INFORMATION FOR THE PROCESSING OF PERSONAL DATA

(EU REGULATION No. 2016/679 - General Data Protection Regulation)

SOFTAGILE S.r.l., with registered office in via Giovanni Falcone, 9, 20094 Corsico (MI), CF e P.Iva 13425590158 (henceforth "Controller"), as data controller, informs you pursuant to EU Regulation n. 2016/679 (henceforth, "GDPR") that your data will be processed in the manner and for the following purposes:

1. Object of the treatment
The Controller processes personal, identifying and non-sensitive data (in particular, name, surname, company name, address, email address, telephone number - subsequently, "personal data" or even "data") communicated by you when requesting contact and activation of the app from the website and from the app store of the Controller and / or when subscribing to the newsletter service offered by the Controller.

2. Purpose of the processing
Your personal data are processed:
A) without your express consent (GDPR), for the following Service Purposes:
- request actions for contacting and activating services (app and freemium) requested by you;
- allow registration to the newsletter service provided by the Controller;
- conclude the contracts for the services of the Controller;
- fulfill the pre-contractual, contractual and tax obligations deriving from relations established with you;
- fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority;
- prevent or discover fraudulent activities or malicious abuses for the website and app stores;
- exercise the rights of the Controller, for example the right to defense in court.
B) Only subject to specific and distinct consent (article 7 of the GDPR), for the following Marketing Purposes:
- send e-mail newsletters, commercial communications and / or advertising material on products or services offered by the Controller.
We report that if you are already our customer, we may send commercial communications relating to services and products of the Controller similar to those you have already used, unless your dissent.

3. Methods of processing
The processing of your personal data is carried out by means of the operations indicated in art. 4 n. 2) of GDPR and more precisely: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of data. Your personal data are subjected to both paper and electronic and / or automated processing.
The Controller will process the personal data no longer than is necessary for the purposes for which the personal data are processed.

4. Access to data
Your data may be made accessible for the purposes referred to in points 2.A) and 2.B):
- to employees and collaborators, even external, of the Controller or of the company SoftAgile of which the Controller forms part, as persons in charge and / or internal managers of the processing and / or system administrators;
- to subjects providing services that are instrumental to the aforementioned purposes (for example, marketing services or technical services for data processing and management of information systems and technical project management activities, personal data storage, etc.) or third parties (for example, suppliers, lenders, professional offices, consultants, etc.) who carry out outsourcing activities on behalf of the Controller, appointed as external data processors.
These subjects will act as data processors or persons appointed to process data. The updated list of the subjects to whom the data can be communicated is available at the Controller, writing to softagile@pec.collabra.it.

5. Communication of data
Without express consent (pursuant to art. 6 lett. b) and c) of GDPR), the Controller may communicate your data for the purposes referred to in point 2.A) to Supervisory Bodies, Judicial Authorities and to all other subjects to whom the communication is mandatory by law for the accomplishment of said purposes. Your data will not be disclosed.

6. Data transfer
The management and storage of personal data will be carried out on servers located within the European Union of the Controller and / or appointed third-party companies and data processors duly appointed. Currently the servers are located in Italy. The data will not be transferred outside of the European Union. In any case it is understood that the Controller, if necessary, will have the right to move the servers to non-EU countries as well. In this case, the controller hereby ensures that the transfer of non-EU data will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.

7. Nature of the provision of data and consequences of refusal to reply
The provision of data for the purposes referred to in point 2.A) is mandatory. In their absence, we can not guarantee you neither the registration to the site nor the services of the point 2.A).
The provision of data for the purposes referred to in point 2.B) is optional. You can therefore decide not to give any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material relating to the Services offered by the Controller. In any case you will continue to be entitled to the services referred to in point 2.A).

8. Rights of the data subject
As data subject, you have the rights set forth in art. 15 of GDPR and precisely the rights to:
i. obtain the confirmation as to whether or not personal data concerning you are being processed, even if not yet registered, and their communication in an intelligible form;
ii. obtain the indication: a) of the origin of personal data; b) of the purposes and methods of the processing; c) of the logic applied in case of treatment carried out with the aid of electronic instruments; d) of the identification details of the Controller, the managers and the designated representative pursuant to art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it as designated representatives in the territory of the State, managers or agents;
iii. obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) c) certification that the operations referred to in letters a) and b) have been notified, also as regards their contents, to subjects to whom the data have been communicated or disseminated, except in the case that such operation is impossible to perform or involves the use of means that are manifestly disproportionate to the protected right;
iv. object, in whole or in part: a) for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by email and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the data subject, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that without prejudice to the data subject retains the right to object even only partially. Therefore, the data subject can decide to receive only communications using traditional methods or only automated communication or none of the two types of communication.
Where applicable, it also has the rights referred to in Articles 16-21 of GDPR (Right of rectification, Right to erasure (‘right to be forgotten’), Right to restriction of processing, right to data portability, right to object, as well as the right to lodge a complaint with a supervisory authority.

9. How to exercise rights
You can exercise your rights at any time by sending:
- a certified e-mail. at the address softagile@pec.collabra.it;
- a letter with advice of receipt at SOFTAGILE S.r.l., Via Giovanni Pezzotti, 2 - 20141 Milan.

10. Minors
This website and the services of the controller are not intended for minors under the age of 18 and the Controller does not intentionally collect personal information about minors. In the event that information on minors were unintentionally registered, the Controller will delete them in a timely manner, at the request of users.

11. Owner, manager and agents
The controller is SOFTAGILE S.r.l. with registered office in Via Giovanni Falcone, 9 - 20094 Corsico (MI) and operational headquarters in Via Giovanni Pezzotti, 2 - 20141 Milan.
The updated list of data processors or persons appointed to process data is kept at Controller's headquarters.

12. Changes to this Statement
This information may change. It is therefore advisable to regularly check this information and refer to its latest version.