This privacy disclosure notice was compiled pursuant to art. 13 of Legislative Decree 196/2003, i.e. the Italian “Personal Data Protection Code” (hereinafter the “Code”) and is given to users accessing the website owned by EDOC s.r.l.s. (“EDOC”) on www.edoc.tips (the “Website”). Its purpose is to describe terms and conditions for the use and processing of users’ personal data within the Website. This notice is only intended for the Website above and does not relate to the other websites users may access by clicking on the hyperlinks featured in the Website.
This notice is also designed to inform the Website users of the terms and conditions for EDOC’s processing of any personal data they should decide to provide.
Users are required to carefully read this notice before providing any personal information and/or completing any e-form available on the Website.
1. TYPE OF PROCESSED DATA
EDOC may collect personal data from users including, e.g., their respective User IDs and passwords, their first and family names, their email addresses, any data or information collected when navigating in the Website, and other personal data voluntarily provided by them during their registration, on ordering the goods and services offered by the Website, or on submitting their email enquiries through the Website.
The Website may be accessed by users with no need to enter any personal data. However, some Website functions (e.g., document download) are only accessible to registered users.
1.1 Navigation Data
IT systems and software procedures for the normal operation of this Website involve the collection of a few data that are implicitly uploaded by the use of Internet communication protocols.
This type of data include, e.g., IP addresses, the domain names of computers used by users accessing the Website, the URI (Uniform Resource Identifier) addresses of any used resources, the time band of server queries, the method used in making a query to the server, the size of files obtained in return, the numeric identifier of the status of a response given by the server and other parameters related to the user’s operating system and computer environment.
As a rule, this type of information is not collected in order to be associated with specific data subjects and may be used by EDOC for the purpose of collecting anonymous statistical information on the Website use and check its correct operation.
The same data may also be used to assess any liabilities in case of any cyber-crime-related damage or loss caused to the Website.
Cookies are text files sent by the Website to the user’s PC browser. The browser saves information and forwards it on to the Website server when a user accesses the Website the next time.
The Website will use:
(a) session cookies, i.e. cookies that are temporarily stored in the user’s browser ‘cookie’ folder for the full duration of the navigation session;
(b) permanent cookies, i.e. cookies that remain stored in the browser folder for longer periods of time (depending on the duration of each cookie).
The use of session cookies (not stored permanently on the user’s PC and to be deleted when a user logs off the browser) is meant (i) to ease the Website navigation and the use of applications that can be accessed from the Website; and (ii) to collect anonymous statistical information on the Website use and control its correct operation.
The use of permanent cookies is intended to provide users with specific services. For instance, when registration is made with a User ID and a password, users are given the opportunity to choose whether to store this information for it to be used on their next log-ins; this is made by storing a cookie on the user’s PC.
The Website can also be accessed and navigated without cookies. Most browsers accept cookies automatically. Automatic cookie storage can be avoided by selecting the relevant function from the browser. For further information on how to make this selection, kindly refer to the browser’s instructions. Through the browser, users may also delete any cookies stored on their hard disk at any time.
Please note that the choice not to accept cookies from the browser may make navigation in the Website more difficult or limit the use of the applications that are accessible from the Website.
1.3 Personal Data supplied by Users
EDOC will also collect the personal data entered by the users on filling in registration forms or on requesting goods or services, as well as any of their emailed personal data.
2. PURPOSE OF DATA PROCESSING
The Website users’ personal data will only be processed in accordance with the terms and conditions hereof and in compliance with the applicable provisions of the Privacy Code.
Data processing may consist of one of more of the following operations: collection, logging, organisation, archiving, consultation, processing, change, selection, extraction, comparison, use, interconnection, communication, disclosure, blocking, deletion and/or destruction of the Data.
Depending on the consent given or not given by each user, data will be processed for any of the following purposes:
(a) authorising, enabling and/or customising users’ access to the various Website areas and contents;
(b) provision of the users’ requested services;
(c) Newsletter mailing;
(d) mailing of communications and informative/promotional materials from EDOC and third parties;
(e) observance of the obligations required by any applicable laws and regulations transposing EU legislation, or of the instructions received from public authorities or regulatory bodies.
3. TERMS OF PROCESSING
Data will be processed in accordance with the principles of confidentiality, necessity, relevance, lawfulness and transparency as required by the Privacy Code.
Data will mainly be processed by means of electronic media, in compliance with the applicable legislation. Suitable security measures shall be observed to prevent any loss, illicit use, misuse or unauthorised access to the data.
Data will be archived for an amount of time not exceeding that strictly required for the purposes for which they were collected or subsequently processed.
4. VOLUNTARY or mandatory DATA
Users’ supply of specific types of data (as better identified by an asterisk on the applicable fields of the data input/registration form) is required – as the case may be – to access any reserved areas of the Website or to receive any requested goods or services.
Users’ failure to supply such data will prevent them from accessing the Website reserved areas, or from receiving their requested goods or services.
5. Scope of data COMMUNICATION AND DISSEMINATION
For the purposes under section 2 above and insofar as strictly necessary, data may be communicated to EDOC’s employees and hired contractors for and within the limits of their assigned functions and responsibilities.
In addition, data may be communicated to persons performing activities that are related to and instrumental in EDOC’s own activities, and whose service may be requested by EDOC following their appointment as data processors for the performance of such activities insofar as strictly necessary and in accordance with the purposes under section 2 above. These persons include, without limitation, those providing support to users and IT operators.
Data shall not be subject to dissemination.
7. USERS’ RIGHTS PROVIDED BY ART. 7 OF THE PERSONAL DATA PROTECTION Code
As data subject, you will be entitled to exercise the rights provided by art 7 of the Personal Data Protection Code. Such rights may be exercised in accordance with the terms of art. 9 of the said Code. In particular, please be informed that you may contact the data controller at any time to:
(a) enquire about the personal data that are in its possession, including those that are yet to be logged, and further obtain the communication of such data in intelligible form;
(b) obtain information on (i) the source of such data; (ii) the purposes and methods of their processing; (iii) the logic applied to their processing if the latter is carried out with the help of electronic means; (iv) the identification data concerning the data controller and each of the appointed data processors; and (v) the entities or categories of entity to whom or which data may be communicated, or who or which may get to know said data in their capacity as data processors or persons in charge of the processing;
(c) obtain: (i) the updating, the rectification or, where interested therein, the integration of the data; and (ii) the erasure, the conversion into an anonymous form or blocking of any data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; (iii) a formal confirmation that the operations under items (i) and (ii) above and their relevant contents have been notified to the entities to which or whom data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;
(d) object, in whole or in part: (i) on legitimate grounds, to the processing of his personal data, even though they are relevant to the purpose of the collection; and (ii) to the processing of his personal data, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
Users are entitled to exercise their rights under art. 7 of the Personal Data Protection Code, and receive the full updated list of data processors, by sending a letter to: EDOC or an email to: [email protected]