Pursuant to the General Data Protection Regulation (EU Regulation 2016/679)
Pursuant to law no. 171 of 21 December 2018 of the Republic of San Marino (Republic of San Marino)
Dear interested party, according to the indicated legislation, our treatments will be based on principles of correctness, lawfulness, transparency and protection of your privacy and your rights. Pursuant to articles 7 to 13 of the GDPR 2016/976 and articles 6 and 13 L. 171/2018 of the Republic of San Marino, we therefore provide you with the following information:
By implementing the registration procedure, users voluntarily communicate their personal data to the company ELEVEN SRL, the Data Controller, limited to
The user's personal data sent by users through the registration procedures for our services will be processed in compliance with the principles of personal data protection established by the regulations in the introduction to this legislation;
The provision of data is voluntary and optional; however, the inclusion of some data is essential in order to allow registration to our services (the fields of such data are recognizable by the symbol *); failure to enter such data will prevent correct registration on the site and the possibility of using the services from the portal and reserved for registered users.
1) The personal data collected with this registration are processed in order to allow access to the services provided by the portal and reserved for registered users.
2) Only if the user has freely and unambiguously expressed their consent at the time of activation of the service or expresses it later and until the revocation of the same, their personal data may be processed by ELEVEN SRL for sending advertising and commercial communications on its own products and services.
3) Only if the user has freely and unambiguously expressed their consent at the time of activation of the service or expresses it later and until the revocation of the same, their personal data may be processed by third-party companies, even with automated methods, for direct sales purposes, as well as for sending market research and surveys.
4) Furthermore, if the user freely and unequivocally consents, personal data may also be processed by ELEVEN SRL to identify, also through electronic processing, specific behaviors and consumption habits in order to improve the services provided and direct commercial proposals of interest to the User and to offer third-party advertisers the opportunity to optimize advertising campaigns.
5) The possibility for ELEVEN SRL to process the above-mentioned data in aggregated form and guaranteeing the pseudonymization of the data, in compliance with the measures prescribed by the Data Protection Guarantor and by virtue of the specific exemption from consent provided by the same Authority, for electronic analysis and processing (e.g.: classification of the entire customer into homogeneous categories by levels of services, consumption, expenditure, etc.) aimed at periodically monitoring the development and economic trend of the activities of ELEVEN SRL and guide the related industrial and commercial processes, improve services, design and implement commercial communication campaigns.
6) ELEVEN SRL will also use personal data for administrative and accounting purposes and for the execution of contractual obligations.
The personal data sent through the registration procedures for our services are processed by ELEVEN SRL with automated tools and for the time strictly necessary to achieve the purposes for which they were collected.
Specific security measures are observed by the Data Controller to prevent data loss, illegal or incorrect use and unauthorized access.
Personal data is recorded and stored on electronic databases owned by ELEVEN SRL, and will be stored on servers in the territory of countries belonging to the European Union (EU) or outside the EU in compliance with the legislation on the protection of personal data.
Personal data are processed by ELEVEN SRL through its representatives, responsible for managing the site and marketing activities.
The list of all Data Processors is available at the request of site users.
TRANSFER OF DATA TO NON-EU COUNTRIES: data may be transferred to non-EU countries to ELEVEN SRL for the sole purposes indicated above and in full respect of the processing expressed by the user.
In order to safeguard the right that the European Union considers fundamental, it is necessary that the data collected within the European territory be transferred to international organizations or non-EU countries according to the strict rules established by Chapter V of the Regulation: the transfer must take place in compliance with the principles underlying correct processing and in the presence of sufficient and adequate guarantees to protect all interested parties.
ELEVEN SRL guarantees, in accordance with art. 46 and 49 of EU Regulation 2016/679 and articles 47 and 50, Law 171/2018 of the Republic of San Marino, that any transfer to a Third Party SUPPLIER resident outside the EU will take place in compliance with these rules and always and only those data relating to users who have expressed explicit consent to such transfer and will be treated in such a way as to guarantee adequate security according to principles of integrity and confidentiality. It will always be possible to revoke this consent as required by art. 13 GDPR and art 13 L. 171/2018 of the Republic of San Marino.
