EFFECTIVE April 20, 2020
SOUNDREEF MEDIA SERVICE
The present privacy policy is provided, in accordance with the Article 13 of the Regulation 2016/679 (hereinafter, “GDPR”) and the Code on personal data protection, D.lgs 196/2003 (hereinafter “Code”), by SOUNDREEF MEDIA SERVICE (henceforth, for brevity “SMS”), with registered office in Via del Lauro, 14 – 20121 Milan, such as data controller and for all the purposes of processing, that are described after. In this policy we will explain to you the purpose and the way in which SMS collects and processes your personal data, which categories of data are processed, what are your rights as a data controller and how they can be exercised.
Before giving any personal information, we invite you to read this privacy policy carefully. We inform you that the present privacy policy could be subject of some updates in future, in compliance with national and European legislation; therefore, we invite you to check this page constantly in order to know any modifications.
Categories of personal data
The Web site offers informative and illustrative contents. During the browsing activities, it’s possible to collect some visitor’s information, in the following ways:
1. Navigational information (browsing data)
The computer systems and software used by the site acquire certain personal data in the normal course of the service, which is implicit to be able to use the Internet communications protocols.
This category of data includes: IP addresses, the type of browser used, the operating system, the domain name and addresses of websites from which access or exit has been made, information about the pages visited by users within the Site, the time of access, the permanence on the single page, the analysis of internal path and other relative parameters to the operating system and the computer environment of the user.
2. Data collected using cookies or similar technologies
Cookies or similar tracking technologies may be used by SMS or by third-party service providers to provide the best browsing experience and for other purposes described in the Cookie Policy.
3. Data provided for newsletter subscription
When subscribing to the newsletter service, users must provide their email address. A confirmation email will be sent to validate the subscription.
4. Data provided when activating an account or contacting support
When registering on the website, accessing the reserved area or contacting customer service, SMS may request personal data such as name, email address and website address.
Any additional information voluntarily provided through contact forms or customer support will be processed in accordance with GDPR principles.
SMS does not collect sensitive data pursuant to Article 9 of the GDPR.
Processing place and method
Personal data processing takes place at the offices of SMS or within the European Union and may be carried out on servers of authorized third-party providers acting as data processors.
Processing may be performed using electronic tools, telematic systems or paper archives strictly related to the processing purposes.
Processing purposes and legal basis
1. Establishment and execution of a contract
Personal data are processed to establish contractual relationships and provide requested services including service purchases, newsletter subscriptions, contact requests and customer support.
2. Compliance with legal obligations
Personal data may be processed to comply with legal obligations such as tax obligations, invoicing and payment management.
3. Legitimate interests of SMS
Personal data may also be processed to exercise or defend legal rights or protect the interests of SMS or third parties.
4. Processing based on consent
With the user's consent, SMS may analyze data relating to website usage and interaction with services. Consent may be withdrawn at any time.
Recipients of personal data
Personal data may be shared with third parties necessary for the operation of services including administrative service providers, consultants, public administrations, social security institutions, credit institutions for payments and corporate bodies.
These parties act as data processors pursuant to Article 28 GDPR.
Data retention period
Service purchase data are retained for the duration of the contract and up to 12 years after termination.
Newsletter data are retained until consent withdrawal.
Account data are retained until account deactivation.
Support requests are retained until the request is resolved and for a maximum of three months afterwards.
Rights of data subjects
Users have the right to access their personal data, request correction or deletion, request restriction of processing, request data portability and object to processing.
Requests can be sent to [email protected].
Users may also file complaints with the Italian Data Protection Authority: www.garanteprivacy.it.
Milan, April 20, 2020