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GENERAL INFORMATION
ITS SOFTWARE TECHNOLOGY SYSTEMS LTD, registered in 3 Cavendish Row, Dublin 1, D01 A2T Ireland (hereafter ‘ITS’, ‘we’, ‘our’ or ‘us’), as the processor of personal data, is committed to protecting and respecting the privacy of its users, clients and suppliers, including potential ones (hereafter, collectively, ‘users’), in compliance with Legislative Decree 196/2003 (Code on the protection of personal data) and EU Regulation 679/2016, applicable as of 25 May 2018 (General Data Protection Regulation) (both laws will be collectively referred to below as ‘applicable law’).
This information statement (hereafter, ‘privacy information’) is intended to inform our users about our practices related to the collection and use of the personal data regarding them.
‘Personal data’ means any information regarding an identified or identifiable natural person, with particular reference to an identifier like a name, an identification number, data related to location, an online identifier or one or more characteristic elements of that person’s physical, physiological, psychic, economic, cultural or social identity.
We invite our users to read the following information carefully in order to understand our reasoning and practices governing the processing of personal data.
1.1. Data provided voluntarily
1.1.a. In the fulfilment of a contract that the users are a party to, or in the fulfilment of precontractual measures adopted upon request of the users (for example, request for contact through the ‘Contact us’ form on our site, request to subscribe to our newsletter, etc.), our users can, using our site or other contact channels (for example, email), voluntarily provide their personal data or information and documents containing personal data.
1.1.b. ITS will process all the aforementioned data in compliance with applicable law, assuming that they are referred to the users or third parties who have expressly authorised the users to provide it based on an appropriate legal basis that legalises the processing of the data in question. In such a case, the users are acting as independent processors, assuming all obligations and responsibilities under the law. Accordingly, the users confer on this point the broadest indemnity regarding any dispute, claim, request for remuneration for damages caused by processing, etc., that may reach us from third parties whose personal data has been processed through the use of this site in violation of applicable law.
1.2. Navigation data
1.2.a. Our website’s computer systems collect some personal data the transmission of which is implicit in the use of Internet communication protocols. This is information that is not collected in order to be associated with the users, but that by their very nature could, through processing and association with data held by third parties, allow their identification. These include the IP addresses or domain names of the devices used to connect to our site, the addresses in URI (Uniform Resource Identifier) notation of the resources requested, 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 provided by the server (success, error, etc.) and other parameters related to the user’s operating system and computing environment.
1.2.b. Such data is used for the purpose of obtaining anonymous statistical information on the use of our website and to monitor its proper functioning; to allow – given the architecture of the systems used – the proper provision of the various functions requested by the users, for reasons of security and ascertaining responsibility in the event of any computer crimes damaging our site or a third party’s site, and will be deleted after 7 (seven) days.
1.3. Cookies and similar technologies
1.3.a. We collect personal data through the use of cookies. More information on the use of cookies and similar technologies is available here.
2.1. The personal data provided by users will be processed by ITS for the following purposes:
2.1.a. purposes involving the fulfilment of a contract that the users are a party to or the fulfilment of precontractual measures adopted upon request by the users (for example, request for contact through the ‘Contact us’ form on our site, request to subscribe to our newsletter, etc.);
2.1.b. purposes involving the sending, with the users’ consent as necessary, of marketing materials and information needed to enable our services or to send suggestions and recommendations on services that could interest our users;
2.1.c. purposes of statistical research/analysis of aggregated or anonymous data, therefore without the possibility of identifying the users, intended to measure our site’s operations, measure its traffic and assess its usability and interest;
2.1.d. purposes related to the fulfilment of a legal obligation to which ITS is subject or related to the need to ascertain, exercise or defend a right in court, or any time that the authorities with jurisdiction perform their jurisdictional functions.
2.2. The legal basis for the processing of personal data for the purposes indicated in point 2.1.a) is the provision of a service or the response to a request which do not require consent under applicable law. The legal basis for the processing of personal data for the purposes indicated in point 2.1.b) is the consent of the users involved. The purpose indicated in point 2.1.c) does not involve the processing of personal data, while the purposes indicated in point 2.1.d) are lawful processing of personal data under applicable law.
2.3. Providing personal data for the purposes listed above is voluntary, but any failure to provide them could make it impossible to establish or continue a contractual relationship with the users or to respond to their request or to fulfil a legal obligation that we are subject to.
3.1. The processing of personal data is done through the use of appropriate tools and procedures to guarantee its security and confidentiality and can be done either using paper-based media or through the use of electronic tools.
4.1. The personal data we collect will be processed for the time strictly necessary to fulfil the purposes indicated in point 2. As an example, ITS will process personal data for its newsletter service until the users involved decide to unsubscribe from the service.
5.1. Personal data can be communicated for the purposes specified in point 2, with:
5.1.a. persons we authorise to process the personal data who are committed to its confidentiality or who have an appropriate legal confidentiality requirement (for example, ITS’ employees, associates and consultants), within the limits strictly necessary to perform their job;
5.1.b. courts with jurisdiction in the exercise of their functions when required by applicable law:
5.2. In no case will the personal data we collect be disseminated.
6.1. Some personal data are transferred to parties that might be located outside of the European Economic Area. ITS ensures that the electronic and paper-based processing of personal data by such parties will be done in compliance with applicable law and is based alternatively on a decision as to adequacy or on the Standard Model Clauses approved by the European Commission that guarantee adequate protection for the parties involved.
7.1. Within the limits of applicable law, users have the right at any time to ask ITS for access to their personal data, for its correction or deletion, or to deny consent to its processing, to limit its processing as well as to obtain – in a structured format that is commonly used and readable by an automatic device – the personal data about them.
7.2. Requests should be made by sending an email to the address info@its-platform.com.
7.3. Under applicable law, users have the right in any case to submit a complaint to the competent control authority (i.e., the Ireland data protection authority) if they believe that the processing of their personal data is contrary to the law in force.
8.1. ITS reserves the right to modify or simply update the contents of this privacy statement, in whole or in part, including because of changes in applicable law. To this end, we will inform our users of these changes as soon as they are introduced, and they will be binding as soon as they are published on our site. Therefore, ITS invites users to visit this section regularly to be aware of the most recent and current version of this privacy statement, so that they are always up to date on the personal data collected and how we use it.
Last updated: 20 March 2020