WHY THIS INFORMATION?

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

DATA CONTROLLER

Pursuant to Article 26 of the EU Regulation (GDPR), TeamDev S.r.l., with registered office in Via Settevalli 320, 06129, Perugia, tel. 075 9724382, teamdevsrl@pec.it, in the person of its legal representative p.t. Andrea Cruciani, is the data controller. For any information regarding the processing of personal data, you can contact the data processor at TeamDev by email 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;
• Navigation data: in order to access the WiseTown software service, computer systems and software procedures acquire, during their normal operation, some personal data whose communication is implicit in the use of Internet communication protocols. This category of data includes the IP addresses or domain names of the computer and terminals used by users, the URI/URL (Uniform Resource Identifier/Locator) addresses of the requested resources, the time of the request, the method used to submit 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 related to the user’s operating system and IT environment.

Browsing data suitable for determining the habits, interests, preferences and behaviour of natural persons (profiling) are processed exclusively with the explicit consent of the data subject, who, at any time, has the right to refuse and/or revoke it. The profiling activity that may be carried out by the data controller is not connected to automated processes capable of affecting the legal and/or personal sphere of the data subject. The profiling activity is subject to a specific assessment of the 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 who can be contacted at the email address privacy@teamdev.it.

• Data relating to the exact geographical location of the user: for users who access WiseTown, data that identifies the user’s location at the time of using some of the services of the Application may be processed. These data, necessary for the use of some services of the Application, are processed for the purpose of:
• to allow the proper functioning of specific services to add value to 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 subjects, however, due to their nature, they could allow the identification of users through processing and association with data held by third parties (for example, for the ascertainment of criminal liability related to computer crimes). The user, at any time, can choose to temporarily or permanently interrupt the processing in question.

The processing of data relating to the user’s location is carried out only after obtaining the explicit and specific consent of the latter and is linked to the provision of a value-added service requested by the user himself (the possibility of making reports addressed to the Public Administration through the Application). The geolocation activity is subject to a specific assessment of the related risks (DPIA) by the data controller TeamDev S.r.l.; The relevant documentation is made available upon specific request to be addressed to the company’s Data Protection Officer, who can be contacted at the email address privacy@teamdev.it.

• Data communicated 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 compilation and forwarding of the forms on the website/Application involve the acquisition of the sender’s personal data and contact details necessary to respond, as well as all the data that are reported in the communications. The use of the App assumes authorized access to the image gallery and the camera.

The processing of the data collected is aimed exclusively at providing the requested service. The collection and storage of data is carried out in compliance with the principle of minimization; therefore, the processing is carried out only with reference to the relevant data and limited to what is necessary for the purposes for which they are processed. The provision of data by the interested party is optional but necessary for access to the WiseTown service.

LEGAL BASIS AND PURPOSE OF THE PROCESSING

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

Pursuant to art. 2-ter of Legislative Decree 196/2003 (Legal basis for the processing of personal data carried out for the performance of a task carried out in the public interest or related to the exercise of public authority), the legal basis for the processing of the data covered by this policy is established by Article 6, first paragraph letter b) of the GDPR, by virtue of 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”.

Purposes: more specifically, users’ personal data are collected for the use of the services offered, for the creation and promotion of training courses, consulting and verticalization services;

to fulfil the obligations arising from the contract relating to the service(s) provided, e.g. to contact the data subjects in order to provide assistance on the services offered;

to comply with regulatory obligations related to the services, such as the retention of accounting data or information that is required by law to be archived;

to contact you with mailing lists or other channels in order to keep you updated on service offerings;

to monitor user behaviors 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’s services is carried out through servers owned by Microsoft Azure and possibly with the collaboration of other parties specifically designated as data processors. The processing of data takes place exclusively for the time strictly necessary to achieve the purposes of the service, also through the use of automated tools, observing the security measures aimed at preventing the loss of data, 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. In these cases, the transfer is authorized pursuant to Article 46 of the GDPR as the third parties provide adequate guarantees of protection for the rights of the data subjects.

You can refuse the use of third-party cookies and at any time you can revoke the consent you have already given.

 

DATA RECIPIENTS

The personal data collected are processed by the Data Controller’s staff who act on the basis of specific instructions provided regarding the methods and purposes of the processing itself.

The Data Controller, for the services offered by WiseTown, uses servers owned by Microsoft Azure located in the territory of the European Union. Data is generally not transferred to third parties, except in specific cases:

• legitimate request by the judicial authority and only in the cases provided for by law;
• if it is necessary for the provision of a specific service requested by the User;
• to perform security checks 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 the fulfilment of legal obligations and/or provisions dictated by public bodies;
• external parties who manage/support/assist, even if only occasionally, the joint controllers in the administration of the information system and telecommunications networks.

The subjects belonging to the above categories perform the function of Data Processor (on the basis of specific appointment), or operate in total autonomy as Data Controllers or perform the function of Joint Data Controllers. The list of any data processors is constantly updated and available from each Data Controller.

The Data Controller undertakes to use external suppliers and processors who comply with the guarantees established by art. 46 et seq. of the GDPR.

The Data Controller periodically verifies the tools through which personal data are processed and the security measures provided for them, which it provides for to be constantly updated. In addition, it verifies, also through the persons authorised to process the data, that no personal data is collected, processed, stored or stored that is not necessary for processing; verifies that the data are stored with the guarantee of integrity and authenticity and that their use is limited exclusively to the intended purposes.

DURATION OF STORAGE

In compliance with the provisions of art. 5 paragraph 1 letter e) of the GDPR, the personal data collected will be stored for a period of time not exceeding the achievement of the purposes for which the personal data are processed (principle of storage limitation) or according to the deadlines provided for by law.

NATURE OF PROVISION AND REFUSAL

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

Failure to provide such data, however, may make it impossible to use all or some of WiseTown’s services.

RIGHTS OF THE DATA SUBJECTS

Pursuant to art. 7 of the Privacy Code, at any time the interested party has the right to obtain confirmation of the existence or otherwise of the data concerning him/her and to know its content and origin, to verify its accuracy or to request its integration or updating, or rectification. You also have 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 the processing of data concerning you for legitimate reasons.

Data subjects have the right to object to the processing of their personal data (articles 15 et seq. of the Regulation) by sending a specific request to the e-mail address: support@wise.town.

Revocation of Consent: if 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 by a simple communication using the contacts indicated above. In the event that the processing of personal data is carried out on the basis of additional legal bases, it will be possible that some or all of the data will still be retained to comply with any related obligations.

RIGHT TO LODGE A COMPLAINT

Data subjects who believe that the processing of their personal data is in violation of the provisions of the Regulation have the right to lodge a complaint with the Data Protection Authority, as provided for by art. 77 of the Regulation, or to take legal action (Article 79 of the Regulation).

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 better management of the WiseTown software service. The personal data collected will not be related to any automated decision-making.

For further information on the processing of personal data and the Privacy Policy, please refer to the information on the websites of the Data Controller.