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Privacy Policy

Privacy Policy of www.ice-flex.com

PRIVACY Information document Article 13/14 EU Reg. 2016 / 679- GDPR – 

Owner and Data Controller (art. 4 and 24 of GDPR 2016/679), is:

ICE-Flex srl - Via Bergamo n. 5, 21047 Saronno (VA), Phone: 02 25061085,

Owner contact email: info@ice-flex.com

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: email address, password, Cookies, Usage Data, Data communicated while using the service, first name, last name, Email and various types of Data.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.


MODE AND PLACE OF PROCESSING THA DATA

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The personal data provided will be processed, in compliance with the conditions of lawfulness pursuant to art. 6 GDPR 2016/679, for the following purposes:

  • data collection for the receipt of information to the general, commercial and administrative management via e-mail - consent (Article 6 paragraph 1 letter a) as the legal basis of the processing.
  • the processing is necessary for the execution of a contract with the User and / or the execution of pre-contractual measures;
  • the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
  • processing is necessary for the performance of a task carried out in the public interest or for the exercise of public authority vested in the Holder;
  • processing is necessary for the pursuit of the legitimate interest of the owner or third parties.

It should be noted to the Users with whom the Company has maintained contractual relationships, that the Company may send them communications relating to services and products similar to those that have been the subject of the aforementioned reports, in compliance with all applicable legal provisions and guidelines, except for their dissent pursuant to art. 21, paragraph 2 GDPR.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

 The subjects belonging to the aforesaid categories perform the function of Data Processing Manager, or operate in complete autonomy as separate Data Controllers. The list of data processors is constantly updated and available by writing to info@ice-flex.com

 or at the registered office of the Data Controller in Via Bergamo n. 5, 21047 Saronno (VA).

Data transfer outside EU 

The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.. The data will be transferred according to Article 44 - General principle for the transfer; Article 45 - Transfer on the basis of an adequacy decision; Article 46 - Transfer subject to adequate guarantees, specifically the data will be transferred to third countries international organizations for which the Commission has intervened with an adequacy assessment (Article 45 GDPR 2016/679). The interested party can obtain information about the guarantees for data transfer by writing an email to info@ice-flex.com or at the registered office of the Owner in Via Bergamo 5, 21047 Saronno (VA).

Retention time


Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

 In compliance with the provisions of art. 5 paragraph 1 letter e) of GDPR 2016/679 the personal data collected will be stored in a form that allows identification of data subjects for a period of time not exceeding the achievement of the purposes for which the personal data are processed. The retention of personal data provided depends on the purpose of the processing:

- receive newsletters or promotional communications in general via e-mail (maximum 24 months).

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User, Registration and authentication, Access to third party services' accounts, Analytics, Interaction with support and feedback platforms, Managing support and contact requests, Displaying content from external platforms, Managing contacts and sending messages, Hosting and backend infrastructure, Remarketing and behavioral targeting, Interaction with external social networks and platforms, Interaction with live chat platforms, Infrastructure monitoring, Handling payments, User database management, Commercial affiliation, Tag Management and Data transfer outside the EU.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

The rights of Users

You can assert your rights as expressed in Articles 15, 16, 17, 18, 19, 20, 21, 22 of GDPR 2016/679, by contacting the Data Controller, or the Data Processor, by mail: info@ice-flex.com.

The requests are filed for free and processed by the Data Controller as soon as possible, in any case in 1 month

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities. 

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenace 

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Website does not support "Do Not Track" requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. 
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required. 

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person. 

Usage Data

 Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment. 

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject. 

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This website

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Application as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies

Small piece of data stored in the User's device.

Email

Provides access to the User's primary email address.


Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this Application, if not stated otherwise within this document.