At iGenius S.r.l. (hereinafter referred to as the “Company”) we take privacy and personal data protection very seriously. That’s why we redacted this document to provide you with information on the methods used to process your personal data, collected when browsing our website (https://igenius.ai/ - hereinafter referred to as the “Website”), communicating with our operators or using our live chat system.
With your consent, we can also use other information that you freely provide when requesting information, or that relates to the methods you use to communicate with us (hereinafter jointly referred to as “Data”).
This Privacy Notice (along with our Notice on Cookies and other notices that may be provided regarding individual services) sets out the basis on which your Data will be processed.1. What personal Data will we use?Browsing data It is possible to browse our website without being asked to provide any personal Data. However, during their normal operations, the IT systems used to manage the website acquire some personal Data that is automatically sent as part of the internet communication protocols used. This information is not collected with a view to associate it with specific individuals, but due to its nature, processing and associations could be conducted to identify who is browsing the website.
This category includes, for instance, IP addresses of the computers connecting to the website, the URL of the resources requested and the time of the request.
This Data is used anonymously for statistical purposes related to the use of the website and to check it is operating correctly, and it is deleted immediately after it is processed. This information will not be used for Data processing to directly identify individuals.
2. For what purposes will we use your Data and on the basis of which legal requirements?We will use your Data, occasionally with the use of electronic systems:
- a) To provide you with the information requested. Your Data will be used to fulfil your requests for information;
- b) To meet legal obligations or comply with any orders from legal authorities.
Providing your Data is optional but refusal to do so, in part or in full, may prevent us from correctly meeting your specific requests. With your consent, we can also use your Data for the following purposes:
- c) sending you newsletters, information about products and services provided by the Company (also about products or services different from those you purchased), offers and promotions, and for carrying out market research. For example, we may send you emails or instant messages (e.g. text messages), or an operator may contact you by phone.
- d) Studying your preferences and the methods you use to communicate with us. In particular, in order to gain a better understanding of your tastes and interests in our products and services, we may examine, occasionally using automated systems, the information provided when you send information requests, and your interest in communications and newsletters we send you. In any case, these profiling activities are not capable of producing legal effects in your regard or of having significant effects on you as an individual.
The provision of services and/or the handling of information you request will not in any way be affected by whether you give consent as set out above in c) and d) of Section 2.
In light of what mentioned above, “lawfulness of processing”, as per EU Regulation EU n. 679/2016 (General Data Protection Regulation or GDPR), can be specifically:
- For the purposes defined in 2.a), taking steps at your request, including for the performance of a contract or prior to entering into a contract (GDPR Art. 6.1.b.);
- For the purposes defined in 2.b), complying with a legal obligation to which we are subject (GDPR Art. 6.1.c);
- For the purposes defined in 2.c) e 2.d), your free, specific, informed and unequivocal consent (GDPR Art. 6.1.a).
3. How long will we keep your Data for?Your Data will only be processed for the period of time strictly necessary to fulfil the purposes for which they were collected, with regard to the regulations in force.
In any case, for the purposes of marketing and/or profiling (per c) and d) of Section 2), Data regarding the details of your purchases will not be processed for a period exceeding 12 months. In the same way, information regarding your communications with us will not be retained for a period exceeding 12 months.4. Who will we share your Data with?Your Data may be shared, including for administrative purposes, with subsidiary, parent and partner companies of iGenius and, for the purposes of delivering the services requested, with service providers involved in activities carried out by iGenius (e.g. IT services). These parties (e.g. Mailchimp for email marketing) will occupy the role of Data Processors.5. How will the transfer of your Data to countries outside the EU be regulated?Your Data may be transferred outside the territory of the European Union, including to countries where the level of personal data protection may be less stringent than that ensured by European regulations. In any event, such transfers shall take place in compliance with appropriate guarantees for the protection of your Data; in particular, the standard contractual clauses approved by the EU Commission in Decision No 2010/87/EC. for In particular, data sent transfers to third parties based in the USA (e.g. Mailchimp) will comply with the EU Commission Implementing Decision of 12 July 2016 (Privacy Shield) and subsequent amendments.6. What rights can you exercise?You have the right to request access to your Data, to correct or delete your Data, to restrict the processing of your Data and to object to its use by us, as well as the right to request your Data to be sent to you.
Rights of the Data Subject:Right to accessThe data subject has the right to obtain confirmation from the data controller as to whether his/her personal Data is being processed and, if so, to obtain access to the personal Data and the following information:
Right of correctionThe data subject has the right to demand the correction of inaccurate personal data about him/her from the data controller without any unjustified delay.Right to deletionThe data subject has the right to demand the deletion of his/her personal data without any unjustified delay and the data controller must delete the personal data without any unjustified delay, if any of the following situations apply:
- a) the purposes of the processing;
- b) the categories of personal Data in question;
- c) the recipients or categories of recipients with which the personal Data hsa been or will be shared, especially if they are recipients in third countries or international organizations and, if so, the appropriate guarantees in place;
- d) where possible, the planned period of retention of the personal Data or, if not possible, the criteria used to determine this period;
- e) the right of the data subject to request the data controller to correct or delete his/her personal data, restrict the processing of his/her personal data or to object to it being processed;
- f) the right to file a complaint with a supervisory authority;
- g) if the Data were not collected from the data subject, all information available on its source;
- h) whether an automated decision-making process, including profiling, is used, which produces legal effects regarding the data subject or which similarly has a significant effect on him/her as an individual and, in at least these cases, meaningful information on the approach used and the importance and expected consequences of such processing for the data subject.
