INFORMATION PURSUANT TO ART. 13 et seq. of EU Regulation 679/2016
AiToro owned by Condividiamo Ltd with registered office in Suite 23, Portland House Glacis Road, GX11 1AA, Gibraltar, 00187, as data controller pursuant to EU Regulation 679/2016 applicable from May 25, 2018 - General Data Protection Regulation ("GDPR") (hereinafter referred to for convenience as GDPR or as "Applicable Law"), provides this information only for the website https://www.aitoro.app ("Site") and does not apply to or affect other websites that may be visited through external links and serves as Information provided pursuant to art. 13 et seq. of the Applicable Law.
PRINCIPLES
The processing of your personal data by AiToro is carried out in accordance with the principles of accountability, lawfulness, fairness, transparency, purpose limitation and storage limitation, data minimization, accuracy, integrity and confidentiality, in accordance with the legislative provisions of the applicable Regulations and the confidentiality obligations provided therein.
Data Controller
AiToro with registered office at Suite 23, Portland House Glacis Road, GX11 1AA, Gibraltar, 00187,
(hereinafter briefly AiToro), for the purposes, hereinafter
specified, connected to the provision of its services, and for
forwarding informative requests and contact through its website and
for the operation of said website (hereinafter referred to as the
"Site"), processes your personal data acquired in the performance
of the Services and/or during navigation on this Internet site, as
Data Controller.
The data controller determines the purposes and means of the
processing of personal data.
Personal data subject to processing
The term "Personal data" means any information relating to an
identified or identifiable natural person (the data subject); an
identifiable person is one who can be identified, directly or
indirectly, in particular by reference to an identifier such as a
name, an identification number, location data, an online identifier
or to one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of that
person.
The personal data collected on this site are:
Browsing data
The computer systems of the Site collect some of your personal
data, the transmission of which is implicit in the use of Internet
communication protocols. These are pieces of information that are
not collected to be associated with you as an interested party, but
which by their very nature could, through processing and
association with data held by third parties, allow you to be
identified. Among these are IP addresses or domain names of the
devices used to connect to the Site, URI addresses of the requested
resources, 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
given by the server (successful, error, etc.) and other parameters
relating to the operating system and computer environment.
These data are used in order to obtain anonymous statistical
information about the use of the Site and to check its correct
functioning; to allow - given the architecture of the systems used
- the correct provision of the various requested functionalities,
for security reasons and for ascertaining responsibility in case of
hypothetical computer crimes to the detriment of the Site or third
parties.
Data provided voluntarily
Through the Site, as a data subject, you can voluntarily provide us with personal data such as your name and email address through the forms on the site. AiToro will process this data in compliance with the applicable regulations, considering that they refer to you as a data subject who provided them or who expressly authorized third parties to provide them on his behalf and/or for his account based on an appropriate legal basis legitimizing the processing of the data in question. In such cases, you as the data subject, and the third party who provided them on your/his behalf assume all legal obligations and responsibilities, indemnifying AiToro against any claims, demands, requests for compensation for damages arising from processing, etc. that may be received by AiToro from other parties whose personal data have been processed through the use of the Site in violation of applicable regulations.
Cookies and similar technologies
AiToro collects your personal data through cookies. Cookies are small data files that can be sent from a website to the user's terminal (usually to the browser), where they are stored to be retransmitted to the site on the next visit. A cookie cannot retrieve any other data from the interested party's hard drive, nor transmit computer viruses or acquire email addresses. Cookies can be used both by the site owner and by third parties and can be easily disabled by the interested party. AiToro, in order to regularly provide its Services, needs to use some cookies, including third-party ones, through this Site. Therefore, if you, as the data subject, decide to disable the use of cookies for purely technical reasons, AiToro may be unable to provide you with certain Services or provide them in the manner requested. More information about the use of cookies and similar technologies is available in the dedicated section accessible from the site's footer.
PURPOSE OF PROCESSING AND LEGAL BASIS
Your personal data, provided by you through the Site, will be processed by AiToro for the following purposes:
The registration on the website of AiToro, as well as
purposes aimed at carrying out all that is necessary for the
provision of the Services offered, which takes place mainly through
automated and computerized methods, pre-contractual intentions, and
contract signing. In these cases, when providing certain services
AiToro will provide you with additional and specific
information on the processing of personal data, in addition to this
privacy policy.
The legal basis for processing your personal data for the purposes
described above (point a) is the provision of a contracted service
or responding to a request and does not require consent under the
applicable regulations.
Purpose of research/statistical analysis on aggregated or anonymous
data, therefore without the possibility of identifying you, merely
aimed at measuring the functioning of the Site, evaluating its
traffic, usage, and interest it arouses. The aforementioned purpose
(point b) does not involve the processing of personal data.
