Privacy Policy and Terms of Use

Dear User,

Privacy policy for the processing of personal data pursuant to article 13, Italian Legislative Decree no. 196 of June 30th, and articles 13 and 14 of EU Regulation 2016/679.

Introduction

In compliance with Legislative Decree no. 196 of June 30, 2003, and EU Regulation 2016/679 (hereinafter the "Regulation"), Casa Synergy Srl (hereinafter "CASA SYNERGY"), as the data controller, is required to provide you with information regarding the purposes and methods of processing your personal data (hereinafter referred to as "Data Subject"), as well as the scope of communication and dissemination of the same, the nature of the data in our possession, and their provision.

Purpose of the processing

Personal data is processed within the normal activities of the company for the following purposes:

a) execution of obligations arising from contracts entered into with CASA SYNERGY and/or fulfillment of pre-contractual activities for specific requests from the Data Subject;

b) fulfillment of obligations provided for by laws, regulations, or EU regulations (e.g., accounting processes, billing, and payments);

c) other activities related and instrumental to the management of relationships with the Data Subject, creditworthiness investigations, informational and commercial activities, carried out by letter, telephone, electronic messages, newsletters, profiling, and registration in our mailing lists.

Data Controller

The data controller for the personal data covered by this Information Notice is Casa Synergy Srl, with registered office in Via Leone Tolstoi 66, Milan - Italy.

Processing methods

The processing will be carried out in automated and/or manual form, with methods and tools aimed at ensuring maximum security and confidentiality, by persons specifically appointed for this purpose.

Scope of communication, dissemination, and processing

Your data, subject to processing, will not be disclosed, but may be communicated to affiliated companies abroad and within the limits of the law in order to comply with contracts or purposes related to third parties belonging to the following categories:

1 - subjects who provide services for the management of the company's information system and telecommunications networks (including e-mail);

2 - companies that provide services for the acquisition, recording, and processing of data from documents or media provided and original documents by clients, and having as their object massive processing relating to payments, effects, checks, and other securities;

3 - subjects who provide customer support services (e.g., call center, help desk, etc.);

4 - firms or companies within the scope of assistance and consulting relationships;

5 - subjects who perform control, review, and certification of activities carried out by the company, also in the interest of customers;

6 - subjects who provide services for the management of communication processes (including mailing lists).

The subjects belonging to the above categories perform the function of Data Processor or operate independently as separate Data Controllers. The list of any Data Processors is constantly updated and available at the headquarters of C-Money. Any further communication or dissemination will only take place with your explicit consent.

Your data will be managed and stored in European Union countries or in third countries deemed adequate by the European Commission, or in countries with which the European Union has established special agreements (e.g., the so-called "Privacy Shield" with the USA), for the entire duration of such agreements.

The joint data controllers will be responsible for the same protection that this information notice provides.

Period of retention of data and their protection

The data will be kept indefinitely. The data are subject to a constant backup procedure by CASA SYNERGY or in the areas of processing provided for.

Nature of the provision

The provision of data for activities requested by the data subject is acquired and mandatory without further request for consent in fulfillment of obligations arising from contracts entered into with CASA SYNERGY and/or fulfillment of pre-contractual activities for specific requests of the data subject. The provision of your data for all other purposes is optional. The data controller also informs that the eventual non-communication or incorrect communication of one of the mandatory information necessary for the contract has the following consequences:

1 - the impossibility for the data controller to guarantee the adequacy of the treatment itself to the contractual agreements for which it is carried out;

2 - the possible failure of the treatment results to comply with the obligations imposed by tax, administrative or labor regulations to which it is addressed.

Optional consents for the management of the data of the data subject are documented according to procedures considered unambiguous (such as two-factor authentication and "double-opt-in" system), according to the exchange of communications with the data subject himself, or through the express authorization provided in written or digital forms.

Responsibility and Risk Management

The data controller constantly adjusts the data management and procedures in order to ensure compliance with current regulations. Activities and workflows take into account data from the origin of the treatment and have been considered compliant with the type of data managed, limiting unnecessary treatments to the activity. The register of treatments has not been adopted as the outcome of such verification and the regulations do not provide for it for our structure. The data controller has adopted the following security procedures:

- Identification of persons in charge of the treatment;

- Personal password;

- Access limitations;

- Alarm system;

- Privacy procedure verification within other data controllers and service providers;

- Constant data backup;

- System updates;

- Verification of absence of sensitive data;

- Request for implementation of security procedures by service providers;

- Procedure for verification and communication in case of unauthorized access to premises or data.

Right of access to personal data and other rights

You may exercise your rights as provided by current legislation by directly contacting the data controller with a written request. We also inform you of the rights granted to you by current legislation:

1 - The interested party has the right to obtain confirmation of the existence or non-existence of personal data concerning them, even if not yet registered, and their communication in an intelligible form.

2 - The interested party has the right to obtain indication:

a) of the origin of personal data;

b) of the purposes and methods of processing;

c) of the logic applied in case of processing carried out with the aid of electronic instruments;

d) of the identity of the data controller, data processors, and the designated representative pursuant to article 5, paragraph 2; of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them as designated representative in the territory of the State, data processors or persons in charge.

3 - The interested party has the right to obtain:

a) the updating, rectification, or, where interested therein, integration of the data;

b) the erasure, transformation into anonymous form, or blocking of data processed unlawfully, including data that does not need to be retained for the purposes for which it was collected or subsequently processed;

c) certification that the operations referred to in points a) and b) have been brought to the attention, also as regards their content, of those to whom the data has been communicated or disseminated, unless this proves impossible or involves a disproportionate effort compared to the right being protected.

4 - The interested party has the right to object, in whole or in part:

a) on legitimate grounds, to the processing of personal data concerning them, even if pertinent to the purpose of the collection;

b) to the processing of personal data concerning them for the purpose of sending advertising or direct sales material, or for carrying out market research or commercial communication.

5 - CASA SYNERGY is obliged to respond within 1 month to the exercise by the Data Subject of their rights.

6 - The interested party has the right to request a copy of the personal data, or to request their transfer to third parties.