Delos processes your personal data in compliance with applicable legislation on the protection of personal data and, in particular, the Regulation (EU) 2016/679 (“GDPR”), Legislative Decree no. 196 of June 30, 2003 (“Privacy Code”).
1) Data Controller
The Data Controller is Edoardo De Juliis, with registered office in Via di Vigna Stelluti 30, 00191, Rome. You can contact us at any time by writing to email@example.com.
2) Purposes of the treatment
Direct marketing to send advertising or direct sales material or to carry out market research, approval or commercial communication and newsletters by automated means such as e-mail.
Communications may contain promotional activities of third parties and / or logos of third parties (cosmetics and personal care supplements of partners in the industry).
There will be no transfer of personal data to third party partners for this purpose.
The owner to compare and possibly improve the results of communications, uses systems to send newsletters and promotional communications with reports. Thanks to the reports, the owner will be able to know, for example: the number of readers, openings, unique “clickers” and clicks; the devices and operating systems used to read the communication; the details of the activity of individual users; the details of the emails sent, delivered and not, of those forwarded; All these data are used in order to compare, and possibly improve the results of communications.
Send you, upon your express consent, communications of an informative and/or promotional nature relating to updates on initiatives, activities or events planned and/or promoted by Delos and/or for inclusion in distribution lists for the sending of communications relating to such activities.
Profiling: personal data will be entered into CRM business / platforms, in order to internal analysis and to divide the interested parties into homogeneous groups for specific characteristics of business activities for better management of services and to send targeted promotional communications.
3) Legal basis of the treatment
We will process your personal data mainly to allow you to use our services and other functionalities made available on the Site in order to perform contractual obligations undertaken towards you or to take pre-contractual measures adopted upon your request in accordance with what is indicated in our Terms of Services, as well as to
enable us to act in accordance with legal obligations to which Delos is subject;
to pursue our legitimate interests in providing you with a smooth and effective service, as well as to improve the functionality of our Site and enhance your browsing and usage experience;
with your consent, to carry out promotional and/or marketing activities.
4) What data do we collect and what data will we have access to through the Site?
Our Site allows us to collect the following categories of personal data:
Information we collect during your use of the Site.
The Site allows us to acquire certain data whose transmission is implicit in your use of the web. We do not collect this information to identify you, but through processing and association with third party data we may be able to identify you. In particular, we may be able to collect:
the IP addresses of the devices you use to access the Site;
the addresses in URI/URL notation of the resources requested;
the time of the request, the method used to submit it and the http response code;
information regarding the actions performed with the mouse on the pages;
information regarding the type of device from which the Site was accessed (PC, mobile, tablet, etc.);
other parameters relating to your browser and/or operating system used by you.
These data will not persist for longer than is strictly necessary for the use of the Site, for the fulfilment of the obligations in force in the field of public security and/or requested by the control authorities and in any case not longer than 7 days.
Information we collect through the request for an appointment
If you intend to submit a request for an appointment to visit with our specialists, we will collect the following information
Name, surname and email address
information regarding the reasons for which you intend to book the visit
other information that the user decides autonomously to indicate when requesting an appointment by filling out the booking form.
Data provided for the purchase of services and/or products available on the Site
The Site may allow you to purchase products and/or take advantage of services provided on payment on the site through the payment methods made available on the same from time to time. Please note that the identification data relating to the transaction will not be stored, even temporarily, in our systems (on this point see also §11).
6) Obligatory nature of providing data
You are not obliged to provide us with your personal data, although failure to provide them, or providing them in part or inexactly, may prevent you from submitting – and us from evaluating – your request for an appointment.
The revocation and/or failure to provide your consent to carry out marketing activities does not entail any consequences for you, although, in this case, you will not be able to stay updated on Delos’ activities.
7) Communication of data
external suppliers who provide activities on our behalf, including, but not limited to, the maintenance and support service of our information systems, press services, information agencies;
individuals, legal entities or professional associations that carry out, on our behalf, any paid services and/or the management of events promoted by us and/or accessible through the Site;
professionals, firms or professional associations appointed to defend Edoardo De Juliis in litigation of any kind;
Public Safety Authorities, Judicial Authorities, subjects or entities to whom it is mandatory to communicate your personal data under the provisions of the law or orders of the competent authorities.
The data subject to communication will concern only the data necessary to achieve the specific purposes for which they were conferred or collected. You can request a list of these subjects by writing to firstname.lastname@example.org
8) Transfer of data abroad
Within the European Union, we may transfer the data collected through our Site in order to comply with legal obligations, regulations or imposed by Community legislation. Your data is stored on the servers of our hosting provider Serverplan, whose servers reside in Italy.
We operate our newsletter service through the “MailChimp” system owned by “The Rocket Science Group LLC”, whose servers are located in the United States and, consequently, limited to this service we will transfer your personal data to the United States in accordance with the decision of the European Commission 1250/2016 (so called “Privacy Shield”), implemented by the National Guarantor with measure no. 436 of October 27, 2016 [web doc. no. 5652873].
Any transfer of your personal data to non-EU countries will take place in accordance with the provisions of Articles 44 et seq. of the GDPR on the basis of an adequacy decision adopted by the European Commission likely to prove that the recipient country offers an adequate level of security of personal data protection
However, for transfers to countries for which there is no Commission decision, we are committed to ensuring an adequate level of protection for your personal data by providing “adequate safeguards” on the basis of Art. 46. GDPR. To request clarification on the transfers or guarantees adopted write to email@example.com.
9) Period of data retention
Your data are stored for a period of time not exceeding that necessary for the purposes for which they were collected, conferred or subsequently processed in accordance with the provisions of the law.
In particular, the data provided for registration on the Site will be kept until you request cancellation and/or deactivation of your account and, subsequently, only for the time necessary to fulfill the related legal obligations.
Please note that the data of your credit card or payment systems that you have used and possibly available on the Site will not be stored, even temporarily, in our systems.
10) Rights of the interested parties
You may have clarity about the processing we perform on your personal data or exercise the rights recognized by Articles 15 et seq. of the GDPR at any time. By way of example, you will be able to exercise the following rights in ours:
Right of access: you will be able to ask us to confirm and which treatments we operate on your personal data. You will also be able to request us to provide you with a copy of your data by email and to verify the data is in our possession.
Right of rectification: you will be able to amend your details if they are incorrect (for example, if they are different to the details you provided to us when you submitted your application) or complete incomplete details.
Right to erasure: you may request us to erase all or part of the data you have provided to us.
Right to restriction: you may ask us to restrict the processing of your personal data in the cases provided for by law.
Right to portability: you may obtain, in a structured, commonly used and machine-readable format, the data you have provided us with and transmit it to another data controller.
Revocation of consent: if the treatment was legitimated by the consent you have given us, we inform you that you can revoke it at any time, without prejudice to the lawfulness of the treatments carried out by us before said revocation.
Right to complain to the Guarantor: without prejudice to any other administrative or judicial recourse, you may complain to the Guarantor Authority for the protection of personal data in the event that you believe that the treatments carried out by us are in conflict or violate existing legislation on data protection.
You can forward any request and / or exercise these rights by writing to firstname.lastname@example.org
11) Other sites
We may amend this policy to comply with any changes in the legislation on the protection of personal data or in case of any indications of the competent authorities. To this end, please check this page periodically to stay informed about how we process your data.
We will publish any new version of this policy and will notify you by email. Any new version of this policy will be binding as soon as it is published. If you do not wish to accept these changes, you may exercise one of the rights mentioned above.
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