Studio Archipass (hereinafter Archipass) aims to inform users of the website www.studioarchipass.it of the policy adopted for the processing of Personal Data through the site, and to highlight its commitment and attention to safeguarding their privacy. This statement is also provided pursuant to the General Data Protection Regulation (GDPR) (EU2016/679) and the Italian Privacy Code (DL 196/2003). In accordance with the provisions of the GDPR, the processing operations will comply with the principles of lawfulness, fairness, transparency, purpose and retention limitation, data minimization, accuracy, integrity and confidentiality.
Types of data collected and purposes of processing
According to the GDPR, Personal Data means any information relating to users and that identifies them personally, either alone or in combination with other information. When you visit this website, Archipass only collects and stores personal data if you actively communicate it via multiple sources. Personal information is collected automatically by the site or received via multiple sources: forms, email, social media and other means. Notwithstanding the above basic conditions, however, the web server of the host automatically registers information about accesses to the website (Browsing or Usage Data). Among the types of Personal Data that this site collects, by itself or through third parties, there are: First name, Last name, Address, Phone number, Company, various types of data as Usage Data, and Cookies. Archipass do not requires, or collects, any sensitive personal information, that is, according to the provisions of the GDPR (Art. 9), personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, data concerning health or sexual orientation.
This site collects non-sensitive browsing data by automatic means in order to enable and improve user navigation (e.g., IP address, date/time of the visit and its length, any referring URL, the pages visited on the site, the device used and other information). The processing of such information allows you to access the site and fully enjoy its features and services. Furthermore, browsing data may be used to verify that the site is functioning properly. From time to time, browsing data are processed anonymously for statistical purposes. Browsing data are stored only temporarily in compliance with the applicable law. In particular your IP address will be processed during the connection process so that Archipass can make this website available to you. It is based on Art. 6 para. 1 lit. f) GDPR. Archipass’ legitimate interest is in the stated purpose. Browsing data could be also used to ascertain responsibility in case of hypothetical crimes against the site.
Data provided voluntarily
The optional, explicit and voluntary submission of personal data through this site involves the subsequent acquisition of your provided data, necessary for the provision of the requested service. In particular:
Archipass offers you the possibility to contact by means of an online form. To do this, you must provide Archipass with your e-mail address so that we can respond to your request. You can also tell us your name and a specific message. Analogously when you contact Archipass at the email addresses provided on this website, at least provide Archipass with your email address and any other information you may provide in your e-mail. In order to be able to process your request, Archipass must process this data. The legal basis is Art. 6 para. 1 lit. f) GDPR. Archipass’ legitimate interest lies in the purpose just mentioned.
Connection to third-party websites or platforms
The site may contain links to other third-party websites or platforms, such as social networks likeFacebook, Twitter, Google+, Pinterest and others. Archipass cannot control the usage of cookies or other monitoring technologies of such websites to which this Policy does not apply, so Archipass cannot be held responsible for their conduct with respect to privacy law. You are encouraged to read their privacy policies to verify how they collect and process personal information.
Retention of Personal Information
Personal information collected by this site will be kept – for each type of data processed – only as long as it is needed to provide you with the required services or to meet legal or tax obligations or for the minimum period prescribed by the law. In order to determine the appropriate retention period for personal information collected and stored by the site under your consent, Archipass will take into account multiple factors to ensure that personal information is not stored for longer than the necessary or appropriate period, including:
– the purpose for which we site holds personal information;
– legal, tax and regulatory obligations in relation to that personal information;
– any specific request in relation to the deletion of personal information;
– legitimate business interests.
Archipass will promptly delete or anonymize personal information that is no longer needed or retained according to the law.
Legal basis of processing
The legal basis of the processing of Personal Data is art. 6 of the GDPR, if one of the following applies:
– the consent has been given for one or more specific purposes;
– provision of data is necessary for the performance of an agreement and/or for any pre-contractual obligations thereof;
– processing is necessary for compliance with a legal obligation;
– processing is related to a task that is carried out in the public interest or in the exercise of official authority;
– processing is necessary for the purposes of the legitimate interests.
Mandatory or optional nature of processing
You have no contractual or legal obligation to provide Archipass with personal information. So, apart from what is specified for browsing data, you are free to provide personal information optionally, explicitly and voluntarily, according to the above-mentioned purposes. However, failure to provide them may make it impossible to complete the request.
Processing methods and security measures
Personal information is processed with IT, automated and electronic tools and, in limited cases, by using documentary means, following organizational procedures and modes strictly related to the purposes indicated. In accordance with the GDPR, Archipass applies all industry standard security measures to protect your personal information as is available within the hosting services, software, plugins and addons we use. Specific security measures have been implemented to prevent data loss, unlawful or improper use, and unauthorized access, including data encryption (SSL/TLS) and plugins that enable firewall against common types of attacks, and protect the site from known security vulnerabilities, hacks and malware.
While Archipass adopts primary security measures, at the same time it cannot exclude the safety risks that are naturally involved by online transmission of data. You accept the inherent risks of providing personal information over the internet and will not hold Archipass responsible for any breach of security, unless this breach is due negligence or willful default.
Place of processing
Personal Data are processed at Archipass’ offices in Milan and London, and in any other places where the parties involved in the processing are located.
Communication and transfer of data
Personal Data are processed by Archipass’ internal staff duly authorized to do so under their respective job duties. Whenever necessary and/or instrumental to the above-mentioned purposes, they may also be processed by third parties, appointed, if necessary, as Data Processors: companies and consultants firms providing assistance and/or consulting or performing related services on behalf of us, e.g. hosting, maintenance of IT systems, updating of the website. Archipass will not transfer any personal information outside the European Economic Area (EEA), unless you have explicitly authorized such transfer or the transfer of personal information outside the EEA is allowed by the GDPR on another legal basis. Personal Data shall not under any circumstances be disseminated to unknown persons.
Additional information about Data collection and processing
Specific information not contained in this policy: more details concerning the collection or processing of Personal Data may be requested at any time. Please use the contact email: firstname.lastname@example.org.
System logs and maintenance: for operation and maintenance purposes, this website and any third-party services may collect files that record interaction with the website itself (System logs) and use other Personal Data (such as the IP Address) for this purpose.
“Do Not Track” requests: this site do 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 and other specific sections in this statement.
Under the GDPR you are entitled to receive confirmation as to whether Archipass hold any personal information about you. If you would like to request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to Archipass, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact Archipass by writing at email@example.com. Archipass will respond to your request consistent with applicable law. In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from Archipass’ database or otherwise let Archipass know what limitations you would like to put on the use of your Personal Information. In any case, you will always be entitled to file a complaint with the competent supervisory authority (the Italian Data Protection Authority, www.garanteprivacy.it), pursuant to art. 77 of the GDPR, if you believe that the processing of your data violates applicable law.