Drafted in accordance with Regulation (EU) 2016/679 of April 27, 2016 (General Data Protection Regulation – GDPR) and Legislative Decree No. 196 of June 30, 2003, as amended by Legislative Decree No. 101 of August 10, 2018, and issued by E-Cute S.r.l. Società Benefit in its capacity as Data Controller.

PREAMBLE

Dear User, this page outlines some rules regarding the processing of personal data entered on the platform (hereinafter, the Platform) managed by E-Cute S.r.l. Società Benefit (hereinafter, the Company or the Data Controller). These rules apply whenever you access the Platform using your credentials after registering.

NAVIGATION DATA

This privacy policy refers to this Platform and does not apply to other websites that the User may visit through links connected to or originating from the Platform. Such websites may contain “privacy policies” that differ, in whole or in part, from this one. Therefore, the Data Controller encourages the User to review the privacy policy of each site they connect to before entering any personal information.

PERSONAL DATA SUBJECT TO PROCESSING

The IT systems and software procedures involved in the operation of the Platform acquire, during their normal operation, certain data whose transmission is automatic when using Internet communication protocols. These data are not associated with identified users, although, by their nature, they could, through processing and association with data held by third parties, allow identification of Users. Personal data include the IP addresses or domain names of the computers used by the Users who connect to the Platform, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the server response status (success, error, etc.), and other technical information automatically sent by the connection management programs (so-called Metadata). These data are used solely for the purpose of obtaining the connection, collecting anonymous statistical information about Platform usage, and monitoring its proper functioning. Furthermore, personal data entered voluntarily by each User during registration and later while using the services provided through the Platform are also processed.

LOCATION OF DATA PROCESSING

The Platform is hosted on servers managed by an Italian company, located in Italy, and is therefore subject to Italian and European Union legislation. The highest technological standards for data processing security are guaranteed, ensuring confidentiality and full compliance with personal data processing regulations. The Data Controller regularly performs checks and audits and receives detailed reports concerning the hardware configuration on which the software operating the Platform is installed.

THE DATA CONTROLLER, PURPOSES, AND LEGAL BASES

The Data Controller acquires/holds and processes your personal data based on the consent provided in accordance with Article 6, letter a of the GDPR via specific checkboxes depending on the purposes indicated, specifically:

• Registration and access to the restricted area of the Platform, subject to mandatory consent;
• Statistical analysis for marketing purposes, with optional consent;
• Receiving newsletters, new product announcements, market research, services and offers, commercial communications, invitations to events promoted by the Data Controller, with optional consent;
• Communication of personal data to third-party companies offering specific services for hearing-impaired individuals, with optional consent.

Consent is provided through a banner and/or pop-up on the Platform during initial registration by ticking the relevant box. Optional consents can be revoked at any time by sending an email to: info@e-cute.it.

RECIPIENTS

The recipients of this policy are all Users who register and voluntarily access the Platform. If a minor registers, their email address will only be used to inform them that registration is not possible due to age restrictions, after which the data will be deleted.

PROCESSING METHODS

Processing is carried out both manually and electronically, via telematics and/or computing tools, including automated systems designed to store, manage, and transmit the data, ensuring the adoption of precautionary measures to guarantee security and confidentiality. Specific security measures are adopted to prevent data loss, unlawful or incorrect use, and unauthorized access. In paper form, the data are processed and stored at the company’s premises and offices. In electronic form, the data are processed at the company’s computers/devices and servers it manages. The data will be processed by the Data Controller’s employees and collaborators, as authorized persons, within the scope of their duties and in accordance with the instructions received. Data will be stored for two years from the User’s last access to the Platform.

DATA COMMUNICATION

The data will not be disseminated, meaning they will not be made available to indeterminate subjects in any way, including by making them available or consultable. The data will be made available to third-party companies or other entities providing outsourcing services on behalf of the Data Controller, to whom the Data Controller assigns certain tasks related to the activities described in this policy, by appointing them as Data Processors. Your data may be communicated, meaning made known (also for potential processing), to one or more specific subjects within the limits strictly necessary to fulfill the obligations, tasks, and purposes outlined above, and, where required, with your specific and prior optional consent.

TRANSFER OF DATA ABROAD

Your data will normally be processed in Italy or, in any case, within the European Union. However, they may be transferred outside the European Economic Area. This Platform may share some of the collected data with services located outside the European Union, specifically with Google, Facebook, and Microsoft via social plugins and the Google Analytics service. This transfer is authorized based on specific decisions of the European Union and the Italian Data Protection Authority, particularly Decision 1250/2016 (Privacy Shield – informational page from the Italian Authority).

RIGHTS OF DATA SUBJECTS

You may exercise the following rights:

• Access: To confirm whether personal data processing is ongoing, and to know its content and origin;
• Rectification, Deletion, Limitation, and Opposition to processing. Under the GDPR, the user has the right to request the deletion, anonymization, or blocking of data processed unlawfully, and to oppose, for legitimate reasons, their processing.

In case of opposition, the data will no longer be processed unless the Data Controller demonstrates legitimate reasons to continue processing or to comply with legal obligations. Requests to exercise your rights, as indicated above, may be submitted by post to the Data Controller at E-Cute S.r.l. Società Benefit, via Papacino, 8 – 10121 Torino, or by email at info@e-cute.it. You also have the right to file a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).

CANCELLATION

The Data Controller will delete your data without undue delay if:

• Your personal data is no longer necessary for the purposes for which it was collected or processed and, in any case, within two years from your last access to the Platform;
• You, as the data subject, have withdrawn consent for processing, and no other legal basis for processing exists;
• You have opposed the processing, and no overriding legitimate grounds for processing exist;
• Your personal data has been processed unlawfully;
• Your personal data must be deleted to comply with a legal obligation.

CONSENTS

Necessary:

1 – I authorize the processing of my personal data necessary to access the Platform and allow navigation within it according to the purposes stated in the related Privacy Policy.

( ) YES (…) NO

Optional:

2 – I consent to the processing of my contact details to receive communication from the Data Controller regarding new services and/or proposals addressed to Platform users.

( ) YES (…) NO

3 – I consent to the communication of my contact details to third-party companies to receive offers and/or communications specifically aimed at hearing-impaired individuals.

( ) YES (…) NO