1 Owner and contact details of the Owner
This page describes the characteristics of the processing of personal data of visitors and users of the website https://edeagroup.cloud/demo/pokescuse.cy (the “Site”), as well as those who decide to send their personal data to Pokescuse through the Site itself (collectively, the “Users”).
Zuclem S.r.l. (hereinafter, “POKESCUSE”) is the data controller.
If you have any doubts about the characteristics of the processing of Data, you can always contact us:
at the e-mail address info@edeagroup.cloud
Please note that the information you find on this page does not apply to third party sites, apps and content in general, even if accessible from the Site. In such cases, the data protection provisions of such third parties may apply, which may be different from these and which we advise you to consult before disclosing any data.
Pokescuse may amend this Policy to reflect future expansions or changes to the Site or the services offered. In the event of substantial changes, Pokescuse will post a notice on the Site and/or send an e-mail notification to Users who have registered, in order to point out the changes and collect a possible request to exercise the rights recognized by the legislation on the protection of personal data.
2 Methods of data collection and types of data processed Navigation data automatically collected by the Site: access and navigation data
Whenever Users access the Site, the computer systems and software procedures responsible for the operation of the Site acquire, in the course of their normal operation, access and navigation data (e.g.: provider IP address, information on the browser used by the User, pages visited, date, time and duration of each visit, as well as other parameters relating to the User’s operating system and computer environment – the “Browsing Data”).
The information is collected automatically by the Site and does not require any action on the part of the User; it does not lead to the identification of visitors as it simply allows for a better understanding of the visits received, how often the Site is visited, and which parts of the Site are of greatest interest.
Data disclosed by Users
Some areas of the Site allow Users to communicate specific personal data: first name, last name, e-mail, profession, telephone, address (the “Personal Data”). This data is processed exclusively to follow up on the request for information about Pokescuse and to evaluate possible forms of collaboration.
The provision of the Master Data is done on a voluntary basis. In addition, the Master Data are collected if and to the extent that they are disclosed by the Users themselves.
Users are requested not to communicate personal data of third parties to POKESCUSE, unless it is necessary (for example, because the User does not have his/her own e-mail address and does not have other direct contact information): in this case, we remind you that it is the User’s responsibility to fulfill the legal requirements regarding the protection of personal data and, in particular, to inform third parties of the communication and collect their consent, if applicable.
Data provided by Users: e-mail for the Newsletter
Users have the opportunity to provide POKESCUSE with their e-mail by filling out a special form to subscribe to the newsletter service (“Newsletter Data”), aimed at allowing the user to benefit from this service and, therefore, to receive updates on POKESCUSE’s activities by e-mail.
The communication of Newsletter Data is necessary: any refusal will result in POKESCUSE being unable to send the newsletter to the user.
CV Data
Users have the opportunity to provide POKESCUSE with their contact data and curriculum vitae (CV Data), aimed at enabling Pokescuse to assess the possibility of employment or collaboration. Purpose of the processing and its legal basis
The Browsing Data will be used: (i) in order to monitor the proper functioning of the Site, (ii) in an anonymous and aggregate form, for statistical purposes related to understanding how the Site is used by Users, to improve the ease of access and increase its attractiveness, and (iii) to detect any technical problems as soon as possible.
Said processing finds its legal basis in Pokescuse’s legitimate interest in the improvement of its products and digital services, and is compatible with the position of the data subjects in that (a) monitoring the operation of the Site and the statistical data related to its use does not involve identification and the outcomes of such activities are not shared with parties other than POKESCUSE, and (b) POKESCUSE’s interest reasonably appears to be also of the data subjects, who will thus be able to enjoy an increasingly high-performing and optimized Site.
The Master Data will be used for the purpose of evaluating possible forms of collaboration or following up on requests for information.
This processing has its legal basis in the execution of pre-contractual measures taken at your request ex art. 6 paragraph 1 letter b) of the GDPR.
