This information takes into account the provisions of the GDPR and the Privacy Code (Legislative Decree 30 June 2003 n. 196). The document has also been drafted in accordance with the Guidelines of the Privacy Guarantor (especially the Guidelines for combating spam issued by the Privacy Guarantor on July 4, 2013).
Data Controller: SELF TUNING FILE S.R.L.
The Data Controller has not appointed a DPO. Therefore, you may send any inquiries directly to the Data Controller.
This document describes how the Data Controller processes your personal data.
The following describes the main processing of your personal data. In particular, we explain the legal basis of the processing, whether the provision of personal data is compulsory and the consequences of not providing personal data. To better describe your rights, if necessary, we have specified if and when a certain processing of personal data is not carried out.On the Site you have the possibility to enter personal data of third parties. In this case you guarantee to have obtained the consent of these subjects to the insertion of these personal data. Therefore, you agree to indemnify and hold harmless the Data Controller from any liability.
The information and data requested in case of registration will be used to allow you both to access the private area of the Site and to use the online services offered by the Data Controller to registered users. The legal basis of the processing is the need for the Data Controller to execute pre-contractual measures taken at the request of the data subject. The conferment of data is optional. However, your refusal to provide the data will make it impossible to register on the Site.
Purchases on the Site
Your personal data will be processed to allow you to make purchases on the Site. in the case of making an online purchase order, to allow the conclusion of the purchase contract and the proper execution of transactions related to the same (and, if necessary under the legislation, to fulfill tax obligations). This treatment of personal data also includes the possibility of sending communications (e.g. tracking and order information) via automated tools such as SMS and/or WhatsApp. The legal basis for the processing is the obligation of the Data Controller to execute the contract with the data subject or to comply with legal obligations. Apart from the above (and therefore your consent), the Data Controller may process your data for the purpose of so-called “soft-spam”, governed by art. 130 of the Privacy Code. This means that limited to the email you provided in the context of a purchase through the Site, the Data Controller will process the email to allow direct offers from similar products/services, unless you object to such processing in the manner provided by this policy. The legal basis for processing is the legitimate interest of the Data Controller to send this type of communication. This legitimate interest can be considered equivalent to the interest of the data subject in receiving “soft-spam” communications.The Data Controller does not process the user’s data to send “reminder” emails to purchase products and/or services from the Data Controller.
Answering your requests
Your data will be processed to respond to your requests for information. The conferment is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis for the processing is the legitimate interest of the Data Controller in fulfilling your requests. This legitimate interest is equivalent to the user’s interest in receiving a response to communications sent to the Data Controller.
The Data Controller will not send you advertising material and/or newsletters regarding its own products or those of third parties.
The Data Controller does not carry out “profiling” with your personal data. Therefore, it will not send you advertising material and/or newsletters relating to its own products or third parties of your specific interest.
The Data Controller does not transfer your personal data to third parties.
The Site does not implement tools to geolocate the user’s IP address.
It is not possible to send CVs via the Website. Your data will therefore not be processed for these purposes.
There are no third-party appointment booking systems active on the Site. Therefore, your data will not be processed for this purpose. In any case, you can always contact the Data Controller at the contacts indicated in the heading.
Communication of personal data
As part of its ordinary business, the Data Controller may communicate your personal data to certain categories of subjects. In article 2 you can find the list of subjects to which the Data Controller communicates your personal data. In order to facilitate the protection of your rights, Article 2 may specify in certain cases when your data is not communicated to third parties.
The “communication” of personal data to third parties is different from the “transfer” (governed by the preceding point). In fact, in the communication the third party to whom the data is transmitted can use it only for the specific purposes described in the relationship with the Data Controller. In the transfer, instead, the third party becomes the autonomous Data Controller. Moreover, to transfer your personal data to third parties is always required your consent.
Without prejudice to the foregoing, it is understood that the Data Controller may still use your personal data in order to correctly fulfill the obligations provided for by the laws in force.
