Privacy Policy

General Data Protection Regulation (EU) 2016/679 (GDPR)

1. Data Controller

The Data Controller is VRMEDIA SRL, responsible for the legitimate and correct use of your personal data and whom you can contact for any information or request at the following addresses:

 

Data Controller: VRMEDIA SRL

Head office: VIA UMBERTO FORTI 9 – 56121 PISA (PI)

 

Contact details and addresses:

Telephone:  +39 050/7846933

E-mail: GDPR@vrmedia.it

PEC: admin@pec.vrmedia.it

 

You may also contact the Data Protection Officer to obtain information and send inquiries about your data or to report disruptions or any issues you encountered.

VRMEDIA SRL appointed as Data Protection Officer AKSILIA S.R.L., with registered office at Via Fontana 22, Milan, VAT number and C.F. 02249540465 which you may contact using the following contact information:

 

Telephone: +39 0583 578787

E-mail: dpo@consilia.srl

PEC: dpo.consilia.srl@pec.it

 

The contact person appointed is Michela Turri, who can be reached using the above contact information and the following mobile phone number: +39 347 3674033.

2. Categories of data collected, purpose and legal basis

The Personal Data processed are collected as provided directly by the User / Data Subject or collected automatically through the site.

Data provided directly by the User/Data Subject:

The data provided directly by the User / Data Subject  includes all Personal Data entered by the same within the site or which are supplied to the Data Controller in any way. The data will be processed in compliance with the guarantees of confidentiality and security measures provided for by current legislation, also with the aid of electronic instruments directly and / or through third parties, for the purposes indicated below along with the legal basis of reference:

 

PURPOSE

PROCESSED DATA

LEGAL BASIS

A

Purposes strictly connected to the execution of pre-contractual measures and to respond to specific requests of the interested party.

 

Name, Surname, Email, Phone number, Company, Company Employee Profile

Contract of which the Data Subject is a party and / or  execution of pre-contractual measures adopted at the request of the Data Subject .

B

Exercise of the Data Controller’s rights, for example the right to defend in court

Name, Surname, Email, Phone number, Company, Company Employee Profile

Legitimate interest

C

Purposes of direct marketing and market research, in order to send newsletters, promotional and informative material

Name, Surname, Email, Phone number, Company, Company Emplyee Profile

Data subject consent

 

The User / Data Subject assumes the responsibility of third party Personal Data obtained, published or shared through this Application and guarantees that he has the right to communicate or disseminate them, freeing the Data Controller from any liability towards third parties.

 

Data automatically collected through the site:

The data automatically collected consists of information automatically collected through the website WWW.KIBER.TECH (also by third party applications integrated in this Application), including, for example: IP addresses or domain names of computers used by the User/Data Subject who connects with this site, Uniform Resource Identifiers (URIs), the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numeric code indicating the status response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal aspects of the visit (for example, the time spent on each page) and the details of the path followed within the Application, with particular reference to the sequence of pages visited, the parameters relating to the User/Data Subject’s operating system and IT environment. Full details on each type of data collected are provided in the dedicated sections of the Cookie Policy of this site.

 

The automatically collected data is processed exclusively for the purposes for which they are collected, as described below.

The Data Controller processes the data provided by the Users/Data Subjects in order to enable the operation of the website, the visualisation of content from external platforms, statistics, optimisation and distribution of traffic, as well as the additional purposes described in this document and in the Cookie Policy

3. Mandatory or optional nature of providing data and consequences of a refusal to provide data

The provision of data for the purposes referred to in point A and B is optional but necessary to execute the contract.

The provision of data for the purposes referred to in point C is optional and your data will be used with your prior consent; in case of no consent, your data will not be processed for the purpose described in afforementioned point.

Unless otherwise specified, all data requested for navigation on the site are mandatory. If the User/Data Subject refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain data as optional, the Users/Data Subjects are free to refrain from communicating such data, without this having any consequence on the availability of the Service or on its operation.

Users/Data Subjects who have any doubts as to which data is mandatory are encouraged to contact the Data Controller.

4. Processing methods

The Data Controller shall take appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of Personal Data.

