Data treatment policy

1) Identity and contacts of the Data Controller

The Data Controller is Search On Media Group S.r.l. Since the Data Controller is located in Italy, there is no need to appoint a representative.

2) Contact details of the Data Protection Officer

The Data Controller has not appointed a Data Protection Officer.

3) Purpose of processing and legal basis of processing

Personal data will be processed for the following purposes:

a) For contractual purposes and / or related to the execution of pre-contractual measures adopted at your specific request, as well as to fulfill any legal obligations connected to these purposes, and in particular to allow you to be contacted to activate the platform’s services. In this case the need to proceed with the processing constitutes the legal basis.
b) To send direct marketing communications, newsletters, advertising material, using either traditional contact systems or automated computer systems, including commercial or promotional communications by email or SMS. Data will also be used for market research and analysis. In this case consent constitutes the legal basis.

c) For purposes related to legal obligations if processing has been carried out for the purposes referred to in letter a). In this case, the legal obligation of the Data Controller to process such personal data in accordance with the national legislation constitutes a legal basis.

4) How to consent

The consent, whenever requested, can be given by clicking on a specific flagbox.

5) Methods of data treatment

In relation to personal data processed and stored for the purposes referred to in point 3a) and 2c), the processing will take place using paper tools, automated logic systems and management software (CRM). In relation to personal data processed for the purposes referred to in point 3c) of this page, the processing will be carried out using software for sending commercial information.

6) Source of personal data

The processing of data will only happen in the respect of the current information, using data collected by the website or by emails. Data from publicly accessible sources will not be processed.

7) Recipients and possible categories of personal data recipients

The recipients of your personal data may be:

  • companies that offer services of an information society, including, in particular, those offering hosting services;

  • companies that offer information society services, including, in particular, those that offer hosting services;

  • companies that make software available in the cloud;

  • the partner companies of the Owner.

8) Data categories

Only personal data of the interested party will be processed. In no case will other kind of data be processed, pursuant to art. 9 GDPR.

9) Data transfer

The Data Controller may intend to transfer personal data to a third country or to an international organization. Such subjects may be:

  • Communication companies which conducts a communication activity on behalf of the Data Controller;

  • Suppliers of services for the communication company;

  • Controlled organizations and/or controllers.

The transfer of personal data to the mentioned subjects, if based in a third country or international organization, is carried out according to a decision of suitability of the European Commission, which evaluates how the third country, the territory or one or more specific sectors in the third country or the international organization ensure an adequate level of protection of the data subject’s rights. In the absence of such decision, the Data Controller – if deemed in any case appropriate – reserves himself the right to conclude specific separate agreements that oblige such subjects to adopt adequate security and also organizational measures, in order to offer appropriate guarantees related to the data subject’s rights. Data may be transferred in the following countries: U.S.A. 

10) Retention period for personal data

Personal data processed and stored for the purposes referred to in point 3a) are processed for no longer than 10 years from the end of the effects of the contract, in case of conclusion of the same, and, in the case of pre-contractual negotiations, for a period not exceeding 10 years from the end of the negotiations.

Personal data processed for the purposes referred to in point 3b) of this policy are processed and stored until cancellation is requested by the interested party.

Personal data processed and stored for the purposes referred to in point 3c are processed and stored for no longer than 10 years starting from the end of the effects of the contract, in the event of its conclusion, and, in case of pre-contractual negotiations, for a period not exceeding 10 years from the termination of the negotiations, without prejudice, in any case, to a different law.

In any case, the Data Controller reserves the right to request the renewal of the express consent.

11) Optional nature of consent and consequences in case of lack of consent

In relation to personal data processed and stored for the purposes referred to in point 3a) of this policy, the communication of personal data is a contractual obligation and a necessary requirement for carrying out pre-contractual negotiations and for the end of the contract. The interested party has the right to provide their personal data; in case of failure to communicate such data, however, it will not be possible to conclude any contract or carry out any contractual negotiation;

In relation to personal data processed for the purposes referred to in point 3b) the communication of personal data is not a contractual obligation. There is the right to provide personal data; in case of failure to communicate such data, however, it will not be possible to carry out any marketing activities;

In relation to personal data processed for the purposes referred to in point 3c), the communication of personal data is a legal obligation. In this case, there is an obligation to provide personal data; in case of failure to communicate such data it will not be possible to conclude the contract.

12) Right to object

The interested party has the right to object in the following terms:

  • the right to object at any time, for reasons connected to their situation, to the processing of personal data concerning him pursuant to Article 6, paragraph 1, letters e) or f) of the GDPR, including profiling. The Data Controller refrains from further processing personal data unless he demonstrates the existence of compelling legitimate reasons to proceed with the processing that prevail over the interests, rights and freedoms of the data subject or for the assessment, exercise or defense of a right in court;

  • if personal data are processed for direct marketing purposes, you have the right to object at any time, including profiling to the extent that it is connected to such direct marketing;

  • in case of opposition to the processing for direct marketing purposes, the personal data are no longer processed for these purposes. It is specified how the data subject's right to object to the processing of their personal data for the aforementioned purposes may be exercised even only in part, i.e. by opposing, for example, only the sending of promotional communications carried out through automated and / or digital tools or to the sending of paper communications;

  • if personal data are processed for scientific or historical research purposes or for statistical purposes pursuant to Article 89, paragraph 1 of the GDPR, the interested party, for reasons connected with his particular situation, has the right to object to the processing of personal data that concerns you, except in the case where the processing is necessary for the performance of a task of public interest.

13) Other rights

The Data Controller shall also inform the data subject about the existence the following rights:

  • The right of access by the data subject: the data subject shall have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning them are being processed, and, where that is the case, access to the personal data and other specific information, pursuant to article 15 of the GDPR;

  • The right to rectification: the data subject shall have the right to obtain from the Data Controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement, pursuant to article 16 of the GDPR;

  • The right to withdraw the consent: the Data Controller shall have the obligation to erase personal data without undue delay where the grounds set out in article 17 of the GDPR apply.

  • The right to restrict processing: the data subject shall have the right to obtain from the Data Controller restriction of processing where the grounds set out in article 18 of the GDPR apply;

  • The right to data portability: the data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to the Data controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller without hindrance from the Data Controller to which the personal data have been provided under the conditions set out in article 20 of the GDPR;

  • The right to object to marketing communications: the contractor has the right to oppose, in every moment, free of charge, to the receipt of commercial communication.

14. Exercise of rights

The requests for exercising the rights indicated in this policy, including, in particular, the right to withdraw the consent given must be addressed directly to the Data Controller at the email address info@searchon.it. Alternatively, you can exercise your rights by sending a registered letter to Search On Media Group Srl Via dei Mille, 3 40121 Bologna.