Art. 1 Method of processing
1.1 The processing of your personal data will be mainly carried out with the help of electronic or automated means, according to the methods and with the tools suitable to ensure their security and confidentiality in accordance with the GDPR.
1.2 The information acquired and the methods of treatment will be relevant and not excessive in relation to the type of services rendered. Your data will also be managed and protected in secure computer environments appropriate to the circumstances.
1.3 Through the Site are not processed “special data”. Particular data are those that can reveal racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade union, health and sex life.
1.4 No judicial data is processed through the Site.
Art. 2 Communication of personal data
The Data Controller may communicate your personal data to certain categories of subjects. The subjects to whom the Data Controller reserves the right to communicate your data are indicated below:
- The Data Controller may communicate your personal data to all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative measures.
- Your personal data may also be disclosed to all those public and / or private individuals and / or legal entities (legal, administrative and tax, judicial offices, Chambers of Commerce, Chambers and Offices of Labor, etc..), if the communication is necessary or functional to the proper fulfillment of obligations under the law.
- The Data Controller uses employees and/or collaborators in any capacity. For the proper functioning of the Site, the Data Controller may communicate your personal data to these employees and/or collaborators.
- In its ordinary activity of managing the Site, the Data Controller makes use of companies, consultants or professionals in charge of the installation, maintenance, updating and, in general, the management of the hardware and software of the Data Controller or which the latter uses for the provision of its services. Therefore, only with reference to these purposes, your data may also be processed by these subjects.
- The Data Controller does not use CRM platforms (companies that carry out the activity of sending automated communications to users. Therefore, your personal data are not communicated to these companies.
- The Data Controller does not use external companies to provide customer care services. Therefore, your personal data will not be processed for this purpose.
- The purchaser’s personal data may be communicated to post offices, couriers or forwarding agents responsible for the delivery of the Products purchased through the Site.
The Data Controller reserves the right to modify the above list in accordance with its ordinary operations. Therefore, you are invited to regularly access this information to check to which subjects the Data Controller communicates your personal data.
Art. 3 Personal data retention
3.1 This article describes how long the Data Controller reserves the right to retain your personal data.
- User data will be kept only for the time necessary to ensure the proper provision of the services offered through the Site.
3.2 Without prejudice to the provisions of Article 3.1, the Data Controller may retain your personal data for the time required by specific regulations, as amended from time to time.
Art. 4 Transfer of personal data
4.1 The Data Controller is based within the European Union. Therefore, the processing of your data is safe from a regulatory point of view as it is governed by the GDPR. If the transfer of your personal data takes place in a non-EU country and for which the European Commission has issued an adequacy opinion, the transfer is in any case considered safe from a regulatory point of view. This Article 4.1 indicates from time to time the countries to which your personal data may possibly be transferred and where the European Commission has issued an adequacy opinion.
- You are therefore invited to access this article regularly to check whether the transfer of your personal data takes place in a country with these characteristics.
4.2 Without prejudice to what is stated in article 4.1, your data may also be transferred to countries outside the EU for which the European Commission has not issued an adequacy opinion. You are therefore invited to regularly review this article 4.2 to find out to which of these countries your data may be transferred.
4.3 In this article, the Data Controller indicates the countries in which it may specifically direct its activities. This circumstance may imply the application of the legislation of the country of reference, together with that of the GDPR.
- The Site processes personal data of individuals located in Australia. This notice has been prepared taking into account the provisions of Australian national and federal legislation. In particular, reference is made to the Federal Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).
- The California Consumer Privacy Act (CCPA) is a California law that was passed in June 2018. The Data Controller processes personal data of California users under this law. The user is informed that the personal data processed are those communicated on the Site to allow the execution of the contract. The user may exercise their rights under the CCPA by contacting the Data Controller at the contact details published in the foreword.
- The Virginia Consumer Data Protection Act (CDPA) is a law in Virginia that was passed in March 2021. The Data Controller processes the personal data of Virginia users in accordance with this law. Users are informed that the personal data processed are those communicated on the Site to allow the execution of the contract. The user can exercise the rights provided by the CDPA by contacting the Data Controller at the contact details published above.