CV Data will be used in order to examine your request for collaboration with “POKESCUSE”, Such processing finds its legal basis in the execution of pre-contractual measures taken at your request ex art. 6 paragraph 1 lett. b) of the GDPR
Newsletter Data will be used in order to send the User informative e-mails related to POKESCUSE activities and the Event.
Such processing finds its legal basis in the need to execute a specific request of the User.
3 Recipients of the communication of the Data
Browsing Data, Master Data, CV Data and Newsletter Data (jointly, the “Data”) will be communicated to and may be known (i) by employees and collaborators of POKESCUSE, duly instructed and designated for processing; and (ii) by third parties who provide services ancillary or instrumental to the activities of POKESCUSE, in connection with the development, delivery and operational management of the Site and the transmission of newsletter services,with whom POKESCUSE has entered into an agreement governing mutual responsibilities, in compliance with Article 28 of the GDPR.
This communication, which constitutes processing of personal data, is based on the need to execute pre-contractual and contractual measures at the request of the User, as well as to fulfill related and related legal obligations.
4 Place of processing and transfer abroad of Data
The processing of the User’s Data will take place at the aforementioned POKESCUSE location and the Data will be stored at servers and/or physical archives located within the European Union.
However, the use of the Site also entails – for reasons of a technical nature related to the data centers on which personal data are also stored, owned by the aforementioned company Register.it – the transfer of Users’ Data abroad.
Transfers of Data abroad will take place only: (i) after the adoption of appropriate safeguards such as, by way of example, the signing of the standard clauses approved by the European Commission, or (ii) upon the occurrence of an exception to the prohibition of transfers outside the European Union and, therefore, again by way of example, upon collection of the User’s explicit and informed consent, or again only to the extent that it is necessary for the performance of a contract concluded between the User and POKESCUSE, or between POKESCUSE and a third party for the benefit of the User, or for the performance of pre-contractual measures taken at the User’s request.
5 Modalities of processing, security measures and retention times of the Data
The Data will be processed with and without the aid of electronic, computerized or automated tools, which ensure the protection of the Data by design and by default, adequate to guarantee its security and confidentiality, and with logics strictly related to the purposes themselves. In addition, specific and adequate logical, legal organizational and technical security measures have been taken by POKESCUSE to prevent the loss of Data, illicit or unauthorized use of the same and unauthorized access.
The Data will be kept in a form that allows identification for a period of time not exceeding that necessary to achieve the purposes of the processing and, in particular:
Navigational Data will not persist for longer than [seven days] and will be deleted immediately after their aggregation (except for any need to ascertain crimes by the competent Judicial Authority);
Master Data and CV Data, are retained for up to 12 months after their collection;
Newsletter Data, used to transmit information and updates to Users, will be kept and processed for up to 24 months after subscription. With one month notice, we will ask the User if he/she wishes to continue receiving the newsletter: in case of denial, the Data will be deleted; in case of assent, it will be kept and processed for the additional period of 24 months.
The Data will be retained for longer periods of time where necessary to fulfill statutory and/or legal obligations, as well as to ensure the judicial protection of POKESCUSE’s rights, subject to the ordinary statute of limitations.
6 User Rights.
Users, as data subjects (i.e., individuals to whom the Data refer), have rights conferred by the GDPR.
In particular, Users have the right to request and obtain, at any time, access to their personal data, information about the processing performed, rectification and/or updating of personal data, deletion and restriction of processing. They also have the right to object to the processing and to request data portability (i.e., to receive personal data in a commonly used, machine-readable, structured format). In addition, where applicable, data subjects always have the right to withdraw their consent at any time and to appeal to the Judicial Authority or complain to a supervisory authority (in Italy: the Garante per la Protezione dei Dati Personali). Finally, the full list of recipients of personal data may also be requested at any time.
These rights may be exercised by writing:
to the e-mail address info@pokescuse.it
For other information or clarifications on the mentioned rights, you can contact us at the same contact details.
Information updated on 03 May 2021