Categories of data processed: art. 4 nn. 1, 2, 3, 6 of this information.
With your optional consent, which can be expressed by selecting the appropriate consent box present in the dedicated sections of the Website (opt-in), in the cookie manager, or by selecting the appropriate box in the paper information models, we will process your data for the purpose of marketing (sending advertising material, carrying out market research, commercial communication, detecting the degree of customer satisfaction) and sending advertising information by mail, newsletter and / or SMS / MMS, offers and promotions relating to our products and services.
In any case, you can freely and freely revoke your consent to the processing of personal data for marketing purposes at any time, even selectively (for example, communicating the desire not to receive communications via email any more, wanting to receive only communications with the other contact methods), by requesting it by email at the addresses indicated in art. 14 of this information.
In relation to the promotional communications sent by email, you can withdraw your consent to the processing of the e-mail address for marketing purposes (newsletter, etc ...) also by clicking on the opt-out link present in each email promotional.
For transparency of information, and as required by the WP259 Guidelines on consent pursuant to the Regulation issued by the Group of European Guarantors, as an exception to the rule of consent granularity (as many consents to be requested as there are purposes and processing operations, if heterogeneous between of them) it should be noted that these Guidelines authorize a single formula of consent "to cover various processing operations, where such processing operations pursue a series of unitary purposes"; in addition, based on Recital 32 of the Regulation, a single consent can be applied "to all processing activities carried out for the same or the same purposes". The aforementioned purposes are objectively referable to the pursuit of a unitary purpose, although the processing operations are different, which is that of commercial promotion and marketing in a broad sense. Consequently, by giving the unitary consent to the Processing for Marketing Purposes, the interested party specifically acknowledges the homogeneous and different promotional, commercial and marketing purposes specified above (including the consequent management and administrative activities) and expressly authorizes said treatments and said purposes, both in the case in which the means used for the Treatment for Marketing Purposes are the telephone with operator or other non-electronic, non-telematic or non-supported means by automatic, electronic or telematic mechanisms and / or procedures, and where the means used are electronic mail, fax, sms, mms, automatic systems without operator intervention and the like, including electronic platforms and other telematic means. The definition of Treatment for Marketing Purposes includes both the treatments and the purposes specified above pursued by the Data Controller during the duration of the contractual relationship, as well as the specific ones consequent to the termination of the Contract, for any reason occurred, and aimed at transmitting communications to the interested party. unsolicited to invite him to renew the contract with each of the means indicated above (telephone with operator, non-electronic, non-telematic means or not supported by automatic, electronic or telematic mechanisms and / or procedures, e-mail, fax, sms, mms, systems automatic without operator intervention and the like, including electronic platforms and other telematic means).
Pursuant to Provv. General of the Guarantor for privacy of 15.5.13 entitled "Consent to the processing of personal data for" direct marketing "purposes through traditional and automated contact tools", the Customer's attention is specifically drawn to the fact that:
- any consent given for sending commercial and promotional communications through the use of e-mail, fax, sms, mms, automatic systems without operator intervention and the like, including electronic platforms and other telematic means, will imply the receipt of such communications , not only through these automated contact methods, but also through traditional methods, such as paper mail or operator calls;
- the right to object to the processing of their personal data for "direct marketing" purposes through the aforementioned automated contact methods, will in any case extend to traditional ones and, even in this case, the possibility of exercising this remains unaffected right in part, both with respect to certain means and with respect to certain treatments.
For the purpose of fulfilling the privacy obligations for the owner in compliance with the principles of simplification of the same obligations pursuant to Provv. General of the Guarantor for privacy of 15.5.13 cited, the Owner informs the Customer that the specific consent formula available according to the procedure for collecting the consent from time to time provided will be unitary and overall and will refer to all possible means of the aforementioned marketing treatment without prejudice to the possibility for the interested party to express a different will as regards the use of certain means and not others for the reception, subject to consent, of the marketing communications by simply sending an email to the addresses indicated in art . 14 of this information.
Furthermore, again for the purposes of the principle of compliance with the privacy obligations for the Data Controller in compliance with the principles of simplification of the same obligations, the Data Controller informs the Customer, also pursuant to the Regulations and the WP259 Guide on the consent pursuant to the Regulations issued by the Group of European guarantors that the specific consent formula will be unitary and comprehensive and will also refer to all the different and possible marketing purposes explained here (without multiplying the consent formulas for each distinct marketing purpose pursued by the owner), without prejudice to the possibility for the interested party to notify a different selective will as regards consent or refusal of consent or revocation of consent for individual marketing purposes by simply sending an email to the addresses indicated in art. 14 of this information.
To proceed with the Treatment for Marketing Purposes, it is mandatory for each Data Controller to acquire from the data subject an informed, free, unequivocal, specific, separate, expressed, documented, preventive and completely optional consent.
With a view to absolute transparency, the Data Controller summarizes in greater detail the purposes of the processing:
- send advertising and informative material (eg Newsletters), of a promotional nature or in any case of a commercial solicitation nature;
- carry out direct sales or placement of products or services of the Data Controller;
- send commercial information or make interactive commercial communications also pursuant to Legislative Decree 206/2005 through the use of email;
- elaborate studies, research, market statistics also in identification form.
Therefore, by giving optional consent, the interested party specifically acknowledges and authorizes these treatments and / or treatments that pursue the homogeneous different purposes provided herein. In any case, even where the interested party has given consent to authorize the Data Controller to pursue all the purposes of the Processing for Marketing Purposes, he will in any case remain free to revoke it, through our site by logging in with his credentials to his own. personal area. Following the withdrawal of any consent given by the interested party, the Data Controller will promptly remove and delete the data from the databases used for the Processing for Marketing Purposes and will inform any third parties to whom the data have been communicated for the same cancellation purposes.
