To obtain information about your personal data collected, the purposes and the parties with whom the data is shared, please contact the Data Controller.

Data Controller

For more information about the Data Controller, please contact the following email address:

Data Controller’s Email Address: flavio.cristiano@22gmbh.ch

Types of Data Collected

The Data Controller does not provide a list of the types of Personal Data collected.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed before the Data is collected.

Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically during the use of this Application.

Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to provide it, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.

Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller.

The possible use of Cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application has the purpose of providing the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application.

Methods and Location of Data Processing

Methods of processing

The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data.

Processing is carried out using IT and/or telematics tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) appointed, if necessary, as Data Processors by the Data Controller may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.

Location

The Data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, please contact the Data Controller.

The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data.

Retention period

Unless otherwise indicated in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be stored for a longer period due to any legal obligations or based on the Users’ consent.

Cookie Policy

This Application uses Tracking Tools. To learn more, Users can consult the Cookie Policy.

Further Information for Users

Legal basis of processing

The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

• the User has given consent for one or more specific purposes;
• processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;
• processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
• processing is necessary for the performance of a task carried out in the public interest or for the exercise of official authority vested in the Data Controller;
• processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

In any case, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on the law, provided for by a contract or necessary to conclude a contract.

Further information on retention time

Unless otherwise indicated in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be stored for a longer period due to any legal obligations or based on the Users’ consent.

Therefore:

• Personal Data collected for purposes related to the execution of a contract between the Data Controller and the User will be retained until the execution of such contract is completed.
• Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until the satisfaction of such interest. The User can obtain further information on the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When the processing is based on the User’s consent, the Data Controller may retain Personal Data longer until such consent is revoked. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period to fulfill a legal obligation or by order of an authority.

At the end of the retention period, Personal Data will be deleted. Therefore, at the expiration of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

User Rights under the General Data Protection Regulation (GDPR)

Users may exercise certain rights with reference to the Data processed by the Data Controller. In particular, within the limits established by law, the User has the right to:

• withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously expressed.
• object to the processing of their Data. The User can object to the processing of their Data when it occurs under a legal basis other than consent.
• access their Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
• verify and request rectification. The User can verify the accuracy of their Data and request its update or correction.
• obtain the limitation of processing. The User can request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose other than their storage.
• obtain the cancellation or removal of their Personal Data. The User can request the cancellation of their Data by the Data Controller.
• receive their Data or have it transferred to another data controller. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to obtain their transfer without obstacles to another data controller.
• lodge a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Users have the right to obtain information on the legal basis for the transfer of Data abroad, including to any international organization governed by international law or constituted by two or more countries, such as the UN, as well as on the security measures adopted by the Data Controller to protect their Data.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that, if their Data is processed for direct marketing purposes, they can object to the processing at any time, free of charge and without providing any reason. If Users object to the processing for direct marketing purposes, Personal Data is no longer processed for these purposes. To find out if the Data Controller processes Data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise rights

Any requests to exercise the User’s rights can be addressed to the Data Controller through the contact details provided in this document. The request is free of charge and the Data Controller will respond as soon as possible, in any case within one month, providing the User with all the information required by law. Any rectifications, cancellations or limitations of processing will be communicated by the Data Controller to each of the recipients, if any, to whom the Personal Data have been transmitted, unless this proves impossible or involves a disproportionate effort. The Data Controller will inform the User of these recipients if requested.

Further Information on Processing

Defense in court

The User’s Personal Data may be used by the Data Controller in court or in the preparatory stages for its possible establishment for the defense against abuses in the use of this Application or related Services by the User.

The User declares to be aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific information

At the User’s request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For needs related to operation and maintenance, this Application and any third-party services used by it may collect system logs, i.e. files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Application and, if technically and legally feasible, by sending a notification to Users through one of the contact details in its possession. Please therefore consult this page frequently, referring to the date of the last modification indicated at the bottom.

If the changes concern processing whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.

Definitions and Legal References

Personal Data (or Data)

Personal data is any information that, directly or indirectly, including in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data

These are the information collected automatically through this Application (also from third-party applications integrated into this Application), including: IP addresses or domain names of computers used by the User who connects with this Application, addresses in URI notation (Uniform Resource Identifier), the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.

User

The individual who uses this Application who, unless otherwise specified, coincides with the Interested Party.

Interested Party

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public administration and any other entity that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Controller)

The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This Application

The hardware or software tool through which Users’ Personal Data are collected and processed.

Service

The Service provided by this Application as defined in the relevant terms (if any) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is intended to extend to all current member states of the European Union and the European Economic Area.

Legal references

Unless otherwise specified, this privacy policy concerns exclusively this Application.