Why this information?

Pursuant to the EU Regulation 2016/679 (hereinafter GDPR) this page describes the purposes and methods of processing personal data of visitors/users using Wisetown (website and mobile app).

Data controller

Pursuant to Article 26 of the EU Regulation (GDPR), Teamdev S.r.l., based at Via Settevalli 320, 06129, Perugia, Italy, tel. 075 9724382, teamdevsrl@pec.it, in the person of its legal representative p.t. Andrea Cruciani, is the data controller. For any information inherent to the processing of personal data, it is possible to contact the data controller at Teamdev by e-mail at the address privacy@teamdev.it.

Categories of Personal Data processed

The Data Controller determines the purposes and means of the processing with reference to the following types of Personal Data:

  • Contact Data: authentication credentials and any additional information voluntarily submitted by the user in order to access the Services offered by the Data Controller;
  • Personal Data: first name, last name, place and date of birth, gender, company name or name, tax code, VAT number, mobile phone number, e-mail address provided directly (and with the user’s consent) by the digital identity manager used to access the Service.
  • Navigation data: for access to the Wisetown software service, computer systems and software procedures acquire, in the course of their normal operation, some personal data whose communication is implicit in the use of Internet communication protocols. This category of data includes IP addresses or domain names of the computers and terminals used by users, addresses in URI/URL (Uniform Resource Identifier/Locator) notation of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment.
    Browsing data suitable for the determination of habits, interests, preferences and behavior of natural persons (profiling) are processed only with the explicit consent of the data subject, who, at any time, has the right to refuse and/or revoke it. Any profiling activity carried out by the data controller is not linked to automated processes capable of affecting the legal and/or personal sphere of the data subject. The profiling activity is the subject of a specific assessment of related risks (DPIA) carried out by the joint data controller Teamdev S.r.l.; the relevant documentation is made available upon specific request to be addressed to the company’s personal data protection officer contactable at the email address privacy@teamdev.it.
  • Data relating to the exact geographical location of the user: for users accessing Wisetown, it is possible that data identifying the user’s location when using some of the services of the Application may be processed. Such data, necessary for the use of some of the services of the Application, are processed for the purpose of:
    • enable the proper functioning of specific value-added services of the Application;
    • obtain statistical information on the use of the services (geographical areas of origin of users);
    • monitor the proper functioning of the value-added services offered.

These data are not collected for the purpose of associating them with identified individuals, however, due to their nature, they could allow the identification of users through processing and association with data held by third parties (e.g. for the investigation of criminal liability related to computer crimes). The user, at any time, may choose to temporarily or permanently discontinue the processing in question.
The processing of data related to the user’s location is carried out only after obtaining the user’s explicit and specific consent and is related to the provision of a value-added service requested by the same user (the possibility of making reports addressed to the Public Administration through the Application). The geolocation activity is the subject of a specific evaluation of related risks (DPIA) by the data controller Teamdev S.r.l.; the relevant documentation is made available upon specific request o be addressed to the company’s personal data protection officer contactable at the email address privacy@teamdev.it.

  • Data disclosed by the user: the optional, explicit and voluntary sending of messages and contact addresses to the entity, reports, comments and private messages sent through the website/Application, as well as the completion and submission of forms on the website/Application entail the acquisition of the sender’s personal and contact data necessary to respond, as well as any data that are included in the communications. Use of the App presupposes authorized access to the image gallery and camera.

The data collected are processed exclusively for the purpose of providing the requested service. The collection and storage of data are carried out in accordance with the principle of minimization; therefore, the processing is carried out only with reference to data that are relevant and limited to what is necessary for the purposes for which they are processed. The provision of data by the data subject is optional but necessary for access to the Wisetown service.

Legal basis and purpose of processing

The personal data indicated on this page are processed exclusively for the performance of the services offered through Wisetown.

Pursuant to Article 2-ter of Legislative Decree 196/2003 (Legal basis for the processing of personal data carried out for the performance of a task of public interest or in connection with the exercise of public authority), the legal basis for the Processing of the data covered by this notice is established by Article 6 first paragraph letter b) of the GDPR, under which the processing of personal data must be considered lawful when “necessary for the performance of a contract to which the data subject is a party”.

