- Data Controller and Processors
Please note that the data controller is the company e4life S.r.l. (P.IVA 12981490969) (hereinafter, “e4life” or the “Data Controller”), with registered office at Via Santa Sofia 18, Milan, 21120, email: firstname.lastname@example.org. The full list of data processors is available upon written request sent to the above email address.
- Personal data collected
In particular, for the purposes indicated in section 4, paragraph a), the following types of data will be processed: (i) personal data (ii) biographical data, (iii) contact information (e-mail, cell phone, …), (iv) shipping data, (v) data related to user preferences.
The personal data collected may be freely provided by Users or, as in the case of browsing data, automatically collected during the use of this Website.
The computer systems and software procedures used to operate the Website acquire, during their normal operation, some data whose transmission is implicit in the use of Internet communication protocols.
This is information that does not allow the direct identification of the User / interested party, but which may, through processing and association with data held by third parties, allow the identification of Users / interested parties.
This category of data includes the IP addresses or domain names of the computers used by the Users who connect to websites, the URI addresses (Uniform Resource Identifier) of the requested resources, the time of the request, the method used to submit the requested request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment.
These data are not disclosed but are used only for the purpose of obtaining anonymous statistical information on the use of the Website and/or to check its correct functioning and are kept for the time necessary to pursue the purposes illustrated. In addition, the data could still be used to ascertain liability in the event of criminal or otherwise illegal activities carried out to the detriment of or through the Website.
- Data provided optionally by Users.
Apart from what has been specified for navigation data, the User is free to provide the personal data reported in the request forms on the Website or otherwise indicated in contacts with the facilities to request the sending of the newsletter, information material or other communications.
Failure to provide them may result in the impossibility of obtaining what has been requested.
Sending messages through the contact email box of this Website entails the subsequent acquisition of the sender’s email address, necessary to respond to email communications, name (corresponding to the email used) and what is included in the text of the message.
It is understood that if, for any reason, the communications forwarded by the User/concerned party, should be ulterior or unnecessary with respect to the processing that the Company carries out/intends to carry out for its users, the Data Controller reserves the right to proceed to the immediate deletion of the data or otherwise to process the data in such a way as not to create organizational and legal fallout that is deemed to be in conflict with e4life’s personal data management system.
- Purposes of processing
The purposes for which Users are asked to provide e4life with their personal data are as follows:
- to provide the User with the requested information;
- to enable the User to take advantage of the services made available through the Website;
- to manage the applications submitted through the Website;
- to allow the User to register on the Website;
- to allow the User to purchase via e-commerce;
- to comply with any legal and regulatory obligations (hereinafter referred to as “Legal Purposes”);
- to assert and defend rights in court;
- to send communications regarding the operation and updates of the device, as well as new features and/or services related to it (via email, SMS,…) (for those who have purchased the device);
- to monitor and analyze traffic data, by way of example for statistical purposes and tag management.
- Legal basis for processing
The Data Controller processes the User’s personal data under the following conditions:
- for the purposes a) to e) (“Contractual Purposes”), insofar as necessary for the purposes of access to the Website and for the use of specific services offered through the Website (Section 6, paragraph 1, (b) of the GDPR).
- for the Legal Purposes, as required under applicable laws (Section 6, paragraph 1, (c) of the GDPR).
- for the purposes g), h), i), for the pursuit of the legitimate interest of the Data Controller or of third parties (“Purposes of Legitimate Business Interest”) in the performance of economic operations within the meaning of Section 6, paragraph 1, (f) of the GDPR, appropriately balanced with the interests of the Users in that the processing is carried out to the extent strictly necessary for the performance of such operations.
The processing of data is optional but necessary for the pursuit of the purposes illustrated and so that e4life can render the services requested.
- Personal data processing methods
The User’s personal data are processed with the support of computerized means and are protected by appropriate security measures to ensure their confidentiality and security.
In particular, e4life takes appropriate organizational and technical measures to protect the personal data in its possession, aimed at preventing the loss and destruction of personal data as well as their unauthorized access, disclosure or modification.
