Privacy Policy
WHAT TYPES OF DATA DO WE COLLECT?
When you use our services, you agree that our company collects certain personal data about you. This page is intended to describe our Privacy Policy, tell you what data we collect, why we collect it and how we use it.
We deal with two types of data:
⦁ data provided by the user
⦁ data we collect automatically
PRIVACY POLICY: DATA PROVIDED BY THE USER
When you browse our site, we ask you to provide us with certain data that we need in order to be able to use our service. These are, for example, the data we ask you for:
⦁ address, e-mail and password
⦁ other data that change depending on the contact form you are filling in (e.g. if you are filling in a contact form to request information on one of our services, we ask for your profession, city of residence and other relevant information)
⦁ name
⦁ telephone number
PRIVACY POLICY: THIRD-PARTY DATA
If you provide personal data of third parties, such as those of your family members or friends, you must be sure that these parties have been adequately informed and have consented to their processing in the manner described in this policy.
PRIVACY POLICY: DATA WE COLLECT AUTOMATICALLY
We collect the following data through the services you use:
⦁ technical data: e.g. IP address, browser type, information about your computer, data about the current (approximate) location of the instrument you are using;
⦁ data collected using cookies or similar technologies: for more information, please visit the “Cookies” section.
- HOW WE USE COLLECTED DATA
We use the data collected to offer you our service every day, to inform you about our business activities or to offer you a more personalised service in line with your interests.
1.1. To guarantee your access to our services and improve their delivery
We use your data to ensure your access to and delivery of our services, including:
⦁ Comment on articles and pages on our site
⦁ Using contact forms
⦁ Newsletter registration
Such processing is necessary in order to correctly provide WitUp Ltd services to its users.
Such processing is based on the legitimate interest of the Controller (see point 3.1) and you may object at any time.
1.2. To inform you about our business activities
We use the data collected, where you have expressly given us consent, to inform you about promotional activities that may be of interest to you in line with our privacy policy
⦁ communicate promotional, commercial and advertising activities on WitUp Ltd events, initiatives or partnerships by e-mail, SMS or push notifications
⦁ do analysis and reporting related to promotional communication systems
1.3. To offer you a personalised service
We process the data collected, if you have expressly given us your consent, to analyse your consumption habits or choices in order to offer you a service that is increasingly personalised and in line with your interests and to improve our commercial offer.
- IS THE PROVISION OF DATA COMPULSORY?
The provision of personal data is compulsory only for the processing necessary for the provision of services offered by WitUp Ltd (refusal for the purposes of service provision makes it impossible to use the service itself); it is optional for promotional and profiling purposes and refusal to give consent has no negative consequences on the provision of the service offered on the website www.moreglobe.com and related applications.
- WHO ARE THE SUBJECTS OF THE TREATMENT?
3.1. Data controller
The data controller is WitUp Ltd in the person of its pro-tempore legal representative, with registered office located in Uk, 71-75, Shelton Street, Covent Garden, London, WC2H 9JQ- 71-75, Company Number: 16572774
The data controller employs data processors to achieve the purposes specified in point 1 and a Data Protection Officer (DPO) to supervise the protection of personal data.
Please refer to Section 3.2 below for any requests concerning your personal data.
3.2. Data Protection Officer (DPO) and contact information
The designated Data Protection Officer pursuant to Article 37 of the GDPR is WitUp Ltd
Please note that you may contact the DPO at any time and send any questions or requests concerning your personal data and respect for your privacy by writing to info@moreglobe.com
3.3. Persons to whom personal data may be disclosed
The data collected as part of the provision of the service may be disclosed to:
⦁ companies that perform functions strictly connected and instrumental to the operation – also technical – of WitUp Ltd services, such as suppliers that provide services aimed at reviewing and verifying advertisements, suppliers of direct marketing and customer care services, companies that provide filing, administrative, payment and invoicing services
⦁ administrative and judicial bodies and authorities by virtue of legal obligations
⦁ Your personal data may be transferred outside the European Union to be processed by some of our service providers. In this case, we ensure that this transfer takes place in compliance with applicable legislation and that an adequate level of protection of personal data is guaranteed by relying on an adequacy decision, on standard clauses defined by the European Commission or on Binding Corporate Rules.