The user may at any time exercise the rights referred to in art. the Right to be Forgotten pursuant to art. 17 EU Regulation 679/2016 and art. 17 L. 171/2018 of the Republic of San Marino, including:
The right to object to the processing of your data for the purpose of sending advertising material, direct sales and commercial communications and to request an updated list of data processors, by written communication to be sent to: info@eleven.sm
ELEVEN SRL. accepts third-party advertising on the site, in different forms: banners, email campaigns, promotions, sponsorships, etc.
In order to send commercial and advertising information that is as relevant as possible to the area of interest reported by users who have consented to it, the Data Controller may offer advertisers:
Under no circumstances will the Data Controller provide disaggregated or individual personal data to third parties, nor will it allow third parties to communicate directly with users.
WHAT ARE COOKIES AND HOW DO WE USE THEM
A cookie is a text file that is stored on computers, tablets, mobile phones and on any device used to browse the Internet, capable of storing the user's browsing information and preferences. Some cookies can be used, as will be seen better below, to make browsing easier and personalize your experience on our websites, allowing the user to be identified when using our website and use shopping carts for online purchases, as well as they can indicate which parts of our sites are visited and help us evaluate the effectiveness of advertising and analyze user behavior to improve our communications and products.
While browsing, we can collect information related to traffic flow and visits to the pages of our website. Any information, obtained through cookies, will be treated and stored in a secure manner.
The purpose of using cookies is to personalize access to the website, optimizing navigation and operation of the site, improving our services and providing content and/or advertising related to user preferences, analyzing browsing habits.
ELEVEN SRL complies with the provisions contained in the Code regarding the protection of personal data (“Privacy Code”), as amended by Legislative Decree no. 69 of 28 May 2012, transposing European Directive 2009/136/EC, as well as the provisions contained in EU Regulation 679/2016 and Law 171/2018 of the Republic of San Marino.
Cookies can be classified into:
For our websites and other online services, we use the following categories of cookies:
1. Strictly necessary cookies
These cookies are essential for the proper functioning of our websites and for using and/or improving the various functions and services requested.
Without these cookies it would not be possible to manage and remember, by way of example, user authentication, access to the reserved area of the website, the contents of the shopping cart for online purchases, electronic invoicing, the completion of the purchase process of an order.
Pursuant to Directive 2009/136/EC, implemented by Legislative Decree no. 69 of 28 May 2012, and the provision of the Guarantor for the protection of personal data relating to the “Identification of simplified methods for information and the acquisition of consent for the use of cookies” of 8 May 2014, published in the Official Gazette no. 126 of 3 June 2014, since technical cookies are essential for the proper functioning of a website, they can be used even without the user's prior consent, without prejudice to the obligation to provide information pursuant to art. 13 of the Privacy Code.
2. Analysis cookies (so-called. Analytics cookies)
These cookies allow us to improve our websites by monitoring and analyzing user behavior and creating their profiles in order to make improvements to our websites that make browsing easier.
For example, analysis cookies can help us keep track of which pages are visited frequently, what are the user's preferences, which products have already been viewed to prevent them from being re-proposed, if the advertising that is published on the website is effective or not, if and what difficulties the user encounters in using the site.
In order to analyze how websites are used, ELEVEN SRL also makes use of the Google Analytics web analysis service provided by Google. In particular, Google Analytics uses cookies (both temporary and permanent) in order to collect, anonymously, information on how users use our website (including IP addresses) that will be transmitted by the user's browser on Google servers based in the United States. The information collected will be used by Google for the purpose of evaluating the use of the website by the user, compiling reports on the activity of the website useful to the operators of the same site and providing other services related to the activity of the site and the use of the Internet. Google may also transfer this information to third parties where this is required by law or where such third parties process the said information on behalf of Google.
