Unless specified otherwise, this policy also applies as the policy – pursuant to Article 13 of Italian Legislative Decree No. 196/2003 (hereinafter, the “Code”) and Article 13 of Regulation (EU) No. 2016/679 (hereinafter, the “GDPR”) – provided for anyone who interacts with the Website (hereinafter, “User”).
Detailed policies on the processing of personal data are shown, when necessary, on the pages relating to the individual services offered through the Website. These policies are aimed at establishing the limits and methods of processing personal data for each service, based on which, users may freely express their consent, when necessary, and potentially authorise the collection of data and its subsequent processing.
DATA CONTROLLER AND DATA PROCESSOR
The Data Controller is Mr ROBERTO CARELLO, as the owner of the sole proprietorship of the same name (hereinafter, the “Company”):
Tax Code CRLRRT53B06L219J
VAT NO. 03098670015
Residence and registered office at Via Piave No. 8, 10080 Bosconero (Turin), Italy
Telephone +39 0119886840
The Data Protection Officer, as appointed by the Data Controller, may be contacted by:
- ordinary mail at the address, Via Piave No. 8, 10080 Bosconero (Turin) – Italy, FAO the Data Protection Officer
- by phone on the number +39 0119886840
- or by e-mail at the address email@example.com
Data processing location and methods
The data processing connected to consultation of the Website takes place at the offices of the aforementioned sole proprietorship. Personal data is processed with electronic or automated tools (for example, by using electronic media and procedures) and/or manually (for example, on paper) for the time strictly necessary to achieve the purposes for which the data was collected and, in any case, in accordance with relevant existing legislation.
TYPES OF DATA COLLECTED
The type of data processed and the purposes of the processing
The IT systems and software procedures required to run this website acquire certain personal data which needs to be sent for the use of Internet communication protocols. This information alone does not identify Users. However, by its very nature, it might be possible to identify Users when it is combined with data held by third parties.
For example, this category of data includes IP addresses or domain names of computers used by the User to visit the website, as well as other parameters relating to the operating system and computer of the user. This data forms the “log book” and is only used by the Company to extract anonymous statistical information on how the Website is used and to ensure that it is running properly.
Data provided voluntarily by the user
As a customer/user/visitor, by visiting this website, you may provide the Company with your personal data to access certain services or to send requests by e-mail, as well as to subscribe to the newsletter. This shall involve the Company acquiring your IP address and/or your other personal data, which shall only be processed by the Company to reply to your request or to provide the service. The personal data provided may only be disclosed to third parties if it is necessary to fulfil your requests.
What are cookies
Cookies are text files, containing small quantities of information, which are stored on the computer or mobile device of a user who visits a website, or other similar technologies. Each time they subsequently visit the website, the cookies are sent back to their original website (first-party cookies) or to another website that identifies them (third-party cookies). Cookies are useful because they allow websites to identify users’ devices. Cookies cannot recover any other data from your hard drive, or spread computer viruses or acquire e-mail addresses.
Cookies allow the Website to “remember” users for the duration of the visit (session cookies) or for several visits (permanent cookies). Cookies can perform various functions. Some are essential and allow you to browse effectively, set and store your preferences and, more generally speaking, can improve and optimise browsing on a website.
How cookies are used
Most cookies are session cookies, i.e. they are used to allow the Website to run properly and are automatically deleted when you close the browser. However, other types of cookies are saved on your computer hard drive and can only be read by the server which previously archived them.
Information on managing and disabling cookies
The User shall always have the option of accepting all cookies, to be informed about their use or to disable them by independently editing the settings on the browser used (the “Browser”). Please note that if you decide to disable or remove cookies from your browser, it might mean that you cannot access certain parts of the website and it might make browsing less efficient.
There is a list below of the most common Browsers for managing cookies and we advise you to visit the dedicated page through their links, as each Browser has different procedures for managing cookies:
- Internet Explorer
- Google Chrome
Users may decide whether or not to accept cookies by using their browser settings.
Please note: by fully or partially disabling technical cookies, you might not be able to use website features reserved for registered users. On the contrary, public content can also be used when cookies are fully disabled.
Disabling “third-party” cookies will not spoil your browsing experience in any way.
Your settings can be specifically configured for different websites and web apps, based on the instructions given by the relevant providers at the links listed below:
- Chrome: https://support.google.com/chrome/answer/95647?hl=it
- Firefox: https://support.mozilla.org/it/kb/Gestione%20dei%20cookie
- Internet Explorer: https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies
- Opera: https://help.opera.com/en/presto/browser-behavior/
- Safari: http://support.apple.com/kb/HT1677?viewlocale=it_IT
Type of cookies
Technical cookies are divided into browsing cookies and session cookies.
