1. IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER

The data controller of your personal data is Sixeleven s.r.l., VAT No. 10182610013, Largo Montebello 40/M - 10124 Turin (hereinafter "Controller"), email privacy@sixeleven.it. If the Controller makes use of data processors or sub-processors in accordance with Article 28 GDPR, the updated list of data processors and persons in charge of data processing is kept at the registered office of the Controller.

2. WHAT TYPES OF PERSONAL DATA DO WE PROCESS

The types of personal data we collect depend on the purpose for which they are collected. In general, we may directly collect the following types of personal data from you: a) contact personal data, such as name, surname, email address, address, city, phone number; b) usage data, viewing and technical data, including device identification or IP address of the user, the moment when the user visits the site hereinafter “Personal Data”.

The processing also concerns the operations, or the set of operations concerning data collected also through the use of cookies, whose policy is fully referred to, viewable at the following link https://www.sixeleven.it/cookie-policy.

3. WHY WE PROCESS YOUR PERSONAL DATA AND ON WHAT LEGAL BASES

The processing of your Personal Data by the Controller takes place:

A) without your express consent (Article 6 letters b) - f) GDPR), for the following purposes:

• to conclude contracts with the Controller;

• to fulfill pre-contractual, contractual and tax obligations arising from existing relationships;

• to meet legal obligations, regulations, community legislation or orders from the Authority;

• to pursue a legitimate interest of the Controller or third parties, provided that your interests or your rights and fundamental freedoms requiring the protection of personal data do not prevail (e.g. the right to legal defense of the Controller)

B) Only with your specific and distinct consent (Article 6 letter a) and Article 7 GDPR), for the following marketing purposes:

• to send via email, mail and/or SMS and/or phone contacts, newsletters, commercial communications and/or advertising material regarding products or services offered by the Controller and to assess the level of satisfaction regarding the quality of the services;

If you have denied your consent, it will not be possible to carry out these activities, and in any case, if you have expressed consent to the processing activities, you will still have the right to revoke, at any time, the consent given.

4. HOW LONG WE KEEP AND PROCESS YOUR PERSONAL DATA

Your Personal Data will be processed by the Controller only for the time necessary to achieve the purposes of processing referred to in the previous article 3, after which they will be kept only in compliance with the legal obligations in force in the matter, for administrative purposes and/or to assert or defend a right and, in any case, not beyond the terms set by law for the prescription of rights. In particular, for marketing purposes, the User's Personal Data will be kept by the Controller for a maximum of two years.

5. HOW WE PROCESS YOUR PERSONAL DATA

Your Personal Data are processed both on paper and electronically and/or automatically for the time necessary to achieve the purposes for which they are collected by the Controller or by duly authorized and/or appointed subjects to fulfill these tasks, constantly identified and/or appointed, properly trained and made aware of the constraints imposed by law, as well as by employing security measures to ensure the protection of confidentiality and to avoid the risks of loss or destruction, unauthorized access, unlawful processing or processing not in accordance with the purposes mentioned above.

6. TO WHOM WE MAY COMMUNICATE YOUR PERSONAL DATA

For the purposes indicated above, your collected data may be made accessible or communicated to:

• employees and collaborators of the Controller, in their capacity as authorized personnel in charge of processing, within the scope of their respective duties and in accordance with the instructions received. Such individuals are nonetheless subject to confidentiality obligations;

• third parties who perform outsourcing activities on behalf of the Controller to whom some activities, or part of them, functional to the provision and distribution of services offered through the site (e.g. hosting companies, programmers, system administrators and database administrators) are entrusted or whose activity is connected, instrumental or supportive to that of the Controller (e.g. management and/or cloud marketing software);

• all those public and/or private entities, natural and/or legal persons (law, administrative and tax consultancy firms, credit recovery companies, Judicial Offices, Chambers of Commerce, Employment Chambers and Offices, etc.), if communication is necessary or functional to the correct fulfillment of contractual obligations undertaken, as well as obligations arising from the law;

• all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative provisions;

In any case, your collected personal data will not be sold or transferred to third parties for marketing purposes and will not be subject to dissemination. 

