cookies; Usage Data.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Managing contacts and sending messages, Contacting the User, Analytics and Interaction with external social networks and platforms.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Ireland Limited)
Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies; Usage Data.
Mailing list or newsletter (this Application)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.
Personal Data collected: email address; first name; last name.
This type of service allows interaction with social networks or other external platforms directly from the pages of this Application.
The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
AddThis (Oracle Corporation)
AddThis is a service provided by Oracle Corporation, which displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of this Application.
Depending on the configuration, this service can display widgets belonging to third parties such as the managers of social networks where interactions are shared. In this case, also the third parties that provide the widget will be informed of interactions and Usage Data on the pages where this service is installed.
Personal Data collected: Cookies; Usage Data.
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mailchimp (The Rocket Science Group LLC)
Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC.
Personal Data collected: Cookies; email address; first name; last name.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
The means by which the Personal Data of the User is collected and processed.
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User’s device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
1. TYPE OF PROCESSED DATA
Paperlit may collect personal data from users including, e.g., their respective User IDs and passwords, their first and family names, their email addresses, any data or information collected when navigating in the Website, and other personal data voluntarily provided by them during their registration, on ordering the goods and services offered by the Website, or on submitting their email enquiries through the Website.
The Website may be accessed by users with no need to enter any personal data. However, some Website functions (e.g., document download) are only accessible to registered users.
1.1 Navigation Data
IT systems and software procedures for the normal operation of this Website involve the collection of a few data that are implicitly uploaded by the use of Internet communication protocols.
This type of data include, e.g., IP addresses, the domain names of computers used by users accessing the Website, the URI (Uniform Resource Identifier) addresses of any used resources, the time band of server queries, the method used in making a query to the server, the size of files obtained in return, the numeric identifier of the status of a response given by the server and other parameters related to the user’s operating system and computer environment.
As a rule, this type of information is not collected in order to be associated with specific data subjects and may be used by Paperlit for the purpose of collecting anonymous statistical information on the Website use and check its correct operation.
The same data may also be used to assess any liabilities in case of any cyber-crime-related damage or loss caused to the Website.
Cookies are text files sent by the Website to the user’s PC browser. The browser saves information and forwards it on to the Website server when a user accesses the Website the next time.
The Website will use:
(a) session cookies, i.e. cookies that are temporarily stored in the user’s browser ‘cookie’ folder for the full duration of the navigation session;
(b) permanent cookies, i.e. cookies that remain stored in the browser folder for longer periods of time (depending on the duration of each cookie).
The use of session cookies (not stored permanently on the user’s PC and to be deleted when a user logs off the browser) is meant (i) to ease the Website navigation and the use of applications that can be accessed from the Website; and (ii) to collect anonymous statistical information on the Website use and control its correct operation.
The use of permanent cookies is intended to provide users with specific services. For instance, when registration is made with a User ID and a password, users are given the opportunity to choose whether to store this information for it to be used on their next log-ins; this is made by storing a cookie on the user’s PC.
The Website can also be accessed and navigated without cookies. Most browsers accept cookies automatically. Automatic cookie storage can be avoided by selecting the relevant function from the browser. For further information on how to make this selection, kindly refer to the browser’s instructions. Through the browser, users may also delete any cookies stored on their hard disk at any time.
Please note that the choice not to accept cookies from the browser may make navigation in the Website more difficult or limit the use of the applications that are accessible from the Website.
1.3 Personal Data supplied by Users
Paperlit will also collect the personal data entered by the users on filling in registration forms or on requesting goods or services, as well as any of their emailed personal data.
2. PURPOSE OF DATA PROCESSING
The Website users’ personal data will only be processed in accordance with the terms and conditions hereof and in compliance with the applicable provisions of the Privacy Code.
Data processing may consist of one of more of the following operations: collection, logging, organisation, archiving, consultation, processing, change, selection, extraction, comparison, use, interconnection, communication, disclosure, blocking, deletion and/or destruction of the Data.
Depending on the consent given or not given by each user, data will be processed for any of the following purposes:
(a) authorising, enabling and/or customising users’ access to the various Website areas and contents;
(b) provision of the users’ requested services;
(c) Newsletter mailing;
(d) mailing of communications and informative/promotional materials from Paperlit and third parties;
(e) observance of the obligations required by any applicable laws and regulations transposing EU legislation, or of the instructions received from public authorities or regulatory bodies.
3. TERMS OF PROCESSING
Data will be processed in accordance with the principles of confidentiality, necessity, relevance, lawfulness and transparency as required by the Privacy Code.
Data will mainly be processed by means of electronic media, in compliance with the applicable legislation. Suitable security measures shall be observed to prevent any loss, illicit use, misuse or unauthorised access to the data.
Data will be archived for an amount of time not exceeding that strictly required for the purposes for which they were collected or subsequently processed.
4. SCOPE OF DATA COMMUNICATION AND DISSEMINATION
For the purposes under section 2 above and insofar as strictly necessary, data may be communicated to Paperlit’s employees and hired contractors for and within the limits of their assigned functions and responsibilities.
In addition, data may be communicated to persons performing activities that are related to and instrumental in Paperlit’s own activities, and whose service may be requested by Paperlit following their appointment as data processors for the performance of such activities insofar as strictly necessary and in accordance with the purposes under section 2 above. These persons include, without limitation, those providing support to users and IT operators. Data shall not be subject to dissemination.
5. DATA CONTROLLER
The data controller is Paperlit S.p.A., with registered office in Cagliari, Via Sassari, 3 – VAT Number 03297020921. The Data processor is Paperlit Paperlit S.p.A.
6. USERS’ RIGHTS PROVIDED BY ART. 7 OF THE PERSONAL DATA PROTECTION CODE
As data subject, you will be entitled to exercise the rights provided by art 7 of the Personal Data Protection Code. Such rights may be exercised in accordance with the terms of art. 9 of the said Code. In particular, please be informed that you may contact the data controller at any time to:
(a) enquire about the personal data that are in its possession, including those that are yet to be logged, and further obtain the communication of such data in intelligible form;
(b) obtain information on (i) the source of such data; (ii) the purposes and methods of their processing; (iii) the logic applied to their processing if the latter is carried out with the help of electronic means; (iv) the identification data concerning the data controller and each of the appointed data processors; and (v) the entities or categories of entity to whom or which data may be communicated, or who or which may get to know said data in their capacity as data processors or persons in charge of the processing;
(c) obtain: (i) the updating, the rectification or, where interested therein, the integration of the data; and (ii) the erasure, the conversion into an anonymous form or blocking of any data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; (iii) a formal confirmation that the operations under items (i) and (ii) above and their relevant contents have been notified to the entities to which or whom data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;
(d) object, in whole or in part: (i) on legitimate grounds, to the processing of his personal data, even though they are relevant to the purpose of the collection; and (ii) to the processing of his personal data, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
Users are entitled to exercise their rights under art. 7 of the Personal Data Protection Code, and receive the full updated list of data processors, by sending a letter to: Paperlit S.p.A., Via Sassari, 3 – Cagliari – VAT Number 03297020921, or an email to: email@example.com