They are strictly necessary to ensure normal browsing and use of the website www.taptrap.com. These cookies may vary depending on how long they remain on the user’s device. In fact, while session cookies are automatically deleted at the end of each browsing session, browsing cookies have a longer life.
Technical cookies are essential and may also be used without the data subject’s consent. For example, these cookies include:
- Cookies with data entered by the user (session identifiers), which last for one session, or persistent cookies limited to a few hours in certain cases
- Cookies for authentication, which are used for authenticated services and last for one session
- security cookies focused on users, which are used to identify authentication infringement and have a limited duration
- Session cookies for multimedia players, such as cookies for “flash” players, which last for one session
- Session cookies for load balancing, which last for one session
- Persistent cookies for customising the user interface, which last for one session (or slightly longer).
Analytical or analytics cookies
Analytics cookies are used to statistically analyse hits/visits to the website and only serve statistical purposes and not profiling or marketing purposes. They collect aggregate information and cannot identify individual users. For this type of cookie, www.taptrap.com would like to point out that Users always have the option of disabling these cookies (opting out) by following these instructions:
“Open the browser, select the Settings Menu, click on Internet Options, open the privacy tab and choose to what extent you want to block cookies. If you wish to delete pre-saved cookies, just open the Security Tab and delete your history by ticking the box delete cookies”.
Own profiling cookies
The website www.taptrap.com does not use this type of cookie.
Other than cookies directly from www.taptrap.com (known as “first-party or publisher cookies”), we would like to inform you that “analytical and profiling third-party cookies” are installed on the website www.taptrap.com. For these cookies, notwithstanding the option of disabling them through your browser settings as previously indicated, links are provided below to the extended policy of the third parties that install these cookies.
Analytical cookies and performance cookies
These cookies are used to collect information on how the website is used. The Controller uses this information for statistical analysis, to improve the website and to simplify its use, and to check that it is running properly.
These cookies collect anonymous information on the activities of Users at the Website and on how they arrived at the Website and the pages visited. Cookies in this category are sent by the Website itself or by third-party domains.
The Website includes components sent by Google Analytics, a web traffic analysis service provided by Google, Inc. (“Google”). This also involves third-party cookies collected and managed anonymously to monitor and improve the host website’s performance (performance cookies). Processing location: USA. For more information, please click on the following link: https://www.google.it/policies/privacy/partners/
Users may selectively disable Google Analytics by installing the opt-out add-on provided by Google onto their browsers. To disable Google Analytics, please click on the following link: https://tools.google.com/dlpage/gaoptout
SOCIAL WIDGETS AND PLUG-INS
Certain widgets and plug-ins provided by social media networks may use their own cookies to facilitate interaction with the relevant website.
There is a list below of the third-party cookies installed on the Website and any potential social widgets and buttons. For each one, there is the link to the relevant policy on the personal data processing carried out and on how to potentially disable the cookies used.
For third-party cookies, the Controller is only required to include the link to the third party’s website in this policy. Conversely, this third party is responsible for the policy obligation and indicating how any consent is obtained and/or cookies are disabled.
- Google Analytics (Google Inc.). Please see the details mentioned in the previous paragraph.
- Google AdSense (Google). Google AdSense is an advertising service provided by Google Inc. that uses the “DoubleClick” cookie, which tracks the use of this app and the user’s behaviour relating to the advertisements, products and services offered. Users may disable this cookie (please see the following Opt-Out link). Personal data collected: cookies and usage data. Processing location: USA – Opt Out
Content on external platforms
These services help display content hosted on external platforms directly embedded on the pages of the website and to potentially interact with it. If this type of service is installed, the third-party platform may collect traffic data relating to the pages where its service is installed.
MANAGING ADDRESSES AND SENDING EMAILS
The Website uses services to manage a database of email contacts, or any other type, which are used to communicate with users. These services allow the collection of data on the time and date when messages are viewed by users, as well as information on users’ interaction with them (for example, on the clicks made to links included in the messages).
The Website uses third-party services for the statistical monitoring of hits and other metrics relating to visitors of the website and their behaviour at the website.
- Google Analytics (Google Inc.). This web data analysis service uses personal data to track and analyse use of the website, compiling reports which are shared with other services developed by Google. Google Analytics may use personal data to customise the advertisements on its advertising network. Data collected: cookies and usage data. Processing location: USA – Google Analytics Policy – Opt-Out Option
Optional data provision
Apart from the specifications on browsing data, the User is free to provide the personal data requested from time to time by www.taptrap.com; however, if this data is not provided, it might not be possible to provide the services requested.
