Pursuant to art. 13 of Legislative Decree no. 196 of 30 June 2003 (the “Privacy Code”), art. 13 of European Regulation no. 679 of 2016 (the “Privacy Regulation”), and Recommendation no. 2 of 2001 adopted pursuant to art. 29 of Directive no. 95/46/EC, PROMOLINE S.R.L. wishes to inform all users and/or visitors of the site localhost/promoline (respectively the “Users” and the “Site”) about the use of personal data, log files and cookies collected through the Site itself.
The controller of personal data processing is PROMOLINE S.R.L. (Tax code and VAT no. 00778660134), with registered office at Via Besana, 10, 20100 MILAN (MI), Italy, e-mail info@jellyroadgroup.com (hereinafter the “Controller”).
The updated list of appointed Data Processors can be provided on request by data subjects and/or Users.
The company has not appointed a Data Protection Officer.
Like all websites, our Site also makes use of log files, in which information collected automatically during visits is stored. The IT systems and software procedures that operate the Site do in fact automatically acquire certain information during use, the transmission of which is implicit in the use of Internet communication protocols.
The information collected is as follows:
This information is processed in automated form and collected exclusively in aggregate form in order to verify the correct functioning of the Site.
Cookies are used on the Site. Cookies are text files stored on IT media, which make it possible to record certain parameters and data communicated to the IT system through the browser used. These tools therefore allow an analysis of habits in the use of the Site, for different purposes: performing IT authentication, monitoring sessions, storing information on specific configurations relating to users who access the server, storing preferences, etc.
Cookies are divided into:
Consent is not required for the installation of Technical Cookies. Consent is required for the installation of Profiling Cookies: should you not wish your device to receive and store Profiling Cookies, you can change your browser’s security settings. Indeed, through the settings of the browser used to browse, you can decide whether to delete and/or prevent the installation of cookies on the device used.
Please note, however, that by disabling the use of Profiling Cookies you will not be able to make full use of some functions of the Site.
While browsing the Site, your terminal/device may also receive cookies sent by different sites or web servers (hereinafter “Third Parties”). The Third Parties that use cookies on our Site are:
By using the Site, the use of Cookies is considered accepted and consent is deemed given to the processing of data collected by Third Parties.
The data are processed for the following purposes:
The processing of data for the above purposes will be carried out in compliance with the Privacy Code, the Privacy Regulation and all specific sector legislation, including the provisions of the “Rules of the Data Protection Authority for loyalty programmes” of 24 February 2005 and the “Guidelines on the processing of personal data for online profiling” of 19 March 2015.
In compliance with the “Guidelines on promotional activity and countering spam” of 4 July 2013, we point out that any consent given for the sending of commercial, promotional and marketing communications by automated means will also extend to traditional methods of contact.
The data provided will be processed mainly by electronic means under the authority of the Data Controller, by parties specifically appointed, authorised and instructed to carry out the processing pursuant to article 30 of the Privacy Code and articles 28 and 29 of the Privacy Regulation. Please note that appropriate security measures are observed, including pursuant to arts. 5 and 32 of the Privacy Regulation, to prevent data loss, unlawful or incorrect use and unauthorised access.
Please note that for the purposes referred to in points (i), (ii), (v) and possibly the subsequent ones of the preceding art. 3, the provision of personal data is mandatory, since without it you will not be able to use the Services offered by the Site.
Conversely, the provision of personal data is not mandatory but optional for the purposes referred to in points (iii) and (iv) of the preceding art. 3. Failure to provide the data for the purposes just indicated will not allow us to provide the Newsletter, the Marketing Services, or to carry out the Profiling Activity. To this end, you can freely decide whether or not to give consent for these purposes as well, without this preventing the possibility of accessing the Services offered by the Site.
Please note that, in any case and at any time, you may request the Controller to delete your data by means of a simple communication to be sent, without particular formalities, to the contact details referred to in the preceding art. 1.
With reference to the purposes referred to in points (i), (ii), (v) and possibly the subsequent ones of the preceding art. 3, the legal basis of the processing is in fact the performance of the services provided through the Site and requested (pursuant to article 6, paragraph 1, letter b of the Regulation); with reference to the purposes referred to in points (iii) and (iv) of the preceding art. 3, on the other hand, the legal basis of the processing is any freely given express consent (pursuant to article 6, paragraph 1, letter a of the Regulation).
The data may be communicated, within the EU, in full compliance with the provisions of the Privacy Code and the Privacy Regulation, to the following parties:
(i) to the tax authorities and/or other public authorities, where this is required by law or at their request;
(ii) to the structures, parties and external companies which the Controller uses to carry out activities connected with, instrumental to or consequent upon the performance of the Site Services – including the cloud computing storage service – the sending of the Newsletter and the Profiling Activity;
(iii) to external consultants (for example, for the management of tax obligations), if not appointed Data Processors in writing.
(iv) to credit institutions for purposes instrumental to any purchase of goods/services where provided for in any part of the site
The information collected automatically by the Site, referred to in paragraph 2, as well as certain anonymous data relating to the number and type of interactions with activities associated with loyalty purposes in the strict sense, may also be transferred to Third Party cloud servers located outside the EU as well, such processing being necessary for the performance of the requested Site Services. The legal basis of this processing is therefore art. 49, paragraph 1, letter b of the Privacy Regulation and Art. 43, paragraph 1, letter b of the Privacy Code.
Please note that at any time you may exercise the rights referred to in art. 7 of the Privacy Code and in arts. 15, 16, 17, 18, 20 and 21 of the Privacy Regulation, by sending a written communication to the Controller’s contact details referred to in the preceding art. 1 and, as a result, obtain:
You may also object to the processing of personal data previously provided.
With reference to the Newsletter, we highlight the right to request the cessation of processing carried out through automated methods of contact, extended to traditional ones as well. Furthermore, it remains possible to exercise this right only in part, that is by requesting the interruption of, for example, the sending of promotional communications carried out through one or some of the contact tools for which consent was given.
Without prejudice to legal obligations, personal data will be retained for a set period, based on criteria founded on the nature of the services provided.
Please note that data retained for Profiling or Marketing purposes will be retained for a period not exceeding 12 and 24 months respectively from their registration.
Through the Site, data are processed in compliance with applicable law and using adequate security measures in accordance with the legislation in force, including pursuant to arts. 5 and 32 of the Privacy Regulation.
In this regard, we confirm, among other things, the adoption of appropriate security measures aimed at preventing unauthorised access, theft, disclosure, modification or unauthorised destruction of the data processed.
The Controller reserves the right to make changes to this Privacy Notice. In such a case, users will be informed promptly, when they next use the Site.
This notice was issued in September 2018.