The Data Controller reserves the right to amend or simply update, in whole or in part, this statement, also because of changes in the applicable legislation. The Data Controller will make such changes public as soon as they are applied, and they will be binding as soon as they are published on the website. The Data Controller, therefore, invites you to regularly visit this section to view the most recent and updated version of this Privacy Policy so that you are always up to date on the data collected and its use.
Please note that this Privacy Policy applies only to the website www. easrl.com and not to other websites that may be consulted via external links.
Which laws does this document refer to? This Privacy Policy is drafted based on the combined provisions of:
- Law 171/2018 on the Protection of Natural Persons with regard to the Processing of Personal Data (also referred to as the RSM law)
- EU Data Protection Regulation 2016/679 (EU GDPR)
- Legislative Decree 196/2003, as amended by Legislative Decree 101/2018 and subsequent amendments and additions (Italian Personal Data Protection Code)
- "Guidance on cookies and other trackers" dated 10 June 2021 of the Italian Data Protection Authority
- European Directive 2002/58/EC, also known as "ePrivacy".
1. Recipients
Users of website: easrl.com
2. Data controller and data processors
The data controller is the company EA S.R.L., Strada degli Angariari, 25 – 47891 Falciano (SM), COE: SM05756 which should be contacted to exercise the rights under Law 171/2018 on the Protection of Natural Persons with regard to the processing of personal data (the RSM law)
An updated list of all other Data Processors, if any, is available and may be consulted at the Data Controller's premises.
3. Place of data processing
Personal Data are processed at the Controller's premises and at any other place where the parties involved in the processing are located. For more information, please contact the Data Controller.
Personal Data may be transferred to a country other than the one where the User is located. For more information on the location of data processing, you may refer to the section on Personal Data processing details.
You have the right to obtain information about the legal basis for the transfer of Data outside the European Union or to an international organisation under public international law or consisting of two or more countries, such as the UN, as well as about the security measures taken by the Data Controller to protect the Data.
4. Types of Data processed and Purposes of data processing
The Data processed are of a general nature (identification) and navigation data (IP Addresses, URI notation addresses, etc.), but special and/or sensitive data provided voluntarily for your particular needs may also be processed (information in general and in particular on your interests and preferences; food intolerances; health problems; etc.); Data provided when using and navigating social platforms associated with the data controller entails further processing of your personal data by the respective social platform providers, not necessarily limited to your interaction with us. The processing of your personal data complies with the policies in use on the platforms used. Data shared by users through private messages or comments sent directly to the managers of the channels will be processed in accordance with current data protection regulations and this policy.
The Controller will process your data:
A) without your express consent for the following Service Purposes:
- To fulfil contractual and pre-contractual obligations (preparing quotations, managing bookings and appointments, issuing invoices and quotations, providing a service);
- To respond to contact requests via forms on the website, via social platforms used by the owner (Facebook, Instagram, etc.) and via instant messaging services (WhatsApp, Messenger, etc.);
- To fulfil regulatory obligations, in particular accounting, tax and security obligations;
- Following the purchase of a product or service, the data controller may send the user further information, also of a commercial nature, regarding the same category of goods as the purchases made. The legal basis for such data processing is the legitimate interest of the data controller.
- Managing any disputes.
The processing of Functional Data for the fulfilment of these obligations is necessary for the correct management of the requested service and their provision is required to implement the purposes indicated above. Failure to provide such Data may make it impossible for the Data Controller to respond to any request from the data subject.
B) only with your specific and express consent, for the following Marketing Purposes:
- To send you newsletters, commercial offers, or promotions and/or services offered by the Data Controller by email, post and/or SMS and/or by phone; to send information and commercial offers, also from third parties; to send advertising and information material; to send commercial information, also through interactive marketing; to sell or place products or services.
- To send questionnaires or other documents to assess satisfaction with the quality of the services offered; to conduct studies and carry out statistical research on sales, customers and other information, and, if necessary, share them with third parties; to transfer to third parties the data collected and processed for commercial purposes, including for sale or attempted sale and also outside the European Union, or for all lawful commercial and/or statistical purposes. To make it possible for you to enter prize draws associated with promotions and business initiatives.
- To send national holiday greetings.
Failure to provide consent for the purposes referred to in point B) will have no consequences. Consent is optional.
