This Application collects some Personal Data from its Users.
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EASY LEAD DOO (OIB HR68702421054), based in ROVINJ – ROVIGNO D’ISTRIA in TRG ULIKA – PIAZZA DEGLI ULIVI 2
Owner’s email address: email@example.com
APPOINTMENT OF THE EXTERNAL DATA PROCESSING MANAGER pursuant to art. 28 SS. of the REG. EU 679/2016 (GDPR)
EASY LEAD DOO (OIB HR68702421054), based in ROVINJ – ROVIGNO D’ISTRIA in TRG ULIKA – PIAZZA DEGLI ULIVI 2 – firstname.lastname@example.org,
EASY LEAD DOO processes the data of its employees, suppliers, customers and consultants for the purposes of its business activity;
EASY LEAD also generates, purchases and sells so-called leads as an integral part of its business; some of these data have been communicated to you so that you can fulfill existing contracts with us or legal obligations;
These data must also be processed by you in accordance with the REG. EU 679/2016 (GDPR);
ALL THIS GIVEN
1) We appoint you as External Managers of the Processing of the Personal Data that we have transmitted to you.
2) Such data must be processed in accordance with the provisions of the aforementioned EU Reg. 679/2016 (GDPR) and any other source of law on the matter.
3) This assignment is effective for the duration of the existing relationship with us and will automatically cease upon termination of the relationship with us.
4) The data communicated to you must be processed solely and exclusively for the purposes for which they were communicated to you and must be destroyed upon termination of the relationship, without prejudice to the obligation to conserve documents relating to the management of the company for the period required by law.
5) As external managers, when processing data you must comply with the provisions of the art. 28 of the GDPR.
In particular, the Manager is required, to the extent of his/her competence, to implement the security measures required by current legislation regarding the processing of personal data, providing assistance to the Data Controller in ensuring compliance with the same and suggesting suitable measures to ensure that the data processing is lawful and compliant with current laws; the Data Controller, taking into account the state of the art and implementation costs, as well as the nature, object, context and purposes of the processing, as well as the risk of varying probability and severity for the rights and freedoms of natural persons , must also ensure that the security measures prepared and adopted are adequate to guarantee a level of security appropriate to the risk, in particular the destruction, loss, modification,
In any case, the Data Controller will identify the natural persons authorized to process the data and provide them with adequate written instructions regarding the methods of processing.
6) In case of violations of the law in the processing of data, you are obliged to inform us immediately.
7) This contract does not imply any right for you to a specific compensation and/or indemnity and/or reimbursement deriving from the same in addition to those already agreed.
Types of Data collected
Among the Personal Data collected by this Application, independently or through third parties, there are: Usage data; Tracking Tool; e-mail; first name; surname; telephone number; physical address; business name; POSTAL CODE; city; answers to questions; click; keypress events; motion sensor events; mouse movements; position relative to scrolling; touch events; Data communicated during use of the service.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Application.
Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates some 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 Owner.
The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees that he or she has the right to communicate or disseminate them, freeing the Owner from any liability towards third parties.
Method and place of processing of the collected data
The Data Controller adopts appropriate security measures aimed at preventing unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Owner, 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) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.
Legal basis of the processing
The Owner 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; Note: in some jurisdictions the Owner may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, until the User objects (“opt-out”) to this treatment. However, this is not applicable if the processing of Personal Data is regulated by European legislation on the protection of Personal Data;
- the processing is necessary for the execution of a contract with the User and/or the execution of pre-contractual measures;
- the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
- the processing is necessary for the execution of a task of public interest or for the exercise of public powers vested in the Data Controller;
- the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.
However, it is always possible to request 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.
The Data is processed at the Owner’s operational offices and in any other place where the parties involved in the processing are located. For further information, contact the Owner.
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.
The User has the right to obtain information regarding the legal basis of the transfer of Data outside the European Union or to an international organization governed by public international law or constituted by two or more countries, such as for example the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.
The User can verify whether one of the transfers just described takes place by examining the section of this document relating to details on the processing of Personal Data or request information from the Data Controller by contacting him at the details indicated at the beginning.
The Data is processed and stored for the time required by the purposes for which it was collected.
- Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
- Personal Data collected for purposes attributable to the legitimate interest of the Owner will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.
When the processing is based on the User’s consent, the Owner may retain the Personal Data for longer until such consent is revoked. Furthermore, the Owner may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period, the Personal Data will be deleted. Therefore, upon expiry of this deadline the right of access, cancellation, rectification and the right to data portability can no longer be exercised.
Purpose of the Processing of Collected Data
The User’s Data is collected to allow the Owner to provide the Service, fulfill legal obligations, respond to requests or enforcement actions, protect their rights and interests (or those of Users or third parties), identify any malicious activities or fraudulent, as well as for the following purposes: Management of tags, Display of content from external platforms, Remarketing and behavioral targeting, Advertising, Statistics, Management of contacts and sending messages, Management of landing pages and invitation pages, Contacting the User, SPAM protection, User database management, Interaction with live chat platforms and Interaction with social networks and external platforms.
To obtain detailed information on the purposes of the processing and the Personal Data processed for each purpose, the User can refer to the “Details on the processing of Personal Data” section.
Details on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Contact the user
Contact form (this Application)
By filling in the contact form with their data, the User consents to their use to respond to requests for information, quotes, or any other nature indicated by the header of the form.
Personal Data processed: Postal code; city; surname; e-mail; physical address; first name; telephone number; business name.
This type of service is functional to the centralized management of tags or scripts used on this Application.
