PUNTO COM CONSULTING s.r.l. protects the privacy of visitors to its website www.puntocom-consulting.it (hereinafter, the “Site”) by adopting all measures most suitable for the protection of personal data in accordance with legal provisions. This policy describes the processing of information provided by visitors to PUNTO COM CONSULTING s.r.l.’s website and the processing of personal data. Any “personal data” collected through the Site will be processed in accordance with EU Regulation 2016/679 (“General Data Protection Regulation” GDPR).

This policy is intended for all individuals who interact with the pages of the Site and those who send emails to the email addresses of this Site.

This information is provided pursuant to Article 13 GDPR. The processing of data takes place in compliance with the rights of fundamental freedoms, as well as the dignity of the data subject, with particular reference to confidentiality, personal identity, and the right to the protection of personal data. Pursuant to Article 13 of the GDPR, we provide you with the following information:

Data Controller

The data controller is PUNTO COM CONSULTING s.r.l. with registered office at:

Via Don Giuseppe Grazioli 71, 38122 Trento (Italy)

All requests and inquiries regarding the processing of personal data can be addressed to the aforementioned Data Controller at the same address or via email at info@puntocom-consulting.it.

Data Collection

Data is collected through the submission of requests via email to the addresses indicated on the Site.

The optional, explicit, and voluntary sending of emails to the addresses indicated on this Site entails the subsequent acquisition, by PUNTO COM CONSULTING s.r.l., of the sender’s email address, necessary to respond to the sender’s requests, as well as any other relevant personal data.

The provision of personal data is optional. The partial or total failure to provide data by the Site visitor will result in the partial or total impossibility of achieving the purposes for which the data is provided to PUNTO COM CONSULTING s.r.l., and therefore the impossibility of responding to any requests submitted through the Site.

Other information collected by PUNTO COM CONSULTING s.r.l. may be provided automatically when accessing the Site. These are pieces of information not collected to be associated with identified data subjects; by their very nature, these, through processing and associations with data held by third parties but anonymized, do not allow the identification of users.

The personal data provided, collected, and made available to PUNTO COM CONSULTING s.r.l. will be processed using electronic and non-electronic tools.

Processing Purposes and Legal Basis

The processing of personal data (including their registration in PUNTO COM CONSULTING s.r.l.’s databases) is aimed at achieving the following purposes:

• Ensuring registration on the Site and the correct provision of the content and services offered by PUNTO COM CONSULTING s.r.l. (Legal Basis: Performance of a Contract);
• Communicating with the Site user and responding to any requests from the user (Legal Basis: Legitimate Interest);
• Conducting market research and statistical surveys (Legal Basis: Legitimate Interest or Consent, where applicable);
• Evaluating the use of the Site and its content (Legal Basis: Legitimate Interest);
• Improving the products and services offered by PUNTO COM CONSULTING s.r.l. (Legal Basis: Legitimate Interest);
• Making communications related to press conferences and/or sending press materials (only for journalists) (Legal Basis: Consent);
• Carrying out treatments in connection with PUNTO COM CONSULTING s.r.l.’s activity (Legal Basis: Legitimate Interest).

Your consent to the processing of data for one or more of the above purposes may be revoked at any time.

Information Storage

Personal data will be kept for the period necessary to ensure the correct provision of services offered by PUNTO COM CONSULTING s.r.l. and in compliance with legal obligations. Specifically:

• Data collected for contractual purposes: stored for the duration of the contract and for an additional 10 years after contract termination (for legal and tax obligations);
• Data collected for marketing purposes: stored until consent is withdrawn;
• Data collected for statistical purposes: stored in aggregated form where possible, otherwise for a maximum of 24 months.

After these periods, the data will be securely deleted or anonymized.

Communication – Dissemination

PUNTO COM CONSULTING s.r.l. may transfer personal data, possibly collected through the Site, also outside the European Union, to external service companies, even only for technical-computer reasons. In these cases, the transfer of data will take place in accordance with GDPR provisions and only where:

• The recipient country ensures an adequate level of protection as determined by the European Commission;
• Standard Contractual Clauses approved by the European Commission are used;
• Other appropriate safeguards are implemented as required by GDPR.

Personal data may also be disclosed to:

1. Public Authorities who have access to personal data by virtue of regulatory or administrative provisions;
2. Companies, consultants, or professionals entrusted with the sale of products used by PUNTO COM CONSULTING s.r.l.;
3. Public and/or private subjects, where communication is necessary to fulfill obligations arising from the law.

Other Websites

The Site may contain links to third-party applications and other websites. This privacy policy applies only to this Site. Please refer to the respective privacy policies of third-party sites.

Consent

By using the Site, the user consents to the collection and use of information by PUNTO COM CONSULTING s.r.l. according to this policy. If PUNTO COM CONSULTING s.r.l. decides to change this policy, such changes will be posted on this page. By continuing to use the Site, the user accepts such changes. Periodically check this page for updates.

Rights of Data Subjects

Pursuant to Articles 15 – 20 of the GDPR, the data subject has the right to:

1. Access their data and obtain confirmation of the existence or not of personal data;
2. Obtain access to the information referred to in Article 15(1) GDPR, and in particular receive:
   • Indications regarding the purposes, methods of processing, and categories of data concerned;
   • Information on the subjects or categories of subjects to whom the data may be communicated;
3. Request the rectification of inaccurate personal data;
4. Request the erasure of their personal data in the cases provided for by Article 17 of the GDPR;
5. Request the restriction of processing in the cases provided for by Article 18 of the GDPR;
6. Receive their personal data in a structured, commonly used, and machine-readable format;
7. Object at any time, on grounds relating to their particular situation, to the processing of their personal data;
8. Lodge a complaint with a supervisory authority if they believe that the processing of their personal data violates applicable data protection regulations.

To exercise these rights, the data subject may contact PUNTO COM CONSULTING s.r.l. via email at info@puntocom-consulting.it.