The processing is carried out using IT and/or electronic telecommunication tools, within organisational procedures and for reasons strictly related and limited to the stated purposes.

5. Recipients

In addition to the personnel in charge of data processing, your data may also be communicated to the following subjects, who may also be appointed, if necessary, as Data Processors by the Data Controller:

  1. consultants and companies that assist the Company in terms of information technology and infrastructure;
  2. other companies, professionals and agents who collaborate with the Company for the performance of the services;

An updated list of Data Processors is always available on request from the Data Controller.

The data will not be subject to other methods of dissemination.

6. Processing Location

The Data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, contact the owner.

The data is processed at the Data Controller’s operational headquarters and in any other place where the parties involved in the processing are located. For further information, please contact the Data Controller.

The data collected automatically could be transferred to a country other than the one in which the User / Data Subject is located, even outside the European Economic Area. In this case VRMEDIA SRL. ensures that the processing of your personal data by these subjects to whom the data is transferred is in compliance with European Regulation 679/2016, and in any case in compliance with the principles indicated in art. 45 of the GDPR 2016/679 regarding the existence of an adequacy decision by the European Commission, or in the absence of such decisions in compliance with art. 46 relating to the transfer in the presence of adequate guarantees or in compliance with art. . b) – transfer necessary for the execution of a contract concluded between you and the Owner or for the execution of pre-contractual measures.

7. Retention Period

Data provided directly by the User/Data Subject

The Personal Data provided directly by the User/Data Subject and collected for the purpose of responding to specific requests and/or for the performance of pre-contractual/contractual negotiations will be processed and stored for the period of time necessary for the pursuit of the afforementioned purposes and in any case not beyond the terms of legal retention (currently 10 years from the time of termination of the contractual relationship) if the User/Data Subject is part of a contract with the Data Controller, and no more than 10 years from the time of collection in other cases.

The Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. In the event of a judgment pending, the data will be further processed until their resolution. Furthermore, the Data Controller may be obliged to keep the Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

The Personal Data collected for the purpose of direct marketing and market research, for the purpose of sending newsletters and advertising and informative material will be processed and stored for the period of time necessary for the pursuit of the purposes indicated above and in any case not beyond 2 years from their collection.

At the end of the retention period the Personal Data will be deleted. Therefore, upon expiration of this term, the right of access, cancellation, rectification and the right to the portability of the Data can no longer be exercised.

 

Data collected automatically through the website

The automatically collected data will be retained for the period specified in the Cookie Policy,

At the end of the retention period the Personal Data will be deleted. Therefore, upon expiration of this term the right of access, cancellation, rectification and the right to the portability of the Data can no longer be exercised.

8. Data Subject Rights

Pursuant to articles 15 to 22 of the GDPR each User / Data Subject has the right to obtain confirmation of the existence or otherwise of their Personal Data, even if not yet recorded, and their communication in an intelligible form.

In particular, the User/Data Subject has the right to obtain from the Data Controller information on:

  • the origin of the Personal Data;
  • the purpose and methods of processing;
  • the logic applied if the data are processed electronically;
  • the identification details of the Data Controller, the Data Processors and the Designated Representative;
  • the parties or categories of parties to whom the data may be disclosed or who may become aware of it as designated Representatives in a EU State Member, or as Data Processors.

 

In addition, the User/Data Subject has the right to obtain from the Data Controller:

  • the update, rectification or integration of his/her data;
  • the cancellation, transformation into anonymous form or object to the data processing in violation of the law;
  • access to his/her data, i.e. confirmation as to whether or not Personal Data concerning them are being processed;
  • the restriction of the processing;
  • the portability of the data, i.e. the right to receive in structured format the Personal Data concerning him/her;
  • the right to lodge a complaint with a Supervisory Authority.

 

Finally, the User/Data Subject has the right to object, in whole or in part, on legitimate grounds, to the processing of his/her Personal Data, even if pertinent to the collection purposes stated. In particular, the User/Data Subject has the right to object to the processing of his/her Personal Data for the purpose of sending commercial advertising material or for commercial communication purposes. The rights referred to in the previous points may be exercised by writing to the contacts indicated in point 1 of this Privacy Policy.