1.- GENERAL INFORMATION
This policy refers to the Live All site (hereafter Site).
Access to the Site is subject to the following terms and conditions.
Use of the Site and navigation within it constitutes implicit acceptance of the conditions set forth below.
Live All is aware of the importance of the protection of personal data, not least in view of the fact that the internet is potentially a tool for the exchange and circulation of information, which is why we collect and process data in strict compliance with the current rules on the protection of personal data and, specifically, EU Regulation 679/2016 (http://eur-lex.europa.eu/legal-content/IT/TXT/?uri=uriserv:OJ.L_.2016.119.01.0001.01.ITA), always having regard to the principles of fairness, lawfulness and protection of rights.
This notice also has value pursuant to Article 13 of EU Regulation No. 2016/679, on the protection of individuals with regard to the processing of personal data and on the free movement of such data, for persons interacting with the Site.
The purpose of this document is to provide guidance on how, when, and what kind of information the Data Controller must provide to users.
The statement may be subject to updates/changes due to the introduction of new regulations in this regard, so please check this page periodically.
2.- THE DATA CONTROLLER
The Data Controller is Live All, with registered office in Milan – Via Camperio, n. 9 (C.F. / P.Iva 11290640967) – PEC: [email protected]
For all data processing issues, you will be able to contact the Data Controller and/or the Data Processor at the following e-mail address: [email protected].
3.- THE DATA PROCESSED
The data processed by Live All, are:
- identifying data, such as: first name, last name, email address, date of birth, residence, social security number, etc. The collection of such data, will take place through the completion of the appropriate forms on our Site. The data requested may vary from time to time depending on the service / product offered.
Please note: data marked with the symbol (*) are mandatory, which means that in the absence of their communication, we will not be able to offer the requested product / service. In the absence of the symbol (*), it is up to the user to communicate or not to communicate the data, and the choice will have no impact on the availability of the product / service;
- data collected automatically while browsing the Site such as: IP addresses (both static and dynamic) or domain names of the devices used by those who connect, addresses in URI (“Uniform Resource Identifier”) notation, 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.) the country of origin, the characteristics of the browser and operating system used etc;
- other data, both identifying and navigational, from third-party websites or applications, such as: personal information collected on third-party platforms and, in particular, on social networks, such as Twitter, Facebook, Instagram etc.
Live All, collects and analyzes this information when, for example, you post something on our official pages present on social networks, or when you publish a post with one of our “tags,” or even when you register through your social account (e.g. you register by clicking on the “Facebook” button).
Personal data of minors under the age of 14 will be processed by Live All only with the permission of those exercising parental authority.
4.- DATA PROCESSING
The data will be processed exclusively by persons authorized to process the data and by persons designated as Data Processors in compliance with EU Regulation 679/2016) in order to properly perform all Processing activities necessary to pursue the purposes set forth in this Notice.
The legal foundations of the processing of personal data are:
- The consent given by the User for data processing in accessing and/or using Live All’s services/products via Site;
- the contract, for the fulfillment and execution of related obligations;
- The fulfillment of regulatory obligations, including accounting, administrative and tax obligations
- the legitimate interest of the Owner
4.I.- Data i will be processed, by virtue of the legitimate interest of the Owner, as well as legal obligations or contractual needs, for the following purposes:
- Registration to the services of the Site; as well as subscription and activation of the provision of products / services
- Participation in the Site by: posting comments; sending form-based e-mail inquiries; participating in surveys;
- Customization of services/products offered to the user through Site by processing information collected during browsing;
- Technical analysis of the use of the Site’s products/services anonymously, including through the use of computer tools;
- suggestions and technical assistance to products / services. In some cases to receive suggestions or reports from users on possible malfunctions of our products / services we will acquire information regarding IP address, operating system, device type, e-mail, etc;
- communication and / or sending (by e-mail, sms, push notification, email, etc.), including by automated means, of information and material related to the management of the contract and related to the provision of products / services;
- Invoicing inherent in the purchase of products/services; storage and use of accounting data;
- Handling of any complaints and disputes;
- Fulfillment of regulatory obligations including accounting, administrative and tax obligations;
- Fraud prevention and management of late or nonpayment;
- protection and eventual credit recovery, either directly or through third parties to whom the data necessary for these purposes will be disclosed;
- Reporting and quality control;
The provision of data to achieve the above purposes is necessary.
Failure, partial or inaccurate provision may result in the inability to activate and provide the requested product/service.
4.II.- In addition, personal data with the user’s consent, will also be processed for the purposes of:
- Collection and analysis of behaviors and habits in the use of the content of the Site, our products /services, including through cookies or other electronic identifiers (mac address, ip/id etc), search and recommendation engines present on OTT platforms, statistics, preferences released by the customer for the purpose of conducting market research, improving the services provided and personalizing them, as well as to reduce the number of repetitions of advertising messages and facilitate the forwarding of information and commercial offers referred to in the number
- communication and / or sending (by e-mail, sms, notifications, mail, telephone contact, etc.), even by automated means, of newsletters, information and commercial offers, advertising and promotional material on its own services and / or also of third parties, as well as carrying out market research
- communication of data to third party companies
- Collection of multimedia content (photos, video, audio, etc.) sent through the Site, social networks, e-mail, etc.