5. Data disclosure and dissemination
Personal data may only be disclosed to the data subject and to persons explicitly appointed by the data subject. Personal data will not be disseminated and disclosed, except to persons and/or companies duly authorised by the data controller for better management of the service, to fulfil specific legal obligations arising from the service offered, also for tax compliance, or for purposes strictly connected to, and for the provision of the service. Your personal data will not be transferred to any third country or international organisation.
The full list of data controllers can be obtained by sending a written request to the Data Controller, and in particular to ea@easrl.com.
1. Data processing methods
Data processing consists in collecting, recording, organising, storing, and sharing data. Personal data are processed for the above purposes by means of computerised and telematic tools, in compliance with the provisions of Article 5 of Law 171/2018, and in accordance with the principles of lawfulness, legitimacy, confidentiality and security referred to in the regulations in force. Personal data will be retained for a period necessary for the purposes for which they were collected or subsequently processed in accordance with legal obligations, and in any case for no longer than 5 years.
DATA CONCERNING CHILDREN (UNDER THE AGE OF 18)
Children under the age of 18 may not provide personal data. The Data Controller shall in no way be held responsible for any collection of personal data, nor for any false declarations, provided by children, and in any case, should the use of such data be detected, the Data Controller shall facilitate the right of access and cancellation to be exercised by the guardian, custodian, or any person with parental responsibility.
6. Rights of data subjects
You have the right to obtain access to, and rectification of your personal data. You also have the right, for legitimate reasons, to have your personal data erased, to restrict their processing, or to object to their processing, as well as, more generally, to exercise all the rights granted by current legal provisions to data subjects. To exercise your rights, you may always contact the Data Controller, by sending your requests to the ea@easrl.com address, as well as to the Personal Data Protection Authority.
7. Right to lodge a complaint
Data subjects who believe that personal data concerning them has been processed in violation of the provisions of Law 171/2018 have the right to lodge a complaint:
in the area of San Marino, to the Data Protection Authority (www.garanteprivacy.sm), as provided for in Article 66 of the GDPR-SM, or to take legal action in the appropriate courts (Article 70 of the GDPR-SM);
in the European Union, to the Italian the Data Protection Authority (www.gpdp.it), as provided for in Art. 77 of the EU GDPR itself, or to obtain a judicial remedy (Art. 79 of the EU GDPR).
COOKIE POLICY
Cookies are used on our website and in our emails to offer users a better service and experience. From now on, our trusted partners may also share the information we obtain and improve the user experience on their websites. This document describes the categories of cookies we use and share with our partners, their purpose and how you can change your preferences.
This cookie policy is written taking into account the combined provisions of:
- Law 171/2018 on the Protection of Natural Persons with regard to the Processing of Personal Data (also referred to as the RSM law)
- EU Data Protection Regulation 2016/679 (EU GDPR)
- Legislative Decree 196/2003, as amended by Legislative Decree 101/2018 and subsequent amendments and additions (Italian Personal Data Protection Code)
- "Guidance on cookies and other trackers" dated 10 June 2021 of the Italian Data Protection Authority
- European Directive 2002/58/EC, also known as "ePrivacy".
ABOUT COOKIES
Cookies are small text files stored by your browser on your computer's hard disk that contain a certain amount of information exchanged between a website and your terminal device and are normally used by website operators to store information needed to improve website navigation or to send advertising messages in line with the preferences expressed by the user when surfing the net. When visiting the same website or any other website again, your device checks for the presence of a recognised cookie so that it can read the information it contains. Different cookies contain different information and are used for different purposes (efficient navigation of the pages of the same website, profiling in order to send targeted promotional messages, monitoring the number of visits to the website). More generally, some cookies (called session cookies) are temporarily installed on your device until the session expires and are automatically deleted when the browser is closed. Other cookies (known as persistent cookies) remain on your device past the point of session expiration. The specific purposes of the different types of cookies installed on this website are described in detail below. You can follow the information below to disable cookies.
COOKIES USED BY THIS WEBSITE
The cookies we use make it possible for us to detect returning users and their personal information, so that they do not have to enter the same information again and again. They also allow us to analyse the traffic patterns of users visiting our website, so that we can improve its usability. Here are some of the types of cookies used on our website:
Technical cookies
This website may use technical cookies to enable users to take advantage of the services requested through our website. Without these cookies, it would not be possible to provide the services requested. For example, technical cookies may be used to:
- Allow users to access secure areas of our website without having to repeatedly log in;
- Memorise any user activity (e.g., completion of a form) when returning to the previous page of a session.