Specific security measures are implemented to prevent data loss, unlawful or inappropriate use and unauthorised access.
Data subject rights
Data subjects have the right to obtain confirmation at any time on the existence, or otherwise, of their data and to know its contents and origin, to verify its accuracy or to request that it is supplemented, updated or corrected, pursuant to Article 7 of Italian Legislative Decree No. 196/2003, as well as Articles 15 to 22 of EU Regulation 679/2016 on personal data protection.
In particular, data subjects have specific rights:
Right to access your personal data
Users have the right to obtain confirmation from the Data Controller of the existence or otherwise of their personal data, even if not yet recorded, and that this data must be made available in an intelligible form. Users also have the right to know the origin of the data, as well as how and why this data is processed.
Right to correct your personal data
Users have the right to have their data updated, corrected or, if they are interested, supplemented. They also have the right to object, wholly or in part, on legitimate grounds, to the processing of their personal data, even if relevant to the purpose for which it was collected, as well as the right to restrict the processing and the right to object to an automated decision-making process.
Right to data portability
Users have the right to the portability of their personal data from 25 May 2018.
Right to delete data
www.taptrap.com only stores Users’ data for the time required to provide the service or for legal obligations. If Users think that the Company is storing their data for longer than is necessary, they can have it deleted.
Users may exercise their rights by sending a written request to Mr Roberto CARELLO, to the postal address of the registered office in Bosconero (Turin), Via Piave No. 8 – Italy, or to the certified email address firstname.lastname@example.org.
Data processing methods
The data collected is processed using IT and/or online tools, including through its inclusion and organisation in databases in accordance with the provisions of the Code and the GDPR on security measures. Appropriate security measures are implemented to prevent data loss, unlawful or inappropriate use, disclosure, alteration and unauthorised access.
In addition to the data controller, external individuals may have access to certain data (for example, hosting companies, IT consultants, communication agencies, technical service providers or mail couriers) as well as people involved in organising and managing the website (administrative and legal staff or marketing directors). In any case, personal data shall not be circulated.
If necessary, these individuals may be appointed as Data Processors. You may ask the Data Controller for the updated list of Data Processors by following the instructions given above.
Data processing location
Data is processed at the Data Controller’s registered office and operational office. For further information, please contact the Data Controller by following the instructions given in the previous paragraphs.
Data processing times
Data is processed for the time required to perform the services requested by the User or for the purposes described in this policy. Users have the right to request the suspension of the data processing or the deletion of their data at any time.
Purposes and legal grounds for the processing
The personal data collected through the Website shall be processed to:
- handle requests for information sent by the User
- handle requests for documents sent by the User
The data processing does not require the User’s consent for these purposes as the processing is required to fulfil the data subject’s specific requests pursuant to Article 24, paragraph 1, letter b of the Code and Article 6, paragraph 1, letter b of the GDPR.
- provide the services offered by www.taptrap.com, such as subscribing to the newsletter, statistics, contacting the user, and managing email addresses.
The types of data used for each purpose are specified under the relevant sections of this policy.
Right to access, deletion, restriction and portability
Data subjects are entitled to the rights under Article 7 of the Code and Articles 15 – 20 of the GDPR. For example, all data subjects may:
- obtain confirmation whether or not their personal data is currently being processed;
- if their data is currently being processed, they may gain access to the personal data and information on the processing and request a copy of the personal data;
- correct any inaccurate personal data and supplement any incomplete personal data;
- if one of the conditions provided for by Article 17 of the GDPR has been met, they may have their personal data deleted;
- have the processing of their data restricted, in cases provided for by Article 18 of the GDPR;
- obtain their personal data in a structured and commonly used format which is legible on an electronic device, and request its transmission to another controller, if technically feasible.
Right to object to processing
All data subjects have the right to object, at any time, to the processing of their personal data carried out to pursue the legitimate interests of the Data Controller. In this case, their personal data shall no longer be processed, provided that there are no legitimate grounds to proceed with the processing which prevail over the data subject’s interests, rights and freedoms or to ascertain, exercise or defend a right before a court of law.
Right to file a complaint to the Authority
Moreover, all data subjects may file a complaint to the Italian Data Protection Authority if they believe that their rights pursuant to the Code and the GDPR have been infringed, by following the instructions indicated on the Italian Supervisory Authority’s website (Garante Privacy), which can be found at the following address: www.garanteprivacy.it.
Last update: 4 August 2018.