Contact details of the Data Protection Officer of Digital Bros S.p.A.
Digital Bros S.p.A. has appointed according to art. 37 to EU Regulation 2016/679 GDPR a Data Protection Officer and an IT System Administrator. DPO reports directly to the Board of Directors as per GDPR Regulation; periodic privacy committee are held by DPO who writes minutes. The Group General Counsel carries out the Privacy Officer.
Contact details of the Data Protection Officer for data subjects (clients, shareholders, users, suppliers and partners) for Digital Bros S.p.A. are as follows:
Postal address: avv. Veronica Devetag Chalaupka, DPO, Digital Bros Spa, Via Tortona, 37, 3/B 20144 (Milano).
Email address: firstname.lastname@example.org
Contact details of the IT System Administrator of Digital Bros S.p.A.
Digital Bros S.p.A. has appointed a IT System Administrator. Contact details of the It System Administrator for data subjects (i.e. clients, shareholders, users, suppliers and partners, etc.) for Digital Bros S.p.A. are as follows:
Postal address: dott. Stefano Salbe, Amministratore di Sistema, Digital Bros S.p.A., Via Tortona, 37, 3/B (Milano).
Email address: email@example.com
Privacy procedures manual
Aware of the importance of privacy and data protection, the Company has implemented a training program for the Group’s employees. Training is held regularly both in presence and online, supported by material previously made available.
To further hedge the cyber risk to which might be potentially exposed, the Group stipulated an insurance policy to reduce the economic and financial impact of a possible cyber security breach, data loss, business interruptions, privacy violations and data breaches.
Information to all stakeholders on the protection of Personal Data
It is provided pursuant to Regulation 2016/679/EU (General Data Protection Regulation – hereinafter GDPR), Article 122 of the Personal Data Protection Code (Italian Legislative Decree 196/03, the Privacy Code) and the General Provision of the Italian Data Protection Authority of 8 May 2014 on cookies, as supplemented by the Italian Personal Data Protection Authority Guidelines of 10 June 2021 on cookies and other tracking tools, for those who connect to the sites www.digitalbros.com.
Data Controller, Data Protection Officer and categories of persons authorized to process data at Digital Bros S.p.A.
The Data Controller is Digital Bros S.p.A., with registered office in Via Tortona, 37 – 20144 Milan, Italy, email to firstname.lastname@example.org. Digital Bros S.p.A. has appointed a Data Protection Officer, who can be contacted at Digital Bros by writing to the following address: via Tortona, 37\3B – 20144 Milan, Italy; or by sending an email to email@example.com
An up-to-date list of the Data Protection Officer’s contact details can be found at www.digitalbros.com
The above website is owned and managed by Digital Bros S.p.A. who ensures compliance with legislation regarding data protection, in line with the provisions of the Digital Bros Group Code of Conduct.
The data of users/visitors of this Site will be processed by employees of Digital Bros S.p.A., who have been appointed as persons authorised to process personal data and have received appropriate operating instructions in this respect.
The recipients of the data collected following consultation of the site are subjects designated as data controllers by the Digital Bros S.p.A., pursuant to article 28 of the Regulation.
Type of data processed and purpose of processing
1. Browsing data, information for accessing authenticated areas and the storage thereof
The computer systems and the software procedures used to operate these Sites, during their normal operation, acquire some data that are implicitly transmitted when using Internet communication protocols.
This data is not collected in order to be associated with identified data subjects, but by its nature it could, even through processing data held by third parties, allow users/visitors to be identified (e.g. IP address, domain names of the computers used by users who connect to the Sites, identifier, brand and model of the device and other parameters relating to the operating system of the device, the code indicating the status of the response given by the server, type of browser, the identifier of the individual session with timestamps of the beginning and the end of the browsing session, possible identifier of the account and of the activities carried out on the Sites, etc.).
This data is only used for statistical purposes and to check that the Sites are working properly. The data itself is stored for a maximum of six months, without prejudice to further storage for any investigation of computer crimes against the Sites or to meet specific regulatory obligations.
No data from the web service will be disseminated.
2.1 General information on cookies
Cookies are small text files that websites visited by users send to their devices (usually to browsers or smartphones), where they are stored and then transmitted back to the same sites each time they visit using the same device.
In addition, each website may allow the transmission of third-party cookies, i.e. cookies generated by websites other than the one the user is visiting (through objects on it such as banners, images, maps, sounds, specific links to web pages of other domains).
Depending on their duration, a distinction is made between session cookies (i.e. cookies that are temporary and automatically deleted from the device at the end of the browsing session by closing the browser) and persistent cookies (i.e. cookies that remain stored on the device until they expire or are deleted by the user).
Cookies serve several purposes.
They are primarily used to carry out the transmission of a communication or to provide the service requested by the user. More specifically, they enable and optimise the operation of the website, perform computer authentication and prevent abuse, monitor sessions, improve the user’s browsing experience, for example by maintaining the connection to reserved areas while browsing through the pages of the site without having to re-enter the User ID and password and storing specific information about the users themselves (including preferences, type of browser and computer used). They may also be used (anonymously, if third-party) to carry out aggregate analysis on the operation of the site , the number of users and how they visit the site.