Purposes related to the fulfillment of legal obligations
regulations, community regulations, orders and prescriptions of the
competent authorities to which AiToro is subject.
The processing related to the above-mentioned purposes (point c)
does not require consent as it represents a legitimate processing,
constituting compliance with legal obligations, also connected to
the provision of Services;
The pursuit of our legitimate interest, such as Data Controller,
how to manage complaints and disputes, recover credits, prevent
fraud and illegal activities.
The legal basis in this case (point d) is given by the legitimate
interest of AiToro also to exercise and/or defend, where
necessary, its own rights in the appropriate venues.
Carry out commercial and promotional communication activities at
the email address provided by you, as an interested party, related
to services and activities of AiToro
Giving consent to the processing of your personal data for the
purposes listed above (point e) is optional, but their possible
non-provision could make it impossible to respond to a request or
fulfill an obligation to which AiToro is subject or has
been requested.
RECIPIENTS
Your personal data may be shared and communicated, for the purposes specified in point 3, in Italy or abroad, to third parties such as:
subjects necessary for the provision of services offered by the
Site, such as tax and legal consultants of AiToro in
relation to the related obligations, to companies and technical
consultants responsible for the management and maintenance of
information systems, software and databases, to financial,
administrative, archiving, accounting audit and financial
certification services companies, in any case in strict connection
and within the limits of the performance of their respective tasks
and activities.
people authorized by AiToro to process Personal Data who
have committed to confidentiality or have an adequate legal
obligation of confidentiality (e.g. employees and collaborators of
AiToro).
Judicial authorities in the exercise of their functions when
required by the applicable legislation.
TRANSFERS
Some of your personal data may need to be transferred to Recipients outside the European Union, in compliance with applicable regulations.
Data Retention
AiToro will process your personal data for the time strictly necessary to achieve the detailed purposes outlined in point 3 for a limited and different period depending on the type of activity involving the processing of personal data. Once this period has expired, your data will be permanently deleted or irreversibly anonymized.
The data collected to conclude and execute contracts will be
kept for ten years from the date of conclusion of the contract.
The billing-related data will be kept for ten years from the
billing date.
Your data as a registered User, entered by you at the time of
registration on the site, will be kept until the deletion of the
profile is requested.
The data communicated by you to AiToro using the forms will
be kept until its deletion is requested.
Any attachments and data contained therein will be stored for 12
months from receipt;
The data provided to us for commercial communication activities
and/or newsletter sending will be kept until the user requests the
interruption of the activity and/or unsubscribes from the service
or until you ask us to stop sending it.
THE RIGHTS OF THE DATA SUBJECT
Within the limits of the applicable regulations, as a data
subject of the processing of your personal data processed through
the AiToro website, you can exercise the following rights
at any time: -the right to obtain confirmation of the existence or
not of personal data and, in such case, to obtain access to and
copy of them. Unless otherwise required by applicable law,
AiToro may refuse the possibility of obtaining said copy if
this could harm the rights and freedoms of others; the right to
obtain information: on the origin of personal data; on the purposes
and methods of processing personal data; on the logic applied in
case of processing carried out with the aid of electronic tools; on
the identifying details of the controller and, if appointed, of the
processors and privacy representative; on the subjects or
categories of subjects to whom personal data may be
communicated;
The right to obtain: updating, rectification, integration of data,
erasure, transformation into anonymous form or blocking of data
processed unlawfully, including those for which storage is not
necessary in relation to the purposes for which the data were
collected or subsequently processed, in cases provided for by
applicable law, limitation of processing personal data in cases
provided for by law, the right to object, in whole or in part, for
legitimate reasons to the processing of personal data even if
relevant to the purpose of collection, to the processing of
personal data for sending advertising material or direct selling or
for carrying out market research or commercial communication, the
right to withdraw consent at any time, where this constitutes the
legal basis for processing, without affecting the lawfulness of
processing based on consent before its withdrawal, lodge a
complaint with the supervisory authority, in cases provided for by
applicable law, receive the data in a structured format, commonly
used and readable by automatic device and transmit such data to
another controller without hindrance, the right to obtain
confirmation that each of the recipients to whom personal data have
been transmitted has been informed of any rectifications or
erasures or limitations on processing, except where this proves
impossible or involves a disproportionate effort compared with the
right being protected. In any case, upon request as a data subject
you may also obtain the details of said recipients.
The above requests must be sent by email to the following addresses:
Email: companyltd@condividiamo.club
CHANGES
The present Privacy Policy is effective from 25 May 2018. AiToro reserves the right to modify or simply update its content, in part or completely, also due to variations in the applicable Regulations. AiToro will inform about such variations as soon as they are introduced and they will be binding as soon as they are published on the Site. In any case, any changes made over time to this information will be duly published in a specific section of this Site.