5.2.2.Purpose - Profiling
Categories of data processed: art. 4 nn. 1, 2, 3, 6 of this information.
For marketing purposes and to improve services, through its website, the Data Controller also intends to proceed with the processing of so-called "profiling" data, and this occurs mainly through the use of tools for tracking activities on the website www. mobilirebecca.it, such as own or third-party profiling and pixel cookies, such as Facebook Pixel, which allows you to use Facebook services such as Facebook Custom Audiences, Facebook Lookalike, Facebook Remarketing.
For information on the specific technologies used for profiling purposes (e.g. Facebook Pixel), please also refer to the information on cookies and other technologies available here, where the methods for providing / denying consent are also indicated.
In general, for these treatments, and for the purpose of complete information, reference is made to the definition in art. 4, paragraph 1, no. (4) of the GDPR, which defines "profiling" "any form of automated processing of personal data consisting in the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to professional performance , the economic situation, health, personal preferences, interests, reliability, behavior, location or movements of said natural person ".
Based on the provisions of the Guidelines on profiling WP 251 of 3.10.17 as issued by the Group of European Guarantors, transparent information is provided on the logic, methods and mechanisms of profiling and the cases are clarified below and separately in which the Data Controller will be able to make decisions on the basis of completely automated treatments.
The profiling activity may concern "individual" personal data or "aggregated" personal data deriving from detailed individual personal data. To clarify what "profiling" consists of, reference can be made to the following parameters:
• the data are structured and coordinated on the basis of predefined parameters identified from time to time, according to company needs (regardless of ygfv Q|>ZR6789marketing, contractual, administrative, etc. purposes);
• the starting data, considered individually, may include varied personal information, including data on browsing experiences, type of consent given to receive particular commercial communications and not others, data on navigation and / or game habits to reconstruct the tastes and habits of the user, identifying the profile of potential consumer / player, in order to be able to send the same newsletter, commercial communications, offers and promotions consistent with the identified profile, etc;
• only after profiling (ie structuring according to predetermined parameters) is it possible to derive further indications referring to each interested party, further indications (ie the "profile", for example, market segment, active marketing communication services, commercial attitude, etc. ) that would not derive from the mere informative attitude of the data individually or separately considered.
In other words, profiling in the strict sense can result in the availability of information assets that go well beyond the information considered individually and relating to each interested party; in addition, profiling in the strict sense provides added value given by the many correlations that can be established between the individual data collected, in order to obtain useful additional information.cn,.§
As for the obligations for the Owner to provide - pursuant to art. 13, paragraph 2, letter f) of the GDPR - information on the logic of the profiling treatment as well as the importance and consequences of such treatment, the following is further clarified. Fundamental elements of the profiling treatment will be:
1) the predetermination of the parameters for structuring the data considered individually;
2) comparison, cross-referencing, correlation of these data with each other and comparative analysis carried out on the basis of predefined parameters, also through automated processes (i.e. the cataloging of individual data in clusters);
3) obtaining a profile through the above activities and which allows to identify a consumer profile and additional analytical indications with respect to individual data and allows to generate the mapping / segmentation into homogeneous groups of behavior (dynamic creation of behavioral profiles).
The treatments described above will be hereinafter collectively referred to as "Profiling Treatment".
The Data Controller may carry out the following Profiling Treatments, as in the case of detection of:
- number and type of requests for information on products and services offered made over a predetermined time horizon;
- number and type of expenses realized for products and / or services in a predetermined time horizon;
- number and type of new contracts possibly entered into within a predetermined time horizon;
- number and type of requests for information sent in a predetermined time horizon;
- number and type of visits to the Website over a predetermined time horizon, also through profiling cookies.
To proceed with a Profiling Treatment it is mandatory to acquire a specific, separate consent (also from the marketing consent referred to in art. 5.2.1 above), express, documented, preventive and entirely optional.
Consequently, where the interested party decides to give specific consent, it must be previously informed and aware that the purposes of the treatment pursued are of a specific commercial, advertising, promotional and marketing nature in a broad sense based on a Profiling Treatment. With a view to absolute transparency, the Data Controller therefore informs that the data collected on the basis of specific consent may be subject to a Profiling Treatment for the same purposes referred to in art. 5.2 of this information, while the scope of communication will eventually be the same already explained for Marketing Treatments.
In any case, even where the interested party has given consent to authorize the Data Controller to pursue all the purposes of the Processing for Profiling Purposes, he will in any case remain free to revoke it, through the Data Controller Website www.mobilirebecca.it, by logging in with your credentials in your personal area or, in the absence of a personal profile, by accessing the "Manage cookies" section. It informs itself specifically and separately, as required by art. 21 of the GDPR, that the interested party has the right to object at any time to the processing of personal data concerning him / her carried out for profiling purposes by simply sending an email to firstname.lastname@example.org (even if he has previously given consent) and that if the interested party opposes the profiling treatment, personal data can no longer be processed for these purposes, without prejudice to the legitimacy of the processing carried out until the moment the consent is revoked.
If the interested party does not intend to give consent to the processing for profiling purposes, there will be no consequence or prejudice on the contract possibly existing with the Data Controller. Failure to provide the Treatment for Profiling Purposes will not cause any interference and / or consequence on any other contractual, contractual or other relationships existing with the Customer.
The Customer is then free to give consent to the Treatment for Profiling Purposes but also not the further consent to the communication to third parties who in turn wish to proceed with the Treatment for Profiling Purposes. Where the customer does not intend to give consent to the communication of his data to third parties for the processing for profiling purposes, the consequence will be that there will be no communication from the owner and the data will be processed only and exclusively by the owner, where the user has given this separate consent to the processing for profiling purposes.
The data subject to the Profiling Treatment and the related authorized profiles will not be disclosed.