Privacy Policy

To obtain information about your collected personal data, the purposes, and the entities with whom the data is shared, please contact the Data Controller.

Data Controller

IN3 Sarl VAT FR19502755432 – 20 rue Vignoles 75020 Paris – Data Controller Email: info@hkeitalia.com

Types of Collected Data

The Data Controller does not provide a list of types of Personal Data collected. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed before the data collection itself. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application. Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to provide it, this Application may be unable to provide the Service. In cases where this Application indicates some Data as optional, Users are free to refrain from communicating such Data, without this affecting the availability or operation of the Service. Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller. Any use of Cookies – or other tracking tools – by this Application or third-party service providers used by this Application is for the purpose of providing the Service requested by the User, as well as for any other purposes described in this document and in the Cookie Policy. The User is responsible for Personal Data of third parties obtained, published, or shared through this Application.

Methods and Place of Processing of the Collected Data

Processing Methods

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, alteration, or destruction of Personal 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 Data Controller, in some cases, other subjects involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the Data, if necessary, as Data Processors appointed by the Data Controller. An updated list of Data Processors can always be requested from the Data Controller.

Location

The Data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For further information, please contact the Data Controller. The Personal Data of the User may be transferred to a country other than the one in which the User is located. To obtain further information about the place of processing, the User can refer to the section with details on the processing of Personal Data.

Retention Period

Unless otherwise specified in this document, Personal Data is processed and stored for the time required by the purposes for which it was collected and may be stored for a longer period due to legal obligations or with the User’s consent.

Cookie Policy

This Application uses Tracking Tools. To learn more, Users can consult the Cookie Policy.

Additional User Information

Legal Basis for Processing

The Data Controller processes Personal Data concerning the User if one of the following conditions exists:

• The User has given consent for one or more specific purposes; Note: In some jurisdictions, the Data Controller may be allowed to process Personal Data without the User’s consent or another legal basis specified below, until the User objects (“opt-out”) to such processing. This is not, however, applicable if the processing of Personal Data is regulated by European law on the protection of Personal Data;
• Processing is necessary for the performance of a contract with the User and/or for the performance of pre-contractual measures;
• 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 in the exercise of official authority vested in the Data Controller;
• Processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.

In any case, the Data Controller will be happy to clarify the specific legal basis for each processing and, in particular, whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Additional Information about Retention Time

Unless otherwise specified in this document, Personal Data is processed and stored for the time required by the purposes for which it was collected and may be stored for a longer period due to legal obligations or with the User’s consent. Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until such contract is fully performed.
• Personal Data collected for purposes related to the legitimate interests of the Data Controller will be retained until such interests are satisfied. Users can obtain further information regarding the legitimate interests pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When processing is based on the User’s consent, the Data Controller may retain Personal Data for a longer period until such consent is revoked. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or an order from an authority. At the end of the retention period, Personal Data will be deleted. Therefore, upon expiration of this term, the right to access, delete, correct, and the right to data portability cannot be exercised.

User Rights

Users may exercise certain rights regarding the Data processed by the Data Controller. In particular, within the limits established by law, the User has the right to:

• withdraw consent at any time. The User can withdraw consent previously given for the processing of their Personal Data.
• object to processing of their Data. The User can object to the processing of their Data if the processing is carried out on a legal basis other than consent.
• access their Data. The User has the right to learn if Data is being processed by the Data Controller, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing.
• verify and seek rectification. The User can verify the accuracy of their Data and ask for it to be updated or corrected.
• obtain the restriction of processing. Under certain circumstances, the User can request the restriction of the processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than their storage.
• obtain the erasure or removal of their Personal Data. The User can request the erasure of their Personal Data from the Data Controller.
• receive their Data or have it transferred to another Data Controller. The User has 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 Data Controller without any hindrance.
• lodge a complaint. The User can bring a legal action before the competent authority on the subject of Personal Data protection or file a complaint with the relevant judicial authorities.

Users have the right to obtain information regarding the legal basis for the transfer of Data to countries outside the European Union or to international organizations governed by public international law or set up by two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect their Data.

Details about the Right to Object

When Personal Data is processed for the public interest, in the exercise of an official authority vested in the Data Controller, or for the purposes of the legitimate interests pursued by the Data Controller, Users may object to such processing by providing a ground related to their particular situation. Users are reminded that, if their Personal Data is processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Data Controller is processing Personal Data for direct marketing purposes, Users can refer to the relevant sections of this document.

How to Exercise Rights

To exercise their rights, Users can address a request to the contact details of the Data Controller indicated in this document. Requests can be made free of charge, and the Data Controller will respond within the shortest possible time, but in any case within one month, as required by law. Extensions are possible in certain cases. Users will be informed of any such extensions within one month of the request being received.

Additional Information about Processing

Defense in Court

The User’s Personal Data may be used for legal purposes by the Data Controller 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 Data Controller may be required to reveal Personal Data upon request of public authorities.

Specific Information

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

System Logs and Maintenance

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

Additional Information not contained in this Policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please refer to the contact information provided in this document.

Changes to this Privacy Policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to 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 Data Controller. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If the changes affect processing activities where the legal basis is consent, the Data Controller shall collect new consent from the User, where required.

Definitions and Legal References

Personal Data (or Data) Any information that directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable. 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, other parameters about the device operating system and/or the User’s IT environment. User The individual using this Application, unless otherwise specified, coinciding with the Data Subject. Data Subject The natural person to whom the Personal Data refers. Data Processor (or Data Supervisor) The natural person, legal person, public administration, or any other body, association, or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy. Data Controller (or Owner) The natural person, legal person, public administration, or any other body, association, or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, 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 Application 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, any reference to the European Union contained in this document is intended to extend to all current member states of the European Union and the European Economic Area.

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Legal References This privacy policy relates solely to this Application unless otherwise stated.