The data controller is Inclusive S.r.l. (VAT number 05173250282) (hereinafter referred to as “Inclusive” or “we”) with registered office in Piazza Alcide De Gasperi 45/A, ZIP code 35131 – Padua. The Data Controller can be contacted by PEC or email at firstname.lastname@example.org or email@example.com
Data processed and processing methods
Data provided to us on a voluntary basis.
Data subsequently collected by us.
Browsing data collected automatically.
When you access the Website, the computer systems and software procedures used to operate it automatically collect your browsing data. These include your IP address or the domain name of your computer, the addresses of the websites from which you have accessed the Website (by referral), the addresses of the requested resources in URI (Uniform Resource Identifier) notation, the time of such requests, the method used for submitting a given request to the server, the returned file size, the numerical code indicating the web server response status, and other parameters relating to your browser type (eg Internet Explorer, Google Chrome, Firefox), operating system (eg Windows) and IT environment. These data are acquired through technical and analytical cookies and are treated in an aggregate and anonymous form. This Website does not use any profiling cookies.
Purpose and lawfulness of processing
We process your personal data:
with your consent
- to improve and maintain our Website, based on our legitimate interest in improving our offer;
- in order to assign you the role of SOQUA ambassador and to provide you with the relevant benefits, where necessary for the execution of the pre-contractual measures requested by you and/or for the correct execution of the contract;
- for the administrative and tax management of your role as ambassador, as necessary for the fulfilment of our tax and accounting obligations;
- to manage any disputes, where necessary to defend or assert our right in court.
Providing your data for the purposes under v. and vi. is a prerequisite for starting your contract as a SOQUA ambassador. Failure to provide your data will affect your ability to enter into a business relationship with us.
Your personal data will not be disseminated.
For the purposes indicated above, your personal data may, however, be disclosed to some specific categories of subjects such as:
- employees and collaborators of Inclusive, in their capacity as persons authorised to process data and/or system administrators;
- third parties who perform specific tasks or services that are necessary to fulfil the aforementioned purposes, operating as data processors (e.g. providers of IT services and infrastructures, consultants and professionals who offer banking, administrative, accounting and legal services, individuals who provide promotional and communication services in general, including the organisation of meetings and events aimed at promoting our services);
- Judicial or administrative authorities for the fulfilment of legal obligations.
The list of recipients can be made available to you at your request.
The personal data you provide for the purpose of obtaining information on the SOQUA App and its services are processed only to the extent necessary to reply.
If you have agreed to the processing of your data for marketing purposes, your data will be processed for a period not exceeding 2 (two) years from the time of their collection.
For the administrative and accounting management of your relationship with Inclusive in your role as SOQUA ambassador, your personal, tax and contact details will be processed for the entire duration of the contract and subsequently for 10 (ten) years from its termination to comply with accounting and tax obligations. In the event of a dispute, your data will also be processed for as long as necessary to manage the dispute. At the end of the retention period as identified above, personal data will be irreversibly anonymised or destroyed securely.
International data transfers
Your personal data are stored on servers located both within the EU/EEA area or transferred to third countries, such as the USA, which ensure adequate levels of data protection based on the assessments made by the EU Commission.
Your personal data are not subject to any fully automated decision-making process, including profiling.
Your rights according to articles 15 to 22 of the GDPR
You can at any time:
- request access to your personal data and any relevant information; the correction of inaccurate data or the integration of incomplete ones; the cancellation of personal data concerning you (upon the occurrence of one of the conditions indicated in art. 17, paragraph 1 of the GDPR and in compliance with the exceptions provided for in paragraph 3 of the same article); restrict the processing of your personal data (upon the occurrence of one of the conditions indicated in article 18, paragraph 1 of the GDPR);
- request and obtain – in the event that the legal basis for the processing is a contract or consent, and the same is done in an automated way – that your personal data is transferred to you in structured, machine-readable formats, also in order to disclose such data to another data controller (the so-called right to data portability);
- object at any time to the processing of your personal data in the event of particular situations concerning you as well as, even regardless of the occurrence of such situations, to the processing of your data for direct marketing purposes.
How to exercise your rights
You can exercise your rights at any time by sending a registered letter with return receipt to Inclusive S.r.l., Piazza Alcide De Gasperi n. 45 / A, CAP 35131 – Padua, or a certified/regular e-mail to firstname.lastname@example.org or email@example.com, or by filling in and sending to the above addresses the relevant form that you can download from the Italian Data Protection Authority website under “Forms and online services”.
Right to complain
If you believe that the processing of your personal data carried out through this website breeches the provisions of the GDPR, you can lodge a complaint with the Italian Data protection Authority – www.garanteprivacy.it, based in Piazza Venezia 11, IT-00187 , Rome, e-mail: firstname.lastname@example.org, pec: email@example.com., or take legal action in the competent court.