- The Nevada Privacy Law (Senate Bill 220) is a piece of legislation in Nevada, enacted in 2019, aimed at protecting the privacy of user data. The Data Controller manages the personal data of users in Nevada in line with this legislation. Users are notified that the personal data being handled are those provided through the Site to facilitate the contract’s fulfillment. Users can avail themselves of the rights guaranteed by the Nevada Privacy Law by reaching out to the Data Controller using the contact information provided earlier.
- The New Zealand Privacy Act of 2020, which underwent significant amendments in December 2020, governs the protection of users’ personal data. In accordance with this legislation, the Data Controller diligently handles the personal data of New Zealand users that are collected through the Site to ensure the proper execution of the contract. Users are hereby informed that they can exercise the rights set forth by the New Zealand Privacy Act by contacting the Data Controller at the contact details initially provided.
- The Personal Information Protection Law (PIPL) is a Chinese regulation that came into effect on November 1, 2021, and governs the protection of users’ personal data. In compliance with this law, the Data Controller is committed to the responsible and secure management of the personal data of Chinese users that are collected through the Site, in order to ensure the appropriate fulfillment of the contract. Users are informed that they can exercise the rights granted by the Personal Information Protection Law by contacting the Data Controller using the contact details provided earlier.
- The Personal Data Protection Act (PDPA) is a Singaporean regulation that governs the protection of users’ personal data. In compliance with the PDPA, the Data Controller commits to responsibly managing the personal data of Singaporean users collected through the Site, to ensure proper fulfillment of the contract. Users are informed that they can exercise the rights stipulated by the PDPA by contacting the Data Controller using the contact details provided earlier.
- In Malaysia, the protection of users’ personal data is safeguarded by the Personal Data Protection Act of 2010 (PDPA). The Data Controller adheres strictly to the principles and provisions of this law for the management of personal data collected on the Site from Malaysian citizens, in order to satisfactorily conclude the contract. Users are encouraged to note that they have the right to exercise the rights outlined by the PDPA by contacting the Data Controller through the contacts mentioned earlier.
- For users in the Philippines, please be informed that the Data Controller is committed to complying with the Data Privacy Act of 2012 (DPA) in handling personal data collected through the Site. This law aims to protect individuals’ rights and privacy. Users can exercise their rights under the DPA by contacting the Data Controller using the contact details provided.
- We wish to inform South African users that personal data collected through the Site are managed in compliance with South Africa’s Protection of Personal Information Act of 2013 (POPIA). The Data Controller commits to adhering to the provisions of this law. South African users can assert the rights granted by POPIA by reaching out to the Data Controller through the communication channels provided.
- Thai users are advised that the Data Controller closely follows Thailand’s Personal Data Protection Act of 2019 (PDPA) in handling personal data collected on the Site. This is critical for ensuring users’ data privacy and security. To exercise the rights sanctioned by the PDPA, Thai users can contact the Data Controller using the contact details provided.
- Please be informed that for users residing in the State of Connecticut, the Data Controller closely adheres to the Connecticut Consumer Data Privacy Act (CTDPA), which took effect on July 1, 2023, in processing personal data collected through the Site. This law was established to safeguard consumer data privacy. Users residing in Connecticut can exercise the rights guaranteed by the CTDPA by contacting the Data Controller using the contact details provided.
Art. 5. Your rights under the GDPR
Pursuant to art. 13 of the Privacy Regulations, the Data Controller informs you that you have the right:
- to request from the Data Controller access to your personal data and the rectification or erasure of the same or the restriction of the processing thereof or to object to the processing thereof, in addition to the right to data portability
- revoke consent at any time without affecting the lawfulness of the processing based on the consent given before revocation
- to lodge a complaint with a supervisory authority (e.g. the Italian Data Protection Authority).
The rights referred to above may be exercised by making a request without formalities to the contacts indicated in the Introduction.
Art. 6. Amendments