It should be noted that Google adheres to the privacy principles contained in the Safe Harbor agreement between the EU and the United States, which defines secure and shared rules for the processing of personal data carried out with companies present on American territory. For more information on Safe Harbor regulations, visit the U.S. Department of Commerce website.
More information about the Google Analytics service and the procedures to follow to disable cookies can be found at the following links:
http://www.google.com/intl/en/analytics/privacy
overview.html
https://developers.google.com/analytics/devguides/
collection/analyticsjs/cookie-usage
These data do not allow the user to be personally identified: all the data collected are aggregated and as such anonymous.
3. Advertising and behavioral advertising cookies
These cookies are used by ELEVEN SRL to collect data on browsing habits and user preferences in order to develop a specific profile for customizing the commercial offer, for carrying out market research or distance selling.
In paid online services, these cookies are a valuable tool to allow ELEVEN SRL to continuously improve the product, to offer more efficient services and with characteristics that are increasingly close to the real needs of the user.
The user can decide to refuse the use of this category of cookies using the opt-out tool provided on the settings page of their browser, or based on what is specified below.
4. Third-party cookies and Social media cookies
Our website may allow the use of third-party cookies that may collect information on the user's movements on the Internet and, in particular, within our websites.
In addition, some pages on our website are characterized by the presence of so-called social plugins which allow you to share our content on social media networks such as Facebook, Twitter, YouTube.
Third-party cookies are not under our control and, therefore, for more information on how the Third Party uses cookies, it is advisable to visit the website of the Third Party, the following are the web addresses containing the various information and methods of managing third-party cookies:
At any time, the user may refuse to accept all or some of the cookies used on this website in the following ways.
Data Retention
As noted above, the duration of cookies depends on their nature: session cookies expire when the user closes the browsers; the cookies Persistent ones have typical expiration dates that, with the exception of special exceptions, do not exceed 20 years.
Changes to the cookie policy
ELEVEN SRL reserves the right to make changes to this Cookie Policy. The user agrees to be bound by such possible and future revisions and therefore undertakes to visit this page periodically to be informed of any changes.
Nature of the provision of data
The provision of data is optional, but necessary to formalize, accept and manage requests for assistance. Without the provision of data, it will not be possible to respond to requests for assistance from ELEVEN SRL and/or the subjects appointed by it.
Communication and/or dissemination of data
The data may be communicated, in compliance with the provisions of the Code and therefore without the user's consent, to the following people or entities that for this purpose may carry out processing operations on behalf of ELEVEN SRL: companies or consultants in charge, Bodies, Authorities or Public Institutions; independent collaborators of the company or other companies and/or related bodies, other offices of this company; suppliers of the company; agents; as well as to anyone who is the legitimate recipient of communications required by law or regulations.
In view of the existence of connections made by electronic, IT or correspondence means, the data may be made available abroad both within the territorial framework of the countries belonging to the EU and in non-EU countries.
Rights of the interested party
Article. 17 GDPR 6976/2016 and art. 17 L. 171/2018 (Right to access personal data and other rights) recognize the following rights of the interested party, which we invite you to consider carefully:
The rights referred to in art. 17 GDPR 6976/2016 and art. 17 L. 171/2018 of the Republic of San Marino may be exercised by written communication to be sent to: ELEVEN SRL Via Ventotto Luglio, 99 Borgo Maggiore, Republic of San Marino 47893, info@eleven.sm
Personal data are recorded and stored on electronic databases owned by ELEVEN SRL, the Data Controller, and will be stored on servers in the territory of countries belonging to the European Union (EU) or outside the EU in compliance with the legislation on the protection of personal data.
The data controller is: Cristian Molon
The list of all Data Processors is available to users upon request.
Telephone recordings will be stored on magnetic media not accessible to unauthorized third parties and kept by a special processor, pursuant to art. 13, paragraph 3, of the Code and for the technical time necessary to process user requests and to carry out the statistical surveys mentioned above.
The maximum time for keeping records will not exceed two years. After this deadline, the registrations will be deleted so that they can no longer be used.
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