Rights to restrict processingThe data subject has the right to request the data controller to restrict the data processing in any of the following cases:
- a) the personal data is no longer necessary with regard to the purposes for which it was collected or otherwise processed;
- b) the data subject withdraws the consent on which the data processing is based and there is no other legal basis for it;
- c) the data subject objects to the data processing, and there is no legitimate prevailing reason to continue the processing;
- d) the personal data has been illegitimately processed;
- e) the personal data must be deleted in order to comply with a legal obligation set out by the law of the European Union or the law of a Member State to which the data controller is subject;
Right to objectThe data subject has the right to object to the processing of his/her personal data at any time based on the legitimate interests of the data controller, including profiling. The data subject also has the right to object to the processing of his/her personal data carried out for direct marketing purposes, including profiling when it is connected to direct marketing.Right to data portabilityThe data subject has the right to receive his/her personal data in a structured, commonly used and machine-readable format from the data controller and has the right to send this data to another data controller without hindrance from the data controller to which the data have been provided, if:
- a) the data subject challenges the accuracy of the personal data, for the time period necessary for the data controller to check the accuracy of the personal data in question;
- b) the processing is illegitimate and the data subject objects to the deletion of the personal data and instead requests for its use to be restricted;
- c) although the data controller no longer needs it for the purposes of the processing, personal data is necessary for the data subject to establish, exercise or defend a right in court;
- d) the data subject objects to the data processing, for the time period necessary to check whether the data controller has any legitimate reasons to continue the processing that prevail over those of the data subject.
- a) the processing is based on consent or a contract; and
- b) the processing is carried out using automated methods.
By exercising his/her rights to the portability of data, the data subject has the right to request the direct transmission of personal data from one data controller to another, if technically feasible.7. How can you modify your preferences or withdraw your consent?You can check, modify or withdraw your consent with regard to the purposes set out in letters (c) and (d) of Section 2 via the link in the newsletter, which we will send you, or by contacting the Company.8. How can you contact iGenius in order to exercise your rights?You can exercise your rights by writing to the data controller, iGenius S.r.l. using the details below:
Via Manin, 3
Operational headquarters: Via Principe Amedeo, 5 – 20121 Milan
Certified email: email@example.com
Data Protection Officer: firstname.lastname@example.org
9. How can you contact the competent supervisory authority to make a complaint?Any complaints can be filed with the Italian Data Protection Authority (Autorità Garante per la Protezione dei Dati Personali) which can be contacted using the details below, or with your competent supervisory authority:
Garante per la Protezione dei Dati Personali
Piazza Venezia, 11
Fax: (+39) 06.69677.3785
Tel: (+39) 06.696771
Certified email: email@example.comChanges to this privacy noticeThis privacy notice may be amended or updated, in full or in part, which may be as a result of changes to the applicable law. We will keep you informed of any substantial changes which affect how your Data is processed.
In any case, we invite you to periodically consult the updated privacy notice published on the Website.
For Users outside of the European Economic Area (EEA)
For users outside the EEA (especially in the United States) iGenius S.r.l. (hereinafter referred to as “iGenius”) adds the following provisions. (The “EEA” includes the member state of the European Union and Lichtenstein, Norway and Iceland).Types of Information We Collect or ReceiveLike most other websites, the iGenius Site is structured to collect or receive information when you visit.
Non-personal Information. When you visit the iGenius Site, we receive non-personal information, which is information about things like your IP address, browser and operating system. This is done through “cookies,” which are small files with unique ID numbers. Our cookies do not allow us to learn your real name and address.
Personal Information. We receive more detailed personally-identifiable information from you when you provide us with your personal information such as sign up for a newsletter or contact us. Naturally, this information could include your name, email address and such other information that could identify you.
Advertising Information. Some information created by cookies involves how users such as you navigate the iGenius Site. We do not display ads on the iGenius Site.How Do We Use the Information We Collect?We use the information in several ways, among them to: respond to your requests; improve the iGenius services, including customizing them to your preferences; and to inform you of certain changes in those products and services. We may transfer the data across state and country borders for the purposes of data consolidation, storage and simplified customer information management, which will be done as specified in the privacy notice above. When you sign up for a newsletter you have the opportunity to specify how we use the information you provide. You can opt out of receiving such materials through the procedures included in them.
We don’t sell or trade your personal information. We don’t share the personal information except for limited purposes of running our business by using the services of third parties that have agreed with us to keep such information secure. These would include, for example, cloud storage providers, email services for newsletters and its use by our subsidiaries in the same manner as we have described. We may have to disclose information if we believe that it is appropriate or necessary for legal reasons (such as a government request, court order or legal process served on us).Opting Out of Third Party CookiesYour browser may be set to a default that accepts cookies, but usually you can modify those settings to reject cookies. If you do so, please understand that some of the features of the iGenius Services or parts of the iGenius Site might be disabled. You can also opt out of customized Google Display Network ads by visiting the Google Ads Preference Manager.Additional California DisclosuresShine the Light. Under the California law known as the “Shine the Light” law (Civil Code Section 1798.83) California users have the right to prevent us from disclosing the information you provide to third parties for direct marketing purposes by those third parties. We are also required by the law to respond to your request about our practice of disclosing such information to such third parties. We do not have any practice of such disclosure. If we ever start doing so then we will let you know and give you the opportunity to opt out.
Via Manin, 3
Operational headquarters: Via Principe Amedeo, 5 – 20121 Milan
Certified email: firstname.lastname@example.org
Data Protection Officer: email@example.com
The Data Controller is iGenius S.r.l. (registered at Via Manin, 3, 20121, Milan, Italy, operational headquarters: Via Principe Amedeo, 5 – 20121 Milan).
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