Purpose: More specifically, users’ personal data are collected for the use of services offered, for the implementation and promotion of training courses, consulting services and verticalization;

to fulfill contractual obligations related to the service(s) provided, e.g., to contact data subjects in order to provide assistance on the services offered;

to fulfill regulatory obligations related to the services, e.g., to retain accounting data or information required by law to be stored;

to contact users with mailing lists or other channels in order to keep him/her updated on service offerings;

To monitor user behavior when interacting with Teamdev and its communication channels;

for statistical and scientific purposes useful for national and international research activities;

for the creation of promotional campaigns.

Data Transfer

The processing of data related to Wisetown services is carried out through servers owned by Microsoft Azure and possibly with the collaboration of other parties specifically designated as data processors. Data is processed exclusively for the time strictly necessary to achieve the purposes of the service, including through the use of automated tools, observing security measures aimed at preventing data loss, illicit or incorrect use and unauthorized access.

Exclusively with reference to third-party cookies, some data may have to be shared with services located outside the European Union area. In these cases the transfer is authorized ex art. 46 GDPR as the third parties provide adequate safeguards for the rights of the data subjects.

The user can refuse the use of third-party cookies and at any time can revoke the consent already provided.

Recipients of the data

The personal data collected are processed by personnel of the Data Controller acting on the basis of specific instructions given regarding the manner and purpose of the processing.

The Data Controller, for the services offered by Wisetown, uses servers owned by Microsoft Azure located in the territory of the European Union. Data are generally not transferred to Third Parties, except in specific cases:

  • legitimate request by the judicial authority and only in cases provided by law;
  • if it is necessary for the provision of a specific service requested by the User, rendered by reason of specific contract;
  • for the execution of security controls and optimization of the Application.

Therefore, in these cases, the data provided may be communicated to recipients belonging to the following categories:

  • competent authorities for fulfillment of legal obligations and/or provisions dictated by public bodies;
  • external subjects who manage / support / assist, even only occasionally, the co-owners in the administration of the information system and telecommunications networks.

Subjects belonging to the above categories perform the function of Data Processor (on the basis of specific appointment), or operate completely independently as Data Controllers or perform the function of Co-Processors. The list of any Data Processors is constantly updated and available from each Data Controller.

The Data Controller is committed to using external suppliers and data processors that comply with the guarantees set forth in Articles 46 et seq. of the GDPR.

The Data Controller periodically verifies the means by which personal data are processed and the security measures provided for them, of which it provides for constant updating. It also verifies, including through the persons authorized for processing, that no personal data are collected, processed, stored or retained that do not need to be processed; it verifies that the data are stored with the guarantee of integrity and authenticity and that their use is limited exclusively to the intended purposes.

Length of storage

In accordance with the provisions of Article 5 paragraph 1 letter e) of the GDPR, the personal data collected will be kept for a period of time not exceeding the achievement of the purposes for which the personal data are processed (principle of retention limitation) or in accordance with the deadlines stipulated by legal regulations.

Nature of provision and refusal

Except as specified for navigation data that are acquired automatically, users are free to provide their personal data or not to provide them.

Failure to provide them, however, may result in the inability to use all or some of Wisetown’s services.

Rights of the interested parties

Pursuant to art. 7 of the Privacy Code, at any time the interested party has the right to obtain confirmation of the existence or non-existence of data concerning him/her and to know its content and origin, to verify its accuracy or request its integration or updating, or rectification. He also has the right to request the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, as well as to oppose for legitimate reasons the processing of data concerning him.

Data subjects have the right to object to the processing of their personal data (Art. 15 et seq. Regulation) through specific request to the email address: support@wise.town.

Revocation of Consent: the processing of personal data is based on the consent of the data subject. He/she has the full and free right to revoke it at any time with a simple communication using the contacts indicated above. In the event that the processing of personal data is carried out by virtue of additional legal bases, it will be possible that some or all of the data will still be retained in order to fulfill any related burdens.

Right to complain

Data subjects who believe that the processing of personal data relating to them is taking place in violation of the provisions of the Regulations have the right to lodge a complaint with the Guarantor, as provided for in Article 77 of the Regulations, or to take appropriate legal action (Article 79 of the Regulations).

Profiling

Except as specified in the Cookie Policy for third-party cookies, there are no automated decision-making processes on aggregated data, except for the purpose of better managing the Wisetown software service. Personal data collected will not be related to any automated decision-making process.

For more information on the processing of personal data and the Privacy Policy you can refer to the disclosures on the websites of the Data Controller.