- Scope of data communication and dissemination
e4life, for the purposes set out in Article 4, may communicate Users’ data, in close correlation with the purposes of the processing illustrated, to the following categories of entities:
- to the collaborators, employees and suppliers of e4life, within the scope of their respective duties and/or any contractual obligations with them, relating to business relations with Users;
- sub-suppliers and/or sub-contractors engaged in activities related to the performance of the services and products offered by e4life;
- to the other companies of the e4life group in Italy and abroad, national and international, in the manner set forth in paragraph 7 below.
The User’s personal data are not disclosed to unspecified parties other than those mentioned above.
- Transfers of personal data to third countries
Any transfer of the User’s personal data to countries outside the EEA will, in any event, take place in accordance with applicable law, without prejudice to the User’s statutory rights.
Where applicable, e4life will use the data protection guarantees provided for by Section 46 et seq. of the GDPR such as, but not limited to, standard contractual clauses. In other cases, the transfer of personal data may be based on an adequacy decision pursuant to Section 45 of the GDPR. The User may obtain a copy of the guarantees implemented by e4life, approved by the competent authorities, by sending a request to email@example.com.
- Personal data storage period
In order to determine the most appropriate storage periods for Users’ personal data, e4life has given special consideration to, among other things, the amount, nature and sensitivity of the personal data and the reasons for which they were collected. By way of example:
- the data collected for the Contractual Purposes referred to in paragraph 4 (a) shall be stored for the entire duration of the contract and for 10 years after the expiry of the contract for the purpose of defending and/or enforcing a right of e4life in and/or out of court in the event of disputes in connection with the performance of the contract;
- data collected for the Purposes of the Law as set out in paragraph 4 (b) will be stored for a period equal to the duration prescribed for each type of data by law;
- data collected for Purposes of Legitimate Business Interest as referred to in paragraph 5 (c) will be stored for a period of 24 months from the time of collection.
e4life reserves the right to store the personal data of Users for as long as liability may arise from the processing, in accordance with applicable current legislation, after which the User’s data will be deleted.
- Users’ Rights
The User may, at any time and free of charge, (a) obtain confirmation of the existence or non-existence of data concerning him/her and be informed of the same; (b) be informed of the source of the data, the purposes of the processing and its methods, as well as the logic applied to the processing carried out by electronic means; (c) request the updating, rectification or – if he/she is interested – integration of the data (d) obtain the deletion, transformation into anonymous form or blocking of any data processed in breach of the law, as well as object, on legitimate grounds, to the processing; (e) object, in whole or in part, to the processing of data concerning him/her for the purposes of direct marketing carried out by automated and/or traditional means; (f) withdraw, at any time, consent to the processing of data, without prejudice to the lawfulness of the processing based on the consent given before the revocation.
In addition to the rights listed above, pursuant to the Privacy Regulation, the User may at any time, in accordance with the procedures set out below (a) request the restriction of the processing of personal data in the event that (i) he or she disputes the accuracy of the personal data, for the period necessary to verify the accuracy of such personal data (ii) the processing is unlawful and the User objects to the deletion of the personal data and requests instead that its use be restricted; (iii) although e4life no longer needs the personal data for processing purposes, the personal data are necessary for the User to establish, exercise or defend a right in court; (iv) the User has objected to the processing pursuant to Art. 21(1) of the Privacy Regulation pending verification as to whether the data controller’s legitimate reasons prevail over those of the User; (b) object at any time to the processing of personal data, without prejudice to e4life’s right to assert any overriding legitimate reasons; (c) request the deletion of personal data concerning him/her without undue delay; (d) obtain the portability of personal data concerning him/her; (e) file a complaint with the Data Protection Authority where the conditions are met.
At any time, the User may exercise the above rights, change the contact details, notify e4life of any updates to his or her data, request the removal of his or her personal data communicated by third parties, or to obtain further information about e4life’s use of his or her personal data, by contacting e4life at the email address firstname.lastname@example.org.
- Changes and updates