The above-mentioned cookies are called technical cookies (their use does not require the user’s consent), since without them some of the operations mentioned above could not be carried out or would be more complex and/or less secure.
2.2 Use of first-party cookies
These Sites may use session cookies and persistent cookies.
The types of first-party cookies generated and transmitted by these Sites are:
“technical” cookies, used to verify that the user is a person and not a bot through the use of a Captcha service. The service uses functions supplied by Recaptcha, provided by Google LLC.
2.3 Analytics cookies
Digital Bros S.p.A. does not use web measurement services to collect aggregate/statistical information on the number of users and how they visit these Sites.
2.4 Third-party cookies
Third-party cookies, these cookies are issued by “external” players, such as ad servers and social sharing buttons.
The third parties consist of the following categories:
a) social media, which typically manage cookies to enable, via plug-ins, the sharing of content between “logged in” members of the same social media network. The social media with which the Sites interact, solely for the purpose of sharingpages of the site, are:
2.5 Managing your cookie preferences
Cookies can be managed by the user through their browser.
The user/visitor can manage cookie preferences through menu options present in common browsers (Internet Explorer, Mozilla Firefox, Google Chrome, Apple Safari), which allow users to delete/remove cookies (all or some) or to change the settings of the browser itself in order to block the sending of cookies or to limit it to specific sites (as opposed to others). It is possible to find out how to configure the browser settings (usually accessible from the ‘Tools’ bar) by going to the ‘Support’ web pages of the providers of these browsers (which can also be found using a common search engine).
Disabling cookies does not in itself preclude the use of the Website’s services; however, if all cookies, including technical ones, are deleted/blocked, some operations cannot be performed or will be more complex and/or less secure, such as, performing activities within the website’s Restricted Areas (in fact, cookies make it possible to carry out and maintain user identification during the session).
Data gathering using analytics cookies can be deleted. If cookies are deleted, the information collected before your preferences were changed can still be used. However, disabled cookies will no longer be used to collect more information about your browsing experience. For marketing cookies, when a user chooses not to be tracked, a new cookie is subsequently placed to prevent users from being tracked.
3. Data provided voluntarily by users/visitors
If users/visitors connect to these Sites and send their personal data in order to access certain services, or to make requests by e-mail or filling out web-forms, this involves the acquisition by Digital Bros S.p.A. of the sender’s address and/or any other personal data, which will be processed exclusively for the purpose of responding to the request or to provide the service.
Personal data provided by users/visitors will only be disclosed to third parties if such disclosure is necessary to fulfil the requests of users/visitors.
Processing is carried out by means of automated and telematic tools and/or manually for the time strictly necessary to achieve the purposes for which the data were collected and, in any case, in accordance with the relevant legislation in force.
Data processing to a third country
Digital Bros S.p.A.’s website servers are located in Italy. No data is transferred to third countries outside of the European Economic Area.
Place of processing
The processing of the web services of the Site takes place at Data Controller’s headquarters located in Italy and is carried out by authorized personnel only.
The data is retained only for the period of time necessary in relation to the purposes for which they are processed (“data minimization principle” pursuant to article 5 of EU Regulation) or according to the deadlines set by the Law.
Optional provision of data
Apart from what is specified for browsing data, users/visitors are free to provide their personal data. Failure to provide said data may only result in the impossibility of obtaining what has been requested.
Rights of the data subjects
Users/visitors have the right to access their data at any time and to exercise the other rights provided for in Articles 15 to 22 of the GDPR (e.g. to request the origin of the data, rectification of inaccurate or incomplete data, restriction of processing, erasure or the right to be forgotten, data portability, as well as the right to object to the use of the data for legitimate reasons),
Finally, users/visitors have the right to lodge a complaint with the Data Protection Authority.
1. What is personal data?
“Personal Data” (or “Data”), is all information that identifies you:
- either directly, for example, your last name, first name, email address or telephone number;
- or indirectly, for example your account ID, IP address, cookie identifier or game data.
2. Can minors access our Services?
The age at which minors can create an account or have access to some of our services depends on the personal data protection laws of each country.
3. How long we keep your Personal Data?
Unless the law specifies a different retention period, we will only keep your Data for the time strictly necessary to carry out the operations for which said Data has been collected.
4. What are your rights and how do you exercise your rights?
- Obtain a copy of your Data – “Right of access and data portability”: At any time you can request a copy of the Data associated with your Account. You may also consult the Data, use it yourself or transfer it to another service provider.
- Correct your Data – “Right to rectification”: You have the right to correct your Data when it is inaccurate or incomplete (for example, change your delivery address).
- Give and withdraw your consent – “Right to object and withdraw your consent”: At any time, you may withdraw your consent or object to the receipt of newsletters or advertising emails, the personalisation of advertisements or the sharing of your Data with our partners (except for subsidiaries and technical service providers).
- Delete your Account – “Right to erasure (right to be forgotten)”: You can request the closure of your Account and the deletion of the associated Data.
- Limit the use of your Data – “Right to restriction of processing”: You also have the right to request that your Data no longer be used or not be deleted during the time we are processing your request.
- To exercise your rights or for any question regarding the exercise of these rights, you can write to firstname.lastname@example.org
If you feel that your rights have not been respected after having contacted us, you have the right to make a complaint to the regulatory authority in your country.