The use of these services involves the flow of User Data through them and, if applicable, their retention.
Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Usage data.
This type of service analyzes the traffic of this Application, potentially containing Users’ Personal Data, in order to filter it from parts of traffic, messages and content recognized as SPAM.
Google reCAPTCHA (Google Ireland Limited)
Personal Data processed: clicks; Usage data; keypress events; motion sensor events; touch events; mouse movements; position relative to scrolling; answers to questions; Tracking Tool.
Remarketing e behavioral targeting
This type of service allows this Application and its partners to communicate, optimize and serve advertisements based on the past use of this Application by the User.
This activity is facilitated by tracking Usage Data and the use of Tracking Tools to collect information which is then transferred to partners who manage remarketing and behavioral targeting activities.
Some services offer a remarketing option based on email lists.
In addition to the opt-out features offered by the services listed below, the User can opt-out by visiting the Network Advertising Initiative opt-out page .
Users may also choose not to participate in certain advertising features through corresponding device setup options, such as mobile device advertising setup options or general advertising setup .
Remarketing Google Ads (Google Ireland Limited)
Remarketing Google Ads is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.
For an understanding of Google’s use of Data, please review Google’s partner policies .
Users can opt out of using Google Tracking Tools for ad personalization by visiting Google’s Ad Settings .
Personal Data processed: Usage data; Tracking Tools.
Remarketing con Google Analytics (Google Ireland Limited)
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the tracking activity carried out by Google Analytics and its Tracking Tools with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Usage data; Tracking Tools.
The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to keep track of the User’s behavior.
Google Ads Conversion Tracking (Google Ireland Limited)
Google Ads conversion tracking is a statistics service provided by Google Ireland Limited that connects data from the Google Ads advertising network with actions performed within this Application.
Personal Data processed: Usage data; Tracking Tools.
Google Analytics 4 (Google Ireland Limited)
Google Analytics is a statistics service provided by Google Ireland Limited (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google.
Google may use Personal Data to contextualize and personalize the ads of its advertising network.
In Google Analytics 4, IP addresses are used at the time of collection and then deleted before the data is recorded in any data center or server. To learn more, you can consult Google’s official documentation .
Personal Data processed: Usage data.
Viewing content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service could still collect data on web traffic relating to the pages where the service is installed, even when users do not use it.
Google Fonts (Google Ireland Limited)
Google Fonts is a character style visualization service managed by Google Ireland Limited which allows this Application to integrate such content within its pages.
Personal Data processed: Usage data; Tracking Tool.
Learn how to opt out of interest-based advertising
Users can exercise certain rights with reference to the Data processed by the Owner.
In particular, within the limits established by law, the User has the right to:
- revoke your consent at any time. The User may revoke the previously expressed consent to the processing of their Personal Data.
- object to the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are set out in the section below.
- access their Data. The User has the right to obtain information on the Data processed by the Owner, on certain aspects of the processing and to receive a copy of the Data processed.
- verify and request rectification. The User can verify the correctness of their Data and request its updating or correction.
- obtain the limitation of treatment. The User may request the limitation of the processing of their Data. In this case the Owner will not process the Data for any purpose other than their conservation.
- obtain the cancellation or removal of your Personal Data. The User may request the deletion of their Data by the Owner.
- receive your Data or have it transferred to another owner. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to obtain its transfer without obstacles to another owner.
- lodge a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.
Details on the right to object
When Personal Data is processed in the public interest, in the exercise of public powers vested in the Owner or to pursue a legitimate interest of the Owner, 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 processing for direct marketing purposes, the Personal Data will no longer be processed for these purposes. To find out whether the Owner processes Data for direct marketing purposes, Users can refer to the respective sections of this document.
How to exercise your rights
To exercise their rights, Users can direct a request to the Owner’s contact details indicated in this document. The request can be filed free of charge and the Owner will respond as quickly 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 has been transmitted, unless this proves impossible or involves a disproportionate effort. The Owner communicates these recipients to the User if he requests it.
Learn more about the treatment
Defense in court
The User’s Personal Data may be used by the Owner in court or in the preparatory stages of its possible establishment for the defense against abuse in the use of this Application or related Services by the User.
The User declares to be aware that the Owner may be obliged to reveal the Data by order of public authorities.
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 which 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.
Response to “Do Not Track” requests
This Application does not support “Do Not Track” requests.
To find out whether any third-party services used support them, the User is invited to consult the respective privacy policies.
If the changes affect processing whose legal basis is consent, the Owner will collect the User’s consent again, if necessary.
Definitions and legal references
Personal Data (or Data)
Any information which, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable constitutes personal data.
This is information collected automatically through this Application (also by third-party applications integrated into this Application), including: IP addresses or domain names of the 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 to forward 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 (for example the time spent on each page) and 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.
The individual who uses this Application who, unless otherwise specified, coincides with the interested party.
The natural person to whom the Personal Data refers.
Data Controller (or Manager)
Data Controller (or Data Controller)
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 and the tools adopted, including security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.
The hardware or software tool through which the Personal Data of Users is collected and processed.
The Service provided by this Application as defined in the relative terms (if available) on this site/application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union contained in this document is intended to include all current member states of the European Union and the European Economic Area.
Cookies are Tracking Tools that consist of small portions of data stored within the User’s browser.
Tracking Tool means any technology – e.g. Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – which allows Users to be tracked, for example by collecting or saving information on the User’s device.
This privacy information is drawn up on the basis of multiple legislative systems, including articles. 13 and 14 of Regulation (EU) 2016/679.