Under no circumstances do we give or sell personal data to third parties.
HOW CAN YOU OBTAIN INFORMATION ON THE DATA, MODIFY THEM, DELETE THEM OR HAVE A COPY OF THEM?
4.1. Access to personal data
You may, at any time, ask to see the personal data in our possession by writing an email to info@moreglobe.com
4.2. Exporting and deleting personal data
To export your personal data (takeout) or request deletion of your personal data you can send a request to info@moreglobe.com
Your personal data will be exported within 30 days or, if the export is particularly complex, within three months.
Deletion will be carried out within the technical timeframe and in accordance with the retention period explained in section 5 below.
4.3. Exercise of your rights
Any natural person using our service may:
⦁ obtain from the holder, at any time, information about the existence of their personal data, their origin, the purposes and methods of processing and, if any, to obtain access to the personal data and information referred to in Article 15 of the GDPR
⦁ to request the updating, rectification, integration, deletion, restriction of the processing of data in the event one of the conditions provided for in Article 18 of the GDPR is met, the transformation into an anonymous form or the blocking of personal data processed in breach of the law, including data whose storage is not necessary in relation to the purposes for which the data were collected and/or subsequently processed
⦁ oppose, in whole or in part, for legitimate reasons, the processing of data, even if pertinent to the purpose of collection and the processing of personal data for the purposes of commercial information or sending advertising materials or direct selling or for carrying out market research or commercial communication. Every user also has the right to revoke consent at any time without prejudice to the lawfulness of the processing based on the consent given before revocation
⦁ receive their personal data, consciously and actively provided or through the use of the service, in a structured, commonly used and machine-readable format, and to transmit them to another data controller without hindrance
⦁ lodge a complaint with the Italian Data Protection Authority
Please note that if you have any questions or requests regarding your personal data and respect for your privacy POLICY, you can write to info@moreglobe.com
- HOW AND FOR HOW LONG WILL YOUR DATA BE STORED?
Personal data will be stored on paper and/or electronically/informatically and for the time strictly necessary to fulfil the purposes set out in point 1, in compliance with your privacy and current regulations.
For direct marketing and profiling purposes, we will keep your data for a maximum period of time equal to that provided for by the applicable regulations (24 and 12 months respectively).
Invoices, accounting documents and transaction data are kept for 11 years in accordance with the law (including tax obligations).
In the event of exercising the right to be forgotten through a request for express deletion of personal data processed by the data controller, we remind you that such data will be retained, in a protected form and with limited access, solely for the purposes of investigating and prosecuting criminal offences, for a period not exceeding 12 months from the date of the request, and will subsequently be securely deleted or irreversibly anonymised.
Finally, we remind you that for the same purposes, the data relating to telematic traffic, excluding in any case the contents of communications, will be retained for a period not exceeding 6 years from the date of communication, pursuant to Article 24 of Law No. 167/2017, which transposed EU Directive 2017/541 on anti-terrorism.
- HOW DO WE ENSURE THE PROTECTION OF YOUR DATA?
The data are collected by the entities indicated in point 3, according to the indications of the reference legislation, with particular regard to the security measures provided for by the GDPR (art. 32) for their processing by means of computerised, manual and automated tools and with logics strictly related to the purposes indicated in point 1 and in any case in such a way as to guarantee the security and confidentiality of the data themselves.
- MAY THE PRIVACY POLICY BE SUBJECT TO CHANGE OVER TIME?
This information notice may be subject to change. If substantial changes are made to the use of data relating to the user by the Controller, the latter will notify the user by publishing them with the utmost clarity on its pages or through alternative or similar means.