Providing data for the above purposes is optional and can always be revoked.
NOTICE: The processing of data with the purpose of personalization and profiling (including geolocation) will take place with automated tools and with data processing tools that will create a commercial and behavioral profile of the user in the web.
5.- COMMUNICATION / DATA TRANSFER
The data may be communicated to specific parties (such as Data Processors/Processors) in order to properly carry out all data processing activities; as well as to other recipients of communications necessary for the performance of obligations arising from the provision of products/services;
If required by law or to prevent or suppress the commission of unlawful acts or crimes, the data may be disclosed to public bodies or the judicial authority without these being considered Recipients (see Art. 4 para. 9 EU Regulation No. 2016/679) and, therefore, without them receiving instructions regarding the Processing they will have to carry out.
Personal data may also be communicated to
- Third-party companies specializing in the management of commercial and credit-related information (such as, for example, call centers, data processing centers, banks, etc.);
- companies and/or collaborators for the management of administrative services that we use to fulfill our legal or contractual obligations;
- Other parties (enterprises, companies, individuals) who cooperate with Live All in the realization of the provision of products/services;
- business partner of Live All
6.- DURATION OF DATA RETENTION
The data will be retained for the period necessary to achieve the purposes related to point 4.I. above. Specifically, data will be processed for a period of time equal to the minimum necessary to achieve the purposes, subject to an additional retention period that be imposed by compliance with legal requirements
In addition, data for processing for which consent is optional and indicated in section 4.II above (marketing purposes, profiling and/or communication to third parties), will be kept, unless consent is revoked, for a period of time not exceeding that necessary to achieve the purposes and in any case not exceeding two years.
There are periodic audits of the data processed and whether it can be deleted if it is no longer needed for the intended purposes.
7.- WITHDRAWAL OF CONSENT
Consent to Data Processing may be revoked at any time, in whole and/or in part, without thereby affecting the lawfulness of the Processing based on the consent given by the user prior to revocation.
To revoke consent, simply contact Live All at the contact information listed in 2 above.
8.- DATA PROCESSING TERRITORY
Data will be processed by Live All within the EU territory.
However, the data collected and processed may be provided to commercial third parties possibly also belonging to EU, European Economic Area (Norway, Iceland, Liechtenstein), Non-EU countries but always and only on condition that the processing complies with the principles set forth in EU Regulation 679/2016.
In any case, all necessary precautions will be taken to ensure full data protection by basing such transfer on the evaluation of appropriate safeguards.
Where data has been processed outside the UR territory, the user may at any time request more information from Live All by requesting evidence of the specific safeguards adopted.
9.- EXERCISE OF RIGHTS
At any time the user may exercise his or her rights vis-à-vis Live All, in accordance with EU Regulation 2016/679 at the contact details given in point 2 above
To ensure the proper exercise of rights, you must make yourself unambiguously identifiable by providing a copy of your identity card or other legally valid identification document.
Live All undertakes to provide feedback within 30 days and, in the event of inability to meet these deadlines, to give reasons for any extension of the deadline. The feedback will be provided free of charge except in cases of unfoundedness (e.g., there is no data concerning the requesting data subject) or excessive requests (e.g., repetitive over time) for which a fee may be charged not exceeding the actual costs incurred for the research carried out in the specific case.
Rights referring to personal data concerning deceased persons may be exercised by those with an interest of their own or acting on behalf of the data subject or for family reasons deserving protection.
The user has at all times the right to obtain the following information:
- origin of personal data
- categories of data processed
- purposes and methods of processing
- retention period
- logic applied in case of processing carried out with the aid of electronic instruments
- identification details of the Owner and the Manager
- Subjects and categories of subjects to whom the personal data may be transferred, transferred, communicated or who may become aware of them as Data Processors and/or Persons in Charge
- existence of the profiling process
- confirmation of the existence or non-existence of their personal data and that such data be made available to them in an intelligible form
- updating, rectification, integration of data and restriction cancellation, transformation into anonymous form or blocking of data processed in violation of the law (including those for which storage is not necessary in relation to the purposes for which they were collected or subsequently processed)
- certification that the operations referred to in the above points have also been brought to the attention of those to whom the data have been communicated or disseminated, except where this proves impossible involves a manifestly disproportionate use of means in relation to the right protected by the organization
- copy of the data being processed
The user has the right at any time to oppose
- to the processing of personal data concerning the data subject including profiling for legitimate reasons, even if relevant to the purpose of collection
- to the processing of personal data concerning the person concerned for the purposes of: sending advertising material, direct sales, carrying out market research, commercial communications
- To the processing of data processed for scientific or historical research or statistical purposes except in case of public interest in processing
The user also may file a complaint with the Supervisory Authority, without prejudice to the right to protect his or her interests in the courts. In Italy, the complaint may be submitted to the Garante per la Protezione dei Dati Personali. More information on how to file can be found on the Guarantor’s website at http://www.garanteprivacy.it
Live All, should it suffer a personal data breach, will proceed to notify the competent supervisory authority of the breach within 72 hours of the occurrence and will also notify the data subject of the event, except in cases of exclusion provided for in the regulations.