7. TRANSFER OF PERSONAL DATA OUTSIDE THE EU AREA

The management and storage of your Personal Data will take place in Europe. It is understood that the Controller, where necessary, has the right to have your Personal Data processed outside the EU Area (EEA). In this case, the Controller assures that the transfer of data outside the EU will be carried out in accordance with applicable legal provisions by entering into, if necessary, agreements that guarantee an adequate level of protection and/or adopting the standard contractual clauses provided by the European Commission.

8. MINORS

This site and the Controller do not intentionally collect Personal Data relating to minors under 18 years of age. In accordance with applicable laws, the person exercising parental responsibility must provide consent for the collection of Personal Data of the minor. If Personal Data about minors are inadvertently recorded, the Controller will delete them promptly, at the request of the person exercising parental responsibility.

9. YOUR RIGHTS

Pursuant to Articles 15 et seq. of the GDPR and national legislation on privacy and personal data protection applicable, you have the right to:

1) obtain from the Controller confirmation as to whether or not personal data relating to you is being processed and in that case, to obtain access to personal data and the following information:

• the purposes of processing;

• the categories of personal data concerned;

• the recipients or categories of recipients to whom personal data have been or will be communicated, particularly if recipients are third country recipients or international organizations;

• where possible, the period for which the personal data will be stored or, if not possible, the criteria used to determine that period; the existence of the right of the data subject to request from the data controller rectification or erasure of personal data or restriction of processing of personal data concerning him/her or to object to their processing;

• the right to lodge a complaint with a supervisory authority;

• where the data are not collected from the data subject, all information available about their origin;

• the existence of automated decision-making processes, including profiling.

2) Obtain from the Controller the rectification of inaccurate personal data concerning you without undue delay. Considering the purposes of processing, the data subject has the right to obtain the integration of incomplete personal data, including by providing a supplementary statement.

3) Obtain from the Controller the erasure of personal data concerning you without undue delay and the Controller is obliged to erase personal data without undue delay within the limits and in cases provided by the applicable legislation.

4) Obtain from the Controller the restriction of processing.

5) Receive in a structured, commonly used and machine-readable format the personal data concerning you provided to the Controller and have the right to data portability and thus to transmit such data to another data controller without hindrance from the data controller to whom they have been provided where the processing is based on consent or a contract and the processing is carried out by automated means. 

6) Object at any time, for reasons related to your particular situation, to the processing of personal data concerning you if the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller or the processing is necessary for the purposes of legitimate interests pursued by the Controller or by third parties.

7) If you believe that your rights have been violated by the Controller, file a complaint with the Data Protection Authority (Piazza Montecitorio 121, 00186 Rome (RM) - www.garanteprivacy.it) and/or to another competent supervisory authority under the GDPR.

The Controller following the exercise of the rights referred to in points 2), 3) and 4) communicates to each of the recipients to whom the personal data have been transmitted the possible rectifications or erasures or limitations of the processing within the limits and forms provided for by the applicable regulations.

To exercise the rights listed above against the controller, you need to submit a written request by sending a registered letter with acknowledgment of receipt to Sixeleven s.r.l., Largo Montebello 40/M - 10124 Turin or a communication via certified email to certificata@pec.sixeleven.it

10. WHAT HAPPENS IN CASE OF CHANGES TO THE PRIVACY POLICY

This information may be modified and/or updated at any time. If the Controller intends to process your Personal Data for purposes other than those provided for in the previous article 3, it undertakes to provide you, prior to such further processing, adequate information regarding such different purposes and to carry out such further processing in compliance with current regulations, collecting, where necessary, your specific consent.

This Privacy policy was published on May 25, 2018. Any updates will be published on this page.