Amanuens/Threeplicate Srl Privacy Policy

Last modified: 2010-03-03 — Print this document

Our Privacy Policy In Short

We're an Italian company, thus we're subject to the Italian laws.

Our Promise

  1. We will only collect the minimum required data in order to provision the Services.
  2. We will not disclose, disseminate or transfer your data to any 3rd-party unless, when required by the law or authorities.
  3. We hate spam , thus we will never, ever send unsolicited commercial communications, unless you explicitly allow us to do so, and even so you'll only hear about our own products.

Your Rights

  1. At any time, you can request to delete, update or integrate your personal data.
  2. At any time, you can ask what we're doing with your data and what measures we're using to keep it safe (and we will answer).


Full Privacy Policy

This Privacy Policy statement is entirely governed by the Italian laws.

Threeplicate Srl is committed to protect the online privacy of its users. This document provides information about our privacy policy so that you can understand how your personal information is handled when you use our services and so that you can grant your express, informed consent to the processing of your personal data.

The information and data that you provide or that are otherwise acquired during registration for the various Services provided by Threeplicate Srl will be processed in compliance with the Decree 196/2003 ("Codice in materia di trattamento dei dati personali").

Purposes of Personal Data Processing

The purpose of the processing is to permit provision of the Services requested by the user. The user will access the Services by registering and creating an account on the Services' website. The data will also be processed in order to comply with statutory, accounting, and tax obligations. The personal data can also be processed in order to permit navigation and interrogation of Services website. Furthermore, the purposes of processing also regard the collection and elaboration of your data as part of statistical analysis in anonymous and/or aggregate form. Such analysis does not permit identification of the user, and is designed to audit the quality of the Services we offer. Finally, the data can be processed - but only when the user has granted his or her specific consent - to provide information about products, services, or initiatives that are offered by Threeplicate Srl.

Procedure of Data Processing

Your personal data will normally be processed by means of electronic or automated tools.

Communication and Dissemination of Personal Data

Your personal data may be communicated to:

  1. persons, companies, or professional firms that provide accounting, legal, tax, and financial support and consulting services to Threeplicate Srl in regard to provision of the Services
  2. parties, entities, or authorities to which your personal data must be communicated pursuant to statutory obligations or orders by authorities
  3. parties delegated and/or engaged by Threeplicate Srl to perform activities that are strictly connected with provision of the Services or with which Threeplicate Srl must interact for provision of the Services.

Your personal data that will not be disseminated in other ways that are not described in this document.

Optional or Mandatory Consent

Providing your personal data is optional for all procedures connected with activation of the Services, but if you do not provide your personal data, the requested Services cannot be activated. Your consent is also optional and not mandatory for the processing of personal data for receiving advertising and informative material from Threeplicate Srl. Your consent is also optional for receiving unsolicited commercial messages pursuant to Article 9 of Legislative Decree 70 of 9 April 2003, which received the Electronic Commerce Decree 2000/31/EEC, stating that unsolicited commercial messages must be immediately and unequivocally identifiable as such and indicating that the recipient of the message may refuse receipt of such messages in the future. If you decide not to grant your consent to process your personal data for commercial purposes, such refusal will have no consequences on the provision of the Services.

Processing of Sensitive Data

When you use the Services, certain parts of your data classified as "sensitive" as described in Articles 4(1) and 26 of the Privacy Code might be processed, particularly in regard to data that can reveal your racial and ethnic origin, religious, philosophical, or other convictions, political opinions, membership in parties, trade unions, associations, or religious, philosophical, political, or labor organizations, and in regard to personal data that can reveal your health status and sexual life. We suggest that you do not publish, save or otherwise store sensitive data in connection with our Services, unless this is strictly necessary or if you decide not to use particular Services that might involve such processing. In any event, aside from the exceptions envisaged in Article 26(4) of the Privacy Code, these data may be processed only with written your consent, in compliance with the General Authorizations granted by the Privacy Authority for processing of sensitive data and after authorization by the Privacy Authority for protection of personal data, which may grant general or preliminary authorization - without prejudice to the consent of the data subject - to particular types of processing. Your sensitive data will not be communicated or disseminated by Threeplicate Srl, unless required by the law or authorities.

Navigation Data

The information systems and software procedures used to operate the Services acquire certain types of data in the course of normal operations. The transmission of this data is an implicit part of use of the internet communication protocols and its transmission and processing is thus required for Services operations. The navigation data may also be collected in anonymous/aggregated form in order to analyze the usage of the Services and thus improve the quality of such Services. The navigation data may also be processed in order to investigate on or contrast cyber crimes or illicit activities that you or other subject may perform in connection with the Services. Furthermore, the transmission of temporary or permanent cookies is necessary for operation of certain parts of the Services.

Data Controller and Data Processors

The data controller is Threeplicate Srl, located at Via Timavo 34, 20124 Milano, Italy, with VAT ID IT-06843040962. You may contact the data processor at any time in order to exercise the rights envisaged in Article 7 of the Code.

Storage of Data and Security Measures

The data will be stored for the time defined by applicable laws and regulations on systems located in the USA and managed by Microsoft Corporation, which is a designated external data processor. In any event, your data will be stored strictly for the amount of time necessary to provision the Services and for the purposes illustrated hereinabove, which shall be for as long as the service relationship between you and the data controller. If you should cancel your account, thereby ceasing to use the Services, your data will be deleted except as necessary to comply with contractual, administrative, tax, accounting, or legal obligations after you terminate use of the service. As soon as these obligations are satisfied, your data will be deleted. We also inform you that this data will be collected, processed, and kept in full compliance with the provisions of Articles 31 et seq. of the Privacy Code and the Technical Regulations - Annex B of the Privacy Code, regarding security measures. The data will also be processed in full compliance with the personal data processing self-governance rules set out in the applicable professional codes of conduct.

Right of Access to Personal Data and Other Rights

You may contact the data controllers or data processors at any time, without formal obligations, or by using the specific form prepared by the "Autorità Garante per la protezione dei dati personali" (the "Personal Data Protection Authority," available at www.garanteprivacy.it) in order to assert your rights as envisaged in Article 7 of the Privacy Code, which is included here for your convenience:

  1. A data subject has the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.
  2. A data subject has the right to be informed:
    1. of the source of the personal data
    2. of the purposes and methods of the processing
    3. of the logic applied to the processing, if the latter is carried out with the help of electronic means
    4. of the identification information concerning the data controller, data processors and the representative designated as per Article 5(2)
    5. of the entities to whom or which the personal data may be communicated to and who may get to know said data in their capacity as designated representative(s) in the State's territory, data processor(s) or person(s) in charge of the processing.
  3. A data subject has the right to obtain:
    1. updating, rectification or, where interested therein, integration of the data
    2. erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed
    3. certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom the 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.
  4. A data subject has the right to object, in whole or in part:
    1. to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection
    2. to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials.

Contact

For any information and in order to exercise the rights envisaged in Article 7 of Legislative Decree 196/2003 cited hereinabove, the data subject may write to:

Threeplicate Srl
Via Timavo, 34
20124 Milano
Italy
P.IVA/CF: IT 06843040962
Registro imprese MI: 1918914

The data subject may also send an email message to info@threeplicate.com.