How to disable these cookies? The main and most popular browsers accept all cookies by default. You can change this option by using the features of your browser and, in particular, by turning them off – as described below – or by requiring explicit consent for each incoming cookie when it is received.
Analytical cookies
Analytical cookies may be used to collect information about the use of the website, advertisements and emails and to alert us to possible errors. These cookies also make it possible to obtain detailed technical information such as the last page visited, the number of pages visited, whether an email has been opened, which parts of the website or emails are clicked on by users and the time elapsed between clicks. This information may be associated with user details such as IP address, domain or browser; however, it is analysed together with other people's information so as not to identify a particular user. For example, these cookies may be used on our website to:
- Analyse and improve the performance and design of our website, advertisements and emails;
- Quantify the response to our advertisements and make them more effective;
- Calculate errors occurring on our website to improve service and handle any complaints.
For more information and to disable third-party analytical cookies go to: www.youronlinechoices.com/it
Third-party tracking cookies
Third-party tracking cookies may be sent to your device from our partners' websites. These cookies are used to determine when partners redirect a user to our website and whether that user completes the purchase of a product or service. Information may be shared anonymously with our partners so as not to identify any particular user. In addition, this information is provided in accordance with our contractual obligations to partners to help them improve the effectiveness of their websites.
Functionality cookies
These cookies are not essential, but they allow you to take advantage of several useful features on our website. For example, they may be used on our website to:
- Remember preferences selected by you during previous visits, such as country/language, interests and website presentation (layout, font size, colours and so on). This way, you will not have to enter this information again;
- Remember answers to questions asked by our website, for example about participation in customer satisfaction surveys, so that they are not re-submitted to you;
- Determine whether a service has already been offered to you, for example real-time online support;
- Provide information to enable you to take advantage of optional services, for example, watching an online video or posting a comment on a blog.
Targeting or advertising cookies
These cookies may be used on our website to serve advertisements tailored to your interests. Targeting or advertising cookies allow us to collect detailed information about how users navigate our website (for example, the products or services most viewed by a particular individual). They also allow us to detect users who return to our website and/or a website that is part of the network of one of our advertising partners.
Third-party cookies
When you use our website, it is possible that some unchecked cookies may be stored. This happens, for example, if you visit a page that contains content from a third-party website. As a result, cookies from these third-party services will be installed on your device. These cookies do not contain any personal information unless you are logged in to your account.
For more information on the use of cookies by third parties, please refer to the privacy and cookie policy of the services in question.
CONSENT
Consent to the use of cookies is initially given by closing the information banner or clicking on any of its interactive elements (buttons). You can change your settings at any time by using one of the methods described in the ‘Clearing or blocking cookies’ section, or You can change your cookie preferences for this specific website by clicking here: "cookie preferences".
Clearing and/or blocking cookies
Most web browsers are set to accept cookies by default, but you can use your browser settings to accept all cookies, block them or select which ones to accept based on where they come from. You can also set your browser to accept or block cookies individually before they are installed. You can also regularly delete cookies stored on your device from your browser. Please, remember to configure all browsers installed on your devices (tablets, smartphones, computers, etc.). About the management of cookies and user preferences, configurations may vary from one browser to another. These settings are described in the ‘help’ menu of the browser in use, from where you can also change your cookie preferences.
For example:
Internet Explorer: http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies
Safari: http://www.apple.com/legal/privacy/en-ww/cookies
Chrome: http://support.google.com/chrome/bin/answer.py?hl=en&hlrm=en&answer=95647
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Opera: http://help.opera.com/Windows/10.20/en/cookies.html.
At www.allaboutcookies.org you will find simple instructions on how to manage cookies on different types of browsers. Most advertising networks offer the possibility to disable cookies in your browser.
At www.aboutads.info/choices/ and www.youronlinechoices.com you will find useful information on how to do this.
What happens if you disable cookies
If you set your browser to block cookies, you will not be able to access certain features, pages and sections of the website. You might not be able to restore your previously specified preferences or personalised settings and we will not be able to fully personalise your